Larry Page Deposition in Uber vs. Waymo | Hacker News Reader

Larry Page Deposition in Uber vs. Waymo

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186 pointsheshamg205 comments

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.

What would the business model be? Or to ask the same thing a different way: who is wasting money with the status quo?

Litigants are wasting money with the status quo. Not because of the format, per se, but because of a lack of reasonably good NLP-based search and summary tools. Much money is spent paying people to review transcripts by hand, when the bulk of the heavy lifting could be done with software. I know the market well enough to manage the product development and sell it but lack the NLP skills to build it. Anyone interested in talking about it feel free to hit me up.

You don't understand how large court cases work.

You're obligated to provide everything to the other side, doing so in a format that requires them to have a small army of people to read every line instead of being able to do a simple text search is exactly the point. There are even companies that specialize in taking large amounts of electronic data (email is a good example) and printing every single page so that opposing council ends up with enough paper to fill a room.

Edit: I also have no idea how you'd sell a product that considerably reduces billable hours.

You could sell it to plaintiffs lawyers and the increasing universe of firms that do fixed fee or capped arrangements. Plaintiffs lawyers have huge incentives to minimize per-case investment, but they don't use much legal tech. Which is pretty great evidence of how well it works.

Also you can obviously search PDFs. People read every line of deposition transcripts because they're looking for admissions (places where the deponent slips up and reveals useful information).

Exactly. Large cases often produce box after box of documents and frequently supply documents not related that were not requested. It is a game of burying them in paper because if there is a smoking gun (document that is critical to their side) they may not see it or when they find it, they have paid tens of thousands of dollars in legal fees for the attorneys to find it in the many boxes of documents.

Often times one litigant can starve the less funded litigant out. Successfully starving a litigant out results in favorable settlements for the offending litigant.

> I also have no idea how you'd sell a product that considerably reduces billable hours.

I think you'd want to sell it to the folks who are paying for those billable hours.

They're not the ones using it though

You sell it to firms who would like to compete on price while showing clients that they do so due to their use of cutting-edge technology

The nature means that you'd only reduce your adversary's costs, not your own.

Seems like requiring an electronic copy when one is available originally would go a long way. Is it court's prerogative, or do we need a Congressional amendment for this to become commonplace?

It is common place. I've never gotten paper discovery in a civil case. Opposing counsel sends links to a secure download site, sometimes a CD or USB. The documents are sent as natives plus TIFF images of each page plus metadata. We load them into an ediscovery platform where everything is OCR-ed and indexed. Whoever reviews it works within the platform where documents can be searched, tagged, marked up, etc.

This is where us old-timers go into get-off-my-lawn mode: "You kids today don't know how easy you have it for document discovery — in my day we spent days and weeks in hot, dusty warehouses looking through boxes of mouldering paper files ...."

See https://www.law.cornell.edu/rules/frcp

> I also have no idea how you'd sell a product that considerably reduces billable hours.

Hmm.. perhaps, if they can force the opposition to use similar tech, then they can promise faster resolutions.(That's still assuming both the parties wouldn't mind it much, but don't see it happening).

> There are even companies that specialize in taking large amounts of electronic data (email is a good example) and printing every single page so that opposing council ends up with enough paper to fill a room.

Surely there's a limit to how awkward you can make this for the other side? Why would the courts allow making it intentionally difficult for one side to gather evidence to help their case?

For example, I'm sure they wouldn't allow you to deliver the documents on numbered post-it notes, one sentence per note and in a random order.

I would have thought the court would insist the material is delivered in the most practical format (e.g. emails as text files or in a searchable database) and both sides get access to the same format unless there are special circumstances.

I would imagine they are stuck back a few decades when delivering documents on paper was standard and nothing unusual. So printed paper is a minimal acceptable format. Since part of the legal battle is to also drain the other side's resources it would make sense then to go by the absolute allowed minimum and nothing more.

If delivering documents on posted notes was allowed surely they'd be companies specializing in that.

I thought this happens only on TV. Why the hell would you not require by law that electronic information in the best available format must be supplied if available???

How do you define "best available format" though? There's a rabbit hole of complexity just in this single sentence!

