AGENCE FRANCE PRESSE v. GOOGLE INC.

Filing 28

Memorandum in opposition to motion re 24 Partial Summary Judgment, Count II filed by AGENCE FRANCE PRESSE. (Attachments: # 1 Affidavit Declaration of Gilles Tarot# 2 Text of Proposed Order Proposed Order)(Saunders, Mary)

AGENCE FRANCE PRESSE v. GOOGLE INC.

Doc. 28 Att. 1

Case 1:05-cv-00546-GK

Document 28-2

Filed 10/26/2005

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Agence France Presse, 1015 15th St NW, Washington, DC 20005 Plaintiff, v. Google Inc., a California Corporation, 1600 Amphitheatre Pkwy, Mountain View, CA 94043 Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO.: 1:05CV00546 (GK) Next Due Date: March 21, 2006 (Status Conference)

DECLARATION OF GILLES TAROT IN SUPPORT OF AGENCE FRANCE-PRESSE'S OPPOSITION TO GOOGLE, INC.'S MOTION FOR PARTIAL SUMMARY JUDGMENT Comes now Declaring, Gilles Tarot and based on personal knowledge declares as follows: 1. I am the Director of Sales & Marketing for North America for Agence France Presse. 2. That Agence France Presse commercially licenses it headlines, as a stand-alone product, to third parties for use in their respective product offerings. 3. That the following selections of headline were created by AFP and were offered to subscribers as part of it news service on the dates and times indicated: "Ur dumped" -- research shows text a popular way of ending romances 10/14/2005 03:59 GMT A millionaire hitchhiker's guide to the galaxy 10/12/2005 16:28 GMT Now showing: `Star Wars' under the stars, as US drive-ins cling to life 10/12/2005 12:06 GMT Tarot Declaration in Support of AFP Opposition to Google Partial SJ Motion Page 1 of 3
Dockets.Justia.com

Case 1:05-cv-00546-GK

Document 28-2

Filed 10/26/2005

Page 2 of 3

Philadelphia to become City of Brotherly Wi-Fi 10/05/2005 20:36 GMT Robot dog keeps over-eaters on tight leash 08/31/2005 18:00 GMT Pop goes soda in US schools in victory for health campaign 08/18/2005 21:24 GMT Money can buy happiness, but it's fleeting: new research 08/15/2005 15:01 GMT Chocolate, naughty, nice and good for you? 07/09/2005 GMT `E.T. blog home': US firm to send Internet diaries into space 07/19/2005 14:16 GMT Poor-fitting bras leave Australian women feeling like boobs 07/12/2005 03:34 GMT A goat? How kind! British charity unwraps unorthodox gift service 05/12/2005 11:27 GMT Coming soon: Colonel Kadhafi: the opera 01/13/2005 15:42 GMT Fat, sluggish but he east his greens: the remarried man 12/31/2004 13:07 GMT Ready, steady, wrap! 12/05/2004 08:42 GMT Pizzle fizzle wilts New Zealand trade with China 10/03/2004 09:07 GMT Springsteen plays political born-again in the USA 10/02/2004 05:55 GMT Pebbles, clams and razors; the hottest phones around 02/18/2005 01:45 GMT French modern Bo-peeps flock to shepherds' school 02/26/2005 13:10 GMT

Tarot Declaration in Support of AFP Opposition to Google Partial SJ Motion Page 2 of 3

Case 1:05-cv-00546-GK

Document 28-2

Filed 10/26/2005

Page 3 of 3

Raunchy return to roost for New York hawks 02/17/2005 15:15 GMT I declare under the penalties of perjury that the statements made herein are true and correct to the best of my personal knowledge.

__________________________ Gilles Tarot, Sales & Marketing Director for North America for Agence France-Presse

Tarot Declaration in Support of AFP Opposition to Google Partial SJ Motion Page 3 of 3