UMG Recordings, Inc. et al v. Veoh Networks, Inc. et al

Filing 606

Attachment 1
MEMORANDUM in Opposition to MOTION for Attorney Fees and Costs (REDACTED) 587 filed by Plaintiffs Songs of Universal, Inc., Universal-Polygram International Publishing, Inc., Rondor Music International, Inc., Universal Music - MGB NA LLC, UMG Recordings, Inc., Universal Music - Z Tunes LLC, Universal Music - MBG Music Publishing Ltd., Universal Music Corp.. (Attachments: # 1 Declaration of Brian D. Ledahl in Support of UMG's Opposition, # 2 Exhibit A to Ledahl Decl., # 3 Exhibit B to Ledahl Decl., # 4 Exhibit C to Ledahl Decl., # 5 Exhibit D to Ledahl Decl., # 6 Exhibit E to Ledahl Decl., # 7 Exhibit F to Ledahl Decl., # 8 Exhibit G to Ledahl Decl., # 9 Exhibit H to Ledahl Decl., # 10 Exhibit I to Ledahl Decl., # 11 Exhibit J to Ledahl Decl., # 12 Exhibit K to Ledahl Decl., # 13 Exhibit L to Ledahl Decl., # 14 Exhibit M to Ledahl Decl., # 15 Declaration Carter R. Batsell in Support of UMG's Opposition, # 16 Exhibit A to Batsell Decl., # 17 Exhibit B to Batsell Decl., # 18 Exhibit C to Batsell Decl., # 19 Exhibit D to Batsell Decl., # 20 Exhibit E to Batsell Decl., # 21 Exhibit F to Batsell Decl., # 22 Exhibit G to Batsell Decl., # 23 Exhibit H to Batsell Decl., # 24 Exhibit I to Batsell Decl., # 25 Exhibit J to Batsell Decl., # 26 Exhibit K to Batsell Decl., # 27 Exhibit L to Batsell Decl., # 28 Exhibit M to Batsell Decl., # 29 Exhibit N to Batsell Decl., # 30 Exhibit O to Batsell Decl., # 31 Exhibit P to Batsell Decl.)(Batsell, Carter)

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UMG Recordings, Inc. et al v. Veoh Networks, Inc. et al Doc. 606 Att. 1 1 Steven A. Marenberg (101033) (smarenberg@irell.com) Brian D. Ledahl (186579) (bledahl@irell.com) 2 Carter R. Batsell (254396) (cbatsell@irell.com) IRELL & MANELLA LLP 3 1800 Avenue of the Stars, Suite 900 Los Angeles, California 90067-4276 4 Telephone: (310) 277-1010 Facsimile: (310) 203-7199 5 Attorneys for Plaintiffs 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IRELL & MANELLA LLP A Registered Limited Liability Law Partnership Including Professional Corporations UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. CV-07-05744 AHM (AJWx) DECLARATION OF BRIAN D. LEDAHL IN SUPPORT OF UMG'S OPPOSITION TO VEOH'S MOTION FOR ATTORNEYS' FEES AND COSTS Filed Concurrently Herewith: 1. UMG's Opposition to Veoh's Motion for Attorneys' Fees and Costs 2. Declaration of Carter R. Batsell in Support of UMG's Opposition Judge: Date: Time: Courtroom: Hon. A. Howard Matz December 21, 2009 10:00 AM 14 11 UMG RECORDINGS, INC., et al., Plaintiffs, v. VEOH NETWORKS, INC., Defendant. DECLARATION OF BRIAN D. LEDAHL IN SUPPORT OF UMG'S OPPOSITION TO VEOH'S MOTION FOR ATTORNEYS' FEES AND COSTS 2162202 Dockets.Justia.com 1 2 3 1. DECLARATION OF BRIAN D. LEDAHL I, Brian D. Ledahl, declare as follows: I am an attorney at the law firm of Irell & Manella LLP, counsel of 4 record for UMG Recordings, Inc., and other affiliated UMG entities (collectively, 5 "UMG") in the above-captioned action. I am a member in good standing of the 6 State Bar of California and have been admitted to practice before this Court. I 7 submit this declaration in support of UMG's Opposition to Veoh Networks, Inc.'s 8 ("Veoh") Motion for Attorneys' Fees and Costs. Except where otherwise noted, I 9 have personal knowledge of the facts set forth below and if called as a witness, I 10 could and would testify to these same facts under oath. 11 2. In connection with UMG's Motion for Partial Summary Judgment, 12 UMG and Veoh agreed to the following briefing schedule: UMG would files its 13 motion during the week of September 2, 2008; Veoh would file its opposition not 14 later than September 29, 2008; and UMG would file its reply not later than October 15 10, 2008. The Io Group decision came down on August 27, 2008. 16 3. In this action, UMG produced dozens of license and sales agreements 17 between itself and technology companies regarding the online display, reproduction, 18 and distribution of UMG's copyrighted materials. 19 4. On October 24, 2008, Veoh propounded an interrogatory to UMG 20 asking that: "for each work for which you claim copyright law remedies against 21 Veoh in this case, please provide information sufficient to identify each alleged 22 infringement of such work, including (a) the name or other unique identifier of the 23 infringed work, (b) the copyright registration number of every copyright registration 24 pertaining to the infringed work, (c) the Veoh Video ID number and Permalink for 25 each video allegedly infringing the work for which you claim Veoh bears liability . . 26 . ." On December 1, 2008, UMG timely responded to that interrogatory, identifying 27 1,591 videos for which it asserted claims of infringement. 28 IRELL & MANELLA LLP A Registered Limited Liability Law Partnership Including Professional Corporations 2162202 -1- DECLARATION OF BRIAN D. LEDAHL IN SUPPORT OF UMG'S OPPOSITION TO VEOH'S MOTION FOR ATTORNEYS' FEES AND COSTS 1 3 5. 6. Attached hereto as Exhibit A is a true and correct copy of the Court's Attached hereto as Exhibit B is a true and correct copy of a September 2 September 11, 2009 Order on Veoh's Motion for Summary Judgment. 4 24, 2007 letter from Michael Elkin, counsel for Veoh, to my colleague Steven 5 Marenberg. 6 8 7. 8. Attached hereto as Exhibit C is a true and correct copy of an October 1, Attached hereto as Exhibit D is a true and correct copy of a printout 7 2007 letter from Mr. Marenberg to Mr. Elkin. 9 from http://bits.blogs.nytimes.com/20

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