Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 1 of 23
`
`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 B 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 B TO GOOGLE'S REVISED OMNIBUS ADMINISTRATIVE MOTION TO SEAL
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 2 of 23
`
`
`
`
`Dkt.
`
`Document
`
`410-6 Exhibit 1 to
`Moss
`Declaration (Part
`1)
`
`Portions to
`be Sealed
`
`Portions
`outlined in
`green boxes
`
`CHART B: Cloud Queue-Related Technical Information
`
`Narrowing from
`Original Request to
`Seal
`Removed request to seal
`description of queue in
`YouTube apps in Cast
`framework from internal
`Google documents,
`removed references to
`and discussion of
`operation of “Watch
`Next” queue, operation
`of playback device when
`user initiates local
`playback on YouTube
`apps, media items
`contained in “Watch
`Next” queue, description
`of functions of YouTube
`app when a device
`receives input for taking
`over playback
`responsibility in MDx
`context, description of
`stream transfer
`functionality and
`technical operation of
`stream transfer
`functionality from
`
`Narrowing from Revised
`Request to Seal
`
`Basis for Sealing1
`
`Further removed requests
`to seal source code file
`paths, source code file
`names and descriptions of
`certain parameters.
`
`Pages 17-27, 49-63, 68-73: Contain 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) YouTube functionality related to
`retrieval and playback of media on a client
`device; (2) YouTube functionality related
`to how Google’s WatchNext servers
`retrieve and interact with other backend
`servers when receiving a request for media
`items from a client device; (3) YouTube
`functionality related to how YouTube
`receivers are discover and how media
`playback is Cast to a YouTube receiver
`device, (4) YouTube functionality related
`to receiving and processing transport
`controls, and (5) YouTube functionality
`related to Stream Transfer. In addition,
`these flows also reveal the hierarchy of
`
`
`1 All pin cites refer to internal document page numbers and exhibits.
`
`
`
`1
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 3 of 23
`
`
`
`internal Google
`documents.
`
`410-7 Exhibit 2 to
`Moss
`Declaration (Part
`2)
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`excerpts of internal
`Google documents
`regarding
`MediaRouteButton/Cast
`
`Further removed requests
`to seal source code file
`paths, source code file
`names and descriptions of
`certain parameters.
`
`
`
`2
`
`Google’s source code, how it is organized,
`how error checking is implemented, how
`much space Google devotes to each
`function and activity in the code, and
`Google’s general process for source code
`organization and hierarchy.
`
`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.
`
`Pages 80-85, 93-95, 109-119, 144-146:
`Contain highly confidential flows of source
`code function calls and source code
`hierarchy information that Google does not
`publicly reveal, which discloses Google’s
`
`

