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`Exhibit 31
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`Exhibit 31
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 2 of 229
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` 1 UNITED STATES DISTRICT COURT
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` 2 SOUTHERN DISTRICT OF NEW YORK
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` 3 NETWORK-1 TECHNOLOGIES, )
` INC., )
` 4 )
` Plaintiff, ) Case No.: 14 Civ.
` 5 ) 2396; 14 Civ. 9558
` vs. )
` 6 )
` GOOGLE LLC and YOUTUBE, )
` 7 LLC , )
` )
` 8 Defendant. )
` ____________________________ )
` 9
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`10 PROSECUTION/ACQUISITION BAR MATERIALS
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`11 CONFIDENTIAL TRANSCRIPT: OUTSIDE COUNSEL ONLY
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`12 VIDEO DEPOSITION OF YI LING WANG
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`13 October 17, 2019
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`14 9:11 a.m.
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`15
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`16
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`17 650 Page Mill Road
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`18 Palo Alto, California
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`19
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`20
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`21
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`22 REPORTED BY:
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`23 Tammy Moon, CSR No. 13184, CRR, RPR
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`24
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`25
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`1
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 3 of 229
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` 1 APPEARANCES:
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` 2
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` 3 FOR PLAINTIFF:
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` 4 RUSS AUGUST & KABAT
` BY: AMY E. HAYDEN, ESQ., PhD
` 5 12424 Wilshire Blvd, 12th Flr
` Los Angeles, California 90025
` 6 310.826.7474
` Ahayden@raklaw.com
` 7
`
` 8 FOR DEFENDANT:
`
` 9 WILLIAMS & CONNOLLY LLP
` BY: GRAHAM SAFTY, ESQ.
`10 BY: ANDREW V. TRASK, ESQ.
` 725 Twelfth Street, N.W.
`11 Washington, D.C. 20005
` 202.434.5548
`12 Gsafty@wc.com
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`13
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`14
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`15
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`16 ALSO PRESENT:
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`17 DEMARRON BERKLEY, IN-HOUSE COUNSEL FOR GOOGLE
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`18 MICHAEL BARBER, VIDEOGRAPHER
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`19
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 4 of 229
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` 1 INDEX TO EXAMINATION
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` 2 YI LING WANG
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` 3 Thursday, October 17, 2019
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` 4 Tammy Moon CSR No. 13184, RPR, CRR
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` 5 WITNESS: YI LING WANG
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` 6
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` 7 EXAMINATION PAGE
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` 8 By Ms. Hayden 9
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 5 of 229
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` 1 INDEX TO EXHIBITS
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` 2 YI LING WANG
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` 3 Thursday, October 17, 2019
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` 4 Tammy Moon CSR No. 13184, RPR, CRR
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` 5
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` 6 MARKED DESCRIPTION PAGE
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` 7 Exhibit 1 Amended Notice of Rule 30(b)(6) 27
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` 8 Deposition of Defendants
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` 9 Exhibit 2 Notice of Rule 30(b)(1) Deposition 28
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`10 of Yi Ling Wang
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`11 Exhibit 3 Diagram 79
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`12 Bates-stamped page
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`13 GOOG-NETWORK-00790817
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`14 Exhibit 4 Powerpoint presentation 81
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`15 Bates-stamped pages
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`16 GOOG-NETWORK-00781849-00781916
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`17 Exhibit 5 Document titled "Claims, Licenses, 88
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`18 Policies"
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`19 Bates-stamped pages
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`20 GOOG-NETWORK-699847-699856
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`21 Exhibit 6 Document titled "Business Logic in 95
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`22 Automatic Claiming"
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`23 Bates-stamped pages
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`24 GOOG-NETWORK-00702279-00702284
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`25
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`4
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 6 of 229
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` 1 INDEX TO EXHIBITS
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` 2 YI LING WANG
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` 3 Thursday, October 17, 2019
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` 4 Tammy Moon CSR No. 13184, RPR, CRR
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` 5 Exhibit 7 Document titled "Components of the 97
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` 6 Claiming System"
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` 7 Bates-stamped pages
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` 8 GOOG-NETWORK-699829-30
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` 9 Exhibit 8 Bates-stamped page 102
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`10 GOOG-NETWORK-778905
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`11 Exhibit 9 Presentation titled "Live CID 115
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`12 Logic"
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`13 Bates-stamped pages
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`14 GOOG-NETWORK-00780887-00780902
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`15 Exhibit 10 Document titled "YouTube 132
