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`Exhibit 30
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`Exhibit 30
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` 1
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` 2 UNITED STATES DISTRICT COURT
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` 3 SOUTHERN DISTRICT OF NEW YORK
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` 4 CIVIL ACTION NO. 1:14-cv-02396-PGG
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` 5 - - - - - - - - - - - - - - - - - - - - - - - -
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` 6 NETWORK-1 TECHNOLOGIES, INC.,
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` 7 Plaintiff,
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` 8 vs.
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` 9 GOOGLE, INC., and YouTube,
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`10 Defendants.
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`11 - - - - - - - - - - - - - - - - - - - - - - - -
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`12
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`13
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`14 PROSECUTION/ACQUISITION BAR MATERIALS
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`15 CONFIDENTIAL OUTSIDE COUNSEL ONLY
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`16 HIGHLY CONFIDENTIAL SOURCE CODE
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`17 TRANSCRIPT of the stenographic notes of
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`18 the deposition of HANNA PASULA in the above-entitled
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`19 matter, as taken by and before LORRAINE B. ABATE, a
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`20 Certified Shorthand Reporter and Notary Public of the
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`21 State of New York and Registered Professional
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`22 Reporter, held at the offices of Williams & Connolly,
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`23 LLP, 650 Fifth Avenue, New York, New York, on October
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`24 4, 2019, commencing at 9:15 a.m., pursuant to Notice.
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`25
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`1
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` 1
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` 2 UNITED STATES DISTRICT COURT
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` 3 SOUTHERN DISTRICT OF NEW YORK
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` 4 CIVIL ACTION NO. 1:14-cv-02396-PGG
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` 5 - - - - - - - - - - - - - - - - - - - - - - - -
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` 6 NETWORK-1 TECHNOLOGIES, INC.,
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` 7 Plaintiff,
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` 8 vs.
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` 9 GOOGLE, INC., and YouTube,
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`10 Defendants.
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`11 - - - - - - - - - - - - - - - - - - - - - - - -
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`12
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`13
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`14 PROSECUTION/ACQUISITION BAR MATERIALS
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`15 CONFIDENTIAL OUTSIDE COUNSEL ONLY
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`16 HIGHLY CONFIDENTIAL SOURCE CODE
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`17 TRANSCRIPT of the stenographic notes of
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`18 the deposition of HANNA PASULA in the above-entitled
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`19 matter, as taken by and before LORRAINE B. ABATE, a
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`20 Certified Shorthand Reporter and Notary Public of the
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`21 State of New York and Registered Professional
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`22 Reporter, held at the offices of Williams & Connolly,
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`23 LLP, 650 Fifth Avenue, New York, New York, on October
`
`24 4, 2019, commencing at 9:15 a.m., pursuant to Notice.
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`25
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`1
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`HANNA PASULA-HIGHLY CONFIDENTIAL
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` 1
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` 2 A P P E A R A N C E S:
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` 3 RUSS AUGUST & KABAT, ESQS.
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` 4 Attorneys for the Plaintiff
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` 5 12424 Wilshire Boulevard, 12th Floor
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` 6 Los Angeles, California 90025
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` 7 BY: BRIAN LEDAHL, ESQ.
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` 8 MARC FENSTER, ESQ.
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` 9 (310)826-7474
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`10 bledahl@raklaw.com
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`11 mfenster@raklaw.com
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`12
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`13 WILLIAMS & CONNOLLY, LLP
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`14 Attorneys for the Witness
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`15 725 Twelfth Street NW
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`16 Washington DC 20005
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`17 BY: GRAHAM SAFTY, ESQ.
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`18 KEVIN HARDY, ESQ.
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`19 (202) 434-5548
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`20 gsafty@wc.com
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`21 khardy@wc.com
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`22 A L S O P R E S E N T:
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`23 Demarron Berkley, Esq.
