United States et al v. Google LLC Document 284: Response, Attachment 25

Virginia Eastern District Court
Case No. 1:23-cv-00108-LMB-JFA
Filed July 17, 2023

Response to [280] Order,, filed by Google LLC. (Attachments: # (1) Exhibit 1 MTC Appendix, # (2) Exhibit 2 MTC Brief, # (3) Exhibit 3 MTC EX 1, # (4) Exhibit 4 MTC EX 2, # (5) Exhibit 5 MTC EX 3, # (6) Exhibit 6 MTC EX 4, # (7) Exhibit 7 MTC EX 6, # (8) Exhibit 8 MTC EX 7, # (9) Exhibit 9 MTC EX 8, # (10) Exhibit 10 MTC EX 9, # (11) Exhibit 11 MTC EX 10, # (12) Exhibit 12 MTC EX 11, # (13) Exhibit 13 MTC EX 12, # (14) Exhibit 14 MTC EX 13, # (15) Exhibit 15 MTC EX 14, # (16) Exhibit 16 MTC EX 15, # (17) Exhibit 17 MTC EX 16, # (18) Exhibit 18 MTC EX 17, # (19) Exhibit 19 MTC EX 18, # (20) Exhibit 20 MTC EX 19, # (21) Exhibit 21 MTC EX 21, # (22) Exhibit 22 MTC EX 22, # (23) Exhibit 23 MTC EX 25, # (24) Exhibit 24 MTC EX 27, # (25) Exhibit 25 MTC EX 28, # (26) Exhibit 26 MTC EX 29, # (27) Exhibit 27 MTC EX 30, # (28) Exhibit 28 MTC EX 31, # (29) Exhibit 29 MTC Reply Appendix, # (30) Exhibit 30 Opposition EX A, # (31) Exhibit 31 Opposition EX B, # (32) Exhibit 32 Opposition EX C, # (33) Exhibit 33 Reply EX 1, # (34) Exhibit 34 Reply EX 2, # (35) Exhibit 35 Reply EX 5, # (36) Exhibit 36 Reply EX 6, # (37) Exhibit 37 Reply)(Reilly, Craig)

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EXHIBIT 28
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In the Matter Of:
In Re: Google Antitrust Litigation
August 10, 2021
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Highly Confidential
- August 10,
·1 product proposal and vision, but the core technical
·2 design was written by
with input from several
·3 folks.
·4 · · Q.· ·And when
·5 technical design, was
or
made the core
working off of the original
·6 design that you had put together?
·7 · · A.· ·I'm not sure.· I think that -- as I mentioned
·8 earlier, part of our work process involves proposing an
·9 idea and getting feedback and iterating on it and
10 refining it.
11 · · · · · · · So I wouldn't be surprised if some of his
12 design might have come from earlier versions of a
13 proposal.· My proposal was certainly informed by earlier
14 versions of this and other proposals.
15 · · Q.· ·
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Highly Confidential
- August 10,
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- August 10,
·1 · ·
········25 · · Q.· ·And you said you started work on Banksy in the
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Highly Confidential
- August 10,
·1 first half of 2020?
·2 · · A.· ·Well, as I mentioned, some of these ideas have
·3 been around for years; and we've been iterating on them
·4 for a number of years.· So I guess it's hard to say when
·5 some of these ideas first emerged.· But we regularly go
·6 through numerous proposals and iterations before we
·7 decide to build something that's new and complex.
·8 · · · · · · · But the current effort began in the spring
·9 of 2020, yes.
10 · · Q.· ·And who approved starting work on Banksy?
11 · · · · · · · MS. ELMER:· Same objection that I gave
12 earlier or instruction that I gave earlier,
13 · · A.· ·Yeah.· I think -- I'm not sure I can answer
14 that question without revealing privileged information.
15 · · · · · · · MS. ELMER:· Then don't.
16 · · Q.· ·(By Mr. Geiger)· So you won't answer the
17 question?
18 · · A.· ·I don't think I can answer that without
19 revealing privileged information.
20 · · Q.· ·Who was the attorney with whom you spoke?
21 · · · · · · · MS. ELMER:· The identity of the attorney
22 you can reveal.
23 · · A.·
.· There are a large number of
24 attorneys involved with whom I spoke on the issue that
25 would be privileged.
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Highly Confidential
- August 10,
·1 · · Q.· ·(By Mr. Geiger)· When did you speak with -- you
·2 said
?
·3 · · A.· ·Yeah.· There were several others as well.
.· There's a large number of
··5 lawyers.
·6 · · Q.· ·And when did you speak to them about this
·7 topic?
·8 · · A.· ·Throughout 2020 and 2021.
·9 · · Q.· ·Why did Google start working on Banksy?
10 · · · · · · · MS. ELMER:· Same instruction.
11 · · A.· ·Yeah.· I don't think I can answer that question
12 without revealing legally privileged information.
13 · · Q.· ·(By Mr. Geiger)· You won't answer the question?
14 · · A.· ·I don't think I can answer it without revealing
15 legally privileged information.
16 · · Q.· ·Is Banksy available to any publishers today?
17 · · A.· ·As I mentioned previously, it's not live yet.
18 · · Q.· ·Is it in beta?
19 · · A.· ·It hasn't launched yet.· We are working on
20 launching a pilot.· We are hoping to have a pilot launch
21 soon, but I don't believe anything is live yet.
22 · · Q.· ·
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