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`16 Click-to-Buy"
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`17 Bates-stamped page
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`18 GOOG-NETWORK-00701320
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`19 Exhibit 11 Document titled "Click-to-Buy 134
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`20 backend design doc"
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`21 Bates-stampted pages
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`22 GOOG-NETWORK-00701322-00701331
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`23 Exhibit 12 PowerPoint presentation 135
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`24 Bates-stamped pages
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`25 GOOG-NETWORK-701298-00701311
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`5
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 7 of 229
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` 1 INDEX TO EXHIBITS
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` 2 YI LING WANG
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` 3 Thursday, October 17, 2019
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` 4 Tammy Moon CSR No. 13184, RPR, CRR
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` 5 Exhibit 13 Document titled "Design: 153
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` 6 Programming from Claimed (PfC)
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` 7 Bates-stamped pages
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` 8 GOOG-NETWORK-704507-00704509
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` 9 Exhibit 14 Document titled "PfC Cards Launch 156
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`10 Retrospective"
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`11 Bates-stamped pages
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`12 GOOG-NETWORK-00775842-3
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`13 Exhibit 15 PowerPoint Presentation titled 158
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`14 "Programming from Claimed (PfC)"
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`15 Bates-stamped pages
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`16 GOOG-NETWORK-00776895-00776951
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`17 Exhibit 16 Document titled "Multiple Cards 165
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`18 with PfC"
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`19 Bates-stamped pages
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`20 GOOG-NETWORK-00777245-00777250
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`21 Exhibit 17 Document titled "Programming from 167
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`22 Claimed Benchmark Analysis"
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`23 Bates-stamped pages
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`24 GOOG-NETWORK-00778850-00778855
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`25
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`6
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` 2 QUESTIONS INSTRUCTED NOT TO ANSWER
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` 5 INFORMATION REQUESTED
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` 8 HIGHLY CONFIDENTIAL PORTION
`HIGHLY CONFIDENTIAL PORTION
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` 9 Page 173:1-193:5
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`YI LING WANG-OUTSIDE COUNSEL ONLY
`YI LING WANG-OUTSIDE COUNSEL ONLY
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`‘
`'BARKLEY
`Court Reporters
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 9 of 229
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` 1 Palo Alto, California
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` 2 Thursday, October 17, 2019, 9:11 a.m.
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` 3 THE VIDEOGRAPHER: Good morning. My name is
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` 4 Michael Barber. I'm a videographer associated with
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`09:11 5 Barkley Court Reporters, located at 201 California
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` 6 Street, Suite 375, San Francisco, California 94111.
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` 7 The date is October 17th, 2019. The time is
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` 8 9:11 a.m.
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` 9 This deposition is taking place at Wilson
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`09:11 10 Sonsini Goodrich and Rosati, in Palo Alto, California,
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`11 in the matter of Network-1 Technologies, Inc., versus
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`12 Google LLC, and YouTube, LLC, in the U.S. District
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`13 Court, Southern District of New York, case numbers 14
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`14 Civ. 2396 and 14 Civ. 9558.
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`09:11 15 This is the videotaped deposition of Yi Ling
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`16 Wang being taken on behalf of the plaintiff.
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`17 Counsel, would you please identify yourselves
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`18 for the record and state whom you represent?
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`19 MS. HAYDEN: I am Amy Hayden from Russ August
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`09:12 20 and Kabat. I represent the plaintiff in this case,
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`21 Network-1 Technologies.
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`22 MR. SAFTY: Graham Safty, from Williams and
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`23 Connolly, LLP, on behalf of defendants Google and
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`24 YouTube.
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`09:12 25 Also with me today is Andrew Trask from
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`8
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 10 of 229
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` 1 Williams and Connolly, LLP, and Demarron Berkley,
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` 2 in-house counsel, Google and YouTube.
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` 3 THE VIDEOGRAPHER: Thank you. Will the court
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` 4 reporter please swear in the witness?
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`09:12 5 Yi Ling Wang,
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` 6 called as a witness, having been duly
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` 7 sworn, testified as follows:
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` 8 THE WITNESS: I do.
