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`Exhibit 32
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` 1 IN THE UNITED STATES DISTRICT
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` 2 SOUTHERN DISTRICT OF NEW YORK
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` 3
`
` 4 NETWORK-1 TECHNOLOGIES, INC., )
` )
` 5 Plaintiff, )
` )
` 6 vs. ) Case Nos.
` ) 14 Civ. 2396 (PGG)
` 7 GOOGLE, INC., and YOUTUBE LLC, ) 14 Civ. 9558 (PGG)
` )
` 8 Defendants. )
`
` 9
` London, United Kingdom,
`10
` Wednesday, October 30th, 2019
`11
`
`12 **Highly Confidential - Outside Counsels' Eyes Only**
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`13 **Prosecution/Acquisition Bar Materials**
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`14
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`15 Videotaped deposition of MATTHIAS KONRAD, in
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`16 the above-entitled action, by and before, AUDREY
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`17 SHIRLEY, Qualified Real-time Reporter, Accredited,
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`18 Court Reporter and Member of the British Institute
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`19 of Verbatim Reporters, at the offices of Wilmer
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`20 Hale, 49 Park Lane, London, W1K 1PS, United
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`21 Kingdom, commencing at 9:08 a.m.
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` 1 A P P E A R A N C E S:
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` 2 On behalf of the Plaintiff:
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` 3 RUSS, AUGUST & KABAT
` 12424 Wilshire Boulevard
` 4 Los Angeles, CA 90025
`
` 5 By: Brian D. Ledahl, Esquire
`
` 6 Tel: +1 (310) 826-7474
` Email: bledahl@raklaw.com
` 7
` On behalf of the Defendants:
` 8
` WILLIAMS & CONNOLLY LLC
` 9 725 Twelfth Street, NW
` Washington, DC 20005
`10
` By: Kevin Hardy, Esquire
`11
` Tel: +1 202 434 5257
`12 Email: khardy@wc.com
`
`13 By: Graham W. Safty, Esquire
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`14 Tel: +1 202 434 5548
` Email: gsafty@wc.com
`15
` Also present:
`16
` Demarron Berkley - in-house counsel Google
`17
` Linda Fleet - videographer
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` 1 I N D E X
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` 2 Witness Examination Page
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` 3 Matthias Konrad (By Mr. Ledahl) 6
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` 4
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` 5 E X H I B I T S
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` 6 (Attached to the transcript)
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` 7 Exhibit No. Description Page
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` 8 No. 1 Document bearing Bates No. 58
` GOOG-NETWORK-00804587
` 9 (Page 1)
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`10 No. 2 Document bearing Bates No. 58
` GOOG-NETWORK-00804587
`11 (Page 2)
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`12 No. 3 Document bearing Bates No. 58
` GOOG-NETWORK-00804587
`13 (Page 3)
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`14 No. 4 Document bearing Bates No. 96
` GOOG-NETWORK-00803880
`15
` No. 5 Document bearing Bates No. 117
`16 GOOG-NETWORK-00803878
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`17 No. 6 Document bearing Bates Nos. 143
` GOOG-NETWORK-00779714 - '750
`18
` No. 7 Document bearing Bates Nos. 165
`19 GOOG-NETWORK-00700133 - '136
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`20 No. 8 Document bearing Bates Nos. 169
` GOOG-NETWORK-00704247 - '250
`21
` No. 9 Document bearing Bates No. 175
`22 GOOG-NETWORK-00790817
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`23 No. 10 Document bearing Bates Nos. 188
` GOOG-NETWORK-00702286 - '326
`24
` No. 11 Document bearing Bates Nos. 198
`25 GOOG-NETWORK-00754045 - '064
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` 1 Exhibit No. Description Page
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` 2 No. 12 Document bearing Bates Nos. 203
` GOOG-NETWORK-00700247 - '267
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` No. 13 Document bearing Bates Nos. 208
` 4 GOOG-NETWORK-00700457 - '475
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` 5 No. 14 Document bearing Bates Nos. 213
` GOOG-NETWORK-00781849 - '916
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` No. 15 Document bearing Bates No. 223
` 7 GOOG-NETWORK-00700405
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` 8 No. 16 Document bearing Bates Nos. 228
` GOOG-NETWORK-00746614 - '615
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` No. 17 Document bearing Bates Nos. 232
`10 GOOG-NETWORK-00703278 - '281
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`11
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` 1 (Time noted: 9:08 a.m.)
