Personalized User Model LLP v. Google Inc.

Filing 646

Letter to The Honorable Leonard P. Stark from Karen Jacobs regarding Licensing. (Attachments: # 1 Exhs. A-D)(Jacobs, Karen)

EXHIBIT A

PEARL COHEN ZEDEK LATZER rn
January 22,2008
Direct Dial: [phone]
E-mail: [e-mail]
via Courier
Kent Walker, Esq.
Vice President & General Counsel
Google, Igc.
1600 Amphitheatre Parkway
Mountain View, CA 94043
Re:

US Patents No. 6,981,040 and 7.320.031

Dear Mr. Walker:
We have been retained by Personalized User Model (P.U.M.) LLP to sell, license or otherwise
monetize US Patents No. 6,981,040 (the " '040 Patent") and 7,320,031 (the " '031 Patent").
The patents, entitled Automatic, Personalized Online Information and Product Services, relate to
personalized information services, including personalized search and personalized advertising
results, on the Internet. The '040 Patent discloses:
A method for providing automatic', personalized information services to a computer
user includes the following steps: transparently monitoring user interactions with
data during normal use of the computer; updating user-specific data files including a
set of user-related documents; estimating parameters of a learning machine that
data files; analyzing
define a User Model specific to the user, using the user~specific
a document to identify its properties; estimating the probability that the user is
interested in the document by applying the document properties to the parameters
of the User Model; and providing personalized services based on the estimated
probability. . . (Abstract)
As you can see from the above (and as you will surely see from the '040 and '031 Patent claims),
these. patents are highly relevant to Google's core strategic products relating to personalized search,
news, advertising and other personalization services, particularly iGoogle and associated services.
Google has recognized the strategic importance of personalized search. As Marissa Meyer,
Google's Vice President, Search Products & User Experience stated, "[wle believe that the search
engines of the future will be personalized and that it .will.offer users better results." Accordingly, as
Google announced on February 2, 2007, "[w]elre constantly trying to improve the quality of your
search results. One of the ways we're tackling this is by personalizing your search experience. . .
Today, we're taking another step toward making personalizatio'n more available to you by combining
these two into a single signed-in experience. Now, when you're signed in, you'll have access to a
personalized Google-one
that combines personalized search results and a personalized
homepage."
PUM v. Google
Del. 09-525-LPS

1500 Broadway, 12th Floor, Nw York, NY 10036 Tel [phone], Fax [phone]
e
www.pczlaw.com

PTX1446

Page 2 of 2

Mr. Kent Walker
January 22,2008

We also believe that Google's strategic interests converge with the '040 and '031 Patents based on
a number of Google's currently pending US patent applications, including US Patent Publication No.
200510071328, which has been rejected by the USPTO as anticipated by the '040 Patent.
Please notify me of Google's position on this matter within two weeks of the date of this letter, as the
assignee is currently weighing its options with respect to the patents.

Sincerely;,,,,,'
, 4
,

/'
,

Zedek Latzer LLP
Attachments:
US Patent No. 6,981,040
US Patent No. 7,320,031

1500 Broadway, 12th Floor, New York, N 10036 Tel [phone], Fax [phone]
Y
www.pczlaw.com

EXHIBIT B

PEARL GOHEN
February 15,2008
Direct Dial: [phone]
E-mail: GuvYO,pczlaw.com
Via Federal Express
Kent Walker, Esq.
Vice President & General Counsel
Google, Inc.
1600 Amphitheatre Parkway
Mountain View, CA 94043
Re:

US Patents No. 6,981,040 and 7,320,031

Dear Mr. Walker:

I have not received a response to my letter of January 22,2008.
Please let me know whether Google is interested in acquiring or otherwise licensing Personalized
User Model (P.U.M.) LLP's US Patents No. 6,981,040 (the " '040 Patent") and 7,320,031 (the
" '03 1 Patent").
Please notify me of Google's position on this matter within one week of the date of this letter, as
the assignee is currently weighing its options with respect to the patents.