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` 9 EXAMINATION
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`09:12 10 MS. HAYDEN:
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`11 Q. Okay. Good morning, Ms. Wang. Can you state
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`12 your name for the record?
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`13 A. It's Yi Ling Wang.
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`14 Q. Could you -- could you spell that too?
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`09:12 15 A. Y-I, L-I-N-G, W-A-N-G.
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`16 Q. And are you -- you're currently employed,
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`17 right?
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`18 A. Yes.
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`19 Q. And where do you work?
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`09:12 20 A. Sorry.
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`21 Q. Where do you work?
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`22 A. Oh, Google.
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`23 Q. Do you work at Google or YouTube -- how do you
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`24 or would you describe that?
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`09:13 25 A. When my friends ask me where I work, I say
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 11 of 229
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` 1 YouTube; but when I report it to the IRS, I write
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` 2 Google.
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` 3 Q. Understood. And how long have you worked at --
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` 4 at Google?
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`09:13 5 A. Since November 2006.
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` 6 Q. And what is your current job title?
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` 7 A. It's engineering manager.
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` 8 Q. And how long have you had that title?
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` 9 A. Technically, titles at Google are self-written,
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`09:13 10 and they changed those words to engineering manager this
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`11 year in April. Before that, it said something else.
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`12 Q. What did it say before that?
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`13 A. Staff software engineer.
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`14 Q. Okay. We'll talk more about your current job
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`09:13 15 and background in a bit, but I just wanted to go over
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`16 the, kind of, some ground rules for depositions.
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`17 Have you had your deposition taken before?
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`18 A. No.
`
`19 Q. Okay. So but you understand that you're under
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`09:13 20 oath today, right?
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`21 A. Yes.
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`22 Q. And that's the same oath that you would take if
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`23 you were testifying in court, an oath that's subject to
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`24 the penalty of perjury?
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`09:14 25 A. Yes.
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`10
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 12 of 229
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` 1 Q. And I'll be asking you questions today. And
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` 2 you'll be providing answers. And the court reporter
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` 3 will be taking them down.
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` 4 But I don't want you to answer a question that
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`09:14 5 you don't understand. And so I'll try to be as precise
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` 6 as possible with my questions. But if you don't
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` 7 understand what I'm asking you, please let me know.
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` 8 A. Okay.
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` 9 Q. And if you could, please always give your
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`09:14 10 answers verbally so the court reporter can take them
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`11 down. So instead of a nod or an uh-huh, please say yes.
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`12 A. Yes.
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`13 Q. Okay. And it's important that we talk one
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`14 person at a time, slowly, and clearly for the court
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`09:14 15 reporter. It's a good reminder for myself. So please
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`16 let me finish my question before you begin your answer.
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`17 And your counsel may state objections after my
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`18 questions. But as you can see, there's no judge here to
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`19 rule on those objections, so you're still required to
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`09:14 20 answer my questions unless your counsel instructs you
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`21 not to answer.
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`22 If I dispute your counsel's instruction for you
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`23 not to answer, we may go off the record, and I will
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`24 discuss with your counsel. But if you need a break at
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`09:15 25 any -- any time today, can you just let me know?
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`11
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 13 of 229
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` 1 A. Yes.
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` 2 Q. And I'll try to take a break about every hour.
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` 3 But if -- but if a question is pending, please do answer
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` 4 that question before we go on a break, okay?
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`09:15 5 A. Okay.
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` 6 Q. Is there any medication you're taking or any
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` 7 other health reason that you -- that you can't provide
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` 8 truthful and accurate testimony today?
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` 9 A. No.
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`09:15 10 Q. Okay. And for these next questions, I'm not
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`11 asking for any content of the communications with your
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`12 counsel, but did you meet with counsel to prepare for
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`13 this deposition?
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`14 A. Yes.
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`09:15 15 Q. And who did you meet with?
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`16 A. Graham, Andrew, Demarron, and Judson. Judd?
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`17 Q. Who is Judd?
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`18 A. He is one of -- I think he's -- I actually
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`19 don't know what his exact role is. But he was with
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`09:16 20 the -- like, the lawyers.
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`21 Q. Does he work at Google?
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`22 A. Yes, I believe so.
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`23 MR. SAFTY: Amy, I'll note for the record.
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`24 Judd Ostol is an in-house paralegal at Google.
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`09:16 25 MS. HAYDEN: Thank you.
