Bradburn et al v. North Central Regional Library District Doc.

32

1 The Honorable Edward F. Shea

2
Thomas D. Adams
3 Celeste Mountain Monroe

4 KARR TUTTLE CAMPBELL

5 1201 Third Avenue, Suite 2900
Seattle, Washington 98101-3028
6 (206)223-1313
7 Attorneys for North Central Regional Library District
8

9 UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF WASHINGTON
10
AT SPOKANE
11

12 SARAH BRADBURN, PEARL )

CllERRNGTON, CHARLES )
13 I-llINLEN, and THE SECOND ) NO. CV-06-327-EFS
14 AMENDMENT FOUNDATION, )
) DECLARATION OF PAUL
15
Plaintiffs, ) RESNICK
16 )
v. )
17
)
18 NORTH CENTRAL REGIONAL )
19 LIBRARY DISTRICT, )
)
20 Defendant. )
21 )
22
I, Paul Resnick, declare as follows:
23
24 1. I am over the age of 18 and competent to testify to the matters set

25 forth herein.
26
27
28 DECLARA TION OF PAUL RESNICK -
La", Offices
1

CV -06-327-EFS
KARR TUTTLE CAMPBELL
11658040 v i /42703-00 i A pJ"~fes.'ional Senice COJpora/ion
12111 Third A\'cniic, Suiic 291m, ScatHe. Washin~lCln 98101-)1I2H
TclclJliunc (2UG) 223.1313, Facsimile (2UG) 6H2~71UIl

Dockets.Justia.com
 1 2. I am a Professor at the University of Michigan School of
2
Information. (Attached hereto as Ex. A is a true and correct copy of my
3

4 curriculum vitae.)
5
3. In 2002, I conducted an assessment of the error rates on health-
6
7 related websites of several commercial Internet filters. That study was

8 published in lAMA, the flagship peer reviewed journal of the American Medical
9
Association. (Attached hereto as Ex. B is a true and correct copy of the above-
10
1 1 referenced lAMA article.)
12
4. A subsequent paper abstracting what I had learned about the
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14 methods for conducting tests of filtering software was published in the

15
Communications of the ACM, the flagship publication distributed to all
16
17
members of the Association for Computing Machinery. (Attached hereto as
18 Ex. C is a true and correct copy of the above referenced ACM article.)
19
5. I was retained by NCRL to serve as an expert in the current
20
21 litigation.
22
6. I was asked to explain how the NCRL filtering software works. I
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24 was also asked to assess the methods used in studying the error rates in the
25 filtering software NCRL uses as reported by Plaintiffs' expert, Mr. Bennett
26
Haselton.
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28 DECLARATION OF PAUL RESNICK-
Law Offices
2
CV -06-327-EFS
KARR TUTTLE CAMPBELL
#658040 v l /42703-001 A Proje,\'.\ional Se/ï1ice Corpora/ion
1211 I Third A\'cnuc. Suile 29Ull. ScliUlc, W;ishin~iun 9811)1-3028
Tclc(llinnc (2116) 223-13 13, Fiicsiniilc (2116) 6RZ-71111l
 1 7. I was also asked to conduct a study of my own if I thought it would

2
yield greater insight into whether the NCRL filter block more than the content
3

4 they intended to block. I did conduct such a study and report on the methods

5
and results in a formal report. (Attached hereto as Ex. D is a true and correct
6
7 copy of my formal report, without appendices.)

8 8. NCRL computers make use of the FortiGuard Web Filtering

9
Service offered by Fortinet, Inc.
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11 9. FortiNet maintains a database of websites. Fortinet reports that it

12
includes more than 30 milion sites, covering more than two bilion individual
13

14 pages (URs).
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10. FortiNet assigns each web page to one of 76 categories based on its
16
17
dominant content, or to none of those categories Some pages are additionally
18 assigned one of seven classes.
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11. When a web site contains pages having content with different
20
21 dominant categorizations, each page is separately categorized.
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12. The customer selects classes or categories to block or leave
23
24 unblocked.
25
26
27
28 DECLARATION OF PAUL RESNICK-
Lmi' Offces
3
CV -06-327-EFS
KARR TUTTLE CAMPBELL
#658040 v 1/42703-001 A ProfesJional Service Corporation
1201 Third A\'cnuc, Suile 2911U, Seattle, Washington 98WI-J1I28
Telephone (206) 223-1313, Facsimile (2116) 6R2w71l11