
Larry Page Deposition in Uber vs. Waymo - heshamg
https://www.scribd.com/document/355385613/Larry-Page-deposition-Uber-vs-Waymo#from_embed
======
dbot
Please take a moment to notice how horribly unfriendly a deposition transcript
is. Thousands of these documents are produced every day, in a proprietary
format that is antiquated and near impossible to work with. The PDF is
unusable given the line numbers, headers, footers, etc. The simple act of
copying and pasting - for example, writing a brief, a blog, etc. - is painful.

I know developers could create an amazing solution, but the legal community
hasn't asked yet, unfortunately.

~~~
rayiner
There is nothing antiquated about PDF. It's an incredibly widely supported
standardized format that can cleanly handle everything from a Word document to
a scan of a prisoner's hand written pro se brief to a printed document that
someone has scribbled on. It preserves formatting information, which is
incredibly important because court filings are regularly printed on paper. Not
because there is no electronic workflow (the entire workflow is electronic at
least in federal court), but because it's a pain in the ass to read and
annotate things on a computer versus putting tabs in a binder.

As to the line/page format, it's used because sentences or even words within
depositions are quoted in briefs with citations to exactly where they appear.
And frankly, if your software can't even grok a simple 2D format it's probably
not intelligent enough to do any useful processing of the document.

I'm always on the lookout for good legal technology. But legal technology
purveyors are like those people who think programming IDEs should all be
visual environments where you program by dragging and dropping connectors
between blocks. It's like, no.

~~~
Angostura
I think you misunderstand the original comment. It isn't criticising the PDF
format. It is crticising the format of the PDF

------
MengerSponge
While we wait for someone with legal training to parse this out for us, here's
my favorite deposition related thing on the internet:

[https://www.youtube.com/watch?v=PZbqAMEwtOE](https://www.youtube.com/watch?v=PZbqAMEwtOE)

~~~
gk1
Here's another good one, featuring Bill Gates:
[https://youtu.be/HhdDZk45HDI](https://youtu.be/HhdDZk45HDI)

~~~
IBM
Wow I forgot how painful this was to watch.

~~~
wbl
Now I know why Microsoft employees all have private offices.

------
colinbartlett
I found this part snarky and humorous, though I imagine truthful:

> Questioner: Do you recall that a year or so before Mr. Levandowski left, he
> announced that he was going to leave?

> Page: I mean, I wish I had a penny for every time employees do that and
> don't go. It happens pretty often.

~~~
jboggan
Quite truthful. When I left Google at the end of March to start my own thing a
lot of folks came out of the woodwork telling me about their plans, how
they've saved up $xxx,xxx to start their app and leave the company, etc. I
visit friends back there for lunch every month or so and I still see the same
faces at the same desks. When I ask them about pulling the trigger it's always
"you know . . ."

It's really a testament to the HR and REWS departments that they've
constructed a workspace and a compensation package that keeps so many people
there despite their own intentions! Masterful really.

~~~
dsfyu404ed
Or maybe they just don't hire people they can't trap there...

~~~
RickS
You can't possible believe this, right? Many of them have "fuck you" money
that would permit them to never work a day again in their lives were that to
be their choice.

Please refrain from insulting every employee of a company as an idiot sheep
simply because you don't like the company.

~~~
pgrote
I've always wondered what percentage of employees at Google or Facebook are
like this? Do you know?

~~~
packetslave
One of my coworkers on a previous team has been at Google for 17.5 years, has
employee ID #7X, almost certainly has enough money to never work again, and is
_still_ an SRE carrying a pager with a 3-minute hands-on-keyboard response
SLA.

Some people just love what they do.

~~~
wfunction
Wow. How can you even have that kind of an SLA? Like what if you happen to be
in the shower or in the middle of traffic or if your Internet drops out or
something? How do these SLAs work?

~~~
mining
You're usually on-call for a fairly humane shift, not 24h a day.

~~~
wfunction
Ah I see, thanks. Hopefully you don't need to use the bathroom too badly
during that shift I guess :)

~~~
Xorlev
Then you transfer to secondary or nack the page for the secondary to handle.

------
KKKKkkkk1
-The CEO of Alphabet did not take part in approving a $120m bonus to an employee.

-He does not remember how Project Chauffeur was started.

-He does not know whether due diligence was done when Google made its investment in Uber.

-He does not know whether Waymo is allowed to file a lawsuit against Uber without notifying him.

What is he responsible for in Alphabet then?

~~~
btian
He runs a $100B a year business.

You think he has time for every little detail?

If you read page 24, he said it's not unusual for people to be paid $100M. Do
you expect him to remember all the people and amounts paid?