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`12
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 14 of 229
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` 1 Q. And -- and when did you meet with -- with
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` 2 Graham, Andrew, Demarron, and Judd?
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` 3 A. Yesterday.
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` 4 Q. And about how long did you meet with them?
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`09:16 5 A. From nine o'clock to four o'clock.
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` 6 Q. And besides those four individuals, did you
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` 7 communicate with anyone else about today's deposition?
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` 8 A. I talked to two people on my team to gather
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` 9 more information.
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`09:16 10 Q. And who are those people on your team?
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`11 A. Siddharth Shankar and Xiao Huang.
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`12 Q. And you said you spoke with Siddharth and Xiao
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`13 to gather information?
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`14 A. To understand how certain things work.
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`09:17 15 Q. So starting with Siddharth, what -- what
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`16 information or understanding did you obtain from him?
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`17 A. I needed to know where the code path was for a
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`18 particular feature.
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`19 Q. What feature was that?
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`09:17 20 A. For Liner Notes.
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`21 Q. Is there anything else that you -- that you
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`22 learned from Siddharth from talking to him about today's
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`23 deposition?
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`24 A. Well, to be clear, I talked to him about that
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`09:17 25 feature, just to understand the current state of the
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`13
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 15 of 229
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` 1 code.
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` 2 Q. And so you only talked to Siddharth about the
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` 3 Liner Notes feature?
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` 4 A. It probably also crossed into talking about the
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`09:18 5 PfC feature, since he had a little bit of background on
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` 6 that.
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` 7 Q. And by "PfC," you mean Programming from
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` 8 Claimed?
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` 9 A. Yes.
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`09:18 10 Q. Anything else?
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`11 A. I asked him a few more questions about
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`12 Click-to-Buy, as well, and how to relate it to Liner
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`13 Notes.
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`14 Q. How -- how do you spell his name?
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`09:18 15 A. Oh, S-I-D-D-A-R-T-H. There might be another
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`16 H -- it usually auto-completes at work --
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`17 Q. Understood. It's a difficult name. And last
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`18 name was Shankar?
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`19 A. Yes.
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`09:19 20 Q. Is that S-H-A --
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`21 A. A -- S-H-A-N-K-A-R.
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`22 Q. Okay. And aside from Liner Notes Click-to-Buy,
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`23 and Programming from Claimed, did you discuss any other
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`24 YouTube features with Siddharth in preparing for today?
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`09:19 25 A. No.
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`14
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 16 of 229
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` 1 Q. And you mentioned someone else, I believe, Xiao
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` 2 Huang?
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` 3 A. Yeah. Xiao Huang.
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` 4 Q. Is that S-H --
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`09:19 5 A. X-I-A-O.
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` 6 Q. Oh.
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` 7 A. And Huang, H-U-A-N-G.
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` 8 Q. And what -- what did you discuss with Xiao?
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` 9 A. They were together, so --
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`09:19 10 Q. Oh, I see.
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`11 A. -- I also asked him questions about PfC,
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`12 Programming from Claimed.
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`13 Q. And what -- do you know Xiao's title at Google?
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`14 A. I am -- I can't say for sure. I would hazard a
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`09:20 15 guess that says software engineer.
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`16 Q. And do you know what team he works on?
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`17 A. He's on my team.
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`18 Q. And what -- what team is that?
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`19 A. My team is called Rights Management.
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`09:20 20 Q. Is Siddharth also on your team?
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`21 A. Yes, on the broader team.
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`22 Q. And on your -- who is the leader of the Rights
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`23 Management team?
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`24 A. It would be me.
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`09:20 25 Q. And who is your manager?
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` 1 A. My manager is Matthias Konrad.
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` 2 Q. And what is Mr. Konrad's role at Google?
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` 3 A. He is a director for the org for content ID.
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` 4 Q. For any specific part of content ID or content
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`09:21 5 ID as a whole?
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` 6 A. As a whole.
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` 7 Q. Do you know who his boss is?
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` 8 A. Geoff van der Meer. Do you need me to spell
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` 9 it?
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`09:21 10 Q. Do you know Geoff's last name?
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`11 A. V-A-N.
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`12 Q. Oh, I see.
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`13 A. Geoff, G-E-O-F-F.
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`14 Q. I thought it was two different people?
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`09:21 15 A. Oh, it's Geoff van der Meer, yes.