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` 2 THE VIDEOGRAPHER: This is media
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` 3 No. 1 in the videotaped deposition of
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` 4 Matthias Konrad in the matter of Network-1
`
`09:08 5 Technologies, Inc., versus Google LLC and
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` 6 YouTube LLC in United States District Court,
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` 7 Southern District of New York, Case No. 14 Civ.
`
` 8 2396 (PGG) and 14 Civ. 9558 (PGG).
`
` 9 Today's date is October the 30th,
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`09:08 10 2019. The time on the video monitor is 9:08 a.m.
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`11 The video operator today is Linda
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`12 Fleet representing Barclay Court Reporters.
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`13 This video deposition is taking place
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`14 at the offices of Wilmer Hale, 49 Park Lane,
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`09:09 15 London, W1K 1PS, United Kingdom.
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`16 Counsel, please voice identify
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`17 yourselves and state whom you represent.
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`18 MR. LEDAHL: Brian Ledahl from Russ,
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`19 August & Kabat, on behalf of the Plaintiff.
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`09:09 20 MR. HARDY: Kevin Hardy from Williams
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`21 & Connolly on behalf of the Defendants, and with me
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`22 is Graham Safty, also from Williams & Connolly, and
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`23 Demarron Berkley, in-house counsel at Google.
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`24 THE VIDEOGRAPHER: The court reporter
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`09:09 25 today is Audrey Shirley, and could the reporter
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`5
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`MATTHIAS KONRAD-Highly Confidential
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`Case 1:14-cv-02396-PGG-SN Document 241-7 Filed 11/12/20 Page 7 of 285
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` 1 please swear in the witness?
`
` 2 (Brief audible disruption.)
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` 3 MATTHIAS KONRAD, having been duly sworn, was
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` 4 examined and testified as follows:
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`09:09 5 EXAMINATION
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` 6 BY MR. LEDAHL:
`
` 7 Q. Good morning, Mr. Konrad.
`
` 8 A. Good morning, Brian.
`
` 9 Q. Have you ever had your deposition
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`09:10 10 taken before today?
`
`11 A. No, I did not.
`
`12 Q. Okay. So, I'll go over a couple of
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`13 procedural aspects to hopefully make today's
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`14 process a little more smooth.
`
`09:10 15 First of all, do you understand that
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`16 the oath you took a moment ago is the same oath you
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`17 would take if you were testifying live in court in
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`18 front of a judge and jury in the United States?
`
`19 A. Yes, I understand.
`
`09:10 20 Q. Okay. Now, as you've probably
`
`21 noticed, we have, in addition to a video operator,
`
`22 we have a court reporter who takes down
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`23 a transcript of all of what we say during the
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`24 deposition. To make sure that we have as clear and
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`09:10 25 accurate a transcript as possible, I'll ask you to
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`6
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` 1 do a couple of things and I'll try to do the same.
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` 2 The first is, because only one of us can be
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` 3 transcribed at a time, I'll try to wait until you
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` 4 finish answering a question before asking you
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`09:10 5 another. Likewise, if you can wait until I finish
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` 6 my question before you start answering, that way
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` 7 neither one of us is talking over the other. Do
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` 8 you understand?
`
` 9 A. I understand. I'll do my best.
`
`09:11 10 Q. That's all I can ask.
