Witness No. 1 — Cloudflare, Inc. — Direct Examination
THE CLERK: The People call Cloudflare, Incorporated, to the stand.
THE WITNESS (CLOUDFLARE): Present, Your Honor. Founded 2009, San Francisco.
ATTORNEY LATENCY (EXAMINATION):
State for the record your network size as of 2021.
Approximately 250 cities across 100+ countries. Our Anycast network routes every request to the nearest data center. We also expanded our backbone significantly this year.
And your pricing model?
Our free tier includes CDN, DDoS protection, universal SSL, and basic WAF rulesets. Pro is $20/month per domain. Business is $200/month. Enterprise is custom.
Exhibit A — Cloudflare 2021 Feature Summary
Workers: Serverless V8 isolates at edge, KV storage, Cron Triggers, Durable Objects (beta) · R2 Storage: Announced Sept 2021 — S3-compatible, $0 egress fees · Pages: Static site hosting (GA April 2021) · DDoS: Unmetered on all plans, mitigated 17.2M rps attack in Aug 2021 · Security: WAF, bot management, API Shield · Free tier: Genuinely usable CDN + DDoS + SSL at no cost
Describe the August 2021 DDoS attack you mitigated.
On August 19, 2021, our systems automatically detected and mitigated a 17.2 million request-per-second DDoS attack — the largest HTTP DDoS attack reported at that time. The attack lasted less than 30 seconds. Our autonomous edge detection handled it without human intervention.
What about R2 — the storage product you announced?
R2 was announced in September 2021. The key differentiator is zero egress fees for stored objects, while maintaining S3 API compatibility. It directly challenges traditional cloud data transfer pricing.
OBJECTION — COUNSEL FOR AWS CLOUDFRONT
Implies predatory pricing against a competitor's storage model.
THE COURT: Overruled. The witness may describe their own pricing strategy. Proceed.
What weaknesses should the jury be aware of?
In 2021, advanced WAF custom rules required the Business plan at $200/month. Free and Pro support was community-forum only — no guaranteed response times. Workers had memory limits of 128 MB, and Durable Objects were still in beta. Some enterprise customers felt our support couldn't match Akamai's dedicated account teams.
Court notes: Witness credible. Free tier remarkably generous. R2 announcement strategically significant for the market.