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`24 Google In-House Counsel
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`25 James Brady, Videographer
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` 1
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` 2 I N D E X
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` 3
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` 4
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` 5 WITNESS EXAMINATION BY PAGE
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` 6 Hanna Pasula Mr. Ledahl 4, 117
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` 7
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` 8
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` 9
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`10
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`11 E X H I B I T S
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`12 EXHIBIT PAGE
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`13 1 Plaintiff Network-1 Technologies,
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`14 Inc.'s Amended Notice of Rule 30(b)(6)
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`15 Deposition of Defendants 95
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`16 2 YouTube Content ID Presentation 117
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`17 3 Siberia Content ID's New Match
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`18 System Presentation 131
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`19 4 Eng News Newsletter Printout 144
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`20 5 Video 7 Launch Description 151
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`21 6 Self Evaluation Document 163
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`22 7 Self Evaluation Document 166
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`23 8 Match System Roadmap Presentation 176
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`24
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`25
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`3
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 THE VIDEOGRAPHER: Today's date is
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` 3 October 4th, 2019. The time is 9:18 a.m.
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` 4 My name is Jim Brady. I'm the
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` 5 videographer. We're here today at the law firm
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` 6 of Williams & Connolly, 650 Fifth Avenue, New
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` 7 York, New York. We're here today in the matter
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` 8 of Network-1 Technologies versus Google, et al.
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` 9 Today's witness' name is Hanna Pasula. All
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`10 attorneys' appearances will appear on the
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`11 transcript.
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`12 We ask now that the court reporter
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`13 please swear in the witness.
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`14 H A N N A P A S U L A,
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`15 Having been first duly sworn by a Notary
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`16 Public of the State of New York, was
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`17 examined and testified as follows:
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`18 EXAMINATION BY MR. LEDAHL:
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`19 Q. Good morning, Ms. Pasula.
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`20 A. Good morning.
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`21 Q. Have you ever had your deposition taken
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`22 before today?
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`23 A. No.
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`24 Q. Okay. Then I'm going to go over a
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`25 couple of things just sort of to help us hopefully
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`4
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` 2 make the process a little smoother.
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` 3 First of all, do you understand the oath
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` 4 you took a moment ago is the same as if you were
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` 5 taking if you were testifying live in court in front
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` 6 of a judge and a jury?
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` 7 A. Yes.
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` 8 Q. Okay. And you understand it carries the
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` 9 same penalty of purgery as if you were testifying in
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`10 court?
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`11 A. Yes.
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`12 Q. As we go along today, you've probably
`
`13 noticed that there is a court reporter who takes down
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`14 a transcript of everything that we say. To make sure
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`15 that that's clear and accurate, I'm going to ask that
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`16 you do your best to wait until I finish my question
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`17 to start an answer. Okay?
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`18 A. That sounds good.
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`19 Q. Likewise, I'll wait so that I don't
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`20 speak over your answer. Similarly, if you could do
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`21 your best to say yes or no as opposed to nods of the
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`22 head or things like um-hum or uh-uh that are very
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`23 hard to get accurately in the transcript. I may try
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`24 to remind you if I notice it, but it's not because
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`25 I'm being rude. I just want to make sure we have a
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` 2 clear record. Okay?
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` 3 A. I understand completely.
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` 4 Q. Okay. If at any time you don't
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` 5 understand my question, please let me know and I'll
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` 6 do my best to clarify. Otherwise, if you answer,
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` 7 I'll assume you understood the question. Fair
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` 8 enough?
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` 9 A. Yes.
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`10 Q. Are you on any medication or is there
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`11 any other health reason that would prevent you from
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`12 giving your best and most accurate testimony today?
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`13 A. No.
`
`14 Q. You are employed at Google; is that
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`15 right?
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`16 A. That's right.
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`17 Q. And what is your job title at Google?
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`18 A. Staff software engineer.
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`19 Q. Staff software engineer?
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`20 A. Yes.
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`21 Q. And how long have you worked at Google?
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`22 A. 11 and a half years, I believe.
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`23 Q. And what area or is there a department
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`24 or part of Google that you work within?
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`25 A. I currently work at YouTube.
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`6
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 Q. And is there any further subpart of
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` 3 YouTube that you work in?
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` 4 A. YouTube creator and -- YouTube creator,
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` 5 YouTube Content ID.
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` 6 Q. At some point, have you ever been the
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` 7 technical lead on video matching quality?
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` 8 A. Yes.
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` 9 Q. And are you still in that position?
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`10 A. No. I am now the lead of the match
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`11 system.
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`12 Q. And what is the match system?
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`13 A. It is a system for identifying and
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`14 understanding content reuse at YouTube.