`
`11 The second is, because things like
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`12 shakes and nods of the head or ambiguous phrases
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`13 like "uh-huh" are difficult to transcribe
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`14 accurately, I'll ask you to try to remember to say
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`09:11 15 "yes" or "no", so that it's clear what your answer
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`16 is. Sometimes I may remind you; I'm not trying to
`
`17 be rude, I just want to make sure we have
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`18 an accurate record. Do you understand?
`
`19 A. Uh-huh. Yes.
`
`09:11 20 Q. If at any time you don't understand
`
`21 my question, please let me know, I'll do my best to
`
`22 clarify it for you, otherwise I'll assume you
`
`23 understood, and you provide an answer. Is that
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`24 fair?
`
`09:11 25 A. Yes, that is fair.
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` 1 Q. Okay. Are you on any medication or
`
` 2 is there any other health or other reason why you'd
`
` 3 be unable to give your best and most accurate
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` 4 testimony today?
`
`09:11 5 A. No, I'm not medicated, no.
`
` 6 Q. All right. You understand that you
`
` 7 have been designated to offer some testimony on
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` 8 behalf of Google and YouTube in this case. Is that
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` 9 correct?
`
`09:12 10 A. Yes, that is correct.
`
`11 Q. Okay. And did you review a list of
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`12 topics on which you've been designated?
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`13 MR. HARDY: You can answer that "yes"
`
`14 or "no".
`
`09:12 15 THE WITNESS: Yeah. Yes, we have
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`16 reviewed a list of the topics.
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`17 MR. LEDAHL: And, counsel, I'll just
`
`18 confirm, I won't read in the very long list from
`
`19 the email I got, but the most recent communication
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`09:12 20 I had had a fairly high number of topics and I --
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`21 maybe I do need to just go through them just to be
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`22 clear.
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`23 The list I have is 1 through 6, 9
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`24 through 12, 19 through 30, 42, 44 through 46, 50
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`09:12 25 through 56, and 71 through 93. Is that correct?
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` 1 MR. HARDY: That's correct.
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` 2 MR. LEDAHL: Okay. And there are no
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` 3 other topics on which Mr. Konrad is being
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` 4 designated. Correct?
`
`09:13 5 MR. HARDY: Correct.
`
` 6 BY MR. LEDAHL:
`
` 7 Q. Okay. I won't ask you to verify each
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` 8 and every one of them, because that would take
`
` 9 a very long time and I don't think it will be
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`09:13 10 necessary for our purposes.
`
`11 What did you do to prepare for your
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`12 deposition, Mr. Konrad?
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`13 MR. HARDY: You can describe the
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`14 process in general. I just want to caution you not
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`09:13 15 to reveal the substance of any communications you
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`16 had with your attorneys to prepare.
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`17 THE WITNESS: Okay. I was -- I had
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`18 a meeting at some point with our lawyers and then
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`19 we spent about a day and a half preparing in
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`09:13 20 general.
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`21 BY MR. LEDAHL:
`
`22 Q. And when did you first meet with the
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`23 lawyers to prepare for your deposition?
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`24 A. I don't have exact recollection of
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`09:13 25 that date, I guess that can be given off the
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` 1 record. I -- probably about two to three months
`
` 2 ago.
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` 3 Q. Okay. And then you had some further
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` 4 meeting more recently to prepare?
`
`09:14 5 MR. HARDY: You can answer that "yes"
`
` 6 or "no". Again, just --
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` 7 THE WITNESS: Yes, yeah.
`
` 8 BY MR. LEDAHL:
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` 9 Q. And when was that?
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`09:14 10 A. That was at the beginning of this
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`11 week.
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`12 Q. And who did you meet with?
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`13 A. I met with Kevin, Graham and
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`14 Demarron.
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`09:14 15 Q. Okay. And you said that was for
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`16 about a day and a half?
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`17 A. Correct.
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`18 Q. Did you review any documents as part
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`19 of your preparation for your deposition?
