Case 1:14-cv-02396-PGG-SN Document 234-9 Filed 11/11/20 Page 1 of 6
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`Case 1:14-cv-02396-PGG-SN Document 234-9 Filed 11/11/20 Page 2 of 6
`
`9/25/2019
`
`Network-1 Technologies, v. Google LLC and Youtube LLC
`Confidential - Outside Attorneys' Eyes Only
`
`Jim Schrempp
`
`Page 1
`
` UNITED STATES DISTRICT COURT
` SOUTHERN DISTRICT OF NEW YORK
`
`NETWORK-1 TECHNOLOGIES, INC.,
` PLAINTIFF,
` vs. No. 14 Civ. 2396 (PGG)
`GOOGLE LLC AND YOUTUBE, LLC, 14 Civ. 9558 (PGG)
` DEFENDANTS.
`_____________________________
`
` CONFIDENTIAL - OUTSIDE ATTORNEYS' EYES ONLY
` VIDEOTAPED DEPOSITION OF
` JIM SCHREMPP
` Wednesday, September 25, 2019
`
`Reported By: KATHLEEN WILKINS, CSR #10068,
` RPR-RMR-CRR-CCRR-CLR-CRC
`
` BE IT REMEMBERED that on Wednesday, September
`25, 2019, commencing at the hour of 11:04 a.m.
`thereof, at CROWELL & MORING, Three Embarcadero
`Center, 26th Floor, San Francisco, California, before
`me, Kathleen A. Wilkins, RPR-RMR-CRR-CCRR-CLR-CRC,
`a Certified Shorthand Reporter, in and for the State
`of California, personally appeared JIM SCHREMPP, a
`witness in the above-entitled court and cause, who,
`being by me first duly sworn, was thereupon examined
`as a witness in said action.
`____________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 234-9 Filed 11/11/20 Page 3 of 6
`
`9/25/2019
`
`Network-1 Technologies, v. Google LLC and Youtube LLC
`Confidential - Outside Attorneys' Eyes Only
`
`Jim Schrempp
`
`Page 161
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`indexed search of the database?
` A. Well, I think on one of these documents --
`didn't we just see one of these documents where I
`said that we were running an indexed search? I'm
`getting -- you know, my -- didn't one of these
`announcements to people, didn't I say we've now
`improved and we've got an indexed search or
`something?
` Q. If you're thinking of a particular
`document, please go ahead and take your time. I
`don't recall that, but I'm not sure what document
`you're thinking of.
` A. Could someone else help me with the --
` MR. RAMSEY: Unfortunately, that's not the
`way it works.
` THE WITNESS: Oh, okay. Thanks.
` Okay. I think it's just that we say it's
`faster and bigger, but we don't say -- I didn't
`say -- yep. I don't recall right now having said
`that, but -- yeah.
`BY MR. LEDAHL:
` Q. And am I correct that you didn't provide
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 234-9 Filed 11/11/20 Page 4 of 6
`
`9/25/2019
`
`Network-1 Technologies, v. Google LLC and Youtube LLC
`Confidential - Outside Attorneys' Eyes Only
`
`Jim Schrempp
`
`Page 162
`users of Clango with source code for any portion of
`the system. Is that right?
` A. We did not provide users of Clango with
`source code.
` Q. And the binary code that they had wouldn't
`tell them one way or the other how the search was
`being conducted, for example; is that right?
` MR. RAMSEY: Objection. Vague.
` THE WITNESS: That is correct.
`BY MR. LEDAHL:
` Q. And that search wasn't conducted on their
`computers, correct?
` A. Correct.
` Q. So what was sent from the client side to
`an Audible Magic server?
` A. We sent an XML package that contained
`information about the client times. It contained a
`fingerprint that we had computed from an audio
`sample, and just various other metadata. You know,
`things that we -- what the -- probably how much
`memory the PC had, how much -- whatever we could get
`from kind of Windows system -- you know, system
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 234-9 Filed 11/11/20 Page 5 of 6
`
`9/25/2019
`
`Network-1 Technologies, v. Google LLC and Youtube LLC
`Confidential - Outside Attorneys' Eyes Only
`
`Jim Schrempp
`
`Page 177
`Jim Schrempp. The time is 2:30 p.m., and we're off
`the record.
` (Whereupon, a recess was taken.)
` THE VIDEOGRAPHER: This marks the
`beginning of Media Unit Number 3 in the videotaped
`deposition of Jim Schrempp. The time is 2:40 p.m.,
`and we're on the record.
` MR. RAMSEY: And, Counsel, before we get
`started, I just -- before I forget, I want to
`designate the entirety of today's transcript as
`confidential, outside counsel eyes' only. Thank
`you.
` MR. LEDAHL: Understood. We may need to
`take up specifics of that at some future time, but I
`understand.
` MR. RAMSEY: Absolutely agree. We can
`take up portions as necessary as we proceed.
`BY MR. LEDAHL:
` Q. Mr. Schrempp, I think because I didn't
`start out, there were a couple questions I would
`have wanted to ask you at the outset of the
`deposition that I'll just hit now quickly.
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 234-9 Filed 11/11/20 Page 6 of 6
`
`9/25/2019
`
`Network-1 Technologies, v. Google LLC and Youtube LLC
`Confidential - Outside Attorneys' Eyes Only
`
`Jim Schrempp
`
`Page 190
`
` CERTIFICATE OF REPORTER
` I, Kathleen A. Wilkins, Certified
`Shorthand Reporter licensed in the State of
`California, License No. 10068, hereby certify that
`deponent was by me first duly sworn, and the
`foregoing testimony was reported by me and was
`thereafter transcribed with computer-aided
`transcription; that the foregoing is a full,
`complete, and true record of proceedings.
` I further certify that I am not of counsel
`or attorney for either or any of the parties in the
`foregoing proceeding and caption named or in any way
`interested in the outcome of the cause in said
`caption.
` The dismantling, unsealing, or unbinding
`of the original transcript will render the
`reporter's certificates null and void.
` In witness whereof, I have hereunto set my
`hand this day:
`_______ Reading and Signing was requested.
`_______ Reading and Signing was waived.
`___x___ Reading and Signing was not requested.
`
` _________________________
` KATHLEEN A. WILKINS
` CSR 10068, RPR-RMR-CRR-CCRR-CLR-CRC
`
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`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2019
`
`202-232-0646
`
`
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