So are you saying it's sensible that we're stuck with emails printed on reams of paper because it's too hard to define a better spec? There is really no reason for digital files not to be mandated in 2017 except "lol bureaucracy." Frankly, if someone only has access to paper files they should be required to scan them. As is, at least as much work is being done in the opposite direction (printing tons of paper) which is just ridiculous.

> So are you saying it's sensible that we're stuck with emails printed on reams of paper because it's too hard to define a better spec?

Oh, it's not sensible but I do appreciate the huge gap between a tossed out "lol, use digital" and reality that people blithely ignore. As a trivial example, marking up emails printed on paper can be a lot easier than doing it digitally.

> Frankly, if someone only has access to paper files they should be required to scan them.

How do you prove the scans are correct? Presumably the paper files have some kind of chain of custody going on - how do you enforce that for digital files? What resolution do you enforce? What colour settings? Or B&W? Or shades of grey, even? What happens to the forensic dots that printers add when you scan a document? They might be vital evidence.

It's fine to just "scan them" in an office but you really want to avoid any kind of potential data loss when you're talking about evidence in a court case.

And dipping into the wilder reaches of fantasy, how do you guard against things like steganography being used to pass information secretly? Or avoid viruses / trojans / zipbombs / whatnots?

I work on large lawsuits for a living. You obviously don't understand the point I made.

There is a significant industry based on e-discovery that never sees, or requires actual paper. Much more likely is an inhalation of the contents of a custodian's hard drive, or the ingestion of a full PST file (MS Outlook email form) into a system, or downloading email inboxes from Office 365 or Gmail.

Once ingested, the documents are searched for words or phrases, tagged as relevant, privileged, or non-responsive. See the FRCP (Federal Rules of Civil Procedure) for discussion of electronic documents in discovery.

Not only are courts expecting parties in lawsuits to supply documents in electronic form, there are are now rules in some courts tailored to TAR, or technical assisted review, which often means LSA (Latent Semantic Analysis).

So the idea of dropping tons of paper on the hapless opponent is an idea that is practically of antiquity, dating back to the MCI/ATT lawsuits. Large lawsuits simply don't work that way anymore.

But it would be an act of faith and patience to redact and docket-file high-tech versions-- that is seamless for the low-tech PDF, which was pen-signed and docket-friendly. The PDF was even pulled from the docket and re-posted on scribd, with searchable text intact.

There also would be a time-synchronized video and an e-transcript, yes, in proprietary non-open standards.

is there a link to the video?

A lot of the time they're also provided in other formats, including plain text. It's still got pages and line numbers (they're essential for citing to), and it uses an ASCII form feed for new page, but it's better to work with. You can actually pipe it to port 9100 on a common network printer and it'll come out about right. There is also software to work with these transcripts.

why is so many pages completely redacted? how do you read the unreadcted original

Being on the legal teams for plaintiff or defendant would be a start.

Unless they do something stupid like just draw block boxes over the real text, you don't. That's the purpose of redaction.

Given developers are responsible for CSV, PDF (a complex programming language that renders documents as a side effect), XML, and JSON, I see no particular reason to share your optimism.

For all the good press PDF is still a bitch to work with when trying make end to end workflows (particularly if you want to avoid opening acrobat or something).

There are a number of legal tech companies fighting to break into legal document management (ediscovery). I worked for Everlaw (a16z) and there's also Disco and Logikcull, among others

Let's not forget Relativity :)

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.

It's the structure of the document that's the problem, not the file format. Copying and pasting out of it is painful.

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

not specific to depositions, but a piece that might help: api for pdf's https://www.pdfotter.com/

No freaking kidding. It's 2017, where's the json..

The goal of law firms is to maximize billable hours and make it difficult for non-lawyers to conduct legal work. Working efficiently is not the goal at all.

This is a particular file format used for legal transcripts rendered as a PDF. The underlying format is not all that difficult to work with. Good legal software needs to be able to deal with hundreds of different file formats, from Lotus Notes to the oldest MS Word format or early forms of PowerPoint. The transcript format is a piece of cake relative to others.