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`09:14 20 A. Yes, we have reviewed some documents.
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`21 Q. And is it your understanding that all
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`22 the documents you reviewed as part of your
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`23 preparation are documents that had been provided in
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`24 the discovery process in this lawsuit?
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`09:14 25 MR. HARDY: I'll represent that they
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` 1 were.
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` 2 MR. LEDAHL: That's fine.
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` 3 BY MR. LEDAHL:
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` 4 Q. Did you meet with anyone else outside
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`09:15 5 of the meetings you had with lawyers to prepare for
`
` 6 your deposition?
`
` 7 A. No, I did not.
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` 8 Q. Did you talk to anyone else at
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` 9 Google/YouTube as part of your preparation?
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`09:15 10 A. We -- as part of the preparation, we
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`11 also talked to Oleg, who is a member of my team.
`
`12 Q. And what's -- so, did you say Oleg?
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`13 O-l-e-g?
`
`14 A. O-l-e-g, yeah, uh-huh.
`
`09:15 15 Q. And what's Oleg's last name?
`
`16 A. Ryjkov ... his username is
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`17 olegr@google.com.
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`18 Q. Okay. And what did you talk to Oleg
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`19 about?
`
`09:15 20 MR. HARDY: That's okay, yes.
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`21 THE WITNESS: We had a conversation
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`22 about some metrics that might come up.
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`23 BY MR. LEDAHL:
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`24 Q. What metrics did you talk with Oleg
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`09:16 25 about in particular?
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`11
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` 1 A. We looked at the cost of running the
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` 2 ContentID match system.
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` 3 Q. Anything else?
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` 4 A. We've also looked at where the match
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`09:16 5 system is running globally and how many matches it
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` 6 produced.
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` 7 Q. Any other metrics or things that you
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` 8 discussed with Oleg?
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` 9 A. I don't recollect any others.
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`09:16 10 Q. Was there anyone else, other than
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`11 Oleg, from Google or YouTube that you talked to as
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`12 part of your preparation?
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`13 A. I did not talk to anybody else in
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`14 Google --
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`09:16 15 Q. Okay.
`
`16 A. -- no.
`
`17 Q. So, with respect to -- let me -- let
`
`18 me go through the two things you mentioned you
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`19 spoke with Oleg about.
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`09:17 20 The first I think you said was costs
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`21 of running the ContentID match system?
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`22 A. (Non-verbal response.)
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`23 Q. What kind of costs are you referring
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`24 to?
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`09:17 25 A. We looked at the total hardware
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` 1 resource spent and running the hardware on a -- on
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` 2 an annual basis.
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` 3 Q. And were there documents you
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` 4 consulted about that?
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`09:17 5 A. I believe Oleg looked at internal
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` 6 tools that reported those numbers freshly.
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` 7 Q. What's that tool, do you know, that
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` 8 he would -- was using?
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` 9 A. I'm not fully solid on exactly which
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`09:17 10 tool he showed. It might have been resource
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`11 weather but I --
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`12 THE COURT REPORTER: Resource?
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`13 THE WITNESS: Resource weather. Like
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`14 resource weather, like the weather of the resource.
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`09:17 15 Yeah.
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`16 BY MR. LEDAHL:
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`17 Q. And what -- did you come to any
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`18 numbers or values that were the annual hardware
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`19 costs as you were mentioning?
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`09:18 20 A. It gave us an idea about how much
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`21 each of the parts of the systems are costing. It's
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`22 a bit hard to say exactly what number we would
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`23 refer to if you say you're running ContentID
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`24 because the scope can be defined in many different
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`09:18 25 ways.
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` 1 Q. So, when you say the different parts
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` 2 or components of ContentID, what are you referring
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` 3 to?