`

`
`
`
`
`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 4 of 23
`
`icon, references to and
`discussion of operation
`of “Watch Next” queue,
`discussion of use of
`MDx servers for
`transmission of
`“setPlaylist” messages in
`casting functionality,
`and the discussion of
`and excerpt from
`internal Google
`documents regarding
`launch process.
`
`3
`
`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) YouTube functionality
`related to retrieval and playback of media
`on a client device; (2) YouTube
`functionality related to how Google’s
`WatchNext servers retrieve and interact
`with other backend servers when receiving
`a request for media items from a client
`device; (3) YouTube functionality related
`to how YouTube receivers are discover and
`how media playback is Cast to a YouTube
`receiver device, (4) YouTube functionality
`related to receiving and processing
`transport controls, and (5) YouTube
`functionality related to Stream Transfer. In
`addition, these flows also reveal the
`hierarchy of Google’s source code, how it
`is organized, how error checking is
`implemented, how much space Google
`devotes to each function and activity in the
`code, and Google’s general process for
`source code organization and hierarchy.
`
`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
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 5 of 23
`
`
`
`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.
`
`Images on pages 20 and 21: Contain the
`parameters in a setPlaylist message that
`were not at issue in the litigation and which
`pertain to security and verification, the
`public disclosure of which could harm
`Google’s business. Google has narrowly
`tailored its request and is not seeking to
`redact parameters that were at issue in the
`litigation, such as the videoId, currentTime,
`and listID.
`
`
`410-8 Exhibit 4 to
`Moss
`Declaration
`
`Portions
`outlined in
`green boxes
`
`
`
`
`Further removed request
`to seal description of
`source code operations,
`functions, and file names
`for the grouping and
`casting functionalities.
`
`Removed request to seal
`references to the Cast
`protocol, variables
`passed to the device as
`part of the join_group
`command, and general
`descriptions of: the
`leader election process,
`the launch process
`including launch at
`follower devices,
`available grouping
`functionalities, MDx
`session instantiation, and
`queue usage in the MDx
`context.
`
`
`
`4
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 6 of 23
`
`
`
`438-3 Exhibit 11 to
`Moss
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`general descriptions of
`source code for
`“autoplay” feature and
`MDx session
`instantiation, and queue
`usage in the MDx
`context.
`
`
`Further removed request
`to seal source code file
`paths for casting
`functionality and certain
`parameters in a setPlaylist
`message that were
`discussed in the Court’s
`orders.
`
`438-4 Exhibit 12 to
`Moss
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`entirety of document.
`
`467-3 Exhibit 1 to
`Kaplan
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`document in entirety.
`
`Further removed request
`to seal general discussion
`of firmware code
`implementing Cast
`protocols, certain
`testimony regarding
`meaning of code, and
`source code file names.
`
`Further removed request
`to seal source code file
`paths for YouTube
`products for casting
`functionality.
`
`
`
`
`5
`
`Images on pages 11 and 12: Contain the
`parameters in a setPlaylist message that
`were not at issue in the litigation and which
`pertain to security and verification, the
`public disclosure of which could harm
`Google’s business. Google has narrowly
`tailored its request and is not seeking to
`redact parameters that were at issue in the
`litigation, such as the videoId, currentTime,
`and listID.
`
`Pages 74, 114, 165, 168-175, 181-183, 195,
`196, Contains testimony from Google
`witness explaining the operation of specific
`source code lines for casting and stream
`transfer functionalities of YouTube apps,
`the public disclosure of which would
`competitively harm Google by giving
`competitors an advantage in developing
`similar products by providing them with
`Google’s highly-confidential and
`proprietary information.
`
`Pages 17-27, 49-63, 68-73, 80-85, 93-95,
`109-119, 144-146: Contain 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
`
`

`

`
`
`
`
`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 7 of 23
`
`intend to accomplish in the source code,
`including for the following functionalities:
`(1) YouTube functionality related to
`retrieval and playback of media on a client
`device; (2) YouTube functionality related
`to how Google’s WatchNext servers
`retrieve and interact with other backend
`servers when receiving a request for media
`items from a client device; (3) YouTube
`functionality related to how YouTube
`receivers are discover and how media
`playback is Cast to a YouTube receiver
`device, (4) YouTube functionality related
`to receiving and processing transport
`controls, and (5) YouTube functionality
`related to Stream Transfer. In addition,
`these flows also reveal the hierarchy of
`Google’s source code, how it is organized,
`how error checking is implemented, how
`much space Google devotes to each
`function and activity in the code, and
`Google’s general process for source code
`organization and hierarchy.
`
`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
`
`6
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 8 of 23
`
`
`
`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.
`
`Pages 75-79: Contain 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) YouTube functionality related to
`retrieval and playback of media on a client
`device; (2) YouTube functionality related
`to how Google’s WatchNext servers
`retrieve and interact with other backend
`servers when receiving a request for media
`items from a client device; (3) YouTube
`functionality related to how YouTube
`receivers are discover and how media
`playback is Cast to a YouTube receiver
`
`467-4 Exhibit 2 to
`Kaplan
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`entirety of document.
`
`Further removed request
`to seal source code file
`paths.
`
`
`
`7
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 9 of 23
`
`
`
`device; and (4) YouTube functionality
`related to how the Playlist Service and the
`Playlist Document Service operate for
`retrieval and playback of media on a Hub
`device.
`
`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.
`Image on page 38: Contains information
`from an internal Google document that is
`marked “Confidential & Proprietary” which
`discloses highly confidential information
`regarding the YouTube infrastructure,
`including the transmission, storage and
`processing of security tokens and
`
`475-2 Exhibit B
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`description of how an
`MDx server operates
`when a user initiates a
`Cast session to a
`playback device,
`including the use of
`
`Further removed request
`to seal descriptions of how
`the MDx server generates
`and sends “setPlaylist”
`messages to playback
`devices, queue usage in
`the MDx context and
`
`
`
`8
`
`

