Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
420
NOTICE by Hotfile Corp., Anton Titov of Filing PUBLICLY FILED REDACTED Version of the Declaration of Janel Thamkul Filed In Support of Memoranda In Support of Motions for Summary Judgment (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10)(Munn, Janet)
EXHIBIT 6
Highly Confidential
Page 191
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20427-WILLIAMS/TURNOFF
- - - - - - - - - - - - - - - - - - - - - - - - - DISNEY ENTERPRISES,
INC., TWENTIETH CENTURY
FOX FILM CORPORATION,
UNIVERSAL CITY STUDIOS
PRODUCTIONS LLLP,
COLUMBIA PICTURES
INDUSTRIES, INC., and
WARNER BROS.
ENTERTAINMENT, INC.,
Plaintiff,
v.
HOTFILE CORP., ANTON
TITOV, and DOES 1-10,
Defendants.
HOTFILE CORP.,
Counterclaimant,
v.
WARNER BROS ENTERTAINMENT
INC.,
Counterdefendant.
- - - - - - - - - - - - - - - - - - - - - - - - VOLUME II
H I G H L Y C O N F I D E N T I A L
(Pursuant to protective order, the following
transcript has been designated highly confidential)
30(b)(6) DEPOSITION OF ANTON TITOV
Radisson Blu Hotel
Sofia, Bulgaria
Tuesday, December 6, 2011
AT: 9:10 a.m.
Job No: 44175
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1
2
3
A P P E A R A N C E S
ATTORNEY FOR THE PLAINTIFFS:
4
JENNER & BLOCK
BY: STEVEN B. FABRIZIO, ESQ.
1099 New York Avenue, NW
5
Washington, DC
20001
6
7
8
9
10
11
ATTORNEY FOR THE DEFENDANTS HOTFILE CORP.,
AND ANTON TITOV:
FARELLA, BRAUN & MARTEL
BY: RODERICK M. THOMPSON, ESQ.
235 Montgomery Street
San Francisco, California 94104
12
13
14
BOSTON LAW GROUP
VALENTIN GURVITS
825 Beacon Street
Newton Center, MA 02459
15
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Also present:
2
Court reporter:
3
Fiona Farson
TSG Reporting
4
5
6
Videographer:
Simon Rutson
TSG Reporting
7
8
9
Interpreter:
Assist. Prof. Boris Naimushin, Ph.D.
10
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Technical expert:
Kelly Truelove
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I N D E X
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EXAMINATION
3
BY MR. FABRIZZIO (continued)
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MR. THOMPSON:
Objection, asked and answered.
2
A.
3
BY MR. FABRIZIO:
4
Q.
I don't know for a fact.
Have you ever discussed with your other shareholders
5
terminating Warner's access to the special rights
6
holders' account?
7
A.
8
9
I'm not -- I'm not -- can't remember any discussion like
that, absent the presence of my counsel.
Q.
Has Hotfile changed the way it processes notices sent by
10
Warner through the SRA account since the filing of its
11
counterclaim against Warner?
12
MR. THOMPSON:
Objection, vague.
13
A.
14
BY MR. FABRIZIO:
15
Q.
I'm not aware of any change.
For instance, does Hotfile now manually review files
16
noticed by Warner through the special rights holder's
17
account to see if the files are -- appear to be
18
accurate?
19
A.
20
I'm not aware of any reviews, and to my best knowledge,
the Warner's account still works instantly.
21
(Reporter clarification)
22
BY MR. FABRIZIO:
23
Q.
24
25
Why is Hotfile not engaging in a higher-level review of
notices sent through the Warner SRA account?
MR. THOMPSON:
Objection.
Vague, and asked and answered.
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1
all files from a list page, Hotfile understood that in
2
doing so, it might be deleting files that were not
3
infringing as well; isn't that correct?
4
MR. THOMPSON:
5
A.
6
Objection, asked and answered.
I don't know I can say for a fact what was Hotfile
understanding back then.
7
BY MR. FABRIZIO:
8
Q.
