EXHIBITS re [282] MOTION to Certify Class Exhibit 15 - Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5] [325]; Originally Filed at [281-79] filed byDZ Reserve. (Attachments: # (1) Exhibit 19 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-19] [281] Admin. Motion to Seal), # (2) Exhibit 22 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-28] [281] Admin. Motion to Seal), # (3) Exhibit 25 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-31] [281] Admin. Motion to Seal), # (4) Exhibit 31 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-37] [281] Admin. Motion to Seal), # (5) Exhibit 39 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-48] [281] Admin. Motion to Seal), # (6) Exhibit 44 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-55] [281] Admin. Motion to Seal), # (7) Exhibit 49 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-64] [281] Admin. Motion to Seal), # (8) Exhibit 55 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-71] [281] Admin. Motion to Seal), # (9) Exhibit 58 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-72] [281] Admin. Motion to Seal), # (10) Exhibit 69 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-76] [281] Admin. Motion to Seal), # (11) Exhibit 71 (Unredacted Version Refiled Pursuant to ECF Nos. [253], [320], [325-5]; Originally Filed at [281-79] [281] Admin. Motion to Seal))(Related document(s)[282]) (Graber, Geoffrey) (Filed on 7/20/2021)
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Page 1 UNREDACTED VERSION REFILED PURSUANT TO DKTS. 253, 320, 325-5
ORIGINALLY FILED AT DKT. 281-19
Exhibit 15Page 2 Deposition of:
Gerardo Zaragoza
October 20, 2020
In the Matter of:
DZ Reserve v Facebook, Inc.
Veritext Legal Solutions
800-734-5292 | calendar-dmv@veritext.com |Page 3 HIGHLY CONFIDENTIAL
Page 80
1
about today, and we've notified your counsel
11:03:10
2
of that.
11:03:12
3
Does that make sense?
11:03:13
4
A.
Yes that makes sense.
11:03:17
5
Q.
Okay.
11:03:18
6
So with that in mind --
MS. BLUNSCHI:
Counsel, before
11:03:20
7
you go on, do you have the table name
11:03:21
8
for -- for the file that you created
11:03:23
9
this from?
11:03:28
It's a little bit easier
10
for the folks to reference than the
11:03:30
11
Bates number.
11:03:32
12
13
MR. GRABER:
I think this is the
all_ads_details.
14
MS. BLUNSCHI:
11:03:32
11:03:34
Thank you.
11:03:35
15
BY MR. GRABER:
11:03:35
16
Q.
11:03:39
17
Does that help by referencing
the title, Mr. Zaragoza?
11:03:40
18
A.
Yes, that's very helpful.
11:03:42
19
Q.
Okay.
11:03:43
So with all of that in mind, can
11:03:45
20
21
you tell me what this document is or this
11:03:46
22
excerpt of the document is?
11:03:48
23
A.
Yes, this is an excerpt from
11:03:49
24
all_ads_details, which we talked about
11:03:55
25
earlier.
11:03:56
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830Page 4 HIGHLY CONFIDENTIAL
Page 81
1
2
Q.
And what does the data
represent?
3
11:04:00
MS. BLUNSCHI:
4
form. 5
A.
11:03:58
Object to the
11:04:03
11:04:03
Each row represents information
11:04:05
6
about the ad that is -- you know, the ad_id
11:04:07
7
that's in that row.
11:04:12
8
things like the revenue, impressions,
11:04:15
9
clicks, and other -- other columns here.
11:04:18
10
Q.
11
And so you'll see
Okay.
11:04:18
Let's walk through the columns
11:04:22
12
real quickly.
Maybe you can just tell us
13
generally what each column is.
Okay?
11:04:24
11:04:27
14
A.
Sure.
11:04:29
15
Q.
Okay.
11:04:29
So starting on the far left, do
11:04:30
16
17
you see:
11:04:30
18
"Anon_account_id"?
11:04:33
19
Is that the anonymized account
11:04:34
20
ID?
11:04:36
21
A.
This is a hash account ID, yes.
11:04:36
22
Q.
And that corresponds to an
11:04:41
23
24
25
advertiser?
A.
11:04:42
Yes, this corresponds to an
advertising account.
11:04:43
11:04:45
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830Page 5 HIGHLY CONFIDENTIAL
Page 111
1
A.
Yeah, I mean, this -- this is a
2
reach estimate.
3
Potential Reach is specific to other
11:55:55
4
interfaces.
11:56:03
5
Q.
I guess I don't know if
11:55:51
11:55:53
Well, you generally understand
11:56:04
6
that "Potential Reach" and "reach estimate"
11:56:06
7
mean the same thing; right?
11:56:08
8
9
MS. BLUNSCHI:
Object to the
11:56:10
form and to the extent that counsel is
11:56:11
10
testifying.
11:56:14 11
A.
11:56:14
12
understanding.
11:56:17
13
Q.
What about "result_suma"?
11:56:19
14
A.