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

Here's another good one, featuring Bill Gates: https://youtu.be/HhdDZk45HDI

Wow I forgot how painful this was to watch.

Now I know why Microsoft employees all have private offices.

Here's another transcript reading, done in the voices of Rick and Morty and animated by fans:

https://youtu.be/WTWdP5DMdsM

That was amazing. Thanks for linking it!

You cannot forget the lil wayne deposition:

https://www.youtube.com/watch?v=UT5wi07X4AM

probably NSFW

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.

It's entertaining to see Larry Page wishing he had a penny for every time something happened!

"Mr Page, you do, in fact, have several pennies for each time that could possibly have happened."

In multiple universes

"Man, if only I had a penny every time someone placed a web ad that got seen by 1000 people!"

'But you ... do ...?'

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.

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

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.

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

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.

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?

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

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

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

Yeah, it's not possible (or perhaps just a really, really bad idea) to do "always on" oncall with that kind of SLA. Either people will be constantly missing it, or you'll burn them out really fast. The SRE book talks about this, I think, in terms of the minimum number of people and distributed offices you need in order to do a robust oncall rotation.

Hand off to the secondary.

In my old team's case, the shift was 10am-10pm either Mon-Thu or Fri-Sun. If you needed to commute or grab lunch or something, you just had to coordinate with the secondary oncaller to cover for you for a half-hour or whatever.

Stuff like bathroom visits, showers, etc aren't usually a big deal since 1) we didn't get paged that often (see the SRE Book on proper alerting design) and 2) three minutes is longer than you'd think. Usually plenty of time to "wrap things up" and get back to your laptop.

If your internet dropped out, you'd either switch to tethering, get your secondary to cover while you drove to the office or a coffee shop, or worst case contact your manager to help find emergency coverage.

Normally when I was oncall, I'd be on the couch playing video games or watching a movie with my work laptop nearby and logged into a shell on my work desktop.

Awesome, thanks! I kind of want to be an SRE now. (Not because of the video game part, though I wouldn't mind that ;) I meant because it sounds exciting.)

This is not unique at all to Google, or even tech. People complain and whinge about leaving, but never actually do (or don't for a while).

You're also taking them at their word that they do intend to start their own companies, I think to a lot of folks in the Valley this sentiment is the same as the "I'm going to quit and write my novel" cliche from the 20th century.

What's the line from the first episode of Silicon Valley "I don't want to become a Hooli-lifer"?

Do you think REWS is actually useful for retention?

I've always thought that REWS was much more beneficial for recruiting, in the phase when they walk you around campus and show you all the impressive public spaces, and talk about all the nice services they offer. The one thing they don't show you is the huge, loud, windowless open office space where the team you'll be joining actually works. And by constantly shrinking that space, removing cube walls, and making workplaces more and more miserable, I think they actually hurt retention.

When I left Google in June of 2015, my team was just about to be transitioned from an older building on the main campus where we had actual cubes with walls (nevermind that there were already 6 people per cube) and a few shared offices, into a modern design in Sunnvale, with just a giant room with tables and little/no dividers. Between loosing access to all the cool things on the main campus (cafe choice, gyms, events like TGIF) and the new, crappy workspace, it just seemed like a gigantic downgrade.

I now work from home in the middle of nowhere, where I have an office with a door I can close, and a window for natural light. (and working remotely was something else that was not possible at Google)

"i wish i had a penny for every time" really takes on a different meaning when it's in the same deposition as "i can't be expected to keep track of every hundred million dollar payout"

Interesting comparison given that the hundred-million-dollar payout came from 10 billion pennies' worth of ad clicks.

-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?

Delegating responsibility for countless tasks like any good CEO and focusing his energy on things he is good at?

Does he really need to be the guy approving bonuses to employees and coordinating details of investments in 3rd party companies?

Yet he approved every Google hire until 2011: https://www.quora.com/What-does-it-mean-when-Larry-Page-sign...

It seems far more likely that Page is being evasive and doesn't want to give evidence supporting a narrative that Lewandowski was a superstar, Google was desperate to keep him, failed, and this lawsuit is just a malicious and anti-competitive. (Which I don't believe, but I'm guessing that's the narrative Uber would want to create)

He's responsible for not answering questions if he might misremember and contradict the record.