9
What about right now?
Do you understand that when
Hotfile deletes all the files on a list page, that
10
Hotfile may be deleting files that are not infringing as
11
well?
12
A.
Yes, I understand that.
13
Q.
And is Hotfile going to continue its practice of
14
deleting all files on a list page?
15
MR. THOMPSON:
16
A.
Objection, vague.
I can't speak about future decisions of Hotfile by
17
myself.
18
BY MR. FABRIZIO:
19
Q.
20
21
about changing this practice?
A.
22
23
24
25
Are you planning on talking to your other shareholders
Just right now, as I sit here, I have other things to
think of.
Q.
I can't say.
Do you understand the concept or the term "false
positive"?
MR. THOMPSON:
Objection, vague.
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1
A.
2
3
a compatible statement was there since the beginning.
Q.
4
5
A comparable statement?
What do you consider
a comparable statement?
A.
6
7
I don't know for a fact, but it's my belief that
A statement that will carry all -- carry on the same
substance, I guess.
Q.
Right.
Currently, today, in its IP policy page, Hotfile
8
informs users that it has a policy to terminate repeat
9
infringing users, correct?
10
A.
I believe so.
11
Q.
Okay.
12
And when did that IP policy page first appear on
Hotfile?
13
A.
I think approximately May or June 2010.
14
Q.
Okay.
And before May or June of 2010, where did --
15
where on its website did Hotfile inform users of
16
a policy to terminate repeat infringers?
17
A.
In terms of service, I think.
18
MR. FABRIZIO:
Okay.
I'm asking the court reporter to mark
19
as Titov exhibit 31 a printout from Hotfile terms of
20
service.
21
Q.
This is printed from archive.org.
And you will undoubtedly recognize from convention,
22
Mr. Titov, that this reflects an archive.org capture as
23
of February 2010.
24
25
(Titov exhibit 31 marked for identification.)
BY MR. FABRIZIO:
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BY MR. FABRIZIO:
4
Q.
5
Do you want to take a quick break now, or do you want to
go on for a little bit?
6
A.
A quick break would be nice.
7
MR. FABRIZIO:
Let's take a quick break.
8
VIDEOGRAPHER:
Off the record at 3:53.
9
(A break was taken.)
10
VIDEOGRAPHER:
Back on the record, 4:04.
11
BY MR. FABRIZIO:
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9
Q.
10
Currently -- just wait one second; I kind of feel like
it's dial-an-expert.
It's kind of like he's here.
11
MR. THOMPSON:
We can't hear what he's saying, though.
12
MR. FABRIZIO:
You can't hear what he's saying; I can.
13
I feel like a newscaster.
14
MR. THOMPSON:
15
BY MR. FABRIZIO:
16
Q.
17
Okay.
That's right.
Maybe a puppet, huh?
Sorry, my editor was talking.
Currently, Hotfile receives DMCA notices by regular
18
mail, correct?
19
A.
Correct.
20
Q.
By facsimile, correct?
21
A.
Correct.
22
Q.
By email, correct?
23
A.
Correct.
24
Q.
And by special rights holder account, correct?
25
A.
Correct.
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Page 371
HIGHLY CONFIDENTIAL
CERTIFICATE OF DEPONENT
1
2
3
4
5
6
I, ANTON TITOV, hereby certify that I have read the
foregoing pages of my deposition of testimony taken in these
proceedings on Tuesday, December 6, 2011, and, with the
exception of the changes listed on the next page and/or
corrections, if any, find them to be a true and accurate
transcription thereof.
7
8
//
9
10
Signed:
11
Name:
12
Date:
······fC···········
ANTON TITOV
..f!.~ qpl1-l'(~ .. ....... .
13
14
15
16
18
19
20
21
22
23
24
25
..
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HIGHLY CONFIDENTIAL
1
2
ERRATA
3
Deposition of ANTON TITOV
4
Page/Line No.
Description
Reason for change
5
6
225:25
Remind me.
7
234:20
Presentation
8
234:20
cost of the
9
261:2
-->
There might be.