Sincerely,

Attachments:
Letter of January 22,2008
US Patent No. 6,98 1,040
US Patent No. 7,320,031
PUM v. Google
Del. 09-525-LPS

PTX1447
1500 Broadway, 1 t Floor, New York, NY 10036 Tel [phone]
2h
Fax
www.pczlaw.com

EXHIBIT C

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IN THE UNITED STATES DISTRICT COURT

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02:24:45

IN AND FOR THE DISTRICT OF DELAWARE

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- - PERSONALIZED USER MODEL, L.L.P.,
Plaintiff,

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v.
GOOGLE, INC.,
Defendant.

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CIVIL ACTION

NO. 09-525-LPS

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Wilmington, Delaware
Wednesday, February 26, 2014
Pretrial Conference

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BEFORE:

HONORABLE LEONARD P. STARK, U.S.D.C.J.
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APPEARANCES:

MORRIS NICHOLS ARSHT & TUNNELL, LLP
BY: KAREN JACOBS, ESQ.,
REGINA S.E. MURPHY, ESQ., and
JEREMY A. TIGAN, ESQ.
and
SNR DENTON, LLP
BY: MARK C. NELSON, ESQ., and
RICHARD D. SALGADO, ESQ.
(Dallas, Texas)
and
SNR DENTON, LLP
BY: MARC S. FRIEDMAN, ESQ.
(New York, New York)
and

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1 of 50 sheets

Brian P. Gaffigan
Registered Merit Reporter

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SN R D E N T O N , LLP
B Y : JE N N I F E R D . B E N N E T T , E S Q .
(P a lo A lto , C a lifo rn ia )

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th e re is s o m e la n g u a g e t h a t t h e y m a y s a y , y o u k n o w , c o u ld b e

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h a v e w r itte n a little d iffe re n tly . B u t I th in k w e a ll a g re e

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th a t th e s e a re ite m s th a t a r e liv e to d is c u s s w it h y o u .

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O b v io u s ly , w e c a n d is c u s s th e m in w h a te v e r o r d e r .

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C o u n s e l fo r P e rs o n a liz e d U s e r M o d e l, L L P

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P O T TE R A N D E R S O N & C O R R O O N , LLP
B Y : R IC H A R D L . H O R W I T Z , E S Q .

M R . H O R W ITZ: Thank you.

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Q U IN N E M A N U E L U R Q U H A R T O L I V E R & H E D G E S , L L P
B Y : C H A R L E S K . V E R H O E V E N , E S Q ., a n d
D A V ID A . P E R L S O N , E S Q .
And
A N T O N IO R . S I S T O S , E S Q .
(S a n F r a n c is c o , C a lifo r n ia )

M S . JA C O B S : Y o u r H o n o r .

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THE C O U R T : Y es.

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M S . JA C O B S : W e h a v e n o o b je c tio n to th e lis t,

and
Q U IN N E M A N U E L U R Q U H A R T O L I V E R & H E D G E S , L L P
BY: ANDREA PALLIO S ROBERTS, ESQ.
(R e d w o o d S h o re s , C a lifo rn ia )
C o u n s e l fo r G o o g le , In c .

p e r s e . A s M r. H o rw it z s a id , w e d o n 't fe e l lik e - - it m a y

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b e m is s in g a f e w th in g s b u t fro m o u r p e r s p e c tiv e , a n d , o f
c o u r s e , s u b je c t to w h a t Y o u r H o n o r h a d in m in d in te r m s o f

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w h a t y o u w a n te d to h e a r in th e o r d e r, w e w o u ld p r e fe r n o t to

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fo llo w th a t o r d e r a n d in s t e a d to f o c u s o n -- firs t o f a ll,

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w e th in k s o m e o f th e is s u e s r e a lly a r e , s e v e r a l o f th e m a r e

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Q U IN N E M A N U E L U R Q U H A R T O L I V E R & H E D G E S , L L P
B Y : JO S H U A L E E S O H N , E S Q .
(W a s h in g to n , D is tric t o f C o lu m b ia )

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and

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T H E C O U R T : R ig h t. I'll b e h a p p y to ta k e a lo o k
a t it.