~~~
ryandrake
I call bullshit. I don't care how big your company is. If some employee is
getting $100M, the CEO is going to know about it. There couldn't be more than
a handful of people at that company making that much.

~~~
dancryer
I got the impression that he was aware of it, but had no reason to remember
the specifics of it. He knew it sounded about right, which is what I'd expect
from a CEO months (or years) after the fact.

------
gk1
I found some of the answers humorous because they sound like "billionaire
problems," like hardly remembering a $100M bonus, and this:

> Q Do you also have a ranch property?

> A Yes.

> Q What is it called?

> A I'm not sure which one you mean...

Edit: Also, this gem:

> Q I -- I appreciate that. And again, this can be designated attorneys' eyes
> only. It's not going to be released publicly...

Oops.

~~~
jeffdavis
What does that have to do with the case? Are they just asking him personal
questions to invade his privacy?

~~~
gk1
Apparently some tests of the autonomous vehicles took place at one of Larry's
ranches, along with possible meetings with Levandowski. I'm not sure why they
start with such basic questions, though.

~~~
rayiner
Depositions aren't free form. The rules applying to courtroom testimony mostly
apply. One of those rules is that there has to be a foundation for everything.
You can't ask about what happened at Page's ranch until you establish for the
record that he owns a ranch and what ranch you're talking about.

The other part of asking basic questions is that the deponent's statement
under oath that he started as CEO on such and such date is evidence that's
directly usable. A print out from a web page with his basic bio can be
evidence but it requires more hurdles. When you need that information for
color down the line, it's helpful to have it in the deposition transcript.

~~~
Eridrus
Are depositions ever really useful?

I probably have a skewed view based on what gets posted on the internet, but
it seems like it's a lot of "I don't recall" from everyone.

~~~
dctoedt
> Are depositions ever really useful?

Absolutely. Many depositions (and in significant cases, nearly all of them)
are videotaped; then for trial, each side creates a "documentary" consisting
of selected excerpts — think of it as being like a segment of a news show such
as _60 Minutes_. A string of "I don't know" or "I don't recall" answers, or
even unduly-long pauses before answering, can seriously hurt a witness's
credibility.

And if a witness testifies differently at trial than s/he did at the
deposition, on cross-examination the opposing counsel will pounce and play
back the relevant portion(s) of the video recording to impeach the witness's
credibility that way as well.

Finally, depositions are very often used to "prove up" basic facts, as
'rayiner said in the GP.

------
amasad
TIL Google gives upwards of $100 million bonuses and Larry Page calls it
"start-up-like compensation"!

> Q: You would not have approved of a bonus of over $100 million if he hadn't
> made a significant. Can we agree on that?

> A: I guess I'm questioning -- what is the purpose of that question? No one
> decided to pay me billions of dollars.

[...]

>Q: Did you ever express concern to anyone that the bonus was too high that
was being paid to Mr. Levandowski?

>A: Well, as I kind of just stated, I think that's -- I've stated we were
focused on getting a start-up-like compensation system. And start-ups pay
people a lot of money if they do something significant -- if the start-up does
something significant.

~~~
kinkrtyavimoodh
Not sure why you found that so noteworthy (or scandalous?).

I know that there is a lot of general waffling on Larry's part there (for obv
reasons) but the reasoning he offered sounds reasonable—Google is trying to
run mini-startups within its orgs, and to attract talent, is offering those
people 'bonuses' (or whatever you want to call it) of the order of magnitude
that the co-founders of a successful startup would get.

That provides them incentive to work within Google instead of on their own.

~~~
wavefunction
I guess it's strange because the founders of successful startups have
generally founded a successful startup.

Paying $100,000,000 up-front to someone who hasn't yet delivered the same
success seems to be putting the cart before the horse.

~~~
blackguardx
Success is defined by Google. Clearly Google thought he delivered or they
wouldn't have paid him.

I'm guessing it was tied to shipping that autonomous car with no steering
wheel that they made awhile back.

~~~
huac
page's argument is that waymo as a whole was successful, so waymo as a whole
got paid a lot. because levandowski was an early waymo employee and pretty
senior, he had a large 'stake' in waymo's bonus payout.

however - and this is page's big point - that payout has little to do with his
overall contributions to the project, and rather that he had early
responsibilties and stuck around.

------
imh
>Q: You're saying it's not unusual to pay somebody a bonus of over $100
million?

>A: I don't -- I don't think characterizing it as a bonus is correct. I think
it's more like a start-up compensation, which would be more like equity. We
have executives that are well compensated and certainly make a lot of money
and so on.

