Page 1 PageID#
EXHIBIT 28Page 2 PageID#
In the Matter Of:
In Re: Google Antitrust Litigation
August 10, 2021Page 3 PageID#
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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·········
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Highly Confidential
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Highly Confidential
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·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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Case 1:23-cv-00108-LMB-JFA Document 284-25 Filed 07/17/23 Page 1 of 8 PageID# 3013
EXHIBIT 28
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 284-25 Filed 07/17/23 Page 2 of 8 PageID# 3014
In the Matter Of:
In Re: Google Antitrust Litigation
August 10, 2021
PDF Page 4
Case 1:23-cv-00108-LMB-JFA Document 284-25 Filed 07/17/23 Page 3 of 8 PageID# 3015
Highly Confidential
- August 10, 2021
169
·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.· ·
16
17
18
19
20
21
22
23
24
25
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Case 1:23-cv-00108-LMB-JFA Document 284-25 Filed 07/17/23 Page 6 of 8 PageID# 3018
Highly Confidential
- August 10, 2021
178
·1 · ·
·2
·3
·4
·5
·6
·7
·8
·9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 · · Q.· ·And you said you started work on Banksy in the
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PDF Page 8
Case 1:23-cv-00108-LMB-JFA Document 284-25 Filed 07/17/23 Page 7 of 8 PageID# 3019
Highly Confidential
- August 10, 2021
179
·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.
www.LexitasLegal.com/Premier
Lexitas
888-267-1200· · ·
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PDF Page 9
Case 1:23-cv-00108-LMB-JFA Document 284-25 Filed 07/17/23 Page 8 of 8 PageID# 3020
Highly Confidential
- August 10, 2021
180
·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
·4
·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.· ·
23
24
25
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