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and

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w e p re p a re d . W e s h o w e d it to c o u n s e l fo r P U M . I th in k

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SN R D E N T O N , LLP
B Y : A N D R E W M . G R O D IN , E S Q .
(S h o r t H ills , N e w J e r s e y )

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and

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A P P E A R A N C E S : (C o n tin u e d )

c lu m p e d to g e th e r u n d e r a s in g le ru b ric a n d th a t th e o r d e r

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th a t is th e r e m a y n o t n e c e s s a rily re fle c t th e im p o r ta n c e to

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th e a re p a rtie s fo r a rg u m e n t. S o .

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T H E C O U R T : O k a y . W e ll, I h a v e o n ly ju st h a d a

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c h a n c e to g la n c e a t th e a g e n d a . I a p p r e c ia te th e e ffo rt.

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P a rt o f th e r e a s o n I h a d to d e la y th in g s b y a h a lf h o u r

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g e ttin g s ta r t e d to d a y is th e r e is ju s t a n e n o r m o u s a m o u n t

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th a t y o u a ll s till h a v e in d is p u te w h ic h I th in k h a s b e e n

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P R O C E E D I N G S

c h a ra c te ris tic o f th e c a s e . B u t w e w ill try to g et th ro u g h

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- oO o -

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a ll o f it. If w e d o n 't, th e n w e 'll h a v e a n o th e r p r e tr ia l
c o n fe re n c e s o m e t im e b e tw e e n n o w a n d tria l.

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(R E P O R T E R 'S N O T E : T h e fo llo w in g p r e t r i a l

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c o n fe re n c e w a s h e ld in o p e n c o u rt, b e g in n in g a t 2 : 2 8 p .m . )

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B u t m y p la n is to b rie fly h e a r a r g u m e n t o n th e

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T H E C O U R T : G o o d m o r n in g , e v e r y o n e .

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tw o D a u b e rt m o tio n s firs t, th e n b r ie fly h e a r a r g u m e n t o n t h e

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(T h e a tto r n e y s re s p o n d , "G o o d m o r n in g , Y o u r

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m o tio n s in lim in e , a ll w h ic h lo o k s to b e c o n s is t e n t a c t u a lly

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w ith w h a t M r. H o r w itz h a s p r o p o s e d . T h e n w e 'll g o o v e r th is

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v e ry , v e r y lo n g lis t o f m is c e lla n e o u s is s u e s , p ro b a b ly in

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th e o r d e r th at y o u p u t th e m in th e p r e t r ia l o r d e r. B u t

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H o n o r. " )
T H E C O U R T : I'll h a v e y o u p u t y o u r a p p e a r a n c e s
o n th e r e c o r d fo r u s, p le a s e .
M S . JA C O B S : G o o d a fte rn o o n , Y o u r H o n o r . F o r

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p e rh a p s w e 'll fin d a w a y to m o v e fo r efficie n tly th r o u g h

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p la in tiff Pe rs o n a liz e d U s e r M o d e l, K a r e n Ja c o b s fro m M o r r is

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th e m . T h e n o n c e w e g e t th ro u g h a ll th a t, w e 'll g o th ro u g h

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N ic h o ls. A n d a t co u n s e l ta b le , w e h a v e J e n n ife r B e n n e tt,

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a n y o th e r is s u e s th a t a r e in t h e p re t r ia l o rd e r . A n d a fte r

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M a r k N e ls o n a n d M a r c F r ie d m a n o f D e n to n s . A n d in th e r o w

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w e 're d o n e w ith a ll o f th a t, I'll s e e if th e r e a re o th e r

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b e h in d , R e g in a M u rp h y a n d J e r e m y T ig a n fro m M o rris N ic h o ls ;

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is s u e s e ith e r o n M r. H o rw it z 's lis t o r o th e rw is e , a n d

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a n d R ic h a rd S a lg a d o a n d A n d r e w G r o d in a ls o fro m D e n to n s U .S .