> So anyway, _I don 't think that it's so far outside of the norm for Silicon
> Valley compensation._

(emphasis mine)

Even in context, this seems crazy! Is $100M+ really not far from the norm for
non C-level non unicorn execs here?

Am I unknowingly on a forum of 8-9 digit zillionaires?

~~~
jgh
Haha you see some of the salary conversations around here and you begin to
wonder where you went wrong in life...

~~~
ryandrake
If you believe them, then I'd say "gullibility" is where you went wrong in
life.

Everyone on HN drives a ferrari and has a supermodel partner too, you know!

~~~
jgh
My wife is pretty hot, but unfortunately I only drive an A4 :(

------
bitmapbrother
Lawyer: So, in December of 2015, before he left Google's employment, did you
believe at that time that he had made significant contributions to Project
Chauffeur?

Larry: I mean, I think he's definitely been a significant person in the
history of the project.

Lawyer: And tell me why you believe that. If you can elaborate. What is it
that he did that, in your mind, makes his contribution significant?

Larry: Well, I didn't say that. I said he's been a significant person. I think
it has yet to be determined whether it's a positive or negative.

~~~
Qwertious
Translation: I know he was on the project, but I didn't pay attention to the
contributions of specific developers so I don't know whether he was the
lodestone of the project or useless.

------
urs2102
Larry Page did not want to answer anything.

I guess this is why they're seeking a 'round 2'.

> Uber: Google invested in Uber; correct?

> Page: Yes.

> Uber: Do you recall when?

> Page: My answer is yes.

I'm definitely interested in some folks from Google chiming with respect to
Larry's comments regarded starting side businesses at Google. Does anyone have
any experience doing that? Is that allowed? I would imagine not, but I'm
interested.

~~~
harryh
It's likely that Larry didn't want to be there but I wouldn't infer that from
answers like this. This is _exactly_ what you are taught to do before giving a
deposition. You can't win in a deposition, you can only lose. The more
information you give the other party the more you lose. So when they ask a
question you are taught to answer precisely what they asked and no more.

This is pretty unlike regular life. As an engineer if someone asked me "Hey,
in order to get the widget-spinner to go clockwise do I call function X?" I
might answer "No, what you need to do is set variable X to true." (or
whatever). In a deposition the correct answer would just be "no."

I was in a patent troll deposition once and the opposing attorney kept dancing
around moderately close to the interesting stuff but never really got there
due to the fact that he didn't really know what he was doing. It was kind of
fun just saying "no" over and over again without giving him any additional
context or help. Weird though. It's not how humans normally communicate.

~~~
sokoloff
I was deposed in a case; after referencing one-way hashing in an answer,
opposing counsel attempted to get me to ramble by saying, "I don't think I
understand." I replied, "I agree."

~~~
kinkrtyavimoodh
I just tried to picture it and burst out laughing. Would you be able to
provide any more details about this deposition? In what context did one-way
hashing come up?

~~~
sokoloff
One way hashing came up in the context of sharing email opt-outs without
sharing the actual email addresses. (Send a list of hashes of email addresses
and the hash function and require that no one whose email hashes to a value on
that list may be emailed marketing material.)

It's been many years now, but we did some canonicalization of email addresses
before hashing [downcasing, stripping whitespace, stripping periods (gmail),
stripping any local tags (plus-sign), and maybe a few others I'm forgetting]
since false positives were "safe".

------
keyanp
Does anyone have insight into what the opposing lawyers are trying to get at
by asking about the $120M bonus? It feels like they are establishing
Levandowski's importance to Waymo maybe? But it isn't clear to me how/if this
helps their case.

> I'd like to start by asking you some questions about the bonus that was paid
> to Anthony Levandowski. He received a bonus that was in excess of $120
> million; is that right?

> was there any other occasion where any employee received more than $100
> million for what you described as "start-up-like compensation"?

> Sitting here today, can you recall of any other employee who received more
> than $100 million in what you've described as start-up compensation at
> Google?

~~~
SOLAR_FIELDS
My guess is that if they viewed him as important they can try to establish
that they should have known he was doing what he was doing, instead of going
behind Google's back and doing this without their knowledge. If he was that
important to the company (by virtue of his pay), then it's easier to try to
establish that Google was somewhat negligently not paying attention to a "top
employee"

~~~
Qwertious
An obvious response to that is "we also gave him lots of autonomy, because not
having to deal with bureaucracy is a perk".

