United States et al v. Google LLC Document 284: Response, Attachment 32

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 C
Excerpt of Google Employee Deposition
Submitted Under Seal
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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 · · Q.· ·(By Mr. Geiger)· When did Google start working
·2 on the
?
·3 · · A.· ·Sometime in the first half of 2020.· I think it
·4 was around springtime.
·5 · · Q.· ·Does this product have a code name?
·6 · · A.· ·Yes.
·7 · · Q.· ·Is that code name Banksy?
·8 · · A.· ·Yes.
·9 · · Q.· ·Have you worked on Banksy?
10 · · A.· ·Yes.· Well, I'm a manager; and someone on my
11 team is the product manager for Banksy.
12 · · Q.· ·What work have you done on Banksy?
13 · · A.· ·I was involved in proposing the original idea
14 that we designed in early 2020.· I hired a product
15 manager to lead the effort, and I worked with
16 engineering managers to get it staffed.
17 · · Q.· ·Did you create the original Banksy design?
18 · · A.· ·I created a document proposing what it would
19 look like as a separate document called the Banksy
20 design document, which was authored by an engineer on
21 the team, not by me.
22 · · Q.· ·Which engineer was that?
23 · · A.· ·
.
24 · · Q.· ·Did you work on the technical design of Banksy?
25 · · A.· ·
led the technical -- I designed the
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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
made the core
·5 technical design, was he 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.· ·When you say your version was informed by
16 earlier versions, are you referring to
?
18 · · A.· ·Yes.· That's one of the things that informed
19 the Banksy proposal.
20 · · Q.· ·Is Banksy intended to
?
22 · · A.· ·
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Highly Confidential
- August 10,
····4 · · Q.· ·Well, what is the purpose of
?
·5 · · A.· ·The purpose of
····10 · · A.· ·Yes.
11 · · Q.·
23 · · Q.· ·How does Banksy actually work in practice?
24 · · A.·
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Highly Confidential
- August 10,
·········
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- August 10,
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