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`15 Q. Did you say content reuse?
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`16 A. Yes.
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`17 Q. What do you mean by content reuse?
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`18 A. By content, I mean it is not anything
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`19 semantic. It refers specifically to video footage or
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`20 audio recordings, even like audio recordings of
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`21 single tracks, and also, to melodies. So we try to
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`22 identify when these things are used in more than one
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`23 video.
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`24 Q. And have you worked -- so is that often
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`25 referred to as the Content ID system at YouTube?
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` 2 A. No. I would say Content ID is a larger
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` 3 group that the match system is part of.
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` 4 Q. And what else falls within Content ID
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` 5 that you're distinguishing that from the match
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` 6 system?
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` 7 A. A lot of like communication with
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` 8 creators or with the partners. A lot of front end
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` 9 staff that allows them to upload movies, upload their
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`10 content, and manage it and so on. Let me think.
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`11 Some elements of YouTube, trust and safety. At least
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`12 some -- trust and safety is a different team, but
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`13 part of Content ID is also about identifying content
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`14 that might be bad in terms of trust and safety.
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`15 Q. And trust and safety, does that refer to
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`16 things like pornography or abusive content?
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`17 A. Yes. Yes, like also, violent
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`18 extremists.
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`19 Q. And --
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`20 A. There is probably other part of Content
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`21 ID that I cannot quite remember at this moment.
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`22 Q. Sure.
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`23 A. There is a lot of infrastructure, like
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`24 just the piping of passing videos around, passing
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`25 information around to people storing it.
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 Q. Sure. Let me ask about a specific
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` 3 aspect.
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` 4 So within Content ID more generally,
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` 5 it's my understanding that there is an aspect that is
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` 6 often referred to as claiming by content partners.
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` 7 Do you know what that refers to?
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` 8 A. Yes.
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` 9 Q. Okay. Is that part of something that's
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`10 within your area of responsibility or is that outside
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`11 the match system part that you described?
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`12 A. It is a sister team.
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`13 Q. But not part of your team directly?
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`14 A. No.
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`15 Q. And who is the lead on the claiming
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`16 team?
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`17 A. Krystof Hodor. Krystof, K-R-Y-S-T-O-F.
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`18 I think Hodor, H-O-D-O-R. Sorry, I always call him
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`19 Krystof, and that is also his login name. He leads,
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`20 among other things, the claiming team.
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`21 Q. Now, within the match system, are there
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`22 sub components of that that you use as a sort of
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`23 organizing principle to describe what parts there are
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`24 to the match system?
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`25 A. It has changed over time, but I think
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 most of the time we talk separately about the
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` 3 infrastructure and the quality. Infrastructure is
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` 4 more like productionalizing, like making sure that
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` 5 these things run at scale in a reliable manner. And
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` 6 quality is about designing the algorithems that power
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` 7 the match system.
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` 8 Q. And have you worked on the match system
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` 9 throughout your time at Google?
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`10 A. No.
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`11 Q. So what did you work on when you first
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`12 started, I think you said, about 11 and a half years
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`13 ago?
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`14 A. Product search which was at the time,
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`15 called Froogle.
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`16 Q. When did you shift to working with the
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`17 match system?
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`18 A. I do not exactly remember. I think it
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`19 might have been 2011.
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`20 Q. Was the match system already up and
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`21 running when you started working on it -- when you
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`22 shifted to working on it?
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`23 A. Yes. Very much so.
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`24 Q. Now, how many -- I know there are lots
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`25 of changes that happened incrementally, but are
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` 2 there, from your perspective, versions, if you will,
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` 3 of the match system, that you can identify over that
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` 4 time period since you started working on it?
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` 5 A. Yes. One big change that occurred over
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` 6 the last few years is we completely changed the
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` 7 infrastructure and redesigned the whole system.
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` 8 Q. When did that take place?
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` 9 A. I would say starting in something like
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`10 2014 and finishing this year.
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`11 Q. And I've seen some references to a shift
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`12 to a system that's referred to as Siberia.
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`13 Is that what you're referring to?
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`14 A. Yes. Sorry. Yes. The new system is
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`15 called Siberia.
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`16 Q. How many versions, if you will, of the
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`17 system were there before Siberia?