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` 4 A. ContentID is a very overloaded term
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`09:18 5 within YouTube. I'm, for example, responsible for
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` 6 running the ContentID organization, and then
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` 7 there's an external product that is called
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` 8 ContentID, and the ContentID organization contains
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` 9 many other parts that don't necessarily have much
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`09:19 10 to do with the ContentID as in Copyright System.
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`11 Q. And you said there's an external
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`12 product. What are you referring to?
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`13 A. The ContentID -- YouTube ContentID is
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`14 a -- is a -- is a name that often comes up that has
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`09:19 15 an external presence, so people think of a thing
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`16 when they hear YouTube ContentID.
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`17 Q. Okay. When you think about ContentID
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`18 and the system that your group is responsible for,
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`19 how -- what do you consider to be that system at
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`09:19 20 a high level?
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`21 MR. HARDY: Objection to form.
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`22 You can answer, if you can.
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`23 THE WITNESS: I feel there is a core
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`24 of the system which is a match technology and the
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`09:20 25 match claiming technology.
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` 1 BY MR. LEDAHL:
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` 2 Q. And am I correct that the match and
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` 3 match claiming technology are used to identify when
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` 4 a video is uploaded to YouTube that may contain
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`09:20 5 content that matches to some reference content such
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` 6 as that provided by a copyright holder?
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` 7 A. So, the match system is used for
`
` 8 many, many different purposes. For the -- for the
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` 9 classical copyright use case it has to -- it has to
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`09:20 10 check whether there is any content reuse between
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`11 an uploader videos and any of our partner content
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`12 videos.
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`13 Q. So, I probably skipped over this, so
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`14 I'm going to go back.
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`09:21 15 So you, I assume, work at YouTube as
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`16 a part of Google. Is that right?
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`17 A. That is correct.
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`18 Q. And you're based in Zurich. Is that
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`19 correct?
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`09:21 20 A. That is correct as well.
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`21 Q. How long have you worked for Google
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`22 and YouTube?
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`23 A. I've worked for 12 years for Google,
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`24 and I think about seven years for YouTube.
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`09:21 25 Q. So, just to make sure I'm clear, you
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`15
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` 1 started with Google about 12 years ago, and you
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` 2 started working in the YouTube portion of Google
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` 3 about seven years ago?
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` 4 A. Yes. I'm much more solid on the
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`09:22 5 12 years number because I know that I joined in
`
` 6 2007 and then, yeah, the seven years number
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` 7 I would ...
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` 8 Q. Okay. What did you do --
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` 9 A. Best guess.
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`09:22 10 Q. -- before working at YouTube?
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`11 A. So, just before working at YouTube,
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`12 I worked on Google Search, in various pieces of it.
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`13 Q. And so what was your job when you
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`14 started at Google in 2007?
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`09:22 15 A. My first job was in the
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`16 infrastructure part of Google and I was a software
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`17 engineer.
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`18 Q. And then -- and that was when you
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`19 started. How long were you in that function?
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`09:22 20 A. I mean, I said it's a bit hard to say
`
`21 when somebody's a software engineer and when
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`22 somebody's an engineering manager. At Google --
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`23 I guess, like, the first two years I was working as
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`24 a software engineer and tech lead on
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`09:23 25 infrastructure, and then I spent about three years
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`16
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` 1 as a software engineer and tech lead on Google, and
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` 2 then I -- there I became a manager as well, so
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` 3 I had a mixed -- mixed work between being tech lead
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` 4 and the manager, and then I switched over to
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`09:23 5 YouTube where I was also managing a team from the
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` 6 start.
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` 7 Q. And when you started at YouTube, what
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` 8 was your role or your job function there?
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` 9 A. I was leading a part of the ContentID
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`09:23 10 match system which we called the match system
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`11 quality team.
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`12 Q. And can you explain to me, at least
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`13 when you started, what was sort of the
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`14 high-level organizational structure of the
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`09:24 15 ContentID team within YouTube? You mentioned you
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`16 were leading the quality -- the match system
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`17 quality team. What were the sort of other parts --
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`18 A. Uh-huh.
