Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 1 of 18
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 1 of 18
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`EXHIBIT 10
`
`

`

`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 2 of 18
`
`In the Matter Of:
`TOUCHSTREAM TECHNOLOGIES V.
`
`GOOGLE LLC
`
`JANOS LEVAI
`November 30, 2022
`
`

`

`Janos LevaiJanos Levai
`
`
`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 3 of 18
`November 30, 2022
`
`GOOGLE LLCGOOGLE LLC
`Page 3
`
`Page 1
`
`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑IN THE UNITED STATES DISTRICT COURT
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ FOR THE WESTERN DISTRICT OF TEXAS
`∑2∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ WACO DIVISION
`∑3
`∑ ∑ ∑ TOUCHSTREAM∑ ∑ ∑ ∑ ∑ |
`∑4∑ ∑ TECHNOLOGIES, INC.∑ ∑|
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑|
`∑5∑ ∑ ∑ ∑Plaintiff,∑ ∑ ∑ ∑ |
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑|
`∑6∑ ∑ V.∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑|∑ Civil Action No. 6:21-cv-569
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑|
`∑7∑ ∑ GOOGLE LLC∑ ∑ ∑ ∑ ∑ ∑|
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑|
`∑8∑ ∑ ∑ ∑Defendant.∑ ∑ ∑ ∑ |
`∑9
`∑ ∑ ∑******************************************************
`10∑ ∑ ∑ ∑ ∑ ∑ ∑ ORAL AND VIDEOTAPED DEPOSITION OF
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ JANOS ìJOHNNYî LEVAI
`12∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ NOVEMBER 30, 2022
`13∑ ∑******************************************************
`14
`∑ ∑ ∑ ∑ ∑ ∑ORAL AND VIDEOTAPED DEPOSITION of JANOS ìJOHNNYî
`15∑ ∑LEVAI, produced as a witness at the instance of the
`∑ ∑ ∑Defendant, and duly sworn, was taken in the
`16∑ ∑above-styled and numbered cause on November 30, 2022,
`∑ ∑ ∑from 7:19 a.m. to 7:59 a.m., before Mendy A.
`17∑ ∑Schneider, CSR, RPR, in and for the State of Texas,
`∑ ∑ ∑recorded by machine shorthand, remotely at the offices
`18∑ ∑of MENDY SCHNEIDER, LLC, The Woodlands, Texas,
`∑ ∑ ∑pursuant to the Texas Rules of Civil Procedure and the
`19∑ ∑provisions stated on the record or attached hereto;
`∑ ∑ ∑that the deposition shall be read and signed.
`20
`21
`22
`23
`24
`25
`
`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ EXAMINATION INDEX
`∑2∑ ∑WITNESS:∑ JANOS ìJOHNNYî LEVAI
`∑3∑ ∑ ∑ ∑EXAMINATION∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑PAGE
`∑ ∑ ∑ ∑ ∑ ∑ ∑ BY MR. LANIER∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑8
`∑4∑ ∑ ∑ ∑ ∑ ∑ BY MR. DYKAL∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑22
`∑5∑ ∑ ∑ ∑FURTHER EXAMINATION
`∑ ∑ ∑ ∑ ∑ ∑ ∑ BY MR. LANIER∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ 32
`∑6
`∑ ∑ ∑ ∑ ∑SIGNATURE REQUESTED∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑37
`∑7
`∑ ∑ ∑ ∑ ∑REPORTER'S CERTIFICATION∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ 38
`∑8
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ EXHIBIT INDEX
`∑9
`∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑PAGE
`10∑ ∑ ∑ ∑ LEVAI EXHIBIT NO. 1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ 15
`∑ ∑ ∑ ∑ ∑ ∑ ∑ Appendix to Levai Declaration
`11
`12
`∑ ∑ ∑ ∑ ∑(REPORTER'S NOTE: All quotations from exhibits are
`13∑ ∑reflected in the manner in which they were read into
`∑ ∑ ∑the record and do not necessarily denote an exact
`14∑ ∑quote from the document.)
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`∑1∑ ∑ ∑ ∑ ∑ ∑ R E M O T E∑ A P P E A R A N C E S
`∑2
`∑ ∑ ∑FOR THE PLAINTIFF:
`∑3
`∑ ∑ ∑ ∑ ∑MR. RYAN DYKAL
`∑4∑ ∑ ∑ ∑SHOOK HARDY & BACON
`∑ ∑ ∑ ∑ ∑2555 Grand Boulevard
`∑5∑ ∑ ∑ ∑Kansas City, Missouri 64108
`∑ ∑ ∑ ∑ ∑(816) 559-2572
`∑6∑ ∑ ∑ ∑rdykal@shb.com
`∑7
`∑ ∑ ∑FOR THE DEFENDANT:
`∑8
`∑ ∑ ∑ ∑ ∑MR. GREG LANIER
`∑9∑ ∑ ∑ ∑MS. ANDREA DILL
`∑ ∑ ∑ ∑ ∑51 Louisiana Avenue NW
`10∑ ∑ ∑ ∑Washington, DC 20001
`∑ ∑ ∑ ∑ ∑202.879.3645
`11∑ ∑ ∑ ∑adill@jonesday.com
`12
`∑ ∑ ∑VIDEOGRAPHER:
`13
`∑ ∑ ∑ ∑ ∑MR. HERIBERTO GARCIA
`14
`15∑ ∑ALSO PRESENT:
`16∑ ∑ ∑ ∑MR. ANDY NGUYEN, Google
`∑ ∑ ∑ ∑ ∑MS. CHRISTINE RHEE, Google
`17∑ ∑ ∑ ∑MR. OLIVIER BUFF, Swiss Commissioner
`18
`19
`20
`21
`22
`23
`24
`25
`
`Page 2
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`Page 4
`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE VIDEOGRAPHER:∑ Good morning.∑ We are
`∑2∑ ∑now on the record.∑ Today's date is November 30, 2022.