`

`
`
`
`
`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 10 of 23
`
`related source code files,
`references to “Onesie,”
`and descriptions of how
`queues would work after
`the implementation of the
`“Streaming Watch”
`feature currently under
`development.
`
`“setPlaylist” messages,
`references to the Cast
`protocol and parameters
`used therein, source code
`file paths, discussion of
`the role of Bandaid
`servers in the casting
`process, the operation of
`“Mapping Service” to
`identify servers from
`which the receive should
`request content, queue
`usage in the MDx
`context, and general
`description of the
`operation of source code
`for Hub devices when
`casting.
`
`credentials whose functionality and
`operation was not at issue in this case.
`
`Image on page 41: Describes the
`parameters in a setPlaylist message that
`were not at issue and which pertain to
`security and verification, the public
`disclosure of which could harm Google’s
`business. Google has narrowly tailored its
`request and is not seeking to redact
`parameters that were at issue in the
`litigation, such as the videoId, currentTime,
`and listID
`
`Images and related description on page 51
`and 53: Contain information from internal
`Google documents that are marked
`“Confidential & Proprietary” disclosing
`highly confidential material regarding the
`numbers and locations of servers in
`Google’s content delivery network, the
`caching hierarchy of servers in the content
`delivery network, and information
`regarding how requests for media are
`directed across the servers in the content
`delivery network. Public disclosure of this
`information would competitively harm
`Google by giving competitors an advantage
`in developing similar products by providing
`them with Google’s highly-confidential and
`proprietary information and could
`potentially jeopardize the security of
`Google’s server networks.
`
`9
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 11 of 23
`
`
`
`
`Image on page 54: Contains information
`from a Google document marked
`“confidential,” identifying and describing
`the format and fields within a request to
`retrieve a YouTube media item. Public
`disclosure of this information could pose a
`security risk to Google.
`
`Image on page 153: Contains non-public
`information regarding the fields and format
`within a Onesie response, including fields
`relating to security keys. Although the
`general process by which Onesie requests a
`media item from a Onesie agent was
`discussed in public docket entries, the
`specific fields and format within a Onesie
`agent that are shown in this image were not.
`Public disclosure of this information could
`pose a security risk to Google.
`
`Internal Google document detailing design
`and operation of casting to MDx via
`YouTube Music, the public disclosure of
`which would competitively harm Google
`by giving competitors an advantage in
`developing similar products by providing
`them with Google’s highly-confidential and
`proprietary information.
`
`Pages 17-27: Contain highly confidential
`flows of source code function calls and
`source code hierarchy information that
`
`482-
`13
`
`Exhibit 22 to
`Google’s MSJ
`
`Entire
`document
`
`None
`
`None
`
`488-7 Exhibit 5 to
`Richter
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`description of queue in
`YouTube apps in Cast
`
`Further removed requests
`to seal source code file
`paths, source code file
`
`
`
`10
`
`