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h o p e fu lly w e w ill a ll b e o u t o f h e re s o m e t im e to n ig h t.

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T H E C O U R T : O k a y . W e lc o m e to a ll o f y o u .

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M R . H O R W I T Z : G o o d a ft e r n o o n , Y o u r H o n o r.

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a rg u m e n t o n - - a n d firs t, w h a t d o e s th e p la in tiff w a n t m e to

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T H E C O U R T : G o o d a ft e r n o o n .

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c a ll y o u ?

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M R . H O R W I T Z : R ic h H o r w itz fro m P o tte r A n d e r s o n

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o n b e h a lf o f G o o g le . W ith m e to d a y a t c o u n s e l tab le , a ll

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fro m Q u in n E m a n u e l: C h a r le s V e rh o e v e n , D a v id P e r ls o n , J o h n
S o h n , a n d A n d re a R o b e rts. A n d J o h n L a B a rre, in s id e c o u n s e l

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fro m G o o g le is h e re a s w e ll.

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T H E C O U R T : O k a y . W e lc o m e .

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M R . H O R W I T Z : Y o u r H o n o r , I h a v e a n a g e n d a th a t

02/28/2014 07:21:58 AM

Is it P o o m (p h o n e tic ) ?

I s it P - U -M ? W h a t is it?

M R . N E L S O N : P -U - M o r P e r s o n a liz e d U s e r M o d e l,

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S o w ith th a t, le t's s ta r t w ith ju s t s o m e b rie f

Y o u r H o n o r.
T H E C O U R T : I w ill try to d o P -U -M in m y m in d .
It's b e e n P o o m (p h o n e tic ) b u t I w ill try to d o P -U - M .
S o le t's s ta r t w ith P U M 's D a u b e rt m o tio n to

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e x c lu d e p o r tio n s o f D r. F o x 's n o n in frin g e m e n t te s tim o n y .

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W e 'll ju s t h e a r b r ie f a r g u m e n t o n th a t.

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MR. NELSON: I don't believe we do, Your Honor.

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somehow relevant, you look at the prejudice involved. And

THE COURT: I don't think you have. It's too

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we all know, and it's the only reason they want it in there,

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is that when the jury sees these letters, that they're going

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to think something nefarious has gone on. That is why

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bifurcation is done and that it was why it was done in this

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case. And if you let that in, it all goes away.

late for you to disclose that.
What about, did you have some other reason for
these letters or the speech to be relevant?
MR. NELSON: Yeah. The letters are relevant

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because Google is going to presumably get up and say they're

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a company that respects intellectual property, that they

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take patent threats seriously. And the jury is going to

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THE COURT: All right. Let's move on to your
motion in limine. Is that you?
MR. PERLSON: I think so.

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know why we're here and why we got here. And we certainly

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should have the opportunity to tell the jury how we got here

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and counter that story that they're likely to tell: That

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they're such a great company and they respect intellectual

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There are two things that we're seeking to exclude sort of

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property. It's background information that is important for

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relatedly, one which is this publicly available information

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the jury to know how we got here.

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regarding revenue and the second is the information

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regarding this Kaltix transaction.

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THE COURT: All right. And the '040 patent

THE COURT: Okay. That's the Kaltix revenues
and the acquisition of Kaltix.
MR. PERLSON: So first with this publicly.

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being cited, how is that relevant?
MR. NELSON: The '040 patent being cited is

First, the publicly available information, I

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think it's like this press release that talks about Google's

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relevant to obviousness or lack thereof. Their

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like fourth quarter results; talks about, you know, all the

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characterization of the Konig reference is sort of this

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billions of dollars Google is making. It doesn't mention

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minor part of this. Well, that is fine. That is their

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personalization at all. It just, it really has no -- it

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characterization, that is not ours.

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doesn't show anything other than Google makes a lot of

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money.

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Google tried for many years to develop

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personalized search. As you will hear about in the next

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motion, they bought a company called Kaltix. Kaltix then

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THE COURT: Isn't there a reduced risk of
prejudice because we're not doing damages?