`∑3∑ ∑The time is 8:19 a.m. Eastern Standard Time.
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑This is the video deposition of Janos
`∑5∑ ∑Levai in the matter of Touchstream Technologies versus
`∑6∑ ∑Google LLC.
`∑7∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑This deposition is taking place via web
`∑8∑ ∑videoconference with all participants attending
`∑9∑ ∑remotely.
`10∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑My name is Heriberto Garcia.∑ I'm the
`11∑ ∑videographer representing Lexitas.
`12∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Will counsel on the conference please
`13∑ ∑identify yourself and state whom you represent.
`14∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ My name is Greg Lanier. I
`15∑ ∑am with the law firm of Jones Day.∑ I'm joined by my
`16∑ ∑colleague, Andrea Dill, also of Jones Day.∑ We
`17∑ ∑represent Google and the witness.∑ We are joined on
`18∑ ∑this conference by Andy Nguyen and Christine Rhee also
`19∑ ∑of Google.
`20∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ And Ryan Dykal on behalf of
`21∑ ∑the plaintiff Touchstream.
`22∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE VIDEOGRAPHER:∑ Okay.∑ Thank you. The
`23∑ ∑court reporter will now swear in the witness.
`24∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE REPORTER:∑ Did Mr. Buff need to go
`25∑ ∑first?
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`www.LexitasLegal.com/Premierwww.LexitasLegal.com/Premier
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`
`
`LexitasLexitas
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`888-267-1200 Pages 1–4
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`YVer1f
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`

`

`Janos LevaiJanos Levai
`
`
`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 4 of 18
`November 30, 2022
`
`GOOGLE LLCGOOGLE LLC
`Page 7
`∑1∑ ∑that you will have the chance to correct any errors in
`∑2∑ ∑the transcript and that you will then be asked to sign
`∑3∑ ∑such transcript?
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`∑5∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, do you understand
`∑6∑ ∑that such -- such signed transcript and videotaped
`∑7∑ ∑testimony will then be transmitted to the parties U.S.
`∑8∑ ∑Council for Submission and used before the United
`∑9∑ ∑States District Court of the Western District of
`10∑ ∑Texas?
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`12∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Thank you.
`13∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑This is all from my side.
`14∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Thank you.∑ I've seen this
`15∑ ∑done both ways, but, Mr. Dykal, I've often seen that
`16∑ ∑the U.S. court reporter also swears the witness under
`17∑ ∑U.S. process.
`18∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Do you have a preference either way?
`19∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ No, we don't.∑ I think -- I
`20∑ ∑think we've made our position clear that we object to
`21∑ ∑this process, but you can proceed how you'd like.
`22∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Understood.∑ All right.
`23∑ ∑Then I'd ask, Madam Court Reporter, if you could swear
`24∑ ∑the witness as is typical in your way, too, and then
`25∑ ∑we'll get started.
`
`Page 5
`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Yeah, I guess -- I guess that
`∑2∑ ∑might be easiest if I go first, and then -- because
`∑3∑ ∑this -- my part also has a swearing-in part.
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑So hello, everyone.∑ Good morning.∑ Good
`∑5∑ ∑afternoon.∑ My name is Olivier Buff.∑ I'm the
`∑6∑ ∑so-called Swiss Commissioner appointed by the
`∑7∑ ∑competent Swiss authority, supervising today's
`∑8∑ ∑deposition of Mr. Janos Levai in the matter of
`∑9∑ ∑Touchstream Technologies versus Google LLC.
`10∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Basis for today's deposition is the
`11∑ ∑authorization by the Swiss Federal Department of
`12∑ ∑Justice, which is still valid today.
`13∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑In exercising my function as Swiss
`14∑ ∑Commissioner, I have verified the identity of
`15∑ ∑Mr. Janos who is right here with me in this room at
`16∑ ∑this deposition, and I hereby confirm that the person
`17∑ ∑sitting with me here is indeed Mr. Janos Levai, who is
`18∑ ∑a resident of Switzerland.
`19∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Furthermore, I'm hereby advising
`20∑ ∑Mr. Levai of his rights in accordance with the
`21∑ ∑authorization by the Swiss Federal Department of
`22∑ ∑Justice and the Hague Convention on the taking of
`23∑ ∑evidence.
`24∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Mr. Levai, do you understand that you
`25∑ ∑have the right to be represented by a lawyer in this
`
`Page 6
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`Page 8
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`∑1∑ ∑deposition?
`∑2∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`∑3∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, do you understand
`∑4∑ ∑that you are under no legal obligation to appear today
`∑5∑ ∑to this deposition and that this deposition may be
`∑6∑ ∑ended at any point in time if you wish so?
`∑7∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`∑8∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, do you understand
`∑9∑ ∑that you may invoke the right to refuse testimony or
`10∑ ∑to prohibition of testimony under both Swiss law and
`11∑ ∑U.S. law?
`12∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`13∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, this deposition
`14∑ ∑will be conducted in English.∑ Are you comfortable
`15∑ ∑with this?
`16∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`17∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, do you swear or
`18∑ ∑affirm that the -- that the testimony you are about to
`19∑ ∑provide is the truth, the whole truth, and nothing but
`20∑ ∑the truth?
`21∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`22∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, do you understand
`23∑ ∑that this deposition is transcribed and videotaped?
`24∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑THE WITNESS:∑ Yes.
