Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 1 of 7
`
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
` Sean Pak (Bar No. 219032)
` seanpak@quinnemanuel.com
` Melissa Baily (Bar No. 237649)
` melissabaily@quinnemanuel.com
` James Judah (Bar No. 257112)
` jamesjudah@quinnemanuel.com
` Lindsay Cooper (Bar No. 287125)
` lindsaycooper@quinnemanuel.com
` Iman Lordgooei (Bar No. 251320)
` imanlordgooei@quinnemanuel.com
`50 California Street, 22nd Floor
`San Francisco, California 94111-4788
`Telephone:
`(415) 875-6600
`Facsimile:
`(415) 875-6700
`
` Marc Kaplan (pro hac vice)
` marckaplan@quinnemanuel.com
`191 N. Wacker Drive, Ste 2700
`Chicago, Illinois 60606
`Telephone:
`(312) 705-7400
`Facsimile:
`(312) 705-7401
`
`Attorneys for GOOGLE LLC
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`SONOS, INC.,
`
`Plaintiff,
`
`vs.
`
`GOOGLE LLC,
`
`Defendant.
`
`CASE NO. 3:20-cv-06754-WHA
`Related to CASE NO. 3:21-cv-07559-WHA
`
`CHART A TO GOOGLE LLC’S REVISED
`OMNIBUS ADMINISTRATIVE MOTION
`TO FILE UNDER SEAL PURSUANT TO
`THE COURT’S ORDER RE NEW
`MOTIONS TO SEAL (DKT. 846)
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`CASE NO. 3:20-cv-06754-WHA
`CHART A TO GOOGLE'S REVISED OMNIBUS ADMINISTRATIVE MOTION TO SEAL
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`

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`Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 2 of 7
`
`
`
`
`Dkt.
`
`Document
`
`440-15 Exhibit 6 to
`Moss
`Declaration
`
`Portions to
`be Sealed
`Portions
`outlined in
`green boxes
`
`CHART A: Zone Scenes-Related Technical Information
`
`Narrowing from Revised
`Request to Seal
`Further removed request
`to seal source code file
`paths and reference to and
`description of “prefs file.”
`
`Narrowing from Original
`Request to Seal
`Removed descriptions of
`the operation of Google’s
`products with respect to
`grouping functionality,
`discussions of “no
`standalone mode” non-
`infringing alternative for
`zone scene patents,
`implementation progress of
`redesign, the data
`generated when Google’s
`products receive a request
`to create a speaker group
`and the operation of the
`product when transmitting
`a “join_group” command,
`quotations from internal
`technical spec documents
`regarding multizone
`grouping, references to
`messages sent when
`creating a group.
`
`
`Basis for Sealing1
`
`Pages 13, 16, 17, 27, 31, 37-41:
`Contains highly confidential flows of
`source code function calls and source
`code hierarchy information that Google
`does not publicly reveal, which
`discloses Google’s source code
`functionality because the identified
`functions and source code structures
`include their descriptive names
`indicating what each function and
`structure may intend to accomplish in
`the source code, including for the
`following functionalities: (1) Google
`Home app functionality related to the
`user interface display and user
`interactions regarding speaker group
`(page 13); (2) Google Home app
`functionality related to join_group()
`commands and speaker group formation
`(pages 16 and 17); (3) Google Home
`app functionality related to Cast target
`identification (pages 27 and 31); (4)
`source code related to playback (pages
`37-41). In addition, these flows also
`reveal the hierarchy of Google’s source
`code, how it is organized, how error
`checking is implemented, how much
`
`
`1 All pincites refer to internal document page numbers and exhibits.
`
`
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`1
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`Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 3 of 7
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`space Google devotes to each function
`and activity in the code, and Google’s
`general process for source code
`organization and hierarchy.
`
`Page 15: Contains source code flows
`showing how Google intended to write
`and implement source code for the
`join_group() function, including from
`internal technical documents showing
`the proposed source code flow for
`adding a target device to a multizone
`group which discloses the type of data
`structure Google intended to use in the
`source code to store information related
`to the join_group command and details
`about the leader election process that
`were not described at trial. Although
`the general types of information that
`were included in a join_group command
`were discussed at trial, the source code
`implementation of the same was not
`disclosed and remains Google’s
`confidential and competitively sensitive
`information.
`
`Disclosure of any of this information
`would competitively disadvantage
`Google by giving competitors Google’s
`proprietary source code information that
`they could use to gain an advantage
`when developing the same or similar
`products because, generally, properly
`
`2
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`

