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

Filing 94

Declaration of Keith Ruoff in Support of Plaintiff's Motion for Administrative Relief in the Form of an Order to File Documents Under Seal 93 filed by IO Group, Inc. (Related document(s) 93 ) (Sperlein, Dennis) (Filed on 8/20/2007) Text modified on 8/21/2007 to conform to document caption post by counsel (bw, COURT STAFF).

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

Doc. 94

Case 5:06-cv-03926-HRL

Document 94

Filed 08/20/2007

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GILL SPERLEIN (172887) THE LAW FIRM OF GILL SPERLEIN 584 Castro Street, Suite 849 San Francisco, California 94114 Telephone: [phone] X32 Facsimile: [phone] [e-mail] Attorney for Plaintiff IO GROUP, INC.

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) DECLARATION OF KEITH RUOFF IN SUPPORT OF PLAINTIFF'S MOTION FOR ADMINISTRATIVE RELIEF IN THE FORM OF AN ORDER TO FILE DOCUMENTS UNDER SEAL

I, KEITH RUOFF, declare:

1. I am Vice President of Plaintiff, Io Group, Inc. that operates under the trade name of Titan Media and Titan Men. 2. In this matter, Plaintiff produced to Defendant the following documents, all of which I have viewed: a. 200275 - a DVD containing Plaintiff's copyrighted work Boner
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RUOFF DECLARATION IN SUPPORT OF REQUEST TO FILE UNDER SEAL C-06-3926 (HRL)
Dockets.Justia.com

Case 5:06-cv-03926-HRL

Document 94

Filed 08/20/2007

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b. 200276 - a DVD containing Plaintiff's copyrighted work Don't Ask Don't Tell c. 200277 - a DVD containing Plaintiff's copyrighted work Heat d. 200278 - a DVD containing Plaintiff's copyrighted work Island Guardian e. 200279 - a DVD containing Plaintiff's copyrighted work Sea Men f. 200280 - a DVD containing Plaintiff's copyrighted work Detour g. 200281 - a DVD containing Plaintiff's copyrighted work River Patrol h. 200282- a DVD containing files I downloaded from www.Veoh.com, which contain portions of Boner, Don't Ask Don't Tell, Heat, Island Guardian, Sea Men, Detour, and River Patrol i. 200953 - a DVD containing video files that had previously been available on www.veoh.com. Defendant's produced these video files in response to Plaintiff's discovery requests with a confidential classification under the parties Stipulated Protective Order. The files contain portions of Plaintiff's registered works Carny, Laid Up, and First Crush. j. 200954 - a DVD containing Plaintiff's copyrighted work Carny k. 200955 - a DVD containing Plaintiff's copyrighted work Laid Up l. 200956 - a DVD containing Plaintiff's copyrighted work First Crush 3. Each of the above documents contains sexually explicit material that is not appropriate for minors or individuals not wishing to be inadvertently exposed to it. Pursuant to the laws of the United States, I declare under penalty of perjury the foregoing is true and correct.

Dated: August 20, 2007
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/s/ Keith Ruoff Keith Ruoff
RUOFF DECLARATION IN SUPPORT OF REQUEST TO FILE UNDER SEAL C-06-3926 (HRL)

Case 5:06-cv-03926-HRL

Document 94

Filed 08/20/2007

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I hereby attest that this is the declaration of Keith Ruoff and the original with Keith Ruoff's holographic signature is on file for production for the Court if so ordered, or for inspection upon request by any party. Pursuant to the laws of the United States, I declare under penalty of perjury the foregoing is true and correct. Dated: August 20, 2007 /s/ Gill Sperlein GILL SPERLEIN, Counsel for Plaintiff Io Group, Inc.

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RUOFF DECLARATION IN SUPPORT OF REQUEST TO FILE UNDER SEAL C-06-3926 (HRL)