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`16 Q. Okay. And aside from Siddharth and Xiao, did
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`17 you speak with anyone other -- and any other -- anyone
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`18 else in preparing for today's deposition?
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`19 A. In preparing for this deposition, no.
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`09:22 20 Q. And did you review any documents in preparing
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`21 for today's deposition?
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`22 A. Yes.
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`23 Q. In particular, did you review -- review any
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`24 source code?
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`09:22 25 A. Can you clarify what you mean by "review"?
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`16
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 18 of 229
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` 1 Q. Before the deposition, just however you
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` 2 would -- I'm not sure how you -- how you would find
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` 3 source code at Google, but if you -- did you go and --
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` 4 A. I -- yes.
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`09:22 5 Q. -- look up any code to --
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` 6 A. Yes.
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` 7 Q. -- refresh your memory about the -- about how
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` 8 certain things work?
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` 9 A. Yes.
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`09:22 10 MR. SAFTY: Yi Ling, make sure you let Amy
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`11 finish her question, otherwise it's very hard for the
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`12 court reporter to get it down. It's okay. I know, it's
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`13 very unusual. Thank you, though.
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`14 MS. HAYDEN:
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`09:22 15 Q. And we'll come back to source code in a moment.
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`16 But just talking about documents, separate from source
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`17 code for -- for a moment.
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`18 So a document can refresh your recollection if
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`19 it helps you remember something that you used to know
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`09:23 20 that you have since forgotten.
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`21 Did you review any documents that refreshed
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`22 your recollection?
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`23 A. I reviewed documents. It may have refreshed
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`24 recollection, but I don't recall seeing them in detail
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`09:23 25 before.
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 19 of 229
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` 1 Q. I see. Did -- did the documents you reviewed,
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` 2 did they have a number on -- a production number on the
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` 3 bottom; something that began with something like GOGG
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` 4 network; what we call a Bates number?
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`09:23 5 A. There was a number at the bottom. I don't
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` 6 remember the format of the number. It was letters and
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` 7 numbers.
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` 8 Q. And -- and the -- the code you reviewed, or
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` 9 looked at, why did -- why did you look at code?
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`09:23 10 A. It was when I was asking Siddharth and Xiao
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`11 what this -- what the feature did now or what the state
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`12 the feature was. They pulled up code to show me.
`
`13 Q. Oh, so Xiao and Siddharth showed you code?
`
`14 A. Yes.
`
`09:24 15 Q. Relevant to the features you discussed?
`
`16 A. Yes.
`
`17 Q. And that was the PfC, Click-to-Buy, and Liner
`
`18 Notes?
`
`19 A. Yes.
`
`09:24 20 Q. Each of those?
`
`21 A. Not each of them, but for one of them.
`
`22 Q. Which one?
`
`23 A. For Liner Notes.
`
`24 Q. Okay.
`
`09:24 25 A. Maybe Click-to-Buy together. They're together,
`
`18
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 20 of 229
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` 1 so --
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` 2 Q. Did you do anything else in preparing for
`
` 3 today's deposition?
`
` 4 A. I -- I'm trying to remember. We also asked
`
`09:24 5 Siddharth and Xiao just to tell us the code path where
`
` 6 these were.
`
` 7 Q. What do you mean by "code path"?
`
` 8 A. Just the code directory path of where they are.
`
` 9 Q. And when you say "where they are" --
`
`09:25 10 A. Where the -- where the code is for the features
`
`11 of Liner Notes and Click-to-Buy. But I did not actually
`
`12 click on any of them.
`
`13 Q. Have you reviewed the patents that are asserted
`
`14 in this case?
`
`09:25 15 A. No.
`
`16 Q. Okay. So we talked about your current
`
`17 position, but I'd like to just ask you some more
`
`18 questions about your background.
`
`19 So where did you get your undergraduate degree?
`
`09:25 20 A. At Stanford.
`
`21 Q. And what degree was that?
`
`22 A. In computer science.
`
`23 Q. And do you remember when?
`
`24 A. In 1998 for my bachelor's and -- yes, in June.
`
`09:25 25 Q. And do you have any graduate degrees?
`
`19
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 21 of 229
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` 1 A. Yes. I have a master's in computer science.
`
` 2 Q. Is that also from Stanford?
`
` 3 A. Yes.
