Disney Enterprises, Inc. et al v. Hotfile Corp. et al

Filing 325

NOTICE by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc. re 322 MOTION for Summary Judgment PLAINTIFFS' MOTION AND MEMORANDUM OF LAW IN SUPPORT OF SUMMARY JUDGMENT AGAINST DEFENDANTS HOTFILE CORP. AND ANTON TITOV (PUBLIC REDACTED VERSION) >PLAINTIFFS' NOTICE OF FILING PUBLIC REDACTED VERSIONS OF DECLARATIONS IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT< (Attachments: # 1 Affidavit Declaration of Scott A Zebrak in support of Plaintiff's MSJ (Public Redacted Version), # 2 Exhibit A (Zebrak), # 3 Exhibit B (Zebrak), # 4 Exhibit C (Zebrak), # 5 Exhibit D (Zebrak), # 6 Affidavit Declaration of Dr. Richard Waterman n Support of Plaintiffs' MSJ (Public Redacted Version), # 7 Exhibit A (Waterman), # 8 Exhibit B (Waterman), # 9 Exhibit C (Waterman), # 10 Exhibit D (Waterman), # 11 Exhibit E (Waterman), # 12 Affidavit Declaration of Thomas Sehested in Support of Plaintiffs' MSJ (Public Redacted Version), # 13 Exhibit A (Sehested), # 14 Exhibit B (Sehested), # 15 Affidavit Declaration of Steve Thomas Kang in Support of Plaintiffs' MSJ (Public Redacted Version), # 16 Exhibit A (Kang), # 17 Affidavit Declaration of Dr. Ian Foster in Support of plaintiffs' MSJ (Public Redacted Version), # 18 Exhibit A (Foster), # 19 Exhibit B (Foster), # 20 Exhibit C (Foster), # 21 Exhibit D (Foster), # 22 Exhibit E (Foster), # 23 Exhibit F (Foster), # 24 Exhibit G (Foster), # 25 Exhibit H (Foster), # 26 Exhibit I (Foster), # 27 Exhibit J (Foster), # 28 Exhibit K (Foster))(Stetson, Karen)

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EXHIBIT A STEVE KANG EDUCATION 1991-1994 1986-1990 COLUMBIA UNIVERSITY SCHOOL OF LAW New York, New York Juris Doctor, May 1994. Articles editor, Columbia Law Review. Harlan Fiske Stone Scholar. YALE UNIVERSITY Bachelor of Arts, cum laude, May 1990, in English. New Haven, Connecticut EXPERIENCE 2005 – present NBC UNIVERSAL Universal City, California Vice President and Senior Counsel, Anti-Piracy Legal Affairs Cross-disciplinary position responsible for industry litigation, policy, and negotiations relating to protection of NBC Universal content from commercial scale copyright infringement. Report to general counsels of NBC Universal and of Universal Studios and advise domestic and international commercial executives in television and motion picture groups on anti-piracy issues. Supervise five direct reports in U.S., Korea, Japan, and China and liaise with corporate communications, government affairs and technology groups. Selected matters/responsibilities include: • Supervise industry copyright litigation including lawsuits relating to Internet theft in Norht America, South America, Asia and Australia. • Represent company in industry trade association (Motion Picture Association of America) antipiracy strategy and litigation committees. • Develop and implement digital anti-piracy plans for Beijing, Vancouver and London Olympics. • Represented company in IP working group of the U.S.-China Joint Commission on Commerce and Trade and in industry group overseeing U.S. WTO action against China regarding inadequacy of Chinese IPR enforcement and certain market access restrictions. • Supervised successful referrals for criminal prosecution of several Korean “webhard” (filesharing) sites. • Chair the technology and operations subcommittee of anti-piracy coalition of sports leagues and broadcasters including NBA, MLB Advanced Media, NFL, WWE, UFC, Premier League, CBS, Disney/ESPN and others. • Develop policies regarding digital content security for the motion picture group. • Oversee internal investigations of leaks of film/tv entertainment content. 2004 – 2005 UNIVERSAL MUSIC GROUP Santa Monica, California Senior Director, Litigation Counsel. In-house litigator for world's largest music company. Responsible for broad range of matters, including copyright litigation, commercial litigation, and internal and government investigations. Represented company in Recording Industry Association of America working group on industry litigation matters including MGM v. Grokster. Supervised defense of payola investigation brought by then New York Attorney General Eliot Spitzer. 1998 – 2003 IRELL & MANELLA LLP Los Angeles, California Associate Litigation practice with focus on patent, copyright, antitrust and entertainment law. Representative matters include: defending major record company in class action alleging improper accounting of artist royalties; defending international television distributor in copyright infringement class action; defending major personal computer OEM in action alleging patent infringement by all products containing Pentium-class processors; defending Internet-based postage services provider in patent litigation; and advising various clients on patent misuse and antitrust issues arising from intellectual property licenses. 1997 – 1 998 RICHARDS SPEARS KIBBE & ORBE New York, New York Associate Represented individuals in the financial services industries in various regulatory and white collar criminal investigations brought by various U.S. and U.K. agencies including the U.S. Attorney’s Office (SDNY), SEC, CFTC, and U.K. Financial Services Authority. 1995 – 1997 CRAVATH, SWAINE & MOORE New York, New York Associate Litigation associate. Representative matters include working as sole associate in successful defense of multinational scientific equipment company in FTC antitrust investigation; working as sole associate in preparing breach of contract action for trial on behalf of major pharmaceuticals company; various securities class actions and commercial lawsuits. 1994 – 1995 THE HONORABLE JAN E. DUBOIS Philadelphia, Pennsylvania Law clerk Assisted United States district judge in all aspects of civil and criminal case management.

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