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)

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.