-->
representation
Correct transcription
Correct transcription!
;
-->
concept of
Correct transcription
I
'{
As --> That's
Correct transcriPtionl
j
j
10
273:20
11
279:3
is --> would
Correct transcription
I
12
293:11
following --> logging
Correct transcription
J.
13
306:5
calls --> holds
Correct transcriPtion!
14
306:6
15
321:6
Correct transcriptionl
j
't
service at hotfile.com
would decide it
-->
~
~
I
to abuse@hotfile.com Correct tra ls.
~
with this ID
Correct transcription
-->
i
·transcription I
1
~~
16
333:20
brought --> blocked
Correct
17
337:7
file --> file ID
Correct transcription~
18
Signed:
19
Name:
20
Date:
1
if
I
!
ANTON TITOV
ij
~
21
22
23
TSG Reporting - Worldwide
(877)
702-9580
t·
Highly Confidential
Page 373
,HIGHLY CONFIDENTIAL
1
2
ERRATA
3
Deposition of ANTON TITOV
4
Reason for change
Description
Page/Line No.
5
6
361:25
7
368:7
state
-->
Correct transcription
table
users stay on our uploads
-->
users_cowner_up1oad
8
9
10
11
12
13
14
15
;1/
16
17
18
Signed:
19
Name:
20
Date:
...... f.. ...... .
ANTON TITOV
.f!~'p!?? <~ ...... .
21
22
23
24
25
TSG Reporting - Worldwide
(877)
702-9580
Correct tlt-ans
Highly Confidential
Page 372
1
HIGHLY CONFIDENTIAL
CERTIFICATE OF COURT REPORTER
2
3
4
5
6
I, Fiona Farson, with TSG Reporting, hereby certify that the
testimony of the witness Anton Titov in the foregoing
transcript, taken on Tuesday, December 6, 2011 was reported
by me in machine shorthand and was thereafter transcribed by
me; and that the foregoing transcript is a true and accurate
verbatim record of the said testimony.
7
8
9
I further certify that I am not a relative, employee,
counsel or financially involved with any of the parties to
the within cause, nor am I an employee or relative of any
counsel for the parties, nor am I in any way interested in
the outcome of the within cause.
10
11
12
13
14
Signed:
........................
15
Fiona Farson
16
Dated: 12/17/2011
17
18
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20
21
22
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24
25
TSG Reporting - Worldwide
(877) 702-9580
H I G H L Y
C O N F I D E N T I A L
Page 374
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20427-WILLIAMS/TURNOFF
- - - - - - - - - - - - - - - - - - - - - - - - - DISNEY ENTERPRISES,
INC., TWENTIETH CENTURY
FOX FILM CORPORATION,
UNIVERSAL CITY STUDIOS
PRODUCTIONS LLLP,
COLUMBIA PICTURES
INDUSTRIES, INC., and
WARNER BROS.
ENTERTAINMENT, INC.,
Plaintiff,
v.
HOTFILE CORP., ANTON
TITOV, and DOES 1-10,
Defendants.
HOTFILE CORP.,
Counterclaimant,
v.
WARNER BROS ENTERTAINMENT
INC.,
Counterdefendant.
- - - - - - - - - - - - - - - - - - - - - - - - VOLUME III
H I G H L Y C O N F I D E N T I A L
(Pursuant to protective order, the following
transcript has been designated highly confidential)
30(b)(6) DEPOSITION OF ANTON TITOV
Radisson Blu Hotel
Sofia, Bulgaria
Wednesday, December 7, 2011
AT: 9:09 a.m.
Job # 44429
TSG Reporting - Worldwide
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C O N F I D E N T I A L
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1
2
3
4
A P P E A R A N C E S
ATTORNEY FOR THE PLAINTIFFS:
JENNER & BLOCK, LLP
BY: STEVEN FABRIZIO, ESQ.
