The Authors Guild et al v. Google Inc.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK The Authors Guild, Inc., Association of American Publishers, Inc., et al., Plaintiffs, v. Google Inc. Defendant. DECLARATION OF DAPHNE KELLER IN SUPPORT OF MOTION FOR FINAL APPROVAL OF AMENDED SETTLEMENT AGREEMENT Case No. 05 CV 8136 (DC)
I, Daphne Keller, hereby declare as follows: 1. I am employed by Google Inc. as Managing Product Counsel, and I am the
Product Counsel responsible for Google Books. I make the following declaration based on my personal knowledge and if called upon to do so could testify competently to the matters set forth herein. 2. After the submission of the original Settlement Agreement, Google was
approached by counsel representing the "Privacy Authors and Publishers" who later objected in Docket Item 281. Counsel stated that they were considering objecting to the Settlement Agreement on the ground that it did not contain what they considered to be sufficient protections for user privacy. 3. I, along with other representatives of Google, participated in numerous productive
meetings with counsel for the "Privacy Authors and Publishers" over the course of several months. 4. Counsel explained their concerns, and Google responded by making clear that the
written commitments regarding user privacy for the services contemplated by the ASA even before those services are made available to consumers, in a departure from Google's regular practice. 6. In addition to the current privacy commitments in place for the entire Google