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Rosetta Stone v. Google (Joint Appendix) Research Projects and Empirical Data
3-18-2010 Vol. VIII, Tab 38 - Ex. 76 - Wojcicki Deposition (Google Vice-President Product Management) Susan Wojcicki Google
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Automated Citation Wojcicki, Susan, "Vol. VIII, Tab 38 - Ex. 76 - Wojcicki Deposition (Google Vice-President Product Management)" (2010). Rosetta Stone v. Google (Joint Appendix). Paper 49. http://digitalcommons.law.scu.edu/appendix/49
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) IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRlA DMSION
ROSETTA STONE, LID,
Plaintiff;
vs. Case No. J :09-cv-ll0736(GBIJrCB) GOOGLE,INC.,
Defendant:
CONFIDENTIAL DEPOSITION OF
SUSAN WOJCICKI
Marcb 18,2010 9:22 a.m.
525 University Avenue, S)lite 900 ( Palo Alto, Califomia.
Michelle L. Arcbuletta, CSR No. 11028
--
Telephone: 415.591.3333 facsimile: 415.S9L3335
44 Montgomery Street Suit!! 11DO r ESQill.E~• San Francisco, CA 94104
3928 ...... ~: :- .. Susan ¥roj cicki March 18, 2"010 CONFIDENT+AL
·-.: ' 6
1 A Yes.
2 Q Did you ever testify in any of those matters?
3 A No,' I did not .
4 Q Wh~n was your last deposition?
5 A Last week.
Q So given hO.w recent your last deposition was, I 7 take it you 're 'familiar with the rules of a deposition?
A · Yes.
9 Q Do you need me to 'go over them at ~ll today?
10 A No.
11 Q okay.
12 A I mean unless there's anything special about 13 this ca-se. I assume it'S like other depositions.
14 Q Just like it's' an ordinary deposit~on . i( 15 A Yes.
16 Q Can you . giv~ me your educational background
17 starting from colleg~.
18 A I have an undergraduate degree from Harvard
19 University that I gr'aduated from in 1999 19"90, excuse 20 me. I have a master's in economics' from UC Santa cruz 21 and I graduated in "1"993, and I have an "MBA from UCLA and
22 I graduated in 1998.
23 Q What1s your current position at Google?
"24 A My current position is vice president of
. "25 product management responsible for our adv~rtising
ToD Free: soo.nO.3363 Facsimile: 415:591.3335
" SuIte 1100 44 Montgoml!fY Sb"eet - San Frandsc.o, "CA 94104 ESQ1Jl~ www.esquiresolutions.com
3929 " ~ 0 •• " Susan. woj cicki March IB, 2010 CONFIDENTIAL
. 7 .J' 1 products.
2 Q When .you say advertising pro~ucts, do you mean 3 ali of Google's advertising products?
4 .A Yes, so that means AdWords, AdSense,
5 DoubleClick, and our Analytic~ ·produces . . Q When did you join Google?
7 A 1999.
8 Q Do you remember the month,
9 A May. 10 o Do you know when Google was founded? 11 A Google was founded in the fall of 1998.
U Q Do you know what employee number you are?
13 A 16. - 14 Q What was your position when you joined aOogie [' 15 in May 1999?
16 A I was the marketing manager, so I was
17 responsible fo.r all of Google'.s marketing. So I w~s the 18 first person at Google that did marketing, 50' 1 worked 19 initial.ly on things like our lc',go, our brand identity,
20 and trying to market our company with ~o budget.
21 Q. Which is usually the case with start- ups.
22 And how long were y.ou marketing manager?
23 A wel~, my title officially didn't change for iii 24 couple of years beca use Google wasn't that focused on 25 . titles, but I really focus.l'd on marketing probably for
Toll Free: 800.770.3363 Facsirr\Jle: 4LS.S91.3335
. Suite uoo 44 Montgonu!ry Street ESQUIRE San francisco, CA 94104 ( -~-~, .. www.esquiresolutlons.com
3930 Susan Woj cicki . March 18, 201 0 CONFIDENTIl'.L.
'.' ..., . 8
l. the first year, qnd then I transitianed to working more
2 . on what today's known as product ' manag~ment which is
3 more working on the pr~ducts and how the products are 4 designed, and I worked on am Web sear,ch product and how tliat was licensed to partners . ..
Q When you say the licensing of Web search -- the
7 ' Web s~a rch product, the partners, do you mean so that 8 other companies can use Googlels Web search product on 9 their Web site?
l.0 A Yes. So Netscape, for example, was an early 11 partner and we would license to Netscape a version of
12 Google Search so that ~sers on Netscape could search and
· 13 ·use Google . ,.t,· ... Q Since titles were not particularly important ~ .. I III focus on responsibilities.-· So you were focused on 16 marketing for about your first year at Google, right?
l.7 A Correct .
l.8 Q And then you switched over to working mo+e 19 primarily in the product management side focused on the
20 Web search product; and licensing . that out to partners,
. 21 right?
22 A Yes, and the way they were linked was . one of 23 the ways I did marketing when we had no budget was I 24 thought about how other sites could. put Google on their
25 sites_ So we had, for ~ample, a university' program
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e Suite 1100 44 Montgomery Street ESQUIRE San Fnl"ldsco, CA 94104 .. --~, www.esquiresolll;tions.com
3931 Susan. Woj cicki Mar.cb 18, 201.0 CONFIDENTIAL
175
1. Q Is there any li~ that's not on the bottom of a 2 search results page on Google.com. that will take users' 3 to. a Web page telling them what information ·Google uses 4 to show ads to users?