`25∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. BUFF:∑ Mr. Levai, do you understand
`
`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ JANOS LEVAI,
`∑2∑ ∑having been first duly sworn, testified as follows:
`∑3∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Thank you.∑ And, again,
`∑4∑ ∑good morning and good afternoon to all and thank you
`∑5∑ ∑all for your patience as we got ourselves started.
`∑6∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ E X A M I N A T I O N
`∑7∑ ∑BY MR. LANIER:
`∑8∑ ∑ ∑ ∑Q.∑ ∑Mr. Levai, my name is Greg Lanier.∑ I'm one
`∑9∑ ∑of the lawyers for Google in this case.∑ Thank you for
`10∑ ∑joining us today.
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Would you introduce yourself to the
`12∑ ∑jury, please?
`13∑ ∑ ∑ ∑A.∑ ∑Of course.∑ My is Janos Levai, and I work as
`14∑ ∑a software engineer at Google.
`15∑ ∑ ∑ ∑Q.∑ ∑Are you sometimes known as "Johnny Levai"
`16∑ ∑when speaking with people who speak English?
`17∑ ∑ ∑ ∑A.∑ ∑Yes.∑ That's my more English friendly
`18∑ ∑nickname.
`19∑ ∑ ∑ ∑Q.∑ ∑Where are you sitting today, sir?
`20∑ ∑ ∑ ∑A.∑ ∑Today I'm sitting in Zurich, Switzerland.
`21∑ ∑ ∑ ∑Q.∑ ∑Is that where you generally work, in Zurich,
`22∑ ∑Switzerland?
`23∑ ∑ ∑ ∑A.∑ ∑Yes, I generally work in Zurich.
`24∑ ∑ ∑ ∑Q.∑ ∑Do you live in Switzerland?
`25∑ ∑ ∑ ∑A.∑ ∑Yes, I live in Switzerland.
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`www.LexitasLegal.com/Premierwww.LexitasLegal.com/Premier
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`LexitasLexitas
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`888-267-1200 Pages 5–8
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`YVer1f
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`

`

`Janos LevaiJanos Levai
`
`
`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 5 of 18
`November 30, 2022
`
`GOOGLE LLCGOOGLE LLC
`Page 11
`∑1∑ ∑ ∑ ∑Q.∑ ∑Was YouTube Remote already out and available
`∑2∑ ∑in the world when you started at Google?
`∑3∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑4∑ ∑ ∑ ∑Q.∑ ∑As you started to get to work at Google, did
`∑5∑ ∑you learn when YouTube Remote was launched?
`∑6∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`∑7∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑8∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ I'm sorry, Mr. Levai,
`∑9∑ ∑occasionally Mr. Dykal may object, so give him a
`10∑ ∑moment to say his words, and then you may answer his
`11∑ ∑question.∑ So --
`12∑ ∑ ∑ ∑A.∑ ∑All right.
`13∑ ∑ ∑ ∑Q.∑ ∑And what did you learn about when YouTube
`14∑ ∑Remote was first launched at Google?
`15∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`16∑ ∑ ∑ ∑A.∑ ∑I learned that the YouTube Remote application
`17∑ ∑for Android was first launched approximately
`18∑ ∑November 2010.
`19∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Have you heard of something
`20∑ ∑called "YouTube Leanback"?
`21∑ ∑ ∑ ∑A.∑ ∑Yes.
`22∑ ∑ ∑ ∑Q.∑ ∑What's that?
`23∑ ∑ ∑ ∑A.∑ ∑It is one of the technologies that is
`24∑ ∑essential for the YouTube Remote system to work.
`25∑ ∑ ∑ ∑Q.∑ ∑And have you heard of YouTube Lounge?
`
`Page 9
`∑1∑ ∑ ∑ ∑Q.∑ ∑Thank you for joining us by video today.∑ You
`∑2∑ ∑mentioned you're a software engineer.
`∑3∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Do you have any technical or academic
`∑4∑ ∑training in software engineering?
`∑5∑ ∑ ∑ ∑A.∑ ∑Yes.∑ I have a bachelor's degree in computer
`∑6∑ ∑science.
`∑7∑ ∑ ∑ ∑Q.∑ ∑And when did you get that bachelor's degree?
`∑8∑ ∑ ∑ ∑A.∑ ∑Approximately in the summer of 2011.
`∑9∑ ∑ ∑ ∑Q.∑ ∑Okay.∑ I thought I heard you say that you are
`10∑ ∑with Google.
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑When did you first start working with
`12∑ ∑Google in any capacity?
`13∑ ∑ ∑ ∑A.∑ ∑I first started working at Google as an
`14∑ ∑intern in 2011, July.
`15∑ ∑ ∑ ∑Q.∑ ∑Were you working on any particular project
`16∑ ∑when you started working at Google?
`17∑ ∑ ∑ ∑A.∑ ∑Yes.∑ My main project was something called
`18∑ ∑"YouTube Remote."
`19∑ ∑ ∑ ∑Q.∑ ∑What is YouTube Remote?
`20∑ ∑ ∑ ∑A.∑ ∑Well, YouTube Remote is mostly known by an
`21∑ ∑Android application that we launched and it allowed
`22∑ ∑people to look for YouTube videos, then play back
`23∑ ∑those videos on a big screen device like a TV and then
`24∑ ∑control the playback of those videos from the YouTube
`25∑ ∑Remote Android application.
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`Page 10
`∑1∑ ∑ ∑ ∑Q.∑ ∑And so YouTube Remote, was that something you
`∑2∑ ∑could access from a -- a phone and -- and use your
`∑3∑ ∑phone to do those things you just described?
`∑4∑ ∑ ∑ ∑A.∑ ∑Correct.
`∑5∑ ∑ ∑ ∑Q.∑ ∑Using YouTube Remote, could you use your
`∑6∑ ∑phone to find video that you wanted to watch?