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`Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 4 of 7
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`
`
`structured and efficient source code is
`superior to source code that is not, both
`for maintenance and in operation.
`Further, revealing Google’s proprietary
`source code information would pose an
`increased security risk to Google by
`exposing the workings and flows of
`Google source code such that hostile
`parties may be able to learn how to
`exploit portions of the source code,
`potentially resulting in privacy issues
`for consumers, unauthorized use of
`copyrighted or proprietary content,
`among other issues.
`
`
`Page 33: Contains source code trace
`showing how join_group messages are
`handled in Google’s system, including
`identification of how Google has
`engineered handling the join_group
`message in its source code, the
`hierarchy of member functions, where
`each call to those member functions is
`made, and how those member functions
`are organized according to Google’s
`confidential source code practices. This
`information was not disclosed at trial
`and is highly confidential and
`proprietary information. .
`
`Although not source code itself, the
`information sought to be sealed reveals
`
`528-4 Exhibit L to
`Google’s MSJ
`
`Portions
`outlined in
`green boxes
`
`
`
`
`Further removed request
`to seal source code
`regarding grouping
`redesign and discussion of
`certain functions for
`firmware on Google’s
`speaker products.
`
`Removed request to seal
`discussion of source code
`paths and operation for the
`grouping functionality
`when receiving join_group
`command, discussion of
`source code paths and
`operation for grouping
`functionality when
`receiving join_group
`command after redesign
`was implemented, changes
`to certain source code
`functions as a result of the
`implementation of the
`redesign, and references to
`
`3
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`Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 5 of 7
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`the StopCurrentApp()
`function.
`
`
`4
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`important information about Google’s
`source code including: (1) which
`function calls are made in which classes
`and member functions, (2) through the
`descriptive naming of Google’s member
`functions and classes, the underlying
`source code functionality of the same,
`and (3) Google’s general processes for
`structuring its source code. Public
`disclosure of this information would
`divulge Google’s highly confidential
`and proprietary source code architecture
`and functionality, which could be used
`by competitors to gain a competitive
`advantage that Google has in the
`marketplace because, generally,
`properly structured and efficient source
`code is superior to source code that is
`not, both for maintenance and in
`operation. Further, revealing Google’s
`proprietary source code information
`would pose an increased security risk to
`Google by exposing the workings and
`flows of Google source code such that
`hostile parties may be able to learn how
`to exploit portions of the source code,
`potentially resulting in privacy issues
`for consumers, unauthorized use of
`copyrighted or proprietary content,
`among other issues.
`
`Google has narrowly tailored its sealing
`requests to avoid requesting to seal the
`
`

`

`Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 6 of 7
`
`
`
`None
`
`RefreshDeviceGroups() source code that
`was discussed at trial; however, the
`parent source code functions are not
`necessary for the understanding of the
`RefreshDeviceGroups() source code
`described or disclosed at trial.
`
`Page 10: Contains source code flow for
`adding a target device to a multizone
`group, which shows the type of data
`structure Google intended to use in the
`source code to store information related
`to the join_group command and further
`includes details about the leader election
`process that were not described at trial.
`Although the general types of
`information that were included in a
`join_group command were discussed at
`trial, the source code implementation of
`the same was not disclosed and remains
`Google’s confidential and competitively
`sensitive information.
`
`Further removed request
`to seal general discussion
`of source code regarding
`functional capability to
`display previously created
`groups and source code
`file paths.
`
`Page 235: Contains portions of the
`source code functionality and source
`code flow for how Google’s Home app
`for Android handles the display of
`speaker groups. Although not source
`code itself, the information sought to be
`sealed reveals important information
`about Google’s source code including:
`(1) which function calls are made in
`
`546-6 Revised Sealed
`Dkt. 252-2
`(Google’s
`Opposition to
`Sonos’s MSJ)
`
`Portion
`outlined in
`green box on
`page 10
`
`692-2 Exhibit 3
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`references to the
`join_group message,
`contents of the join_group
`message, operation of
`speaker after receiving a
`join_group command,
`testimony of Google’s
`engineer regarding storage
`of group membership on
`speaker devices, and
`portion of presentation
`regarding Google’s
`proposal for operation of
`grouping and casting
`functionalities in Cast for
`Audio product.
`Removed request to seal
`references to “prefs file.”
`
`
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`5
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`Case 3:20-cv-06754-WHA Document 852 Filed 08/09/23 Page 7 of 7
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`which classes and member functions, (2)
`through the descriptive naming of
`Google’s member functions and classes,
`the underlying source code functionality
`of the same, and (3) Google’s general
`processes for structuring its source code.
`The public disclosure of this
`information would divulge Google’s
`highly confidential and proprietary
`source code architecture and
`functionality, which could be used by
`competitors to gain a competitive
`advantage that Google has in the
`marketplace because, generally,
`properly structured and efficient source
`code is superior to source code that is
`not, both for maintenance and in
`operation. Further, revealing Google’s
`proprietary source code information
`would pose an increased security risk to
`Google by exposing the workings and
`flows of Google source code such that
`hostile parties may be able to learn how
`to exploit portions of the source code,
`potentially resulting in privacy issues
`for consumers, unauthorized use of
`copyrighted or proprietary content,
`among other issues.
`
`Google has narrowly tailored its sealing
`request and is not seeking to seal, for
`example, mere identification of file
`names and file paths.
`
`6
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`