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`18 A. In the same sense, this is the -- just
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`19 the second version, but many of the components of the
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`20 system have changed more often.
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`21 Q. Was there a name that was used to refer
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`22 to the first version?
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`23 A. No.
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`24 Q. Did you work on the first version, the
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`25 prior, pre-Siberia version, as well?
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 A. Yes. I was an individual contributor
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` 3 engineer on the video channel.
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` 4 Q. Now, I think you just said video
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` 5 channel; is that right?
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` 6 A. So as I said, we identify content reuse
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` 7 in video footage, audio recordings and melody. And
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` 8 we refer to these three different things as channels.
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` 9 Q. So -- so video, audio and melody are the
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`10 channels that are -- I've seen that reference in a
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`11 lot of documents.
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`12 Is that typically what are referred to
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`13 as the channels in the Content ID -- or excuse me, in
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`14 the match system?
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`15 A. Yes. Although, I'm not sure I should
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`16 add this, but engineers are much more sloppy about
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`17 terminology than lawyers. Channel also has other
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`18 meanings.
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`19 Q. Okay. I've seen some references in the
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`20 code to channels.
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`21 Does that refer to the video, audio and
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`22 melody or is that something separate?
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`23 A. You would have to show me the specific
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`24 piece.
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`25 Q. Okay. We can look at that later.
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` and a brain-based or neural network-based
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 When you came to the match system, what
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` 3 within the video channel was your particular area of
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` 4 responsibility?
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` 5 A. I spent about a year launching a new
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` 6 version of the video fingerprint, yeah.
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` 7 Q. And was that -- so my understanding is
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` 8 there have been iterations of the video fingerprint,
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` 9 but is it fair to say that broadly speaking, there
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`10 have been two kind of versions; there was
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`
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`12 version?
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`13 A. There have been two types of
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`14 fingerprints, but we actually count the version
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`15 numbers. And we're now up at Video 8.
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`16 Q. And Video 8, that's a release that
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`17 relates to how the fingerprints are generated?
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`18 A. Yes. Each of these numbers refers to a
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`19 specific path used -- well, to be more crisp, I think
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`20 it refers to a specific space in which the -- into
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`21 which the fingerprints -- which the fingerprints form
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`22 part of.
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`23 Q. And you said currently the sort of
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`24 operative release of that is Video 8?
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`25 A. Yes.
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` 2 Q. Do you recall when you started working
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` 3 on Content ID and the match system what the video
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` 4 release was at that time?
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` 5 A. I believe the one I was working on was
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` 6 Video 5.
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` 7 Q. And that was sometime around 2011?
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` 8 A. Yes.
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` 9 Q. And at that time, the fingerprints, am I
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`10 correct, were
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`11 A.
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`12 used to index the video prints.
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`13 Q. How would you characterize what the
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`14 fingerprints were at the time you were working on
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`15 Video 5?
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`16 MR. SAFTY: Objection. Vague and
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`17 ambiguous.
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`18 A. Well, they were generated in somewhat
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`19 hand crafted way using some features and stored as
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`
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`
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`25 over used word for us.
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` Also, fingerprint is a very
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` So a whole video would have been described by
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 Q. Sure.
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` 3 A. These -- here, when I say fingerprint, I
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` 4 mean a description of a whole video. It would have
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` 5 been made up of sub fingerprints generated, I do not
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` 6 quite remember, perhaps,
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`
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` 8 a sequence of these.
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` 9 Q. Okay. So let's talk about one of those
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`10 sub fingerprints, if you will.
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`11 You said -- I think you indicated you
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`12 thought they were generated every --
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`
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`14 A. Yes.
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`15 Q. That's also
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`16 A. Yes, it is.
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`17 Q. How were those --
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`18 (Discussion held off the record.)
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`19 Q. How were -- I want to focus on a single
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`20 one of those.
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`21 A. Yes.
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`22 Q. What you I think called sub
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`23 fingerprints.
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`24 A. Yes.
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`25 Q. How were each of those generated in that
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` 2 earlier system? Let me step back for a second.
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` 3 I think you mentioned there were sort of
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` 4 two types of fingerprints, if you will, that have
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` 5 been used even though there were iterations of each
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` 6 of those over time; is that fair?
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` 7 A. Yes.
