THE FACE BOOK VS. CONNECTU MARK ZUCKERBERG Qi Has somebody done tis-on yous behalf? 2 AT think so. 3 Q- Who would have done this en your behalf, 4 ifyou recall? 5 MR, GUY: Objection, cals for speculation & Answer f you know, 7 THE WITNESS: | believe the sume person oes mine as does Dustin's. 9. BYMR.MOSKO: (Q. And who is that person, please? A Leder know. O, Who engaged this perso forthe purpose of filling out tax resus? "MR. GUY: Objection, vague as to time, Calls for speculation. “THE WITNESS BY MR. MOSKO: Do you know if Dustin did? MR. GUY: Same objection. ‘THE WITNESS: | think be did BY MR. MOSKO: I deett know. APRIL 25, 2006 3B 1A: That depends on how you define cofounder 2 Q. Whats yourdefiition of cofounder since 3 you used the word iiilty? 47 A, So called it poople who ar there very 5 early, So whenever we refer to that we say that | & tum the founder because | made the ie tially and 77 the other page who joined me very quickly after that were cofounders, 8 Q. And who joined you very quickly afterwards, 10 use your phrase? ‘s. Busta, Chis, and Bard The sca for Facebook was 100 percent yours; isthat core? MKC GUT: Objection, vague. Answer if you ean, “THE WITNESS: I mean tothe extent that something can be. yes. BY MR. MOSKU: Wat does tha mean? ‘MR. GUY: Objection vague and ambiguous "THE WTTNESS: Like the idea for thirehai, {Q. Priocto your work with TheFaccbook, do 22. the person who made this chat you koow if anyone was ever engaged foc the purpose |22 BY Mi. orTSKO. ‘of completing a tax return on your behalf? 24 Q. Well, where did you get the idca for ‘AI don't know 25 Facebook? 3 38 2 Q.Do,you know if. tax renum a any time 2 MR. GUY: Objection, assumes facts. Answer 2 has been filed in any o€ the United States for you 2 ifyousen. 3. during the pest four years? 30 THE WITNESS: It seems like good thing 4 A Yes. 4 tome. 5 —Q. What year to the best of your knowledge is 5 BYMR, MOSKO: 6 the frst year im atax requ wag filed on yar 5 Q.Okay. 7 thal? 7A. And itwas a combination of other tines t MR. GUY: Objection, vague and ambiguous, | 8 that [had made in the pas, 9 alls for speculation. THE WITNESS: { don't know BY MR. MOSKO: Q. Was it after you started with Facebook? MR. GUY: Sanne objections, STHE WITNESS: [don't know, Ident think 2. BY MR. MOSKO: 1Q, Do you recall what state: your First tan serum was fied in? MR. GUY: Sume objection ‘THE WITNESS: No. BY MR. MOSKO: Q.lbetieve you told me that the cofoarders-- well, lt me just ask this question ‘Who do you believe the cofounders of Facebook were? (650) 324-1181 Comp-U-Scripts!GROSSMAN & COTTER/Weber & Volzing 3 Q. Acombination of what other things ‘A. Things like Course Match, Face Mash, other websites I had made, Q. Anything lve? ‘A. Tost sorts f combined a lot of interests ‘had. [thought that crunching alex of infocrnation was useful, | mean that goes back in ‘he day to Synapse when Trade that Q. Anything else that you betieve you polled from in ordes to come up with Facebook? MR. GUY: Objection, vague and ambiguous. Answer if you can "THE WITNESS: I dont think so'bus Tem sure there ane other things. BY MR. MOSKO: (Q. All ight, And how soom after you founded Farctcok did Dustin, Chris, and Edvando join you? @ (Pages 33 to 36) O6APRI513 24 25THE FACE BOOK ¥S.CONNECTU MARK ZUCKERBERG BPESHESSSTRGSESE Swarm ueene ‘A. Eduardo was there prety uch immediatly. ©. And what does that mean? ‘A He helped me financed it orginally (Q How far along was Facebook before Eduardo ‘came along? terms of what? In terms ofits design, its conception? MR. GUY: Objection. vague and ambiguous, calls for speculation. Answer if you can "THE WITNESS: | already thought | was going to-make it, and then = we didnt have a company at that time formally, BY MR, MOSKO: Had you began writing ~ strike that ‘Were you the initial code writer of the initial code for Facebook? ‘A. Yes ¢ Q. Was there anybody else wino asisted in ‘writing the initial code for FaceBook t AN Q. Did Eduacdo join you in your efforts before you started writing code for Feeebook? ‘MR. GUY: Tm gory, can] have the ! 37 1 2 3 4 6 7 8 19 ab 12 rey 14 as 1s a7 18 APRIL 25, 2006 ae BY MB. MOSKO: Q-Inkiatly. A Ido think 50 Q. Has he ever had any responsibility or involvement in what goes on vo TheFacebook web site? “MR, GUY: Cbjection, compound, calls for speculation. Answer if you can. “THE WITNESS: Advertisements BY MR. MOSKO: Q Anything ese? ‘A. Perhape, he like Flonied ideas. but 1 dont remember. (Q, How soon after Eduardo began assisting 903 ‘with Facebook did Dustin join you? ‘A. That depends on when exactly you define ‘Eduardo begioning to assist me but Pustinsasted, 1 ‘think. it was like around the mile af February (Q, Well, how do you define Eduardo's ing, with respect to Facebook? ‘A. don't. I mean its never been relevant. Well, whether ifs relevant o¢ not, can you pinpoit any particular point in time in which BEBSEETRESCSeSeewamewer 24 ‘question