`∑7∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑8∑ ∑ ∑ ∑Q.∑ ∑Using YouTube Remote, could you use your
`∑9∑ ∑phone to direct that that video actually be displayed
`10∑ ∑on a different screen, something other than your
`11∑ ∑phone?
`12∑ ∑ ∑ ∑A.∑ ∑Yes, like a -- like a TV, for example.
`13∑ ∑ ∑ ∑Q.∑ ∑In that example, use -- in YouTube Remote,
`14∑ ∑could you use your phone to control the playback of
`15∑ ∑the video on that other screen such as the TV?
`16∑ ∑ ∑ ∑A.∑ ∑Yes.
`17∑ ∑ ∑ ∑Q.∑ ∑You could start it, stop it, rewind it,
`18∑ ∑things like that?
`19∑ ∑ ∑ ∑A.∑ ∑Yes.∑ All -- all of those actions were
`20∑ ∑supported in YouTube Remote.
`21∑ ∑ ∑ ∑Q.∑ ∑And those actions were -- those actions were
`22∑ ∑engaged in by the user on their phone, but it had
`23∑ ∑effect on the display as you were watching it on the
`24∑ ∑TV; is that correct?
`25∑ ∑ ∑ ∑A.∑ ∑Correct.
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`Page 12
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`∑1∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑2∑ ∑ ∑ ∑Q.∑ ∑And what is that?
`∑3∑ ∑ ∑ ∑A.∑ ∑It also encompasses a set of technologies
`∑4∑ ∑that are part of the YouTube Remote system.
`∑5∑ ∑ ∑ ∑Q.∑ ∑And were YouTube Leanback and YouTube Lounge,
`∑6∑ ∑were they around when you started at Google?
`∑7∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑8∑ ∑ ∑ ∑Q.∑ ∑Have you heard of something called MDX
`∑9∑ ∑protocol?
`10∑ ∑ ∑ ∑A.∑ ∑Yes.
`11∑ ∑ ∑ ∑Q.∑ ∑What is MDX protocol?
`12∑ ∑ ∑ ∑A.∑ ∑MDX protocol essentially describes the way
`13∑ ∑that the YouTube Remote systems communicate with each
`14∑ ∑other that would be due to remote Android applications
`15∑ ∑with the servers, and then the servers with the big
`16∑ ∑screen devices like the TVs.
`17∑ ∑ ∑ ∑Q.∑ ∑And was MDX protocol part of the YouTube
`18∑ ∑Remote technology when you started at Google?
`19∑ ∑ ∑ ∑A.∑ ∑Yes.
`20∑ ∑ ∑ ∑Q.∑ ∑So it had been developed already by the time
`21∑ ∑you got there?
`22∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`23∑ ∑ ∑ ∑A.∑ ∑Yes.
`24∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ You mentioned servers in your
`25∑ ∑answer.∑ What did you mean by servers?
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`www.LexitasLegal.com/Premierwww.LexitasLegal.com/Premier
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`888-267-1200 Pages 9–12
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`Janos LevaiJanos Levai
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`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 6 of 18
`November 30, 2022
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`GOOGLE LLCGOOGLE LLC
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`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`∑2∑ ∑ ∑ ∑A.∑ ∑Servers are essentially computers that are
`∑3∑ ∑running in, let's say, a data center.∑ It -- those are
`∑4∑ ∑computers which are not in the hands of users.
`∑5∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Did servers play a role in
`∑6∑ ∑YouTube Remote?
`∑7∑ ∑ ∑ ∑A.∑ ∑Yes.∑ They were an essential part of the
`∑8∑ ∑YouTube Remote system.
`∑9∑ ∑ ∑ ∑Q.∑ ∑What -- what part or what role did servers
`10∑ ∑play in the YouTube Remote system at a high level?
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Objection; form.
`12∑ ∑ ∑ ∑A.∑ ∑At a high level they would connect the
`13∑ ∑YouTube Remote Android application to the big screen
`14∑ ∑devices like TV and allow them to change information.
`15∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Did the servers store
`16∑ ∑information relating to the operation of YouTube
`17∑ ∑Remote?
`18∑ ∑ ∑ ∑A.∑ ∑Yes.∑ There was information on the server
`19∑ ∑about YouTube Remote operations.
`20∑ ∑ ∑ ∑Q.∑ ∑Are you familiar with a capacity or
`21∑ ∑functionality on the servers in the YouTube Remote
`22∑ ∑system called MIM cache?
`23∑ ∑ ∑ ∑A.∑ ∑Yes.
`24∑ ∑ ∑ ∑Q.∑ ∑What is MIM cache?
`25∑ ∑ ∑ ∑A.∑ ∑MIM cache is a technology that allows to
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`∑1∑ ∑ ∑ ∑A.∑ ∑An API defines the way two digital systems
`∑2∑ ∑can communicate with each other.∑ It's kind of like
`∑3∑ ∑the rules of how two systems can exchange information.
`∑4∑ ∑ ∑ ∑Q.∑ ∑Did you review APIs during your -- relating
`∑5∑ ∑to YouTube Remote during your time at Google?
`∑6∑ ∑ ∑ ∑A.∑ ∑API documentation?
`∑7∑ ∑ ∑ ∑Q.∑ ∑Yes.
`∑8∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑9∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Ms. Dill, could you load
`10∑ ∑into the exhibit folder what we'll mark as Exhibit 1?
`11∑ ∑It's been production No. GOOG PA 2268 through 2270.
`12∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑(Marked Levai Exhibit No. 1.)
`13∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Mr. Levai, that will go into
`14∑ ∑the exhibit folder.∑ And when you see it pop in there,
`15∑ ∑if you would, open it and please tell us when that
`16∑ ∑happens.
