DZ Reserve v. Facebook, Inc. Document 334: Exhibit(s)

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UNREDACTED VERSION REFILED PURSUANT TO DKTS. 253, 320, 325-5 ORIGINALLY FILED AT DKT. 281-19

Exhibit 15

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Deposition of:

Gerardo Zaragoza October 20, 2020 In the Matter of:

DZ Reserve v Facebook, Inc.

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about today, and we've notified your counsel

11:03:10

of that.

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Does that make sense?

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A.

Yes that makes sense.

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Q.

Okay.

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So with that in mind --

MS. BLUNSCHI:

Counsel, before

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you go on, do you have the table name

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for -- for the file that you created

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this from?

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It's a little bit easier

for the folks to reference than the

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Bates number.

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MR. GRABER:

I think this is the

all_ads_details.

MS. BLUNSCHI:

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Thank you.

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BY MR. GRABER:

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Q.

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Does that help by referencing

the title, Mr. Zaragoza?

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A.

Yes, that's very helpful.

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Q.

Okay.

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So with all of that in mind, can

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you tell me what this document is or this

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excerpt of the document is?

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A.

Yes, this is an excerpt from

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all_ads_details, which we talked about

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earlier.

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Q.

And what does the data

represent?

11:04:00 MS. BLUNSCHI:

form.

A.

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Object to the

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Each row represents information

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about the ad that is -- you know, the ad_id

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that's in that row.

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things like the revenue, impressions,

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clicks, and other -- other columns here.

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Q.

And so you'll see

Okay.

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Let's walk through the columns

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real quickly.

Maybe you can just tell us

generally what each column is.

Okay?

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A.

Sure.

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Q.

Okay.

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So starting on the far left, do

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you see:

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"Anon_account_id"?

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Is that the anonymized account

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ID?

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A.

This is a hash account ID, yes.

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Q.

And that corresponds to an

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advertiser?

A.

11:04:42 Yes, this corresponds to an

advertising account.

11:04:43 11:04:45

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A.

Yeah, I mean, this -- this is a

reach estimate.

Potential Reach is specific to other

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interfaces.

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Q.

I guess I don't know if

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Well, you generally understand

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that "Potential Reach" and "reach estimate"

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mean the same thing; right?

11:56:08

MS. BLUNSCHI:

Object to the

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form and to the extent that counsel is

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testifying.

11:56:14

A.

11:56:14

understanding.

11:56:17

Q.

What about "result_suma"?

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A.

So "result_suma," the next

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In general, yes, that's my

column, is the reach estimate with the SUMA

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modeling applied.

11:56:28

Q.

And the "ds" is what?

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A.

"ds" stands for date stamp.

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Q.

So each of these is -- so each

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of these date stamps corresponds to when

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this -- when each of these one run?

11:57:08

A.

So this date stamp actually more

closely corresponds to when this data was

written.

should be the same as when these were run in

But the -- it should be, yes.

11:57:11 11:57:17

It

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11:57:18 11:57:20

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the native file or rather an excerpt

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from a native file, have both been

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introduced.

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[Deposition Exhibits 217 and 218 marked for identification.]

MS. BLUNSCHI:

15:22:34

15:22:37 15:22:38

MS. BLUNSCHI:

And do you have

the table name for this one?

MS. PUTTIEVA:

MS. BLUNSCHI:

This is the list

BY MR. GRABER:

Q.

Okay.

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of ad IDs with custom audiences.

That's right.

218.

Sorry, 218;

15:22:37 MS. PUTTIEVA:

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right?

15:22:26

Perfect.

15:22:41 15:22:42 15:22:46 15:22:47

Do you see it?

Do you see

Exhibit 218, Mr. Zaragoza?

15:22:56 15:22:57

A.

Yes, I do.

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Q.

Great.

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I believe you sent us some

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information this morning that said that this

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data reflects US advertisers from August 15,

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2014 to May 16, 2019.

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field for any ad, ads that had custom

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audience targeting criteria.

15:23:27

It includes ad ID

Is that

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correct?

A.

15:23:27 Yes, this is correct.

This is

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the -- this is the ad IDs that had the

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custom ISS.

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Q.

When was this data created?

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MS. BLUNSCHI:

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Object to the

form and scope.

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A.

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recall.

Q.

A.

These are ad

IDs.

For the ad ID -- these are ad

That's correct.

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IDs, not advertiser IDs; right?

Over the past couple of months

we've been working on this.

This data was pulled -- I don't

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Q.

And this means that these ads

were run using custom audiences right?

15:24:10 15:24:14

A.

That's -- that's correct.

15:24:17

Q.

But for each of these ad IDs,

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they could have been run with various

15:24:24

subtypes of custom audiences; right?

15:24:27

MS. BLUNSCHI:

Object to the

15:24:31

form and scope.

15:24:33

A.

15:24:38

Yes, there could be several

clusters of custom audience tied to these

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IDs.

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