`
` 4 Q. And when did you get a master's degree?
`
`09:26 5 A. In June 1999.
`
` 6 Q. So you didn't -- so you didn't work between
`
` 7 undergrad and graduate school?
`
` 8 A. It depends our definition of work. I worked as
`
` 9 a TA.
`
`09:26 10 Q. I have as well, so understood. And what was
`
`11 your first job after graduate school?
`
`12 A. First full-time job?
`
`13 Q. First full-time job, yes.
`
`14 A. It was at Interwoven, which was a start up at
`
`09:26 15 the time.
`
`16 Q. What type of business was Interwoven in?
`
`17 A. It was a enterprise software company that made
`
`18 software for companies to build websites.
`
`19 Q. And what did you do at Interwoven?
`
`09:27 20 A. I was in professional services, so I was a
`
`21 consultant.
`
`22 Q. And how -- and you left your job at Interwoven,
`
`23 obviously. When did you leave your job there?
`
`24 A. I have to really think. I left, I believe, in
`
`09:27 25 December through -- maybe three and a half years after I
`
`20
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 22 of 229
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` 1 joined. So if I joined in June, maybe in 2000- -- it
`
` 2 was three and a half years after I joined.
`
` 3 Q. That works. And what was your next job after
`
` 4 Interwoven?
`
`09:27 5 A. I worked at PayPal.
`
` 6 Q. And what was your role at PayPal?
`
` 7 A. I was a software engineer.
`
` 8 Q. And about how long did you work there?
`
` 9 A. For three years as well. Almost four.
`
`09:28 10 Q. And what was your next job after PayPal?
`
`11 A. It was at YouTube.
`
`12 Q. And is that the -- is that the same job that
`
`13 you have now, or did you have a different role at that
`
`14 time?
`
`09:28 15 A. I had a different role in the sense that my
`
`16 title was software engineer.
`
`17 Q. And when you first joined YouTube, did you --
`
`18 were you working in Rights Management?
`
`19 A. Yes. In the sense that for that overall area,
`
`09:28 20 but the name and the team was different then.
`
`21 Q. What was it called then?
`
`22 A. It was called CYC.
`
`23 Q. Does that stand for "Claim Your Content"?
`
`24 A. Yes.
`
`09:28 25 Q. And you're familiar with a product called
`
`21
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 23 of 229
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` 1 content ID?
`
` 2 A. Yes.
`
` 3 Q. Did -- did you work on content ID when you
`
` 4 joined YouTube in 2006?
`
`09:29 5 A. It depends on what you define as content ID.
`
` 6 If you define it as the actual matching, the answer is
`
` 7 no.
`
` 8 Q. But there are -- there are different -- there
`
` 9 are other components to content ID besides the matching
`
`09:29 10 system, right?
`
`11 A. Yes. That clarifying question for me is
`
`12 because some people considered the content ID part the
`
`13 actually ID'ing part, so that's why I wanted to make
`
`14 sure.
`
`09:29 15 Q. Kind of lower case content identification?
`
`16 A. Yes.
`
`17 Q. I see. So yeah. I'm referring to content ID
`
`18 meaning the matching part as well as the claiming --
`
`19 A. Okay.
`
`09:30 20 Q. -- part.
`
`21 And what part of, kind of, capital content ID
`
`22 did you work on when you started at YouTube?
`
`23 A. There was no matching part, so I was working on
`
`24 the claiming part.
`
`09:30 25 Q. If there was no -- no matching part, was this
`
`22
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 24 of 229
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` 1 in 2006?
`
` 2 A. Yes.
`
` 3 Q. If there was no matching part, how did content
`
` 4 ID know what to claim?
`
`09:30 5 A. The partners had to do it manually. And we did
`
` 6 eventually use a third-party vendor.
`
` 7 Q. So going back to the -- the manual claiming,
`
` 8 how did that work?
`
` 9 A. At the same time I joined the team was also
`
`09:30 10 building out a tool, if I remember correctly. A -- a UI
`
`11 tool, where they could log in and claim videos.
`
`12 Q. Would the partners have to search user uploaded
`
`13 content?
`
`14 A. Yes.
`
`09:31 15 Q. On their own?
`
`16 A. I -- it's very fuzzy in my mind, since it's so
`
`17 long ago. But I would imagine yes.