read back, 24° Dustin began ~ strike that. BY MR. MOSKO: 25 That Eduarde began working with you on a i Q. Did Eduardo join your effores with respect Facebook? to TheFacebook web site before you stared writing code fort? ‘A. [dont remember. But I rean that depend ‘on your definition of joined efforts Q. Well, what was Eduardo’ itil ibiliies or duties? ‘objection. Objection, assumes facts, calls fOr ‘speculation, Answer if you can, “THE WITNESS: Test [think it was to belp setup the company initially are get financed and hnelp figore out some of the business suff BY MR. MOSKO: -Q. Di he have any invalvement inthe web site's content? MR, GUY: Objection, vague. Answerif you ‘THE WITNESS: What do you mean? BY MR. MOSKO: Did Eduardo have any invelvernent in deciding what was actually going to go onthe site? MR. GUY: Same objestion MR. GUY: Con we ~ you want to rephrase? BYMR, MOSKO: Q, With respect te Eduardo ean you pinpoint any particular point in time in which Ye began wordang with you? (A We set up the web site and I guess the ‘company bogan when the site Was launehed on February “th, 2004 co that dae I woul soy ts eae 1 sy that be was working with me. 'Q. When did yoo initially begin wating code forthe website? ‘A, Soxnetite in Jaman. , War tiduardo working with you atthe tie you began waiting code? ‘A Toni remember. Q, Was Dustin working with youat the time you began writing code” ANs, {G, Can you be moce specific as vo when January you began writing code forthe web site? ‘A. 1 on remember, Q, Hew much time did you devate im order 10 -weté code in January fr a Febmiary ih launch? 25 THE WITNESS: Al what point? 25 MR.GUY: Objection, Assumes fact, calls 10 (Pages 37 to 40) (650) 324.1181 Comp-U-Seripts/GROSSMAN & COTTER/Weber & Volzing O6APR2513.‘THE FACE BOOK WS.CONNECTU MARK ZUCKERBERG foe speculation, vague and ambiguous, Answer if you 4 2 ean, 2 ‘THE WITNESS: I don't know exactly. I had 4 problem sets and other stiT going on then. My 5 figals. Sof mean the amoont of time that [bad 6 have been capped by that. | think it was 7 8 think so. ‘when you say "problem ses," what do ‘you mean? ‘A. Assignments for classes. (Q. What kind of load did you have at Harvaget during the fall semester of 20037 MR. GUY: Objection, vague. Answer if you ‘THE WITNESS: What do you mean? BY MR. MOSKO: Q, Wasi fall load? Were you taking ‘lusses, a sufficert numbes of classes and waits 10 ‘qualify asa full student at Harvard during the fal of 20037 AL Yes (Same question with respect to the spring, of 2008, 2 2 2 a Ayes $ _Q.SoinJanuary you vegan writing code fora & February 4th launch; covect?™ 7 MR. GUY; Objection, misstates — 8 miseharacterizations his price tesimoay.. Vague and 9 ambiguous. Answer i you can, "THE WITNESS: You'e aking ms if began in January? BY MR, MOSKO: Yes. A. And if it launched on February ath? Q Yes. A. Lthink both of these are true. Q. And ittook you somewhere between one and {ovo eck (o write the initial code thet you launched with; correct? A. Yeah, I betiewe 80. And Eduardo daring tha time was doing ‘what for you while you wese writing cove? ‘A. Timpot sure he was doing mach daring that time, Think he may have been beginning te think: about hou he would potemially monetiae the ste or (650) 324-1181 a Comp-U-Seripis4ROSSMAN & COTTER/Weber & Volzing APRIL 25, 2006 a bow to sett up as acorporation. BY MR. MOSKO: (Q, What about Dustin, what was he deing for Yyouduring that time you were writing cove for February 4$h launch? MI. GUY: Chjecton, same objections regarding assume cts cals for sprculatica, Answer if you can. ‘THE WITNESS; He wast working with m= at tha ime. BY MR MOSKO: Q. Was Chris working fr you a the tim desing he woking fe il cote? A , Wel tthing about Cris Highs? A Yeah. 7 (Q. Prior to February 4th, 2008, when the webs site Ianched, Nad you diseased with Eduardo any arrangement of es of how he site would be owe? ‘A. What da you mes? Q. Ast who owned the web site? ‘A. Yeah. We both di {Ane what discussions i you ha Within prior to February 4th, 20047 A, L guess we had an informal agreement over sho did wha. (Q. And did you have any informa! agreement as to what peccentage ofthe web ic you would own, a: ‘opposed o what perceotage of the web site be would a MR. GUY: Objection. BY MR. MOSKO: ‘Q. And agai, prior to February ah, 20087 ‘MR. GUY: ‘Objection, mischaracierzes his {estimony. Answer itif you can. ‘THE WITNESS: ‘Yes, but I dort think the ownership was over the web ste as moch asthe business othe company. BY MR. MOSKO: Q.So youre talking about you would take care of certain duties and Ive would take care of different duties? ‘A. What do you mean? ‘MR. GUY: Objection, vague, yeah BY MR. MOSKO: Q. Well, your response was — previous response was I don think the owsership was over the we site.as much as the business or the company. ‘What did you mean by that? ‘A. Limes the web site is part of ~ fke an 11 (Pages a1 to 44) OGAPROSI3