1099 New York Avenue, NW
Washington, DC 20001
5
6
7
8
9
10
ATTORNEY FOR THE DEFENDANTS HOTFILE CORP.,
AND ANTON TITOV:
FARELLA, BRAUN & MARTEL, LLP
BY: RODERICK THOMPSON, ESQ.
235 Montgomery Street
San Francisco, California 94104
11
12
13
BOSTON LAW GROUP
BY: VALENTIN GURVITS
825 Beacon Street
Newton Center, MA 02459
14
15
16
17
18
19
20
21
22
23
24
25
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1
Also present:
2
Court reporter:
3
Fiona Farson
TSG Reporting
4
5
6
Videographer:
Simon Rutson
TSG Reporting
7
8
9
10
Interpreter:
Assist. Prof. Boris Naimushin, Ph.D.
Elena Alexieva
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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Page 506
I'll just look around.
6
7
MR. FABRIZIO:
Okay.
Why don't we take that break.
8
VIDEOGRAPHER:
Off the record, 3:57.
(A break was taken.)
9
10
VIDEOGRAPHER:
Back on the record, 4:13.
11
BY MR. FABRIZIO:
12
Q.
Has Hotfile implemented some form of copyright filtering
since the institution of this lawsuit?
13
14
A.
Ask you asking about overall?
15
Q.
Well, I was asking any form of copyright filtering.
16
A.
Do you consider this?
17
Q.
Yeah, I do consider it -- well, let me put it this way;
18
since the institution of this lawsuit, has Hotfile
19
implemented any form of content identification
20
technology?
21
A.
Yes, we started using Vobile.
22
Q.
Anything else?
23
A.
No, I don't think so.
24
Q.
Okay.
25
MR. THOMPSON:
And for the record, what is Vobile?
Objection, vague.
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1
A.
Vobile is a company that will provide technology for
2
fingerprinting, taking fingerprints from videos --
3
videos, and they -- then they have service for
4
presenting these fingerprints to them, and they will
5
respond if this video matches any video in their
6
database.
7
BY MR. FABRIZIO:
8
Q.
And when they respond, because a finger -- they have
9
a fingerprint match, do they provide information about
10
the copyright owner and instructions from a copyright
11
owner with regard to a particular file?
12
MR. THOMPSON:
13
A.
Objection, compound and vague.
I know for sure that they provide the copyright owner,
but I'm not sure about the instructions.
14
15
BY MR. FABRIZIO:
16
Q.
Okay.
Well, let me put it this way, if there's a -- if
17
upon submission of a fingerprint to Vobile there's
18
a fingerprint match, Vobile sends information back to
19
you?
20
A.
It's more like we are supposed to connect and to check
21
if the submission is processed, but basically that's the
22
idea.
23
Q.
Okay.
And when Hotfile connects in to check, what
24
information does Vobile make available to Hotfile about
25
the file that it was checking?
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1
A.
It would be an XML file that will either say that there
2
is no match, or a response that will indicate
3
a copyrighted work name, maybe the producer of the
4
copyrighted work, and I believe the offset in the video
5
where the fingerprint starts the partial match.
6
Q.
Does -- anything else?
7
A.
That is what I can think of.
8
Q.
Does the Vobile data indicate whether the file should be
allowed for distribution or blocked?
9
10
A.
Since you are mentioning a certain time, I assume that
it does, but I don't have clear memory of it doing so.
11
12
Q.
Okay.
13
MR. THOMPSON:
Again, Mr. Titov, I know Mr. Fabrizio knows
14
a lot about this, but you should just testify to what
15
you know.
16
MR. FABRIZIO:
17
BY MR. FABRIZIO:
18
Q.
Don't give me too much credit.
Did Hotfile consider using -- well, strike that.
If I refer to Vobile's technology as "video
19
20
fingerprinting technology," will you understand what I'm
21
referring to?
22
A.
Yes, I will.
23
Q.
Is that how you refer to it as well?
24
A.
Let's say yes.
25
Q.
Okay.
Did Hotfile consider using video fingerprinting
TSG Reporting - Worldwide
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Page 509
technology prior to the institution of this lawsuit?