------
dlgeek
I love the part where the lawyer for one of the defendants gets his
questioning off to such a start:

> BY MR. CHATTERJEE:

>

> Q Hi, Mr. Brin. We haven't met before. My name is Neel Chatterjee. I
> represent an entity called Otto Trucking.

> MR. VAN NEST: Mr. Page.

> MR. CHATTERJEE: Mr. Page. It's -- the names are used so interchangeably in
> the market. Mr. Page.

~~~
frandroid
Possibly a tactic to make himself look dumb so Page underestimates him.

~~~
Zhenya
Wow - that is interesting.

Looked him up - well accomplished and seemingly in the know.

------
ChuckMcM
That sounded pretty painful for Larry. It sounded to me like Levandowski's
lawyers were trying to get on the record that everything he got compensation
wise was in exchange for past accomplishments. I don't know if anyone is
seeking to claw that back or not.

~~~
CalChris
This is not Larry's first encounter with the witness stand and it won't be his
last. He sounded the same as during the Oracle trial. He's a bright guy and is
well coached. To a certain degree, you wonder why he was called.

------
Animats
This is a bit strange. Remember, Waymo is the plaintiff, and Uber's lawyer is
asking the questions.

There's a long series of questions about Levandowski's $120 million bonus.
Uber is establishing that Levandowski's contribution was valuable, which is
the opposite of what they want to prove. There's a big censored section which
may have to do with Levandowski's compensation agreement.

There's a censored discussion of Sebastian Thrun ("He was CEO of Udacity").

Uber's lawyer asks Page how much Google invested in Uber. Page evades.

There's discussion of conflict between Levandowski and Chris Urmson.
Levandowski wanted to be in charge. Page says Levandowski's contribution may
have been negative.

There's more, but if there's anything exciting in there, it's in the censored
sections.

~~~
unityByFreedom
maybe Uber wants to show that Levandowski is the prized asset -- not any
documents he might have taken with him

if the documents are known to have been taken, all they can do is downplay
their significance

------
redm
I couldn't make it through the whole thing. I understand Larry wanted to be
specific but he seemed to be purposely obtuse on straight forward questions.
Is this the way all depositions go?

~~~
fspacef
From what I understand, depositions by design are a place for opposition
lawyers to try and trip you up. LP is being cautious with his words and trying
to be as vague as he can because of that.

~~~
staticautomatic
No one is trying to trip you up. Quite the contrary. They're trying to figure
out what you know, a so-called "fishing expedition."

~~~
fspacef
Of course in a perfect world that's what its supposed to be but as some other
comments in the thread have pointed out, opp. lawyers are hoping to press on
issues and hope you say something that can be misinterpreted as malicious or
incompetent later in front of a jury.

~~~
staticautomatic
Sure, but looking for or even trying to force an admission which may be useful
down the line is different than actively trying to trip someone up.

------
roguskinta

      MR. GONZALEZ: Are you generally aware of the policies of Google?
      MR. PAGE: I mean, there's a lot of policies.

------
IncRnd
That was ---------- when reading through the ----------, because ---- the
-----. So, the real reason was yes.

------
kainolophobia
> Page: I think they had a really hard time getting along [Levandowski and
> another employee], and yet they worked together for a long time. And it was
> a constant -- yeah, constant management headache to help them get through
> that.

> Questioner: Do you recall that Anthony Levandowski was put on a personal
> improvement plan before he left?

> Page: I don't recall that.

> Questioner: Do you recall that Mr. Levandowski wanted to be head of the
> Project Chauffeur team?

> Page: I mean, that does not surprise me.

> Questioner: Do you recall having conversations with him, where he said to
> you that he wanted to be head of the team?

> Page: I don't recall, but it wouldn't be surprising, you know. I think he
> clearly felt things could be done better.