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?

You have to wonder if that's really true though. Even the CEOs of the best performing investment banks don't make more than a fraction of that.

The bonus go to the trader, not the CxO.

>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?

That's a lie. Do you really think Google would be paying someone $100M or something close to that and the CEO wouldn't hear of it?

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.

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.

Eh, there's definitely a limit, but if the maintainer of a major piece of software didn't remember how a particular feature first started or if they were in the OWNERS file of a particular directory, I would consider them to be a completely representative member of our species.

He's the CEO of alphabet, not the CEO of waymo. He manages Alphabet's investment in waymo, he doesn't manage waymo.

Waymo is a relatively recent invention though; Project Chauffeur started in Google.

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.

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

>Oops.

The paragraphs surrounding that are all blacked out, so I'm not sure that this is an oops.

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

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.

It's always a good idea to start with the basics

To get it on record who you are for evidentiary reasoned also to lull the exponent into a false sense of ease or comfort. The attorney's try to be friendly, even chatty, so you will expound on your answers, correct them if they ask something wrong, etc.

They will also ask quite frequently if you are on any medication that impairs your ability to participate in the deposition or that could affect your ability to recall events, etc. This prevents you from being able to later say, "oh well I did not say that correctly. I had taken a pain pill for my back that morning, etc. ". The point is to avoid future surprises if the case goes to court.

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.

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.

> 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.

No, in a deposition you are open to having to answer questions about pretty much anything. Your attorney can't do much to object or stop a line of questioning without a court order limiting scope.

Some attorney's will ask about totally irrelevant things just to annoy you or hoping to catch you off guard when they come back to the topic later. Or in some cases, they simply want to get you frustrated so that they get under your skin when they are asking their important questions. Depositions are just another part of discovery.

All the attorney has to do is catch you in one lie or to get you to make a misstatement that conflicts with some document they know they have and they will pound it into the ground in court. This is where the ammunition for the "were you lying then or are you lying now?" crap comes from.

Can you take your own sweet time to answer the questions?

I think that's partly where the "don't know which ranch you're talking about" thing comes from. Might as well spend some time on some irrelevant stuff instead of immediately saying which ranch it is.

I don't think you would get away with a one minute pause before answering each question without risk of potential sanctions if the lawyer felt you were simply driving up costs, etc. Of course to get sanctions the court would have to agree that your intent was to needlessly drive up the cost of the deposition or to harass the other party. If you are simply answering the question as asked the court would not grant any sanctions. However, if you ask for clarification on a question occasionally and only answer the question as asked you can get away with quite a bit.

He could have answered yes when asked about owning a ranch and made the attorney inquire further. Then upon further questioning he could have said I have multiple ranches. Then made them ask about each one in order to get to their intended question. Depositions are discovery so if they want to uncover, or discover, something then they have to ask the right question in order to get to the information.

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.

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.

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.

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.

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.

The upfront payment sweetens the pot. Now the 'cofounder' has the choice of 100 million on the table v/s say a much larger POTENTIAL payout 5-10 years down the line.

Are there really people who would turn down a hundred million dollars for a chance at a larger potential payout in 5-10 years? Are these people even members of Homo sapiens?

A $100MM bonus seems like a career-ending bonus to me. How do you keep going to work after that?

Mark Zuckerberg turned down an offer from Yahoo. Evan Spiegel, from FB.

Plenty of CEOs have career ending incomes / bonuses already.

Yes, but they turned it down to work on what they liked. This is just paying you upfront to do that. Granted you don't own it...

The difference is at that point Mark had something worth that much money and had already spent several years building it. If he decided in 1 year he was done he could have probably found another buyer at a valuation high enough to retire unless he royally screwed up the company.

Turning down $100mm when you have nothing of value yet is very different imo

I'm not positive, but I think Spiegel already made FU money as part of a funding round prior to the FB offer.

Can anyone confirm?

> Are there really people who would turn down a hundred million dollars for a chance at a larger potential payout in 5-10 years?

Sure, and the numbers get far larger than $100 million.