`17∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑I see it in the folder.∑ It's titled
`18∑ ∑"Appendix to Levai Declaration" and it goes from
`19∑ ∑there.∑ If you wouldn't mind opening that, sir, and
`20∑ ∑tell me when you're ready.
`21∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑(Discussion off the record.)
`22∑ ∑ ∑ ∑A.∑ ∑And it ends with 2270, right?
`23∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ That's correct.
`24∑ ∑ ∑ ∑A.∑ ∑Okay.∑ I have it open.
`25∑ ∑ ∑ ∑Q.∑ ∑All right.∑ If you would turn to the second
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`Page 14
`∑1∑ ∑store key value pairs.∑ Yeah.∑ Pretty much that --
`∑2∑ ∑that's what MIM cache is as -- as a technology
`∑3∑ ∑library.
`∑4∑ ∑ ∑ ∑Q.∑ ∑You said "key value pairs."∑ What did you
`∑5∑ ∑mean by that?
`∑6∑ ∑ ∑ ∑A.∑ ∑Key value pairs are types of information used
`∑7∑ ∑to generally identify certain parts of information
`∑8∑ ∑that can be retrieved with a key which is usually an
`∑9∑ ∑identifier.
`10∑ ∑ ∑ ∑Q.∑ ∑And was that identifying information used in
`11∑ ∑YouTube Remote to help the communication that
`12∑ ∑ultimately resulted in you picking a video on your
`13∑ ∑phone and watching it on your TV?
`14∑ ∑ ∑ ∑A.∑ ∑It -- it was essential to allow communication
`15∑ ∑of the YouTube Remote app with the TV.
`16∑ ∑ ∑ ∑Q.∑ ∑Did Google keep written documentation of how
`17∑ ∑the MDX protocol worked?
`18∑ ∑ ∑ ∑A.∑ ∑Yes.
`19∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Objection; form.
`20∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Did Google keep written
`21∑ ∑documentation of APIs related to YouTube Remote?
`22∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`23∑ ∑ ∑ ∑A.∑ ∑Yes.∑ Most -- most of the APIs were
`24∑ ∑documented.
`25∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ What's an API?
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`∑1∑ ∑page of this exhibit, sir, up at the top it says,
`∑2∑ ∑"7/12/2010," and under that in big letters "API server
`∑3∑ ∑documentation."
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Do you see that?
`∑5∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑6∑ ∑ ∑ ∑Q.∑ ∑Do you recognize this to be documentation of
`∑7∑ ∑an API relating to YouTube Remote?
`∑8∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑9∑ ∑ ∑ ∑Q.∑ ∑And in very general terms, what does this
`10∑ ∑particular documentation describe or disclose?
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`12∑ ∑ ∑ ∑A.∑ ∑In general terms, it describes certain parts
`13∑ ∑of the MDX API implemented by the server, and, yes,
`14∑ ∑it's -- it's mostly around video playback, playlist
`15∑ ∑management, and disconnecting.
`16∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Up at the top, there's
`17∑ ∑numbers that look to be like a date "7/12/2010."
`18∑ ∑ ∑ ∑ ∑ ∑ Do you see that?
`19∑ ∑ ∑ ∑A.∑ ∑Yes.
`20∑ ∑ ∑ ∑Q.∑ ∑Now, Mr. Levai, I know you are in Europe and
`21∑ ∑sometimes Europeans write their dates differently than
`22∑ ∑we do in the United States.∑ Did Google have a
`23∑ ∑practice in dating documentation as to whether to use
`24∑ ∑the European or American format?
`25∑ ∑ ∑ ∑A.∑ ∑Yes.∑ Google generally uses the American
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`Janos LevaiJanos Levai
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`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 7 of 18
`November 30, 2022
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`GOOGLE LLCGOOGLE LLC
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`∑1∑ ∑format, mostly because it's an American company.
`∑2∑ ∑ ∑ ∑Q.∑ ∑And so 7/12/2010 in the American format would
`∑3∑ ∑be July 12, 2010.
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Is that how you understand it?
`∑5∑ ∑ ∑ ∑A.∑ ∑Yes.∑ Especially if you see these date
`∑6∑ ∑formats with slashes, we see these as month, day, and
`∑7∑ ∑year; so the American format.
`∑8∑ ∑ ∑ ∑Q.∑ ∑Was it typical at this time for Google to
`∑9∑ ∑keep dates on API documentation?
`10∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`11∑ ∑ ∑ ∑A.∑ ∑Yes.∑ It's -- it's generally good practice to
`12∑ ∑keep a date on the documentation.
`13∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ And from your work at Google,
`14∑ ∑what's your understanding of the purpose of keeping
`15∑ ∑the date on the documentation?
`16∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Objection; form.
`17∑ ∑ ∑ ∑A.∑ ∑Generally the date on documentation refers to
`18∑ ∑the date that the documentation was last updated on.
`19∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Would reading this API
`20∑ ∑documentation be one way that you, doing your work at
`21∑ ∑Google, would understand how YouTube Remote operated?
`22∑ ∑ ∑ ∑A.∑ ∑Yes --
`23∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`24∑ ∑ ∑ ∑A.∑ ∑-- this is one of -- one of the ways to
`25∑ ∑understand how an API works.
`
`∑1∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑2∑ ∑ ∑ ∑Q.∑ ∑Did you regularly work on it and make changes
`∑3∑ ∑or updates to it?
`∑4∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑5∑ ∑ ∑ ∑Q.∑ ∑Did Google have a practice at that time of
`∑6∑ ∑keeping source code relating to its product operation?
`∑7∑ ∑ ∑ ∑A.∑ ∑Yes.∑ Every -- every product is by definition
`∑8∑ ∑made up of source code.