5 .'MS. CARUSO : Obj·ection. Vague. I just want to 6 clarify. You're talking generally about search results 7 pages. You're not talking about, for example, a search . 8 results page for a search for that information. 9 BY MR. SEEK:
10 Q Right. I'm talking generally a search results
11 page on Google.com~
~2 There's DO link other than the links that you
13 identified appearing at ~he bottom qf a search results page, right? . ( 15 MS. CARUSO: Objection. Foundation.
16 THE ·WITNESS: I don't know what's under nMore~
17 9 r under IIsearch.Setti.ngs~" I mean, -I've looked at them 18 numerous times, I just don't remember off the top of mY 1.9 head if we link to other sites or links that would be 20 relevant : . 21 BY MR. SEEK:
22 Q Is Google less transparent· about its ads on 23 Google.com than it is for ads shown on the AdSense
2~ partner network and YouTUbe?
25 MS. CARUSO: Objection: Vague.
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Suite llOD 44'Montgomery ~ - San Frandsco, CA. 94104 ESQV1E"~ www.esquiresolutions.com
.: ... . .: .. . 3932 SUsan Woj' cicki March 18, 2010 CONFIDENTIAL
' ''-''', ' " ' 2,~ 176 ',=].} ? 1 THE ' WITNESS, SO I'm only stating my opinion
2 because I can't -- I can't represent more than that, and
3 this is my opinion. I believe that we try to be as
4 transparent as possible to our advertisers' and our users
5 about what we're doing, and that '"sponsored links" is
6 the term that was used in the industry to determine 7 these or· to define what these terms are. And· I think
8 it's really important to point out that Goog~e bas'
9 always had the philosophy since the beginning of when
10 Google-·first started .to make our ad,s clearly marked.
11 There's no discussion or .debate in the company
12 about whether 'ads should be clearly marked or n~t .
13 Eyerybody a~ees that ads should be clearly marked, and -;'..! ~" 14 it's only a question as to what is that implementation. { . ".'\.i "" IS ' we ' haye never done paid inclusion,. which I'll say when
H Google started was the standard ~ay that people served
~7 ads. Ads were served in the results, they were not 18 marked, ana Google never, never did that. '19 Our partners. asked us for that; we could have
,20 generated more revenue by doing that: We probably could 21 have had more advertising,- and Google has never, ever n done that. The reason we have never done that is our
23 ' business philosophy. is on generatdng good result.s for
'24 users so our users come back and so that we can feei
25 that we have offered our users the best results that are
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3933 .'. : . ;. ": ".-. '" ' " . -. Susan Wojcicki March U, 2010 CONFIDENTIAL
177
1 the most objectiv~ possible per o~ algor~~hms.
2 And as a result, we have always tried .to mark .I 3 our ads clearly, and th.ere may be various opinions .about 4 how and, you know',' ?-egrees of what is the .most clear way 5 of doing it, but there is no debate within the company 6 that ads should always be clearly marked as ads-and
7 clearly-marked that there ~s some -- I mean, that's why 8 . we have the word sponsored _ Sponsored means - - I mean',
9 that's how advertis'ing' first started. Tv advertising 10 was often listed as here is the sponsor for this TV
1.1 . show. 12 And so this idea of here are these links, these 13 links are organic, and these are the sponsored ones. 14 These are the ones where there. is money and there's a
15 transaction ~d_ ·that I 5 .always been the philosophy of the' 16 company. :3 BY MR. SHEK,
:8 Q Are you aware that Google 'has conducted user
: 9 studies that found that some of Google~s users cannot~·
20 differentiate between sponsor~ links and the organic
21 search results that appear on Google.com?
22 A I am not aware of those studies.
23 Q Is there a team at Google called Rosetta? MS. CARUSO: Objection. Foundation.
25 THE vIITNESS: There1s a team ,named MaI).etta, but
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3934 Susan Wojcicki March 18, 2010 CONFIDENTIAL
.,.,. , . ~ J 178 i, '...... 1 I·lm not aware of a team named Rosetta.
2 (Exhlbi ts 13 and 14 were marked)
3 BY MR, SEEK:
4 Q You Ive been handed two documents . The fir.st 5 op,e·is marked 'Wojcicki 13. It's a document produced by
. 6 Google, Bates ~umbered GOOG-RS-0487810; the second one 7 is Wojcicki 14, a document produced by Google, B.ates
8 number~d GOOG-RS-0487812 to 814. 9 In 2006 w.ere you a member of the Content Ads 10 Quality e-mail group? 11 A Yes.
12 Q Do you recognize wojcicki 13?
13 A I donlt remember it. There 1 s a lot of e-mail · .' .. · !) 14 threads and they don't directly relate to me. f · . ,\ 15 Q Do you know who Jeff Chfn is? 16 A No.
17 , Q Mike Liang.? 18 A Yes, I know Mike Liang. 19 Q Who is Mike Liang? 20 A He is a PM who works on my team respon~ible . for-' ·· 21 content ads qUality, especially internationally. 22 Q In about the middle of the page Mr. Liang 23 writes, aBi guys, Jeff Chin from the Rosetta team and I
24 have been discussing the possibility of sh~wing targeted
25 ads on pages' that have been translated~ n
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":'. ' 3935