Larry Page and Sergey Brin for example, turned down very large acquisition offers, including for at least a billion dollars from Yahoo, at a time when they didn't even have a serious business model.

Mark Zuckerberg turned down several large offers for Facebook when it didn't have a serious functional business. He could have walked away nearly a billionaire before Facebook had even printed a dollar of profit.

Bill Gates turned away numerous, large acquisition offers in the first ~10 years of Microsoft's existence. IBM was interested in buying them for years.

The Snapchat owners turned down ~$3 billion from Google to go public instead as an exit. Even after the beating their stock has taken in the last few months, the market cap of Snap is $15 billion today.

> The Snapchat owners turned down ~$3 billion from Google

from Facebook

Haven't you met the people who work up on the roof?

Cruise was acquired by GM for $1B, at a time when it was a fraction of the scale & sophistication of Waymo. So how does Waymo not count as a success when you consider the comparables...?

Cruise was not acquired for $1B. http://www.businessinsider.com/gm-cruise-automation-price-20...

581 million

GM CFO said $581M. Sorry, I was off by a factor of 2x... but my point still stands. If Cruise was worth $581M, then Waymo is worth a lot more.
http://fortune.com/2016/07/21/more-on-what-gm-paid-to-buy-cr...

The $100,000,000 was not paid upfront. It was paid due to the success of the project.

Seriously. I would have been happy to go there and accept a mere $1M bonus (saving Google shareholders $99M), and I probably would have done better than "leave mid-way through, copy a bunch of docs, and go to work for a competitor".
It's the same bogus excuse for outrageous CEO pay: "We just can't seem to find anyone good without offering 1000X more than normal people make."

>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?

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

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!

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

Just didn't meet the right people at the right time.

Am I unknowingly on a forum of 8-9 digit zillionaires?
Yes, but most of us are temporarily embarrassed.

I believe Larry Page is saying that you get compensation like being a C-level exec, but instead of having your own company you work at Google.

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.

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.

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.

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.

> 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."
Or, even, possibly, “You might” (given the question phrasing ”...do I...”), if it is technically possible to get the fidget spinner to go clockwise with a call to function X, even though it's not the right way.

Hah, even better!

This cautious question-answering might feel unusual because it potentially violates Gricean norms:
https://en.wikipedia.org/wiki/Cooperative_principle
https://en.wikipedia.org/wiki/Implicature
(In typical conversation, speakers often guess why a question was asked and try to respond to the inferred motivation.)

Do not go overboard or it will backfire:
Take a 2 hour disposition transcript to the judge.
All answers are ~I cannot recall~.
Profit.

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."

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?

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".

That's hilarious but did the comment even need a reply?

No; counsel was clearly stopping and waiting for me to respond. I could have remained silent, but my reply was a way to move things along (by indicating I wasn't going to ramble in response to a non-question as well as getting a poke in).

Haha I see, thanks!

Sounds like a joke straight out of Rick and Morty, got a laugh out of me!

> So when they ask a question you are taught to answer precisely what they asked and no more.
I find this interesting conceptually.
Can you elaborate where this is being taught? or, if not of general knowledge, who, when, where taught you that?
Not a deposition, just an internet question.

Lawyers tell their clients this right before they, the client, is deposed. As another commentor here hinted at, when being deposed you are either going to play it safe or lose, there is really no winning. Deposition hiccups are later used, at trial or in settlement negotiations, as leverage against your opponent or to try to discredit them as a witness/simply make them look stupid as a witness. A deponent seldom has anything to gain from waxing poetic about whatever they are being deposed about.
That's the litigation game.
Edit: spelling.

Not sure if it's taught anywhere per se, but in many arenas it becomes habit. "Do you know what time it is?" "Yes." "Can you tell me the time?" "Yes." "What time is it?" "11:30".

Why cough up the answer so soon? Make them specify the time zone.

And that they are asking for the current time. Not the time of the lunch break.

If you work for a "normal" company, your company's lawyer will spend a day or so prepping you for deposition before the actual thing.
And the deposition is very tiring.