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`19 Q. -- of the ContentID system team?
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`09:24 20 A. Uh-huh, so there was the match system
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`21 quality team and there was a match system
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`22 infrastructure team that was led by my peer
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`23 manager. There was a match claiming team, also in
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`24 Zurich, and then there was a rights management team
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`09:24 25 that operated in Mountain View.
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` 1 Q. Who led the infrastructure team at
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` 2 the time you came to YouTube?
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` 3 A. That was Kathrin Paschen.
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` 4 Q. And who led the claiming team?
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`09:24 5 A. The claiming team was managed by
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` 6 David Erb, and the tech lead was somebody else.
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` 7 Q. Do you remember who that was?
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` 8 A. Sai Suman.
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` 9 Q. How do you spell that?
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`09:25 10 A. So Suman -- saisuman is the username,
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`11 I think s-a-i-s-u-m-a-n@google.com.
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`12 Q. Fair enough. And then who led the
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`13 rights management team?
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`14 A. So this is -- I did not have many
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`09:25 15 connection points with rights management at this
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`16 point. I believe it was Jimin.
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`17 THE COURT REPORTER: It was?
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`18 (Reporter clarification.)
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`19 THE WITNESS: Jimin. Jim --
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`09:25 20 I wouldn't be able to --
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`21 BY MR. LEDAHL:
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`22 Q. Is that like --
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`23 A. -- spell you the --
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`24 Q. -- J-i-m --
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`09:25 25 A. J-i-m-i-n, would be my best guess.
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`18
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` 1 Q. Okay. And at some point, did your
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` 2 responsibilities shift from being the manager of
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` 3 the quality team?
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` 4 A. Yes, they did shift.
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`09:26 5 Q. And how did -- when did that happen,
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` 6 approximately?
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` 7 A. I think it happened in 2014, but I'm
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` 8 not 100 percent solid, it could have been 2015.
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` 9 I think it was 2014, summer 2014.
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`09:26 10 Q. And what was your, sort of, new role
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`11 at that point?
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`12 A. I started being responsible for the
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`13 whole match systems of infrastructure, quality and
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`14 also applications.
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`09:26 15 Q. And when you say "applications", what
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`16 are you referring to?
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`17 A. When -- we were, basically --
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`09:28 10 Q. Now, at some point after you switched
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`11 -- well, strike that.
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`12 When you started working with
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`13 YouTube, was there already a functioning ContentID
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`14 system?
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`09:28 15 A. Yes, there was.
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`16 Q. And do you know why YouTube and
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`17 Google had developed the ContentID system in the
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`18 first place?
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`19 A. I have not been present when the --
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`09:28 20 when those decisions were made, so I couldn't know
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`21 exactly why.
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`22 Q. Do you have any understanding of why?
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`23 A. I believe that it was developed to
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`24 let the content owners manage policies of their
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`09:29 25 content on YouTube at scale.
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`20
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` 1 Q. Did you have any understanding that
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` 2 before ContentID was developed, Google had other
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` 3 systems for allowing content owners to manage
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` 4 content on YouTube?
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`09:29 5 MR. HARDY: Objection to form.
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` 6 You can answer, if you can.
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` 7 THE WITNESS: So there is -- there's
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` 8 essentially two ways for content owners to manage
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` 9 their content on YouTube. One is ContentID that is
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`09:29 10 available to some content owners, and the other one
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`11 is the DMCA framework, which I believe is a legal
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`12 requirement for companies like YouTube to provide
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`13 and -- but I do not recollect whether the DMCA
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`14 framework was there before or after ContentID.
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`09:30 15 I would guess it was there before.
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`16 BY MR. LEDAHL:
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`17 Q. And, just to be clear, the DMCA
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`18 framework you're referring to, that's a system
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`19 where a content owner can identify a video on
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`09:30 20 YouTube as having content belonging to them under
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`21 US copyright law and ask that it be removed?