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` 8 Q. Okay. So I want to start with the first
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` 9 type which was in the earlier time, as I understand
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`10 it, and was in use, generally speaking, when you
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`11 started working on the match system.
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`12 So in that first iteration, how was each
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`13 of those sub fingerprints, those every four times a
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`14 second, how was one generated?
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`15 A. I am actually not completely sure how
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`16 they were generated for the earlier iterations before
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`17 I started.
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`18 For Video 5, it is quite a long process,
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`19 actually describing. How would you like me to
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`20 approach it?
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`21 Q. So I would like to understand what were
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`22 the -- at a sort of basic level, what is that sub
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`23 fingerprint?
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`24 So is each one -- first of all, is each
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`25 one
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` 2 A. Yes.
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` 3 Q. Okay. And how was that
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`
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` 5 A. I may not be recollecting some things
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` 6 completely correctly, but from as far as I remember,
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` 7 it goes like this; first, we would take several
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` 8 frames, so we're talking about a specific point in
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` 9 time. We will be generating a sub fingerprint to
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`10 describe a specific point in time in the video.
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`11 So first, we would take several frames
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`12 around that point in time and
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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`23 Q. And then all of those things together
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`24 were essentially calculated out to be represented by
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`25 that
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`18
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`Case 1:14-cv-02396-PGG-SN Document 241-5 Filed 11/12/20 Page 21 of 276
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` and the
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 A. Eventually. Like you want me to go into
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` 3 detail?
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` 4 Q. That's okay. I think I have a rough
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` 5 understanding.
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` 6 And so each of those that you mentioned,
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` 7 those were sort of values that were set up for every
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` 8
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` 9 collection of them would be what was often referred
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`10 to as a fingerprint for that particular video?
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`11 A. We have actually missed several steps.
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`12 Q. Oh, sorry. Go ahead, please.
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`13 A. So after collecting these, we would also
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`17 Q. Collect?
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`18 A. These descriptors that I have been
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`19 talking about. So you would have descriptors at this
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`20 current point in time and then you would have them
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`21 also from the -- a few times before and after. I do
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`22 not remember exactly how long that interval was,
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`Case 1:14-cv-02396-PGG-SN Document 241-5 Filed 11/12/20 Page 22 of 276
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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`10 Q. And I just want to make sure I
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`11 understand.
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`12 There was -- so there was
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`21 A. Would be what I call a sub fingerprint.
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`22 Q. Okay. So each hash representation is a
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`23 sub fingerprint in the way you've been describing it?
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`24 A. The sub fingerprints were generated
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`Case 1:14-cv-02396-PGG-SN Document 241-5 Filed 11/12/20 Page 23 of 276
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` for a
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` apart for video,
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 called actually,
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` 3 Q. Thank you.
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` 4 What I would like to try to understand
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` 5 is if I'm thinking about a video as a sequence in
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` 6 time, how -- is it true, is it the case that there
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` 7 would be
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` 8 single video; each one is a sub fingerprint. Am I
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` 9 understanding correctly?
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`10 A. For each of these instances in time
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`11 which I think was
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`12 there would be one of these
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`13 representing what was going on around that point in
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`14 time in a highly encrypted and probabalistic way.
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`15 Q. Understood. Okay.
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`16 And the collection of all of those would
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`17 be what was referred to as the fingerprint for that
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`18 video?
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`19 A. Yes. Although, we no longer use that
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`20 terminology because it's confusing.
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`21 Q. Fair enough.
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`22 Now, at some point, am I correct that
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`23 YouTube switched to a completely different approach
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`24 to generating fingerprints; if that's a fair way to
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`25 put it?
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`21
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`Case 1:14-cv-02396-PGG-SN Document 241-5 Filed 11/12/20 Page 24 of 276
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` that you were talking about earlier.
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 A. Yes.
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` 3 Q. And how would you characterize the later
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` 4 or the second approach?
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` 5 MR. SAFTY: Objection. Vague and
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` 6 ambiguous.
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` 7 A. We switched to a neural network-based
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` 8 approach.
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` 9 Q. And which -- so you mentioned that for
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`10 example, Video 5 I think was still using
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`12 Which release was the first to utilize
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`13 the neural network-based fingerprint?
