Page 1 PageID#
EXHIBIT C
Excerpt of Google Employee Deposition
Submitted Under SealPage 2 PageID#
In the Matter Of:
In Re: Google Antitrust Litigation
August 10, 2021Page 3 PageID#
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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Highly Confidential
- August 10,
·········
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PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 284-32 Filed 07/17/23 Page 1 of 7 PageID# 3345
EXHIBIT C
Excerpt of Google Employee Deposition
Submitted Under Seal
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 284-32 Filed 07/17/23 Page 2 of 7 PageID# 3346
In the Matter Of:
In Re: Google Antitrust Litigation
August 10, 2021
PDF Page 4
Case 1:23-cv-00108-LMB-JFA Document 284-32 Filed 07/17/23 Page 3 of 7 PageID# 3347
Highly Confidential
- August 10, 2021
168
·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
www.LexitasLegal.com/Premier
Lexitas
888-267-1200· · ·
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PDF Page 5
Case 1:23-cv-00108-LMB-JFA Document 284-32 Filed 07/17/23 Page 4 of 7 PageID# 3348
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
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
17
?
18 · · A.· ·Yes.· That's one of the things that informed
19 the Banksy proposal.
20 · · Q.· ·Is Banksy intended to
21
?
22 · · A.· ·
23
24
25
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PDF Page 6
Case 1:23-cv-00108-LMB-JFA Document 284-32 Filed 07/17/23 Page 5 of 7 PageID# 3349
Highly Confidential
- August 10, 2021
170
·1
·2
·3
·4 · · Q.· ·Well, what is the purpose of
?
·5 · · A.· ·The purpose of
·6
·7
·8
·9
10 · · A.· ·Yes.
11 · · Q.·
12
13
14
15
16
17
18
19
20
21
22
23 · · Q.· ·How does Banksy actually work in practice?
24 · · A.·
25
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