`
`18 Q. And when I used the term "partners," I also
`
`19 mean that as the content owners. Does that --
`
`09:31 20 A. Yes.
`
`21 Q. -- terminology make sense to you?
`
`22 A. Yes.
`
`23 Q. Okay. And we may use those interchangeably --
`
`24 A. Yes.
`
`09:31 25 Q. -- today.
`
`23
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 25 of 229
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` 1 MR. SAFTY: Yi Ling, I'm sorry to interrupt,
`
` 2 but, again, make sure you let Amy finish her question so
`
` 3 the court reporter has a moment to take it down and then
`
` 4 give your answer, okay?
`
`09:31 5 MS. HAYDEN: Thank you.
`
` 6 MR. SAFTY: Thank you.
`
` 7 MS. HAYDEN:
`
` 8 Q. I know this is an artificial way to -- for
`
` 9 humans to communicate, so thank you.
`
`09:32 10 Okay. So the UI tool that partners with
`
`11 content owners use to do manual claiming, how did the
`
`12 search algorithm work when they searched for user
`
`13 uploaded videos?
`
`14 A. I can only try to remember in a very vague
`
`09:32 15 sense. I imagine you -- it more than likely was just
`
`16 using normal search in whatever way we had search backed
`
`17 in to just type in phrases that the partners were
`
`18 looking for.
`
`19 Q. So something like keywords?
`
`09:32 20 A. I -- that's what I would guess, yes.
`
`21 Q. And then you mentioned that a third-party was
`
`22
`
`23 party was that?
`
`24 A.
`
`09:33 25 Q. And when did -- when was
`
`
`
` What third
`
`24
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 26 of 229
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` right?
`
`
`
` of content ID?
`
`
`
` But I don't remember
`
` 1 used for the matching part of the system?
`
` 2 A. I can't really pinpoint the exact -- the exact
`
` 3 month. But I believe it was
`
` 4 Q. And YouTube content ID doesn't use
`
`
`
` 6 A. No.
`
` 7 Q. When did YouTube stop
`
`
`
` 9 A. Once again, this is pretty vague in my mind.
`
`09:33 10 It was sometime
`
`11 the exact date.
`
`12 Q. Were you involved in the decision to use
`
`13
`
`14 A. No.
`
`09:34 15 Q. So you weren't involved in the decision to stop
`
`16 using
`
`17 A. No.
`
`
`
`
`18 Q. And after YouTube stopped usingg
`
`
`
`
`
`
`
`
`22 A. What was built at Google.
`
`23 Q. So let's go back and talk about the -- what I'd
`
`24 referred to as the "claiming system."
`
`09:34 25 A. Okay.
`
`25
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 27 of 229
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` 1 Q. Is that something that you started to work on
`
` 2 when you first joined YouTube in 2006?
`
` 3 A. Yes.
`
` 4 Q. And how long did you work on the claiming
`
`09:35 5 system; or are you still working on it?
`
` 6 A. Technically, I guess I still work on it since
`
` 7 that is still what my team does.
`
` 8 Q. Is there a -- in addition to the Rights
`
` 9 Management team you lead, is there any other team at
`
`09:35 10 YouTube that works on the claiming system?
`
`11 A. Yes, in a sense. There is a match claiming
`
`12 team in Zurich.
`
`13 Q. What is the difference between the match
`
`14 claiming team in Zurich and the team -- the Rights
`
`09:36 15 Management team that you lead?
`
`16 A. The match claiming team takes information from
`
`17 the -- the matches that they get from the Zurich
`
`18 Matching Team and decides what claims should be created,
`
`19 which then -- once they've decided that, then they call
`
`09:36 20 our API to actually create the claims.
`
`21 Q. Okay. We'll probably come back to that a
`
`22 little bit more later to understand the interaction of
`
`23 those teams.
`
`24 But first, I just wanted to talk about kind of
`
`09:36 25 the scope of today's deposition. So do you understand
`
`26
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`YI LING WANG-OUTSIDE COUNSEL ONLY
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`Case 1:14-cv-02396-PGG-SN Document 241-6 Filed 11/12/20 Page 28 of 229
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` 1 that you've been designated to testify on a couple of
`
` 2 subjects or topics?
`
` 3 A. Yes.
`
` 4 Q. And I just want to make sure I have a correct
`
`09:37 5 understanding of those topics.
`
` 6 (Ex
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