------
tarr11
Well, I guess that I've learned that Larry Page has a ranch where they test
self driving automobiles.

~~~
brianpgordon
And the whereabouts of the ranch depend on the time of day... does Larry Page
have a secret lair in _space_?

------
TheSageMage
IANAL, and I'm reading between the (redacted) lines. Did anyone get the sense
that Uber's lawyers line of questioning was leading towards the possibility
that Alphabet let this theft of their IP happen to catch Uber with their pants
down?

There are questions about how Larry felt about Mr. Levandowski real
contribution to Waymo/Chauffeur(p21 Line 15). They are asking about David
Drummond's position on Uber's Board(p40 line 13). This leads to questions
about when Larry knew Mr Levandowski was leaving the company(p45 Line 14).
These lead to questions about Mr. Levandowski's attempt to spin off a team
from Google/Alphabet (p64 Line 2). ... Setting up the dates on a redacted
email, they to be talking about Larry's knowledge of IP and people taken by
Uber for autonomous cars (p181 line 10).

Maybe I'm reading too much into this, but what are the implications of Google
getting sloppy with protecting itself at the risk of catching a competitor
steal your work?

------
bquinlan
The disposition makes it look like Levandowski was very difficult to work
with:

Q. "Anthony threatens to leave the team if he isn't the single leader." Do you
see that.

A. Yeah

...

Q. Sebastian says:

"If he is the single leader, a good number of team members will leave." Do you
see that?

...

There is more but copying and pasting from the source is really hard.

------
ocdtrekkie
The amount of information which must live in the blocked out text is insane.
Questions like "Why was it (Waymo) created as a separate company under the
umbrella of Alphabet?" have had their answers blocked out. I'm sure beyond the
PR, a lot of people would love to see candid answers like that.

The Otto lawyer suggests "Otto" and "Otto Trucking" are two separate entities,
but if anyone explains to Larry the difference, it's not visible in this
version. I hadn't heard anything about that before and am curious.

~~~
cdolan
You assume there are candid answers in there, though - in a deposition you
answer as little as humanly possible. Your side of lawyers will ask a few key
questions, any everything else is from your opposition trying to trip you up.

~~~
georgemcbay
Well, candid means "truthful and straightforward", doesn't necessarily mean
exhaustive. Sure, they are going to give away as little as possible, but
considering it is a legal deposition and perjury is a thing, they aren't going
to lie or actively dissemble like they might otherwise.

------
imh
"I don't recall" seems to be an unusual statement here. It seems like he's
using it more like, "I don't recall it outside of certain things I don't have
to/won't answer." Am I reading that right?

~~~
staticautomatic
You're only supposed to testify as to things about which you have first hand
knowledge, and you aren't supposed to speculate. So if you don't remember
something clearly you should not say it.

~~~
imh
How does that relate to the privileged communication stuff? It seems like
there's a lot he recalls, but not outside privileged communication, so he says
"I don't recall?"

~~~
staticautomatic
I take it to mean he doesn't recall learning anything about the topic aside
from what his lawyers told him.

~~~
imh
Cool thanks for confirming/clarifying :)

------
acdx
Do you have a PDF link?

------
br-g
"beginning 12:06 a.m., and commencing at 4:54 p.m."

Wow..

~~~
computerphage
They meant 12:06 PM, actually, but still

~~~
CalChris
I had an EE20N HW set due at 12am when I was at Berkeley. I was the only
person to get that wrong. The prof laughed and let it slide.

~~~
DaiPlusPlus
This is why the 12-hour clock system, with its inherent ambiguities mustn't be
used when noting the time actually matters. If someone's going to use the
12-hour notation they should use the verbose "noon" and "midnight" terms
instead of "12".

~~~
paulmd
Even worse, this is ambiguous as well. When is "midnight" on a given day, is
that the earlier or the later time?

Best-practice is to specify a non-midnight time, i.e. "must be turned in by
23:59 Friday evening"

~~~
kissickas
I get your point, but your example should have been "must be turned in by
23:59" or "must be turned in by 11:59 Friday evening".

If you're going to use both, I might as well say "midnight Friday evening," or
even the worse "12:00 Friday evening" as both of those are still
straightforward.

------
mcemilg
It tagged as 'HIGHLY CONFIDENTIAL' and published on HN. It was really
secret(!) meh.

------
ronack
I would not have expected Larry Page to have such a severe "I mean" verbal
crutch.

~~~
cookiecaper
From what I can gather, Brin and Page have never been polished image-centric
executives like their peers who lead other public companies. There's a reason
they don't come out much.

------
stillhere
>If you're going to buy a company or something, you would do more thorough
diligence. >When you say "more thorough diligence" what do you mean by that?
>I don't know.

------
joeblau
I wonder if someone could write an RNN to fill in the black boxes?

~~~
unityByFreedom
hah I thought the same thing. I think that's possible in the future but doubt
anyone's attacking it now.

Plus, who would fund it, a rogue state? Not so interested in being treasonous
myself. Interesting problem though. Getting any level of accuracy above
repeating "the" would be impressive.

------
brooklyntribe
Just a life tip. If doing a deposition, take a 1/2 a Xanax. Stare at the
opposing lawyer, long and hard. And answer in a very slow tone. Like
slooooowwwwwwww.

Bonus points, spell out the names, VERY SLOW, of everyone involved. Watch
lawyer meltdown.

Enjoy. :-)