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worked on it. The very product at issue are the Kaltix

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Twiddler. That Google was late to the game in coming to

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thing is that when the jury sees a big number, it affects

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this, filed a patent application on it. The patent

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everything. And they're going to think, they're going to

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application gets rejected by the patent-in-suit here. That

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know down the road there is going to be damages here.

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is very relevant as a secondary consideration to

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Someone is seeking a remedy for something. And they're

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nonobviousness. That they tried and failed, long-felt need,

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going to think, well, if they find infringement, what is the

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Patent Office recognition. And I think we have said in the

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big deal. There are billions of dollars at issue here.

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briefing we're not going to allege that they copied it

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That is why they want it in.

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unless some evidence comes out that we don't have, that we

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MR. PERLSON: No. Because that's the whole

Google a chance to respond.
I think my main question is are you going to get

Now, we talk about relevance of it. They say
it's relevant because there is some nexus between these

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revenues and what they have accused here, but there is zero,

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THE COURT: All right. Thank you. Let me give

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don't know about thus far.

absolutely zero evidence of a nexus.

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Dr. Carbonell, who is I guess the only person

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up and say how wonderful Google is and it always respects

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who they would have to make this link, said -- I asked him

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patents right, et cetera, et cetera? If so, doesn't that

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at his deposition. I said.

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open up the door to the background here?

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MR. PERLSON: Well, I don't think that the fact

"Question: So you have no way of knowing, sir,

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what Google is doing that contributes to the success of its

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that Google says that it respects patent rights opens the

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products that may infringe the patents that plaintiff is

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door. Those were just a letter offering to license the

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pointing to or all the other things that Google is doing

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patent. I mean we don't have -- we say we don't infringe,

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that plaintiff didn't accuse?

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and that is the reason why we respect intellectual property.

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What we're going to tell the jury is that we respect

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Google is doing with respect to personalization or with

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intellectual property and we don't infringe this patent.

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respect to other improvements to doing search."

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That doesn't open the door to this evidence.

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And, again, 403 looks at the -- even if it was

02/28/2014 07:21:58 AM

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"Answer: I have not done an analysis of what

THE COURT: Didn't we already say there was some
evidence to which nexus can be found?

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EXHIBIT D

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IN THE UNITED STATES DISTRICT COURT

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02:24:45

IN AND FOR THE DISTRICT OF DELAWARE

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- - PERSONALIZED USER MODEL, L.L.P.,
v

Plaintiff,

GOOGLE, INC.,

Defendant.
------------------------------------GOOGLE, INC.,
:
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Counterclaimant,
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v
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PERSONALIZED USER MODEL, L.L.P.,
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and YOCHAI KONIG,
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Counterclaim-Defendants. :

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1 of 113 sheets

NO. 09-525-LPS

Wilmington, Delaware
Thursday, March 13, 2014
Jury Trial - Volume D

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CIVIL ACTION

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- - BEFORE:

HONORABLE LEONARD P. STARK, U.S.D.C.J.
- - -

APPEARANCES:
MORRIS NICHOLS ARSHT & TUNNELL, LLP
BY: KAREN JACOBS, ESQ.,
REGINA S.E. MURPHY, ESQ., and
JEREMY A. TIGAN, ESQ.
and
Valerie Gunning
Official Court Reporter

Page 914 to 914 of 1199

Brian P. Gaffigan
Official Court Reporter

03/13/2014 06:26:44 PM

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Alferness - direct

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Alferness - direct

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MR. VERHOEVEN: Thank you.

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product management, it's not just my responsibility to lead

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my direct reports and those product managers forward, but to

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BY MR. VERHOEVEN:

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manage a broader team of engineers, marketing folks, sales,

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Q.

Good afternoon, Mr. Alferness.

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et cetera.

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A.

Good afternoon.

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Q.

How long have you been working at Google?

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Q.

Let me ask you a few questions about your background

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A.

I've been at Google almost ten years. In October of

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before we get into Google. Where did you grow up?