`∑9∑ ∑ ∑ ∑Q.∑ ∑And was it Google's practice at the time when
`10∑ ∑you started to keep dates on or near source code, say,
`11∑ ∑for example, in a comments field?
`12∑ ∑ ∑ ∑A.∑ ∑Back in the time it -- yes, source code
`13∑ ∑generally had in the header the creation date and --
`14∑ ∑as -- as a comment.
`15∑ ∑ ∑ ∑Q.∑ ∑And what was the -- what was conveyed by the
`16∑ ∑date that was kept on -- on or in the header for
`17∑ ∑source code at that time?
`18∑ ∑ ∑ ∑A.∑ ∑Generally that was the date of which the --
`19∑ ∑the source code file was created on.
`20∑ ∑ ∑ ∑Q.∑ ∑Earlier in the course of this case, did you
`21∑ ∑review source code relating to YouTube Remote?
`22∑ ∑ ∑ ∑A.∑ ∑Yes.
`23∑ ∑ ∑ ∑Q.∑ ∑And did you prepare and did you verify that
`24∑ ∑source code that you reviewed was actually the source
`25∑ ∑code that related to YouTube Remote back in the past?
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`∑1∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Okay.∑ All right.∑ I'm -- I
`∑2∑ ∑am done with this now.∑ You may close this document,
`∑3∑ ∑Mr. Levai.∑ Thank you.
`∑4∑ ∑ ∑ ∑ ∑ ∑ I'm not going to show it to you, but I'm going
`∑5∑ ∑to talk to you about source code.∑ Did you work with
`∑6∑ ∑source code during your time working on YouTube Remote
`∑7∑ ∑at Google?
`∑8∑ ∑ ∑ ∑A.∑ ∑Yes, of course.
`∑9∑ ∑ ∑ ∑Q.∑ ∑Very generally, sir, what is source code?
`10∑ ∑ ∑ ∑A.∑ ∑Very generally, source code is a human
`11∑ ∑readable list of instructions that later then can be
`12∑ ∑executed by computers.
`13∑ ∑ ∑ ∑Q.∑ ∑So if you -- you'll see those movies, or I've
`14∑ ∑even seen people actually sit there clicking away,
`15∑ ∑software engineers like you clicking away like this.
`16∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Is it -- is it often that they are
`17∑ ∑working on source code?
`18∑ ∑ ∑ ∑A.∑ ∑Yes.∑ Generally software engineers spend most
`19∑ ∑of their time working on source code.
`20∑ ∑ ∑ ∑Q.∑ ∑And are software engineers able to read
`21∑ ∑source code and understand something about how a
`22∑ ∑particular system operates?
`23∑ ∑ ∑ ∑A.∑ ∑Yes.
`24∑ ∑ ∑ ∑Q.∑ ∑When you were working on YouTube Remote, did
`25∑ ∑you regularly review source code for that product?
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`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`∑2∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑3∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Do you recall signing a
`∑4∑ ∑declaration in this case that, among other things,
`∑5∑ ∑talked about the source code for YouTube Remote?
`∑6∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑7∑ ∑ ∑ ∑Q.∑ ∑And did you verify before signing that
`∑8∑ ∑declaration that the source code that you reviewed
`∑9∑ ∑was, in fact, source code for YouTube Remote at
`10∑ ∑particular points in time?
`11∑ ∑ ∑ ∑A.∑ ∑Yes.
`12∑ ∑ ∑ ∑Q.∑ ∑So one way to understand how a product -- a
`13∑ ∑software product works is to read API documentation,
`14∑ ∑correct?
`15∑ ∑ ∑ ∑A.∑ ∑Yes, that's one way.
`16∑ ∑ ∑ ∑Q.∑ ∑And another way to understand how a product
`17∑ ∑works -- a software product works is to read the
`18∑ ∑source code, correct?
`19∑ ∑ ∑ ∑A.∑ ∑Correct.
`20∑ ∑ ∑ ∑Q.∑ ∑And these were both things that you did
`21∑ ∑regularly in your time at Google as a software
`22∑ ∑engineer, correct?
`23∑ ∑ ∑ ∑A.∑ ∑Yes.
`24∑ ∑ ∑ ∑Q.∑ ∑Now, just to make sure I understand
`25∑ ∑everything, when you -- the -- the -- the version of
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`Janos LevaiJanos Levai
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`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 8 of 18
`November 30, 2022
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`GOOGLE LLCGOOGLE LLC
`Page 23
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`∑1∑ ∑YouTube Remote that you first started working with,
`∑2∑ ∑that was the public version that had already been
`∑3∑ ∑released, correct?
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`∑5∑ ∑ ∑ ∑A.∑ ∑Sorry, you're asking if I was working on the
`∑6∑ ∑version of YouTube Remote that was already released?
`∑7∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Yes, that was my question.
`∑8∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑When you first started -- let me just
`∑9∑ ∑ask again.∑ And -- and Mr. Dykal may have objections,
`10∑ ∑so please give him a moment.
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑But when you first started working at
`12∑ ∑Google on YouTube Remote, you -- that product was
`13∑ ∑already released, correct?
`14∑ ∑ ∑ ∑A.∑ ∑Yes.
`15∑ ∑ ∑ ∑Q.∑ ∑It was already out in the public; is that
`16∑ ∑right?
`17∑ ∑ ∑ ∑A.∑ ∑Yes.
`18∑ ∑ ∑ ∑Q.∑ ∑And you could use that YouTube Remote to find
`19∑ ∑content on your phone, have it displayed on another
`20∑ ∑screen and control that playback on that other screen
`21∑ ∑when you started at Google, correct?
`22∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Object to form.
`23∑ ∑ ∑ ∑A.∑ ∑Yes.