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`22 A. Yes, that is that system.
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`23 Q. And that's essentially a manual
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`24 system; there's no automated functioning? It's
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`09:30 25 essentially they send a message through an email
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`21
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` 1 portal to Google about a particular video. Is that
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` 2 right?
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` 3 A. It is a manual system for the issuer
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` 4 of the DMCA takedown. It is not necessarily fully
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`09:31 5 a manual system for a site like YouTube that
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` 6 gets ...
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` 7 Q. So -- and just to clarify, does that
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` 8 mean that when you get a request at YouTube there's
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` 9 an automated process that handles what happens to
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`09:31 10 that video after the request comes in?
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`11 A. So now it depends about -- I do not
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`12 know how that system looked like at the beginning.
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`13 I do know how the system looks like since, like,
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`14 the last three years. And the system cannot just
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`09:31 15 reject a DSC -- DMCA takedown without being
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`16 reviewed by a human but it can accept it --
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`17 Q. I see.
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`18 A. -- without being reviewed by a human,
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`19 and that's where we basically can save operations.
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`09:31 20 Q. Understood. There's no -- that
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`21 system, though, or that process, doesn't have any
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`22 automated identification, using computers, of the
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`23 particular content, at least not that's running on
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`24 YouTube. Correct?
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`09:32 25 MR. HARDY: Objection to form.
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`22
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` 1 You can answer.
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` 2 THE WITNESS: The strict DMCA
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` 3 takedown system does not -- does not, for example,
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` 4 use the match system.
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`09:32 5 BY MR. LEDAHL:
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` 6 Q. Now, before Google's match system,
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` 7 did you have an understanding that Google and
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` 8 YouTube
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`09:32 10 A. I've heard of times that, on some
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`11 point, long before I joined the team, that
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`12
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`13 Q. Do you know why
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`16 A. I would be speculating what the
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`17 reason was back then.
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`18 Q. To your knowledge, has Google or --
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`19 and YouTube ever used any other third-party system
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`09:33 20 to identify copyrighted content on YouTube?
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`21 A. I do not remember ever having seen
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`22 any other third party.
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`23 Q.
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`23
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`16 A. I do not understand that, no.
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`17 Q. Okay.
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`18 A. No, I don't know.
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`19 Q. And just to be clear, you understood
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`09:37 20 my question; you don't understand what they --
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`21 A. Oh, yeah.
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`22 Q. -- were doing?
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`23 A. I do understand the question, yes.
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`24 No, we were
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`26
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` 2 Q. Okay, thank you.
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` 3 Did you obtain
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`11 Q. Why was it important to have the
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`12 robustness that you mentioned?
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`13 A. If -- the scalability aspect is only
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`14 interesting for us if the -- if the -- if the
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`09:39 15 robustness is there.
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`16 Q. I understand. I'm actually asking,
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`17 with respect to the robustness, why is that
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`18 important? Why is it important that it be robustly
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`19 able to detect transforms, for example?
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`09:39 20 A. We have seen at times that uploaders
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`21 created effects on videos that made it hard to
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`22 detect if there was content reuse from one of our
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`23 content owners, so it has been important to create
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`24 a system that is robust in still finding reuse when
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`09:39 25 those effects were there.
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`27
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` 1 Q. I may be asking a slightly more
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` 2 fundamental question: why is it important to be
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` 3 able to find those kinds of reuse?
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` 4 MR. HARDY: Objection to form.
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`09:40 5 You can answer, if you can.
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` 6 THE WITNESS: The goal of ContentID
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` 7 is to provide content owner an ability to manage
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` 8 their copyrighted content at scale on YouTube. To
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` 9 be able to do that, it's important that we detect
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`09:40 10 content reuse for all uploaded videos and not just
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`11 a small subset.
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`12 BY MR. LEDAHL:
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`13 Q. Is it your understanding th
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