I had a similar experience with the deposition (instructed by my attorney to keep things simple and single-syllable if I wanted to get out of it quickly), and the switch from on-record to off-record was pretty weird, as the opposing side knew my attorney pretty well, which inspired a lively exchange about weekend plans, common acquaintances, etc. In a few minutes we're back on record with just dry "Yes"es, "No"es and "Do not recall"s flying around.

Not Google, but side business related. I once worked with a person that built and sold computers on the side. He fielded customer support calls from his desk. He was let go shortly thereafter. The new guy did have to answer his customer support calls, though.

> Larry Page did not want to answer anything.
That's how you do a deposition. I don't know how many depositions Page has had to do over the years, but it's not his first rodeo. Depositions aren't just used as fact-finding (and in a case like this most of the facts are already known) - they're used to force the deposed party into either lying or omitting something they later rely on in order to discredit their eventual testimony.
For example, the question "do you recall when" seems simple enough, but let's say I mistakenly mix up the year in my deposition. "How can he be trusted", the defense will say, "if he can't remember basic facts like when the company was bought?".

Why is this downvoted? He's not incorrect, Page wanted to provide the bare minimum answers, as he has the right to.

Probably because the example used was not an instance of that

There are some good examples of him not wanting to answer anything, but this isn't one of them. Read the next 2 lines!
> Q: Do you recall when? [asked again]
> A: No, I don't remember when we did that.
They were probably talking over each other or something.

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?

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"

or show that the employee was more prized than any stolen documents, thus downplaying the significance of the documents

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

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.
Reminds me of the Silicon Valley subplot where Hooli gives Big Head outrageous compensation so they can use him in a legal proceeding. https://www.youtube.com/watch?v=0owqfskr_jQ
My guess is that Uber's lawyers are trying to gather evidence for the argument that nothing was stolen from Waymo: Levandowski was (supposedly) so crucial to the success of Waymo that when he went to work for Uber, he was just bringing over his own IP.

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.

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

Wow - that is interesting.
Looked him up - well accomplished and seemingly in the know.

Or maybe just trying to get under his skin.

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.

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.

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.

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

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?

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.

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."

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.

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.

I've been deposed, and prior to the deposition my attorney said not to volunteer anything and to answer as short as possible to the exact questions that were asked.
The point for a deposition is to make the deposed say something incriminating, spill the secret sauce, or somehow get tripped up. The point for someone being deposed is to finish the deposition after having said as little as possible.

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

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

> 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.

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

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

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?

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.

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.

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.

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.

Is it possible Waymo was created this way to address this specific outcome? The title of this article could have been "Larry Page Deposition Uber vs. Google Cars."

Possible, sure. But very few interested people are unaware that Waymo = Google = Alphabet in every sense except a technical legalistic one. I don't really think hiding the Google brand's involvement is of the sort of significance of value to justify the whole Alphabet move.
A theory of my own based on this read: A lot of questions Larry Page was asked were below "his level". Compensation, policy, etc. But presumably, as the CEO of the company when this issue started, he is deposed on it. Maybe with a higher level of vertical structure, Google and 'other bets' legal concerns will go up to the level of that subsidiary's CEO and no further. Or to say otherwise, just that creating the additional level of obfuscation moves Larry and Sergey further from being involved in day-to-day operations, which at Google's size is considerable and presumably take up a significant amount of time to be involved with.

That whole "Otto Trucking" portion was embarrassing, and not for Larry.

Otto and Otto Trucking could indeed be 2 difference companies. There was even a lawsuit as they both operate in the self-driving tech space... more here: https://www.ottomotors.com/company/newsroom/press-releases/o...

"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?

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.

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?"

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

Cool thanks for confirming/clarifying :)

Do you have a PDF link?

"beginning 12:06 a.m., and commencing at 4:54 p.m."
Wow..

They meant 12:06 PM, actually, but still

They also meant concluding.

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.

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".

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"

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.

It was conducted in an aircraft traveling west to east near the arctic.

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

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

I mean, he was a software engineer to start off.
Facetiousness aside, the deposition went on for 5 hours. It's quite a stressful endeavor that makes it more difficult to control any linguistic idiosyncrasies one might have.

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.

>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.

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

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.

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. :-)

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