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this year it will be ten years.

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A.

I grew up in Holmdel, New Jersey.

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Q.

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Q.

Did you go to college?

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the various positions you have had since you joined the

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A.

I did, yes. I did my undergraduate work at Cornell

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company, please?

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University in Ithaca, New York, and then I spent some time

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A.

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at graduate school at Cal Tech in Pasadena, California.

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2004, I joined a portion of the company called the Partners

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Q.

Where do you work?

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Solutions Organization. My job in that role was to help our

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A.

I work at Google.

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large partners, America Online specifically, to utilize our

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Q.

What is your current role at Google, sir?

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syndicated ads products, to help them make sure that those

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A.

I'm a director of product management at Google.

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products were working well, and that they continued to, you

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Q.

Are you married?

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know, make the revenue that they were supposed to through

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A.

I am, yes.

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those products.

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Q.

Do you have kids?

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A.

We have two children. We have a son who is six years

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role, I switched over to the product management

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old and our daughter is three.

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organization, where I took ownership of the syndicated ads

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Q.

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products that are across all of our different partners.

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what you do in your role at Google?

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A.

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grew that role into, you know, still being a product

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management, it's my responsibility to lay out the strategy

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manager, but into a broader Search Ads role where I took

DIRECT EXAMINATION

Going back to your job, just summarize for the jury

Yes. I sure can. As a director of product

Could you walk the jury briefly through a summary of

Sure thing. Sure thing. When I started in late

After about a year-and-a-half of time in that

After doing that for about a year-and-a-half, I

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for our products, to understand what the features are that

1

ownership of a large portion of our Search Ads, products,

2

we're going to develop, you know, to put those together in a

2

technologies, businesses, continuing to own those syndicated

3

timeline.

3

ads products.

4

And then I would say most importantly, it's

4

I worked in the Search Ads teams owning the vast

5

my responsibility to not only look after the products, but

5

majority of what the Search Ads team does for about five to

6

the business as well, to make sure that the business is

6

six years. The last two years I've been focused on our

7

healthy and growing.

7

Mobile Display Ads products.

8

Q.

8

Q.

9

Google?

9

Google right now?

10

A.

11

How did your position fit within the hierarchy at

How many engineers would you say are working at

10

A.

think about it is we have numeric associations with our

11

45,000 people right now. So I think from an engineering

12

various levels at Google. One is the most junior and then

12

perspective, we're above 25,000 or so. We like to maintain

13

ten is vice president, essentially the most senior. I'm

13

a greater than 50 percent ratio, i.e., 50 percent or more of

14

currently a level nine or a senior director.

14

the folks at Google are engineers.

15

Q.

15

Q.

16

for a senior executive.

16

Google are engineers, sir?

17

A.

17

A.

More than 2500 now.

18

Valley or tech perspective, that's, that's pretty old. If

18

Q.

Mr. Alferness, why did you come from California to

19

you think about a lot of the folks, Mark Zuckerberg

19

this courthouse to testify today?

20

Facebook, I think, for example, is in his early thirties.

20

A.

21

Q.

21

very strongly in continually innovating and trying to invent

22

Google?

22

the future and we feel strongly about this not just from

23

A.

23

Google's perspective, but from the broader ecosystem

24

then a broader team of about nine product managers who roll

24

perspective across all of technology. As such, we take

25

up through those direct reports. And as a director of

25

intellectual property and intellectual property rights very

I'd say it's a rather senior position. One way to

Mr. Alferness, I have to say you look pretty young

I'm actually 39, 40 years old, and from a Silicon

Okay. Do people report to you in your position at

Oh, absolutely. I have about five direct reports and

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That's a good question. So Google is about 40 to

How many of the people who work on advertising at

Google, Google works hard to innovate. We believe

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seriously. So I'm here today to represent that on Google's

1

or useful result appear at the top of that stack, and

2

behalf.

2

those results are displayed on what we call a search results

3

Q.

3

page.

4

was Google founded?

4

5

A.

Google was founded in 1998.

