AGENCE FRANCE PRESSE v. GOOGLE INC.

Filing 24

Attachment 3
MOTION for Partial Summary Judgment Dismissing Count II For Lack of Protectable Subject Matter by GOOGLE INC.. (Attachments: # 1 Text of Proposed Order # 2 Exhibit A# 3 Exhibit B)(Bain, Scott)

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AGENCE FRANCE PRESSE v. GOOGLE INC. Doc. 24 Att. 3 Case 1:05-cv-00546-GK Document 24-4 Filed 10/12/2005 Page 1 of 3 EXHIBIT B: Selected Requests For Admissions of Google and AFP's Responses to Same Request No. 156: Standard AFP style requires headlines to be concise. AFP's Response: Admitted. Request No. 157: Standard AFP style requires headlines not to exceed one line on a computer. AFP's Response: Admitted. Request No. 158: AFP's phrase "one line on a computer" means approximately 10 words. AFP's Response: Admitted. Request No. 159: A headline of an AFP Article contains and accurately reflects the same information as the lead paragraph of the corresponding AFP Article. AFP's Response: Admitted. Request No. 160: Standard AFP style requires a headline to contain and accurately reflect the same information as the lead paragraph of the corresponding AFP Article. AFP's Response: Admitted. Request No. 161: Headlines of AFP Articles typically are not "hardened" or "jazzed up" to make them eye catching. AFP's Response: Admitted. Request No. 162: Standard AFP style forbids headlines of AFP Articles to be "hardened" or "jazzed up" to make them eye catching. AFP's Response: Admitted. Request No. 163: Headlines of AFP Articles typically are factual, simple, and contain only one idea. AFP's Response: Admitted. Request No. 164: Standard AFP style requires headlines to be factual, simple and contain only one idea. AFP's Response: Admitted. Request No. 165: Headlines of AFP Articles typically use plain language. AFP's Response: Admitted. Request No. 166: Standard AFP style requires headlines to use plain language. AFP's Response: Admitted. 1 Dockets.Justia.com Case 1:05-cv-00546-GK Document 24-4 Filed 10/12/2005 Page 2 of 3 EXHIBIT B: Selected Requests For Admissions of Google and AFP's Responses to Same Request No. 167: Headlines of AFP Articles typically use the present tense and active verbs. AFP's Response: Admitted. Request No. 168: Standard AFP style requires AFP headlines to use the present tense and active verbs. AFP's Response: Admitted. Request No. 169: The lead paragraphs of AFP Articles typically are clear, short and simple. AFP's Response: Admitted. Request No. 170: Standard AFP style requires the lead paragraphs of AFP Articles to be clear, short and simple. AFP's Response: Admitted. Request No. 171: The lead paragraphs of AFP Articles typically use short, familiar words rather than long or unusual ones. AFP's Response: Admitted. Request No. 172: Standard AFP style requires lead paragraphs of AFP Articles to use familiar words rather than unusual ones. AFP's Response: Admitted. Request No. 173: The lead paragraphs of AFP Articles typically do not exceed 30 words or three lines on a computer screen. AFP's Response: Admitted. Request No. 175: The lead paragraphs of AFP Articles typically answer the questions "who, what, when and where" with respect to the subject of the article. AFP's Response: Admitted. Request No. 176: Standard AFP style is for the lead paragraph to answer the questions "who, what, when and where" with respect to the subject of the article. AFP's Response: Admitted. Request No. 216: AFP policy forbids fanciful headlines. AFP's Response: Admitted. Request No. 217: AFP policy forbids fanciful lead paragraphs. 2 Case 1:05-cv-00546-GK Document 24-4 Filed 10/12/2005 Page 3 of 3 EXHIBIT B: Selected Requests For Admissions of Google and AFP's Responses to Same AFP's Response: Admitted. Request No. 218: Standard AFP style forbids fanciful headlines. AFP's Response: Admitted. Request No. 219: Standard AFP style forbids fanciful lead paragraphs. AFP's Response: Admitted. 3

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