`

`
`
`
`
`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 12 of 23
`
`names and descriptions of
`certain parameters.
`
`framework from internal
`Google documents,
`references to and
`discussion of operation
`of “Watch Next” queue,
`operation of playback
`device when user
`initiates local playback
`on YouTube apps, media
`items contained in
`“Watch Next” queue,
`and description of
`operation of auto play
`functionality from
`internal Google
`documents,
`
`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) YouTube functionality related to
`retrieval and playback of media on a client
`device; (2) YouTube functionality related
`to how Google’s WatchNext servers
`retrieve and interact with other backend
`servers when receiving a request for media
`items from a client device; (3) YouTube
`functionality related to how YouTube
`receivers are discover and how media
`playback is Cast to a YouTube receiver
`device, (4) YouTube functionality related
`to receiving and processing transport
`controls, and (5) YouTube functionality
`related to Stream Transfer. In addition,
`these flows also reveal the hierarchy of
`Google’s source code, how it is organized,
`how error checking is implemented, how
`much space Google devotes to each
`function and activity in the code, and
`Google’s general process for source code
`organization and hierarchy.
`
`Public disclosure of this information would
`divulge Google’s highly confidential and
`proprietary source code architecture and
`
`11
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 13 of 23
`
`
`
`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.
`
`Internal Google document providing
`confidential architecture and
`implementation details regarding playback
`operations in YouTube Music, including
`descriptions of how various back-end
`YouTube services issue and process remote
`procedure calls to obtain information that is
`returned to a YouTube Music client under
`different scenarios for media
`playback. Information regarding Google’s
`back-end YouTube infrastructure and
`remote procedure calls that are made by
`this back-end infrastructure is confidential,
`and the public disclosure of this
`information could pose a security threat and
`
`488-
`10
`
`Exhibit 8 to
`Richter
`Declaration
`
`Entire
`document
`
`None
`
`None
`
`
`
`12
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 14 of 23
`
`
`
`491-5 Exhibit 8 to
`Hefazi
`Declaration
`
`Portions
`outlined in
`green boxes
`
`491-7 Exhibit 10 to
`Hefazi
`Declaration
`
`Entire
`document
`
`Removed request to seal
`operation of casting
`functionality in
`YouTube apps using
`”setPlaylist” message
`and MDx protocol.
`None
`
`None
`
`None
`
`
`
`13
`
`would competitively harm Google by
`giving competitors an advantage in
`developing similar products by providing
`them with Google’s highly-confidential and
`proprietary information.
`Page 6: Contains reference to personal
`home address of Google employee, the
`public disclosure of which may cause
`privacy and/or security issues for the
`employee and his family.
`
`Internal Google document providing
`confidential architecture and
`implementation details regarding playback
`operations in YouTube Music, including
`descriptions of how various back-end
`YouTube services issue and process remote
`procedure calls to obtain information that is
`returned to a YouTube Music client under
`different scenarios for media
`playback. Information regarding Google’s
`back-end YouTube infrastructure and
`remote procedure calls that are made by
`this back-end infrastructure is confidential,
`and the public disclosure of this
`information could pose a security threat and
`would competitively harm Google by
`giving competitors an advantage in
`developing similar products by providing
`them with Google’s highly-confidential and
`proprietary information.
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 15 of 23
`
`
`
`491-9 Exhibit 19 to
`Hefazi
`Declaration
`
`Portions
`outlined in
`green boxes
`
`None
`
`Removed request to seal
`references to “Shared
`Queue” or “Remote
`Queue,” source code file
`paths, and source code
`file names.
`
`491-
`11
`
`Exhibit 21 to
`Hefazi
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Included request to seal
`confidential information
`regarding Google’s
`content delivery network.
`
`Removed request to seal
`discussion regarding the
`operation of “Mapping
`Service” to identify
`servers from which the
`receive should request
`content, source code file
`paths, discussion of
`comments in source
`code regarding storage
`of queue when casting
`for YouTube and GPM
`apps, and general
`descriptions of cloud
`queue feature from
`internal Google
`documents.
`
`491-
`14
`
`Exhibit 25 to
`Hefazi
`Declaration
`
`Entire
`document
`
`None
`
`
`
`None
`
`14
`
`Page 88: Contains source code for MDx
`queue functionality, the public disclosure of
`which would divulge Google’s highly
`confidential and proprietary source code
`that competitors could use to gain a
`competitive advantage in developing same
`or similar products because, generally,
`properly structured and efficient source
`code is superior to source code that is not,
`both for maintenance and in operation
`
`Images on page 37-39: Contains
`information from internal Google
`documents that are marked “Confidential &
`Proprietary” disclosing highly confidential
`material regarding the numbers and
`locations of servers in Google’s content
`delivery network, the caching hierarchy of
`servers in the content delivery network, and
`information regarding how requests for
`media are directed across the servers in the
`content delivery network. Public disclosure
`of this information would competitively
`harm Google by giving competitors an
`advantage in developing similar products
`by providing them with Google’s highly-
`confidential and proprietary information
`and could potentially jeopardize the
`security of Google’s server networks.
`
`Internal Google document detailing the
`operation, design, and architecture of
`Streaming Watch functionality for casting,
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 16 of 23
`
`
`
`502-4 Exhibit 1 to
`Hefazi
`Declaration
`
`Portions
`outlined in
`green boxes
`
`as well as analysis of potential issues with
`and employee commentary on the new
`solution. The public disclosure of which
`would competitively harm Google by
`giving competitors an advantage in
`developing similar products by providing
`them with Google’s highly-confidential and
`proprietary information.
`Pages 75, 76, 79: Contain 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) YouTube functionality related to
`retrieval and playback of media on a client
`device; (2) YouTube functionality related
`to how Google’s WatchNext servers
`retrieve and interact with other backend
`servers when receiving a request for media
`items from a client device; (3) YouTube
`functionality related to how YouTube
`receivers are discover and how media
`playback is Cast to a YouTube receiver
`device; and (4) YouTube functionality
`related to how the Playlist Service and the
`Playlist Document Service operate for
`
`Further removed request
`to seal source code file
`paths.
`
`Removed request to seal
`excerpts from internal
`Google documents
`regarding Get Watch
`Next and “Watch Next”
`queue, discussions of list
`of media items in
`“Watch Next Queue,”
`description of operation
`of YouTube app for
`playback of queues
`when transferring
`playback, excerpts from
`internal documents
`regarding illustration of
`“client-side expansion”
`process when Casting
`YouTube Music,
`operation of setPlaylist
`message and MDx
`servers for playback,
`general description of
`version 3 of MDx
`protocol, and excerpts
`from internal Google
`
`
`
`15
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 17 of 23
`
`
`
`documents regarding
`autoplay feature for
`YouTube apps.
`
`506-1 Exhibit 1 to Ma
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Removed request to seal
`reference to
`“PlaylistService,”
`description of usage of
`cloud servers, including
`MDx servers, during
`casting and playing back
`content on YouTube
`apps, description of
`“auto play” feature from
`
`Further removed request
`to seal descriptions of
`source code comments and
`operations, descriptions of
`how the PlaylistDocument
`Service and WatchNext
`service operate in the
`context of queue playback
`in the MDx context,
`descriptions of how Hub
`
`16
`
`
`
`retrieval and playback of media on a Hub
`device.
`
`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.
`Page 77-79: Contain 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,
`
`