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`14 A. I believe it was Video 6.
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`15 Q. Okay. The neural network-based
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`16 fingerprinting also -- well, I guess not also. It
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`17 generated
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`18 that correct?
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`19 A. No.
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`20 Q. Thank you. Sorry.
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`21 A. And we stopped referring to them as sub
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`22 fingerprints.
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`23 Q. What is the reference to them at this
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`24 point?
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`25 A. Embeddings.
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` as the sub fingerprint; is
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`22
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 Q. E-M-B-E-D--
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` 3 A. Yeah. Things embedded in a space, yeah.
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` 4 It's -- yeah. It's what they would be called in the
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` 5 literature of neural networks.
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` 6 Q. And can you describe what each embedding
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` 7 is.
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` 8 MR. SAFTY: Objection. Vague and
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` 9 ambiguous.
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`10 A. It's a point in a
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`11 Q. And that's represented by the
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`13 A. Yes. It's a vector which is a
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`14 description of a point in space.
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`15 Q. And what does that point in
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`17 underlying video?
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`18 A. Not much. It's not so much that it
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`19 represents something intrinsically. It has sort of a
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`20 certain property.
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`21 Q. Well, so when you say it has a certain
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`22 property, what do you mean by that?
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`23 A. So we trained the neural network so that
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`24 embeddings corresponding to -- in video, video frames
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`25 that came from the same footage, from the same point
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`represent with respect to the
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`23
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 in the same footage, end up close together in the
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` 3 same space, even if they have been heavily
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` 4 transformed; and that embeddings that come from
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` 5 completely different frames, are far away.
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` 6 Q. So an individual embedding, is that
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` 7 generated from a snapshot of a point in time within
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` 8 the video?
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` 9 A. For the video channel, it's a single
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`10 frame.
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`11 Q. And that single frame, how often are
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`12 those captured to generate the embeddings?
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`13 A. I believe it is still
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`15 Q. So let's step to just one of those.
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`16 So I take it, then,
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`17 there is something that essentially extracts a single
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`18 frame at that point in time from the video, and then
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`19 that is processed in some way to
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`21 A. I believe we just request a transcode
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`22 that has
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`23 infrastructure or we ask it to transcode it in such a
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`24 way and then we process each frame individually.
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`25 Q. When you say you ask it to process a
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` from YouTube's
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`24
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 transcode, can you just explain to me what that
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` 3 means.
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` 4 A. So there are many different video
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` 5 represent -- a video can be represented many
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` 6 different ways, with like higher, smaller resolution.
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` 7 There can be different frame rates, different N
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` 8 codings of the video. We ask for a specific N coding
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` 9 which is -- in which the frames are explicit --
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`10 represented explicitly. And they
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`12 YouTube has a lot of infrastructure for
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`13 purchasing different transcodes for different
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`14 purposes.
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`15 Q. And so -- so you receive that transcode,
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`16 and then it -- that's essentially a collection of
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`17 frames from the video; is that fair?
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`18 A. Yes.
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`19 Q. Okay. And each of those frames is then
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`20 processed to generate one of these vectors or
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`21 embeddings?
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`22 A. For the video channel, yes.
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`23 Q. And how is it different from the audio
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`24 channel?
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`25 A. The audio channel is -- well, based on
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`25
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` 1 CONFIDENTIAL - Pasula - October 4, 2019 - CONFIDENTIAL
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` 2 audio, and audio is a wave form. So what we do is we
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` 3 produce what is called a spectrogram. It is a visual
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` 4 representation of the frequencies and the times in
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` 5 the audio wave form, and it basically sort of shows
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` 6 the notes that are occurring at different points in
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` 7 time and how they're sustained. And so we produces
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` 8 this rolling tape of what's going on with audio, and
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` 9 then we take snapshots of it and produce embeddings
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`10 from those.
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`11 Q. And are those snapshots also
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`13 A. I believe they are
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`14 Q. For audio,
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`15 A. Yes, and they are
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`16 Q. How -- what's the duration on the ones
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`17 for video? Is it --
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`18 A. It's just a frame.
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`19 Q. Just the frame.
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`20 And is there a third way that -- I
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`21 believe you also mentioned there is a melody channel.
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`22 A. I am less familiar with how the melody
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`23 channel preprocess
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