Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 1 of 7
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`Exhibit G
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`Exhibit G
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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
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` 4 NETWORK-1 TECHNOLOGIES, INC., )
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` 5 Plaintiff, )
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` 6 vs. ) Case Nos.
` ) 14 Civ. 2396 (PGG)
` 7 GOOGLE, INC., and YOUTUBE LLC, ) 14 Civ. 9558 (PGG)
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` 8 Defendants. )
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` 9
` London, United Kingdom,
`10
` Wednesday, October 30th, 2019
`11
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`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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`22
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`23
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`24
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`25
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`Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 2 of 7
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`1
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`MATTHIAS KONRAD-Highly Confidential
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` 1 that need to be able to utilize this capacity. For
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` 2 some teams, it's important to have their services
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` 3 run in certain locales, other teams just need the
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` 4 resources. I would say ContentID is a team that
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`10:53 5 just needs the resources, so we don't put too many
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` 6 constraints.
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` 7 There are maybe considerations to not
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` 8 have everything in just one data center because of
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` 9 the potential of power outages and other things and
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`10:54 10 having higher redundancy to be able to have better
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`11 reliability. But I don't believe we ever had
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`12 a conversation as to it should be all in the US or
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`13 not in the US as part of any such consideration for
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`14 reliability.
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`10:54 15 Q. Do you have any understanding of what
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`16 would be required to, for example, not have any in
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`17 the US?
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`18 A. I believe that would be -- the first
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`19 thing that we would be doing is we would contact
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`10:54 20 the resource planners, Christine Moor's team, to
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`21 make sure we have enough provisioning in other data
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`22 centers. I guess there would be other teams that
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`23 could be locating their services out of non-US data
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`24 centers into US data centers and we could get those
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`10:55 25 resources there and, once we would have that, it
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`Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 3 of 7
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`MATTHIAS KONRAD-Highly Confidential
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` 1 would be as simple as pushing a couple of
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` 2 configuration to bring it up in non-US data
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` 3 centers, yes.
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` 4 Q. Have there been any discussions about
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`10:55 5 whether that's feasible and under what
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` 6 circumstances Google would be able to do that?
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` 7 A. I have been in conversations about
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` 8 this yesterday as part of the preparation to this
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` 9 meeting. We have never otherwise discussed this.
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`10:55 10 Q. And when you say you were in
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`11 conversations yesterday, what do you mean? What
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`12 are you referring to?
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`13 A. As part of the preparation of this
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`14 deposition we discussed whether it would be
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`10:55 15 difficult to operate ContentID just in data centers
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`16 exclusively outside of the United States.
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`17 Q. And that was the first time any
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`18 analysis had been done of that type to your
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`19 knowledge?
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`10:55 20 A. I do not recollect that otherwise we
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`21 have ever done any analysis, like other people
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`22 might have. And I wouldn't say we did very
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`23 specific analysis but, like, the experts on that --
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`24 like, this would be Oleg again on the team --
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`10:56 25 sounded very solid that it would be a -- not
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`Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 4 of 7
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`69
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`MATTHIAS KONRAD-Highly Confidential
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` 1 a heavy amount of work to get that done.
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` 2 Q. Why hasn't Google done it already?
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` 3 MR. HARDY: Objection to form.
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` 4 THE WITNESS: I mean, yeah, so going
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`10:56 5 back to my previous answer, I don't -- I could
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` 6 neither tell you why Google hasn't moved ContentID
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` 7 fully to the US versus fully to the non-US.
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` 8 BY MR. LEDAHL:
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` 9 Q. You mentioned that it would require
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`10:56 10 adjustment or re-provisioning of some services to
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`11 different data centers. What other services would
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`12 have to move to make that accommodation?
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`13 A. So the -- I mean, this would be one
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`14 solution how -- like, if you look at, like, what
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`10:57 15 our resource use is compared to YouTube's total
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`16 resource usage or Google's total resource usage,
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`17 it's a very, very small fraction. So, I would
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`18 believe that, even without moving any services, we
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`19 could -- we could operate all of ContentID, I'm
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`10:57 20 sure we could operate all of ContentID with today's
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`21 resources outside of the US.
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`22 In general, the more flexibility you
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`23 have, the higher utilization can be for these kinds
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`24 of systems. So, whenever a service can run
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`10:57 25 everywhere, there is some advantages in overall
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`Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 5 of 7
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`MATTHIAS KONRAD-Highly Confidential
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` 1 utilization. But whether you can run it everywhere
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` 2 outside of the United States or everywhere doesn't
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` 3 really matter in overall utilization. So, I don't
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` 4 believe, for example, that it would increase
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`10:58 5 resource cost for us to do so.
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` 6 Q. So, what would be the cost associated
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` 7 with making that switch?
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` 8 A. So, I'm a bit like -- the thing that
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` 9 I cannot assess is general resource cost in data
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`10:58 10 centers outside of US versus inside of US. So if
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`11 there's a difference in how data centers operation
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`12 prices are, that might, of course, factor into
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`13 that. I would be surprised if that was too big.
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`14 There's going to be a bit of cost of people that
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`10:58 15 have to do a bit of planning. I couldn't assess
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`16 a dollar number, but it might just be one week or
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`17 a month of work for one person to get that done.
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`18 Q. And how did you arrive at that
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`19 figure?
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`10:59 20 A. That is based on conversations we had
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`21 with Oleg yesterday and the main question was is it
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`22 -- is where a -- where a match system or an indices
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`23 is run, is it just changing a couple of
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`24 configuration files or are there any other things
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`10:59 25 that depend on the exact location? And Oleg
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`Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 6 of 7
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`MATTHIAS KONRAD-Highly Confidential
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` 1 confirms that it was very few configuration files
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` 2 that would have to be changed.
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` 3 Q. And do you know what information Oleg
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` 4 looked at to make those assessments?
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`10:59 5 A. So, Oleg would often be involved in
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` 6 starting a new instance of a match system, stopping
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` 7 instance of a match system, redirecting upload
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` 8 traffic from one match system to another. He has
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` 9 done such things multiple times, also when we had
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`11:00 10 rollouts of new versions. So, based on that,
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`11 I believe he has very firm knowledge as to how much
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`12 it would take to move an instance of a match system
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`13 from one data center to another.
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`14 Q. Now, when you talk about moving
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`11:01 15 instance of the match system, are you referring to
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`16 just the portion that -- basically from the receipt
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`17 of the fingerprints to the output of the pair-wise
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`18 matches?
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`19 A. Yeah, that's the portion I'm talking
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`11:01 20 about.
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`21 Q. Okay. So you're not referring to the
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`22 portions relating to generating the fingerprints,
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`23 which happens where the transcoding happens, or to
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`24 the what I'll call the claiming portions of the
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`11:01 25 system?
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`Case 1:14-cv-02396-PGG-SN Document 249-7 Filed 04/07/21 Page 7 of 7
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`MATTHIAS KONRAD-Highly Confidential
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