`

`
`
`
`
`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 18 of 23
`
`devices operate when
`casting using stream
`transfer, source code file
`paths, and references to
`Casting protocol
`
`internal Google
`documents, description
`of Hub devices when
`playing back media and
`requirements when
`casting, deposition
`testimony from Google
`witnesses regarding
`storage of YouTube app,
`
`17
`
`including for YouTube functionality related
`to how Google’s WatchNext servers
`retrieve and interact with other backend
`servers (including the Playlist Document
`Service and Playlist Service) when
`receiving a request for media items from a
`client device. In addition, these flows also
`reveal the hierarchy of Google’s source
`code, how it is organized, how error
`checking is implemented, how much space
`Google devotes to each function and
`activity in the code, and Google’s general
`process for source code organization and
`hierarchy.
`
`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
`
`

`

`Case 3:20-cv-06754-WHA Document 853 Filed 08/09/23 Page 19 of 23
`
`
`
`506-5 Exhibit 5 to Ma
`Declaration
`
`Portions
`outlined in
`green boxes
`
`Further removed requests
`to seal source code file
`paths, source code file
`names and descriptions of
`certain parameters.
`
`Removed request to seal
`description of queue in
`YouTube apps in Cast
`framework from internal
`Google documents,
`references to and
`discussion of operation
`of “Watch Next” queue,
`operation of playback
`device when user
`initiates local playback
`on YouTube apps, media
`items contained in
`“Watch Next” queue,
`and description of
`operation of auto play
`functionality from
`internal Google
`documents,
`
`
`
`18
`
`copyrighted or proprietary content, among
`other issues.
`
`Pages 17-27: Contain 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
`