So "result_suma," the next
11:56:21
In general, yes, that's my
15
column, is the reach estimate with the SUMA
11:56:25
16
modeling applied.
11:56:28
17
Q.
And the "ds" is what?
11:56:43
18
A.
"ds" stands for date stamp.
11:56:44
19
Q.
So each of these is -- so each
11:56:53
20
of these date stamps corresponds to when
11:57:04
21
this -- when each of these one run?
11:57:08
22
A.
So this date stamp actually more
23
closely corresponds to when this data was
24
written.
25
should be the same as when these were run in
But the -- it should be, yes.
11:57:11
11:57:17
It
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
11:57:18
11:57:20Page 6 HIGHLY CONFIDENTIAL
Page 206
1
the native file or rather an excerpt
15:22:21
2
from a native file, have both been
15:22:24
3
introduced.
15:22:26
4
5
[Deposition Exhibits 217 and 218
marked for identification.]
6
7
MS. BLUNSCHI:
9
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
15
BY MR. GRABER:
16
Q.
Okay.
15:22:38
15:22:39
of ad IDs with custom audiences.
14
17
That's right.
218.
12
13
Sorry, 218;
15:22:37
MS. PUTTIEVA:
10
11
15:22:26
right?
8
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
18
A.
Yes, I do.
15:23:00
19
Q.
Great.
15:23:02
I believe you sent us some
15:23:06
20
21
information this morning that said that this
15:23:08
22
data reflects US advertisers from August 15,
15:23:13
23
2014 to May 16, 2019.
15:23:17
24
field for any ad, ads that had custom
15:23:22
25
audience targeting criteria.
15:23:27
It includes ad ID
Is that
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830Page 7 HIGHLY CONFIDENTIAL
Page 207
1
correct? 2
A.
15:23:27
Yes, this is correct.
This is
15:23:32
3
the -- this is the ad IDs that had the
15:23:34
4
custom ISS.
15:23:38
5
Q.
6
When was this data created?
15:23:39
MS. BLUNSCHI:
15:23:44
Object to the
7
form and scope.
15:23:45 8
A.
15:23:49
9
10
recall.
Q.
A.
These are ad
IDs.
15
16
For the ad ID -- these are ad
That's correct.
15:23:54
15:23:57
IDs, not advertiser IDs; right?
13
14
Over the past couple of months
we've been working on this.
11
12
This data was pulled -- I don't
15:24:00
15:24:03
15:24:05
15:24:08
Q.
And this means that these ads
were run using custom audiences right?
15:24:10
15:24:14
17
A.
That's -- that's correct.
15:24:17
18
Q.
But for each of these ad IDs,
15:24:21
19
they could have been run with various
15:24:24
20
subtypes of custom audiences; right?
15:24:27
21
MS. BLUNSCHI:
Object to the
15:24:31
22
form and scope.
15:24:33 23
A.
15:24:38
Yes, there could be several
24
clusters of custom audience tied to these
15:24:40
25
IDs.
15:24:44
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 1 of 7
UNREDACTED VERSION REFILED PURSUANT TO DKTS. 253, 320, 325-5
ORIGINALLY FILED AT DKT. 281-19
Exhibit 15
PDF Page 3
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 2 of 7
Deposition of:
Gerardo Zaragoza
October 20, 2020
In the Matter of:
DZ Reserve v Facebook, Inc.
Veritext Legal Solutions
800-734-5292 | calendar-dmv@veritext.com |
PDF Page 4
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 3 of 7
HIGHLY CONFIDENTIAL
Page 80
1
about today, and we've notified your counsel
11:03:10
2
of that.
11:03:12
3
Does that make sense?
11:03:13
4
A.
Yes that makes sense.
11:03:17
5
Q.
Okay.
11:03:18
6
So with that in mind --
MS. BLUNSCHI:
Counsel, before
11:03:20
7
you go on, do you have the table name
11:03:21
8
for -- for the file that you created
11:03:23
9
this from?
11:03:28
It's a little bit easier
10
for the folks to reference than the
11:03:30
11
Bates number.
11:03:32
12
13
MR. GRABER:
I think this is the
all_ads_details.
14
MS. BLUNSCHI:
11:03:32
11:03:34
Thank you.
11:03:35
15
BY MR. GRABER:
11:03:35
16
Q.
11:03:39
17
Does that help by referencing
the title, Mr. Zaragoza?
11:03:40
18
A.
Yes, that's very helpful.
11:03:42
19
Q.
Okay.
11:03:43
So with all of that in mind, can
11:03:45
20
21
you tell me what this document is or this
11:03:46
22
excerpt of the document is?
11:03:48
23
A.
Yes, this is an excerpt from
11:03:49
24
all_ads_details, which we talked about
11:03:55
25
earlier.
11:03:56
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
PDF Page 5
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 4 of 7
HIGHLY CONFIDENTIAL
Page 81
1
2
Q.
And what does the data
represent?
3
11:04:00
MS. BLUNSCHI:
4
form.
