Oracle America, Inc. v. Google Inc.

Filing 509

DECLARATION of RUCHIKA AGRAWAL in Opposition to 496 MOTION in Limine No. 5, 494 MOTION in Limine No. 3, 492 MOTION in Limine No. 1, 493 MOTION in Limine NO. 2, 495 MOTION in Limine No. 4 filed byGoogle Inc.. (Attachments: # 1 Exhibit 1-1, # 2 Exhibit 1-2, # 3 Exhibit 1-3, # 4 Exhibit 1-4, # 5 Exhibit 1-5, # 6 Exhibit 1-6, # 7 Exhibit 1-7, # 8 Exhibit 1-8, # 9 Exhibit 1-9, # 10 Exhibit 1-10, # 11 Exhibit 1-11, # 12 Exhibit 1-12, # 13 Exhibit 2-1, # 14 Exhibit 2-2, # 15 Exhibit 2-3, # 16 Exhibit 2-4, # 17 Exhibit 2-5, # 18 Exhibit 2-6, # 19 Exhibit 2-7, # 20 Exhibit 2-8, # 21 Exhibit 2-9, # 22 Exhibit 2-10, # 23 Exhibit 2-11, # 24 Exhibit 2-12, # 25 Exhibit 2-13, # 26 Exhibit 2-14, # 27 Exhibit 2-15, # 28 Exhibit 2-16, # 29 Exhibit 2-17, # 30 Exhibit 3-1, # 31 Exhibit 3-2, # 32 Exhibit 3-3, # 33 Exhibit 3-4, # 34 Exhibit 3-5, # 35 Exhibit 3-6, # 36 Exhibit 3-7, # 37 Exhibit 3-8, # 38 Exhibit 3-9, # 39 Exhibit 3-10, # 40 Exhibit 3-11, # 41 Exhibit 4-1, # 42 Exhibit 4-2, # 43 Exhibit 4-3, # 44 Exhibit 5-1, # 45 Exhibit 5-2, # 46 Exhibit 5-3, # 47 Supplement 5-4)(Related document(s) 496 , 494 , 492 , 493 , 495 ) (Kamber, Matthias) (Filed on 10/7/2011)