`24∑ ∑ ∑ ∑Q.∑ ∑(BY MR. LANIER)∑ Okay.
`25∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Thank you, sir.
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`∑1∑ ∑ ∑ ∑A.∑ ∑What do you mean as in "Google"?∑ Like
`∑2∑ ∑exactly what are you referring to?
`∑3∑ ∑ ∑ ∑Q.∑ ∑Do you personally know what was happening
`∑4∑ ∑inside of Google on these projects before you started
`∑5∑ ∑working there in July 2011?
`∑6∑ ∑ ∑ ∑A.∑ ∑You mean what was happening inside the
`∑7∑ ∑YouTube Remote project?
`∑8∑ ∑ ∑ ∑Q.∑ ∑Yes.∑ You've discussed YouTube Remote,
`∑9∑ ∑YouTube Leanback, MDX, and some other things.
`10∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Do you recall that?
`11∑ ∑ ∑ ∑A.∑ ∑Yes.
`12∑ ∑ ∑ ∑Q.∑ ∑Do you personally know what was happening
`13∑ ∑with those projects prior to July 2011, from your
`14∑ ∑personal knowledge?
`15∑ ∑ ∑ ∑A.∑ ∑No.∑ Before I joined Google, I did not know
`16∑ ∑what sort of development phase was the project in. I
`17∑ ∑just know that there existed an app on the Play Store.
`18∑ ∑ ∑ ∑Q.∑ ∑And you've testified about some things that
`19∑ ∑happened prior to your working at Google.
`20∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Do you recall that?
`21∑ ∑ ∑ ∑A.∑ ∑Yes.
`22∑ ∑ ∑ ∑Q.∑ ∑Did you learn that from speaking with other
`23∑ ∑people?
`24∑ ∑ ∑ ∑A.∑ ∑I learned that from my colleagues and from
`25∑ ∑looking at the documentation.
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`Page 22
`∑1∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ I have no more questions.
`∑2∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Mr. Dykal?
`∑3∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. DYKAL:∑ Yeah.∑ One second.
`∑4∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Sure.
`∑5∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ E X A M I N A T I O N
`∑6∑ ∑BY MR. DYKAL:
`∑7∑ ∑ ∑ ∑Q.∑ ∑Mr. Levai, when did you start working for
`∑8∑ ∑Google again?
`∑9∑ ∑ ∑ ∑A.∑ ∑As an intern or as full-timer?
`10∑ ∑ ∑ ∑Q.∑ ∑How about as an intern first?
`11∑ ∑ ∑ ∑A.∑ ∑Okay.∑ As an intern in 2011, July.
`12∑ ∑ ∑ ∑Q.∑ ∑And were you still in college at that time?
`13∑ ∑ ∑ ∑A.∑ ∑I was between a bachelor's program and a
`14∑ ∑master's program.
`15∑ ∑ ∑ ∑Q.∑ ∑Were you working full time as an intern?
`16∑ ∑ ∑ ∑A.∑ ∑Yes.
`17∑ ∑ ∑ ∑Q.∑ ∑When did you start working full time at
`18∑ ∑Google?
`19∑ ∑ ∑ ∑A.∑ ∑Full time as in non-intern position, as like
`20∑ ∑a full-time position?
`21∑ ∑ ∑ ∑Q.∑ ∑Yes.
`22∑ ∑ ∑ ∑A.∑ ∑That was in 2012, March.
`23∑ ∑ ∑ ∑Q.∑ ∑Do you have any personal knowledge of what
`24∑ ∑was occurring at Google prior to your working there in
`25∑ ∑July 2011?
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`Page 24
`∑1∑ ∑ ∑ ∑Q.∑ ∑Did you meet with Google's lawyers before
`∑2∑ ∑this deposition?
`∑3∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑4∑ ∑ ∑ ∑Q.∑ ∑Who did you meet with?
`∑5∑ ∑ ∑ ∑A.∑ ∑I met with Greg Lanier.
`∑6∑ ∑ ∑ ∑Q.∑ ∑Anyone else?
`∑7∑ ∑ ∑ ∑A.∑ ∑Andy -- oh, I'm sorry.∑ Andy Nguyen.
`∑8∑ ∑ ∑ ∑Q.∑ ∑Anyone else?
`∑9∑ ∑ ∑ ∑A.∑ ∑Anyone else from the Google legal team?
`10∑ ∑ ∑ ∑Q.∑ ∑Anyone else from Google legal.
`11∑ ∑ ∑ ∑A.∑ ∑Evan -- I'm sorry about the last name. I
`12∑ ∑don't remember the last name now.
`13∑ ∑ ∑ ∑Q.∑ ∑Okay.∑ For how long did you meet with
`14∑ ∑Google's lawyers before this deposition?
`15∑ ∑ ∑ ∑A.∑ ∑I think a couple of hours.
`16∑ ∑ ∑ ∑Q.∑ ∑Did you review any documents with those
`17∑ ∑Google lawyers?
`18∑ ∑ ∑ ∑A.∑ ∑Yes.
`19∑ ∑ ∑ ∑Q.∑ ∑Did you remember everything you saw in those
`20∑ ∑documents?
`21∑ ∑ ∑ ∑A.∑ ∑Not everything.
`22∑ ∑ ∑ ∑Q.∑ ∑What were some of the things that you didn't
`23∑ ∑remember until you saw those documents?
`24∑ ∑ ∑ ∑A.∑ ∑Probably the initial pitch deck of the
`25∑ ∑project.
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`Janos LevaiJanos Levai
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`TOUCHSTREAM TECHNOLOGIES V.TOUCHSTREAM TECHNOLOGIES V.
