IO Group, Inc. v. Veoh Networks, Inc.

Filing 101

Declaration of Gill Sperlein in Support of Reply to Defendant's Opposition to Plaintiff's Motion for Summary Judgment 99 filed by IO Group, Inc. (Attachments: # 1 Exhibit Papa Exhibit Pages# 2 Exhibit Styn Exhibit Pages# 3 Exhibit Veoh v. UMG Complaint)(Related document(s) 99 ) (Sperlein, Dennis) (Filed on 8/21/2007) Text modified on 8/22/2007 to conform to document caption post by counsel (bw, COURT STAFF).

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IO Group, Inc. v. Veoh Networks, Inc. Doc. 101 Att. 2 Case 5:06-cv-03926-HRL Document 101-3 Filed 08/21/2007 Page 1 of 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ____________________________ IO GROUP, INC., a California Corporation, ) ) ) ) Plaintiff, ) ) vs. ) ) VEOH NETWORKS, INC., a ) California Corporation, ) ) Defendant. ) ____________________________) CASE NO. C-06-3926(HRL) DEPOSITION OF JOHN STYN SAN DIEGO, CALIFORNIA MAY 31, 2007 REPORTED BY REGINA L. GARRISON, CSR NO. 12921 1 Dockets.Justia.com Case 5:06-cv-03926-HRL Document 101-3 Filed 08/21/2007 Page 2 of 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ____________________________ IO GROUP, INC., a California Corporation, ) ) ) ) Plaintiff, ) ) vs. ) ) VEOH NETWORKS, INC., a ) California Corporation, ) ) Defendant. ) ____________________________) CASE NO. C-06-3926(HRL) DEPOSITION OF JOHN STYN, taken on behalf of the Plaintiff, at 530 B Street, Suite 350, San Diego, California, on Thursday, May 31, 2007, at 9:57 a.m., before Regina L. Garrison, Certified Shorthand Reporter, in and for the County of San Diego, State of California. 2 Case 5:06-cv-03926-HRL Document 101-3 Filed 08/21/2007 Page 3 of 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES FOR THE PLAINTIFF: THE LAW OFFICES OF GILL SPERLEIN BY GILL SPERLEIN 69 Converse Street San Francisco, California 94103 (415) 487-1211, Ext. 32 FOR THE DEFENDANT: WINSTON & STRAWN LLP BY JENNIFER A. GOLINVEAUX 101 California Street San Francisco, California 94111-5894 (415) 591-1506 3 Case 5:06-cv-03926-HRL Document 101-3 Filed 08/21/2007 Page 4 of 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 When you got involved with VEOH, when you talked about VEOH with Dmitry, were you aware of whether or not video clips containing sexual explicit material would be allowed on VEOH.com? A. Q. Yes. And at the time that you made that realization, did you think to yourself as to whether or not there may be issues regarding 2257? A. My client that I work with is not US based, But I do so I don't have a good understanding. remember thinking that it was -- it should be an issue. And -- and, yeah, I remember thinking that that is something that VEOH will have to address. Q. So after you had those thoughts, did you bring that topic up with Dmitry? A. Q. Yes. And do you remember when you had that conversation? A. Not specifically. I know it was before there It was still a was any 2257 prosecutions or actions. theoretical idea, and I remember just mentioning it as, definitely, it was the "sky is falling" hot button of the adult industry. Q. How did you know that there weren't any prosecutions or actions? 45 Case 5:06-cv-03926-HRL Document 101-3 Filed 08/21/2007 Page 5 of 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. I'm active on the adult message boards. Earlier, I asked if you had any conversations Did you actively read up on 2257 on the about 2257. adult message boards? A. Q. No. But did you read to some degree? I mean, you just said that you learned there were no legal prosecutions through adult message boards; is that accurate? A. Yes. MS. GOLINVEAUX: It's compound. BY MR. SPERLEIN: Q. Was the part accurate where you said you I'll object to the form. learned about the lack of prosecutions through message boards? A. Yes. I tried to stay informed enough that it -- what degrees is it an issue. Q. And then at some point, you had at least one conversation with Dmitry about your concerns as far as the applicability of 2257 to VEOH; is that accurate? A. Q. Dmitry? A. No. 46 Yes. Did you have more than one conversation with