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EXHIBIT 2-10 Attorneys' Eyes Only 1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 SAN FRANCISCO DIVISION 4 5 ------------------------ 6 ORACLE AMERICA, INC., ) 7 Plaintiff, ) 8 vs. ) No. CV 10-03561 WHA 9 GOOGLE, INC., ) 10 11 Defendant. ) ------------------------ 12 13 ATTORNEYS' EYES ONLY 14 15 Videotaped Deposition of EREZ LANDAU, 16 taken at 42 Chauncy Street, Boston, 17 Massachusetts, commencing at 9:50 a.m., 18 Wednesday, September 14, 2011, before 19 Jill Shepherd, RPR, MA-CSR No. 148608, 20 NH-CSR No. 128, CA-CSR No. 13275, CLR, 21 Notary Public. 22 23 24 25 PAGES 1 - 113 Page 1 Veritext National Deposition & Litigation Services 866 299-5127 EXHIBIT 2-10 Attorneys' Eyes Only 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 tape two. We are back on the record. Q. To continue where we left off before the break, let's take a look at paragraph 27 on page six. You indicate that you modified two files for your testing. One is RuntimeInit.java and the second one is AndroidRuntime.cpp; is that right? A. Yes. Q. Is RuntimeInit that Java part of the accused functionality? MR. PETERS: Objection. Form. A. I want to open now, which is the accused functionality basically is the fork, disabling the fork -- disabling the usage of fork as a standalone operation and move it into fork/exec combination. When you're using a new process in fork/exec folk, you get disabling of the copy-on-write functionality. So just looking right now which one of the files was that. One file contains -- both of them I use. One file is calling the other function, which is the defining the first one. Let me describe it for you. On 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 one place, and it was sufficient. Q. Do you know which files are part of the accused functionality? MR. PETERS: Objection. Form. A. I did not study it. Q. Do you know if RuntimeInit.java is part of the accused functionality? MR. PETERS: Objection. Form. A. As I was saying, I did not study it. My task was only to disable it. Q. You modified RuntimeInit.java, correct? A. Yes. Q. Do you know if that file was part of the accused functionality before you modified it? MR. PETERS: Objection. Form. A. You asked me this question -- this is the third time you ask me. I say I don't know. Q. Okay. Did your modifications disable the whole preloader? MR. PETERS: Objection. Form. A. What do you mean by "preloader"? In which context? Q. When the zygote starts up, it preloads a Page 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 page one of Appendix A, we added a new JNI function, which is in the RuntimeInit_exec, which do the exec operation. The exec operation disable the fork as a standalone, and, by this, disable copy-on-write. So together they are doing this operation. The actual disabling is inside B and A is calling B. Q. A is RuntimeInit.java? A. Yes. Q. And B is AndroidRuntime.cpp? A. Yes. No, B is AndroidRuntime.cpp. This is A and this is B [indicating]. Q. I'm sorry. Right. Are any other files part of the accused functionality? MR. PETERS: Objection. Form. A. Can you -- are there any other files what? Q. That are part of the accused functionality in Android. MR. PETERS: Objection. Form. A. I was not looking for the accused functionality. I was looking how to disable it. It's the actual functionality is composed many places, but I disable only in Page 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 number of frameworks into memory; is that correct? MR. PETERS: Objection. Form. A. You also do that. This is not the only thing it does. Q. It is one of the functions that it performs; is that correct? MR. PETERS: Objection. Form. A. Correct. Q. And those frameworks that are loaded can be cloned using copy-on-write in Android; is that your understanding? MR. PETERS: Objection. Form. A. Your description of the situation is not precise. Q. Let me start over then. Does Android have a preloader? MR. PETERS: Objection. Form. A. Preloader is used in several places in different contexts. This is why I ask you what context you are referring. Q. Do Java virtual machines have a class preloader? MR. PETERS: Objection. Form. A. Again, same answer. Preloader is not a Page 47 Page 49 13 (Pages 46 - 49) Veritext National Deposition & Litigation Services 866 299-5127 EXHIBIT 2-10 Attorneys' Eyes Only 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 come to Israel. MR. PETERS: I have a few follow-up questions, Mr. Landau. ***** EXAMINATION BY MR. PETERS Q. If you look at Exhibit 496, which is a document entitled "MtaskClassLoading." A. The list of class loading? Yes. Found it. Q. This is your program that will load in the classes that are named here in the static stream classes list on the first page? A. Yes. Q. If I could ask you to turn to page 21, please. A. Yes. Q. And here at the bottom of page 21, there's a series of classes that are in the package space org.apatchi.harmony.xnet.provider.jsse. Do you see those? A. Yes. Q. So when your test program loads, it will load those classes; is that correct? A. It can only load them. It cannot execute them. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Is there any relationship between your test program loading that class and the bluetooth.ScoSocket entries -- in the log entry of Exhibit 499? A. In the Bluetooth case it's likely that you are right, but we have to verify this in the code. Q. So it could be not accidental that these log entries relating to bluetooth.ScoSocket appear in the log because of the loading of the class ScoSocket? A. It could be. We have to check it. Q. Speaking more generally about the tests that you and your team ran, would you say that the tests that are described in your report and you've testified about today, are they representative of the kind of performance testing that you and your team members do in your everyday work? A. Yes. This is a typical scenario of work that we are doing. Q. Okay. And when you do your work, do you normally rely on your colleagues like Seeon to help you do your work? Page 106 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. But what will it do with any sort of static initialization methods that may be present when it initializes the classes, when the classes are loaded? A. In the 4.8, I don't think it's been done. I'm not sure about this. Anyway, this is not a message you get over there -- from the log. The message in the log is not due to that. Q. So there's -- so in your view, there's no relationship between the loading of the classes and the log message in Exhibit 499? A. It could be. I would say it's not. It could be. Q. Okay. If I could ask you to turn to page two of Exhibit 496, MtaskClassLoading.java. A. Which one? The same one? Q. Yes. Page two. So here do you see a series of classes all beginning the name "android.bluetooth"? A. Yes. Q. And the last one on that list is "android.bluetooth.ScoSocket"? A. Yes. Page 108 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I assist a lot of and -- I am being assisted a lot with hands-on work with other of the -- I'm supervising quite multiple projects. Q. Is there anything about the projects that you did in your analysis of Android that you would say is not typical of the kinds of testing you do in the Java environment? A. No. We use normal methods that -- normal procedure. Q. Okay. MR. PETERS: Thank you, Mr. Landau. THE VIDEOGRAPHER: The time is 1:34 p.m. This is the end of tape three, and the deposition is concluded, and we are off the record. (Whereby the proceedings were concluded at 1:34 p.m.) Page 107 Page 109 28 (Pages 106 - 109) Veritext National Deposition & Litigation Services 866 299-5127 EXHIBIT 2-10

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