5

BY MR. VERHOEVEN:

6

Q.

How big was it when it was founded?

6

Q.

Mr. Alferness, what are we looking at here?

7

A.

It was just two people. It was Larry Page and Sergey

7

A.

This is a very, very early screen shot or image of

8

Brin.

8

the Google Search results page.

9

Q.

Where was the first office?

9

Q.

And how do you know that?

10

A.

That's a good question. One could argue it might

10

A.

I was using it at the time. I was finishing up at

11

have been in their dorm room at Stanford, but I think the

11

Cal tech. I was a computer scientist, technologist geek.

12

first formal office was in Susan Grinski's house or her

12

And just about everybody in the community, in the industry,

13

garage.

13

knew about Google and knew about some of the great new

14

innovations that this search engine was delivering. It

Let's talk a little bit about Google's origins. When

14

MR. VERHOEVEN: Can we have DTX-1601, please?

MR. VERHOEVEN: Can we put up DDX-1602, please?

15

BY MR. VERHOEVEN:

15

was -- oh, I don't know, I would say it's much, much better

16

Q.

What's that?

16

than the competition. So I was certainly using it at the

17

A.

That's Susan's house with the garage, and then to the

17

time, yes.

18

right you see really a dated picture of Larry Page and

18

Q.

19

Sergey Brin.

19

Mr. Brin used to build the search engine?

20

Q.

20

A.

Yes. They built a new technology called page rank.

21

they started the company in?

21

Q.

And you describe at a high level for the jury, what

22

A.

Oh, absolutely do. I've known Susan Grinski

22

is page rank?

23

basically the whole time I've been at Google. The house is

23

A.

24

a piece of Google history and, of course, she doesn't live

24

finding this information, but also sorting the results and

25

there anymore, but occasionally some of the other senior

25

finding the highest quality results. It did so by not just

So you actually personally know this is the house

Was there any specific technology that Mr. Page and

So page rank was a novel and new way of not only

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executives will spend time in the house if they live far

1

looking at the content on the pages themselves to see how it

2

away. And our chief economist, for example, will spend

2

matched the question, but to understand the importance of

3

nights there he has brought Susan's mail and still sometimes

3

the papers.

4

it still gets delivered to the house. So, yes, that's

4

5

definitely her house.

5

linking to that page in question. For example, if it was a

6

Q.

6

page with authority, say a page from a newspaper, I don't

7

Mr. Brin?

7

know, CNN or the Wall Street Journal, then that one page

8

A.

Yes.

8

that we were looking at might be considered higher quality.
So really it was looking at those things that were pointing

So there are the founders right there, Mr. Page and

What it looked at is what pages were

9

Q.

Yes?

9

10

A.

Yes.

10

at these pages. Hence, page rank.

11

Q.

What were they working on during this very early time

11

Q.

Was this page rank technology important to Google?

12

frame, sir?

12

A.

It was, yes.

13

A.

Oh, they were working on a search engine.

13

Q.

And why was that?

14

Q.

Can you explain to the jury, just really generally,

14

A.

It was probably the key innovation with Google Search

15

what do you mean when you say search engine?

15

that really made the results that Google Search returned

16

A.

16

above and beyond just better than the best.

17

say a search engine is a web page, a site that folks can

17

Q.

Is Google Search still available today?

18

come to. You enter a query, a question in plain text,

18

A.

It is, yes.

19

basically.

19

Q.

Do users have to pay to use Google Search?

20

A.

No, they don't.
Can you give me some -- I take it, that Google has

20

Sure thing. Let's see. At a high level, I would

It's the responsibility of the search engine,

21

then, to look across all of the information that exists on

21

Q.

22

the Internet, websites, web pages, et cetera, and find

22

grown beyond the early days? It has more products?

23

information that is relevant to answering the question that

23

A.

We have, that's correct.

24

the user entered. Those results are then organized or

24

Q.

Can you give the jury some examples?

25

sorted such that the highest value or the highest relevant

25

A.

Sure. One example would be Gmail. Another might be

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