`Case 6:21-cv-00569-ADA Document 207-10 Filed 04/20/23 Page 9 of 18
`November 30, 2022
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`∑1∑ ∑ ∑ ∑Q.∑ ∑And what project was that?
`∑2∑ ∑ ∑ ∑A.∑ ∑The YouTube Remote.
`∑3∑ ∑ ∑ ∑Q.∑ ∑And what was this pitch deck?
`∑4∑ ∑ ∑ ∑A.∑ ∑It basically defined the main ideas behind
`∑5∑ ∑the project.
`∑6∑ ∑ ∑ ∑Q.∑ ∑Were you involved in creating that pitch
`∑7∑ ∑deck?
`∑8∑ ∑ ∑ ∑A.∑ ∑No.
`∑9∑ ∑ ∑ ∑Q.∑ ∑You said that you believed YouTube Remote
`10∑ ∑launched before you started at Google; is that right?
`11∑ ∑ ∑ ∑A.∑ ∑Yes.
`12∑ ∑ ∑ ∑Q.∑ ∑Were you aware of the -- of the product
`13∑ ∑before you started at Google?
`14∑ ∑ ∑ ∑A.∑ ∑Yes.
`15∑ ∑ ∑ ∑Q.∑ ∑Had you used it prior to starting at Google?
`16∑ ∑ ∑ ∑A.∑ ∑No.
`17∑ ∑ ∑ ∑Q.∑ ∑Now, you mentioned the YouTube Remote; is
`18∑ ∑that right?
`19∑ ∑ ∑ ∑A.∑ ∑If -- sorry, could you repeat the question?
`20∑ ∑ ∑ ∑Q.∑ ∑You discussed YouTube Remote today; is that
`21∑ ∑correct?
`22∑ ∑ ∑ ∑A.∑ ∑Yes.
`23∑ ∑ ∑ ∑Q.∑ ∑Did YouTube Remote change over time, the
`24∑ ∑features?
`25∑ ∑ ∑ ∑A.∑ ∑Yes, just like any software.
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`∑1∑ ∑server."
`∑2∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Do you recall that?
`∑3∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑4∑ ∑ ∑ ∑Q.∑ ∑And I think you said a server is something
`∑5∑ ∑that's in a data center and not in the hands of users,
`∑6∑ ∑correct?
`∑7∑ ∑ ∑ ∑A.∑ ∑Generally, yes.
`∑8∑ ∑ ∑ ∑Q.∑ ∑Generally.
`∑9∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑Is it possible that a user could have a
`10∑ ∑server located in their house?
`11∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Object to form.
`12∑ ∑ ∑ ∑A.∑ ∑You mean generally a server regardless of --
`13∑ ∑I mean, like a computing device that can act as a
`14∑ ∑server?
`15∑ ∑ ∑ ∑Q.∑ ∑(BY MR. DYKAL) Correct.
`16∑ ∑ ∑ ∑A.∑ ∑Yes, that's possible.
`17∑ ∑ ∑ ∑Q.∑ ∑Would you agree that many computing devices
`18∑ ∑could act as servers depending on the functions that
`19∑ ∑they perform?
`20∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR. LANIER:∑ Object to form.
`21∑ ∑ ∑ ∑A.∑ ∑They could.
`22∑ ∑ ∑ ∑Q.∑ ∑(BY MR. DYKAL)∑ Have you heard of a Raspberry
`23∑ ∑Pi?
`24∑ ∑ ∑ ∑A.∑ ∑Yes.
`25∑ ∑ ∑ ∑Q.∑ ∑What's a Raspberry Pi?
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`Page 26
`∑1∑ ∑ ∑ ∑Q.∑ ∑Do you know the dates the different versions
`∑2∑ ∑of YouTube Remote were launched?
`∑3∑ ∑ ∑ ∑A.∑ ∑Not from the top of my head, no.
`∑4∑ ∑ ∑ ∑Q.∑ ∑But it's fair to say that it changed over
`∑5∑ ∑time?
`∑6∑ ∑ ∑ ∑A.∑ ∑Yes.
`∑7∑ ∑ ∑ ∑Q.∑ ∑And you said YouTube Remote was discontinued,
`∑8∑ ∑correct?
`∑9∑ ∑ ∑ ∑A.∑ ∑The YouTube Remote Android application was
`10∑ ∑indeed discontinued eventually.
`11∑ ∑ ∑ ∑Q.∑ ∑Did you do any work on a project called
`12∑ ∑"Chromecast"?
`13∑ ∑ ∑ ∑A.∑ ∑Are you referring to the actual device
`14∑ ∑itself?
`15∑ ∑ ∑ ∑Q.∑ ∑The device and the software on the device.
`16∑ ∑ ∑ ∑A.∑ ∑No.
`17∑ ∑ ∑ ∑Q.∑ ∑Do you know whether YouTube Remote became or
`18∑ ∑was incorporated into the Chromecast product?
`19∑ ∑ ∑ ∑A.∑ ∑No.∑ The YouTube Remote Android application
`20∑ ∑was not incorporated into Chromecast.
`21∑ ∑ ∑ ∑Q.∑ ∑So they were separate projects; is that
`22∑ ∑right?
`23∑ ∑ ∑ ∑A.∑ ∑Yes.∑ They -- they represent two different
`24∑ ∑sides of the YouTube Remote system.
`25∑ ∑ ∑ ∑Q.∑ ∑Now, you also discussed something called "the
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`Page 28
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`∑1∑ ∑ ∑ ∑A.∑ ∑A Raspberry Pi is a really small footprint
`∑2∑ ∑computer.
`∑3∑ ∑ ∑ ∑Q.∑ ∑Could a Raspberry Pi function as a server if
`∑4∑ ∑it were configured in a certain way?
`∑5∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑ ∑MR