5
A.
11:03:58
Object to the
11:04:03
11:04:03
Each row represents information
11:04:05
6
about the ad that is -- you know, the ad_id
11:04:07
7
that's in that row.
11:04:12
8
things like the revenue, impressions,
11:04:15
9
clicks, and other -- other columns here.
11:04:18
10
Q.
11
And so you'll see
Okay.
11:04:18
Let's walk through the columns
11:04:22
12
real quickly.
Maybe you can just tell us
13
generally what each column is.
Okay?
11:04:24
11:04:27
14
A.
Sure.
11:04:29
15
Q.
Okay.
11:04:29
So starting on the far left, do
11:04:30
16
17
you see:
11:04:30
18
"Anon_account_id"?
11:04:33
19
Is that the anonymized account
11:04:34
20
ID?
11:04:36
21
A.
This is a hash account ID, yes.
11:04:36
22
Q.
And that corresponds to an
11:04:41
23
24
25
advertiser?
A.
11:04:42
Yes, this corresponds to an
advertising account.
11:04:43
11:04:45
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
PDF Page 6
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 5 of 7
HIGHLY CONFIDENTIAL
Page 111
1
A.
Yeah, I mean, this -- this is a
2
reach estimate.
3
Potential Reach is specific to other
11:55:55
4
interfaces.
11:56:03
5
Q.
I guess I don't know if
11:55:51
11:55:53
Well, you generally understand
11:56:04
6
that "Potential Reach" and "reach estimate"
11:56:06
7
mean the same thing; right?
11:56:08
8
9
MS. BLUNSCHI:
Object to the
11:56:10
form and to the extent that counsel is
11:56:11
10
testifying.
11:56:14
11
A.
11:56:14
12
understanding.
11:56:17
13
Q.
What about "result_suma"?
11:56:19
14
A.
So "result_suma," the next
11:56:21
In general, yes, that's my
15
column, is the reach estimate with the SUMA
11:56:25
16
modeling applied.
11:56:28
17
Q.
And the "ds" is what?
11:56:43
18
A.
"ds" stands for date stamp.
11:56:44
19
Q.
So each of these is -- so each
11:56:53
20
of these date stamps corresponds to when
11:57:04
21
this -- when each of these one run?
11:57:08
22
A.
So this date stamp actually more
23
closely corresponds to when this data was
24
written.
25
should be the same as when these were run in
But the -- it should be, yes.
11:57:11
11:57:17
It
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
11:57:18
11:57:20
PDF Page 7
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 6 of 7
HIGHLY CONFIDENTIAL
Page 206
1
the native file or rather an excerpt
15:22:21
2
from a native file, have both been
15:22:24
3
introduced.
15:22:26
4
5
[Deposition Exhibits 217 and 218
marked for identification.]
6
7
MS. BLUNSCHI:
9
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
15
BY MR. GRABER:
16
Q.
Okay.
15:22:38
15:22:39
of ad IDs with custom audiences.
14
17
That's right.
218.
12
13
Sorry, 218;
15:22:37
MS. PUTTIEVA:
10
11
15:22:26
right?
8
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
18
A.
Yes, I do.
15:23:00
19
Q.
Great.
15:23:02
I believe you sent us some
15:23:06
20
21
information this morning that said that this
15:23:08
22
data reflects US advertisers from August 15,
15:23:13
23
2014 to May 16, 2019.
15:23:17
24
field for any ad, ads that had custom
15:23:22
25
audience targeting criteria.
15:23:27
It includes ad ID
Is that
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
PDF Page 8
Case 3:18-cv-04978-JD Document 334 Filed 07/20/21 Page 7 of 7
HIGHLY CONFIDENTIAL
Page 207
1
correct?
2
A.
15:23:27
Yes, this is correct.
This is
15:23:32
3
the -- this is the ad IDs that had the
15:23:34
4
custom ISS.
15:23:38
5
Q.
6
When was this data created?
15:23:39
MS. BLUNSCHI:
15:23:44
Object to the
7
form and scope.
15:23:45
8
A.
15:23:49
9
10
recall.
Q.
A.
These are ad
IDs.
15
16
For the ad ID -- these are ad
That's correct.
15:23:54
15:23:57
IDs, not advertiser IDs; right?
13
14
Over the past couple of months
we've been working on this.
11
12
This data was pulled -- I don't
15:24:00
15:24:03
15:24:05
15:24:08
Q.
And this means that these ads
were run using custom audiences right?
15:24:10
15:24:14
17
A.
That's -- that's correct.
15:24:17
18
Q.
But for each of these ad IDs,
15:24:21
19
they could have been run with various
15:24:24
20
subtypes of custom audiences; right?
15:24:27
21
MS. BLUNSCHI:
Object to the
15:24:31
22
form and scope.
15:24:33
23
A.
15:24:38
Yes, there could be several
24
clusters of custom audience tied to these
15:24:40
25
IDs.
15:24:44
Veritext Legal Solutions
215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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