EXHIBIT 2 

FILED UNDER SEAL 

Case 3:17-cv-00939-WHA Document 1342-3 Filed 08/24/17 Page 1 of 5
+,*+/<&21),'(17,$/$77251(<6
(<(621/<



9HULWH[W/HJDO6ROXWLRQV

3DJH

 81,7('67$7(6',675,&7&2857

 1257+(51',675,&72)&$/,)251,$

 6$1)5$1&,6&2',9,6,21

 BBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBB

 :$<02//&



 3ODLQWLII

YV&DVH1R

 FY:+$

8%(57(&+12/2*,(6,1&

 277202772//&2772758&.,1*//&



 'HIHQGDQWV



 

BBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBB



 +,*+/<&21),'(17,$/$77251(<6
(<(621/<



 81'(57+(3527(&7,9(25'(5

 9,'(27$3(''(326,7,212)

 *$(7$13(11(&27

 6DQ)UDQFLVFR&DOLIRUQLD

 7KXUVGD\$XJXVW

 9ROXPH,9





 5HSRUWHGE\

0$5<-*2))

 &651R

 -RE1R

 3$*(6

Case 3:17-cv-00939-WHA Document 1342-3 Filed 08/24/17 Page 2 of 5
HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY

1 was derived, in part, from the work that you did 02:38:29

2 previously on FAC lenses for the GBR3, such as shown 02:38:33

3 in Exhibit 533? 02:38:37

4 MR. MUINO: Objection, form. 02:38:39

5 A Would you agree? 02:38:45

6 Q (BY MR. JAFFE) Would you agree that your 02:38:46

7 work on creating the FAC lens for Fuji here in 02:38:47

8 Exhibit 105 was derived, in part, from the work you 02:38:51

9 did previously on FAC lenses for GBR3, such as those 02:38:56

10 shown in Exhibit 533? 02:39:01

11 MR. MUINO: Same objection. 02:39:04

12 A So I mean, I gained a lot of experience 02:39:05

13 with ZEONEX while at Google, so the optimization -- 02:39:08

14 yeah, like, it helped me, like, probably in the 02:39:19

15 optimization. Like, overall with ZEONEX I have been 02:39:23

16 getting much better. 02:39:27

17 Q (BY MR. JAFFE) I mean, you're not sitting 02:39:28

18 here telling me that 

 

 

 02:39:40

22 MR. MUINO: Objection, form. 02:39:41

23 A So I mean -- 

 

 02:40:01

Page 641

Veritext Legal Solutions

866 299-5127

Case 3:17-cv-00939-WHA Document 1342-3 Filed 08/24/17 Page 3 of 5
HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY

1 02:40:05

2 

 02:40:16

4 

 

 02:40:26

7 Q (BY MR. JAFFE) All right. You're not 02:40:28

8 answering my questions. My -- my question is: 02:40:29

9 , is not 02:40:33

10 a coincidence, is it? 02:40:36

11 MR. MUINO: Objection, form. 02:40:38

12 A I mean, in some ways, yeah, it's -- it's 02:40:40

13 in my head. I have, like, some experience from 02:40:46

14 before, and I -- and you know -- like, you're always 02:40:49

15 impacted by your previous experience. 02:40:52

16 Q (BY MR. JAFFE) Right. So the design here 02:40:56

17 in Exhibit 105 is based, in part, on your work on 02:40:57

18 creating the G -- GBR FAC lens shown here in 02:41:02

19 Exhibit 533, right? 02:41:06

20 A So I -- 02:41:07

21 MR. MUINO: Objection, form. 02:41:07

22 A -- I used my experience. You know, like, 02:41:07

23 my previous experience is always here in my head, so 02:41:10

24 I don't know in which sense I used it or not. I -- 02:41:16

25 I don't -- was I thinking -- I don't know. 02:41:22

Page 642

Veritext Legal Solutions

866 299-5127

02:40:05

2

02:40:16

4

,

Case 3:17-cv-00939-WHA Document 1342-3 Filed 08/24/17 Page 4 of 5
HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY

1 02:41:29

2 02:41:33

3 

 

 So some of it maybe, 02:41:45

6 like -- you know, my work at Google may have 02:41:48

7 impacted a little bit of my work on the FAC lens. 02:41:58

8 MR. MUINO: Jordan, I think it's been more 02:42:32

9 than an hour since our last break. Is this a good 02:42:33

10 time for a break? 02:42:37

11 MR. JAFFE: Sure. 02:42:39

12 THE VIDEOGRAPHER: Off the record at 02:42:41

13 2:42 p.m. 02:42:43

14 (A break was taken from 2:42 p.m. to 02:42:44

15 2:55 p.m.) 02:42:46

16 THE VIDEOGRAPHER: Back on the record at 02:55:12

17 2:55 p.m. 02:55:15

18 Q (BY MR. JAFFE) I'm going to mark as 02:55:18

19 Exhibit 539, a document labeled UBER 86702. 02:55:18

20 (Exhibit 539 was marked for identification 02:55:26

21 and is attached to the transcript.) 02:55:26

22 Q (BY MR. JAFFE) Mr. Pennecot, do you see I 02:55:38

23 have marked -- marked as -- Exhibit 539? 02:55:39

24 A I see. 02:55:48

25 Q This is a transmit board for the Fuji, 02:55:50

Page 643

Veritext Legal Solutions

866 299-5127

02:41:29

2 02:41:33

3

Case 3:17-cv-00939-WHA Document 1342-3 Filed 08/24/17 Page 5 of 5