1
2
MR. THOMPSON:
Objection, vague.
3
A.
4
BY MR. FABRIZIO:
5
Q.
No, I don't think so.
Did you have any discussions with your co-shareholders
about using any form of video fingerprinting?
6
7
A.
I don't recall any such discussion.
8
Q.
And, again, I'm talking about video fingerprinting
9
technology, whether it's offered by Vobile or some other
10
supplier, or even developed on your own, I'm speaking of
11
the technology itself; do you understand that?
12
A.
Yes, I understand that.
13
Q.
So, with that clarification, did Hotfile consider
14
deploying video fingerprinting technology in its system
15
prior to the institution of this litigation?
16
A.
I don't remember any such discussion.
17
Q.
Did Hotfile consider using any form of content
18
recognition technology in order to prevent copyrighted
19
content from being uploaded to Hotfile prior to this
20
litigation?
21
MR. THOMPSON:
22
Objection, vague, to some extent asked and
answered.
23
A.
No, I don't remember anything like that.
24
BY MR. FABRIZIO:
25
Q.
Why, after the commencement of this litigation, did
TSG Reporting - Worldwide
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1
Hotfile implement the Vobile video fingerprinting
2
technology?
3
A.
We understood this to be important to the plaintiffs.
4
Q.
Is it the case that Hotfile first approached Vobile only
after the plaintiff group suggested doing so?
5
6
MR. THOMPSON:
Objection, assumes facts.
7
BY MR. FABRIZIO:
8
Q.
Let me strike that and ask it this way; after the
institution of this litigation, Hotfile representatives
9
10
met with representatives of the plaintiff group,
11
correct?
12
A.
Correct.
13
Q.
And the plaintiff group's -- well, strike that.
I'm trying to be respectful of our discussions.
14
15
MR. THOMPSON:
Yeah.
16
BY MR. FABRIZIO:
17
Q.
I don't see how you can go there.
And it's a fact, is it not, that in the complaint the
18
plaintiffs filed in this action, the plaintiffs
19
indicated that Hotfile could and should be using video
20
fingerprint technology to prevent copyright
21
infringement, correct?
22
MR. THOMPSON:
Objection.
23
A.
24
BY MR. FABRIZIO:
25
Q.
The document speaks for itself.
I have some memories of some language saying that.
When did Hotfile first approach Vobile?
TSG Reporting - Worldwide
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C O N F I D E N T I A L
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1
A.
I think it was end of April or May.
2
Q.
2011?
3
A.
Correct.
4
Q.
Did Hotfile research or consider the content
5
identification technologies of any other company other
6
than Vobile?
7
VIDEOGRAPHER:
It's calibrating -- whatever that is.
8
MR. FABRIZIO:
Sorry.
For the record, the printer in the
room started.
9
10
MR. THOMPSON:
Calibrating.
11
MR. GURVITZ:
12
MR. FABRIZIO:
13
BY MR. FABRIZIO:
14
Q.
Calibrating.
Let me repeat the question.
Did Hotfile research or consider the content
15
identification technologies of any other company besides
16
Vobile?
17
A.
other company.
18
19
I don't think Hotfile by itself ever researched any
Q.
Did anyone on behalf of Hotfile research other content
identification technologies?
20
21
A.
I'm not sure, but might be our counsel.
22
Q.
Anyone other than your counsel?
23
A.
No, I don't think so.
24
Q.
Did Hotfile take a license from Vobile for its servers?
25
A.
There is a contract.
I'm not sure if it's licensed.
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1
Q.
Fair enough.
Is there a name for the product or service
of Vobile that Hotfile is using?
2
3
A.
Yes.
4
Q.
What is that name?
5
A.
Mediawise.
(Reporter clarification.)
6
7
MR. FABRIZIO:
8
BY MR. FABRIZIO:
9
Q.
Has Hotfile considered any other products or services
offered by Vobile?
10
11
Yes.
A.
Yes, we've been informed that Cloud 9 had technology
12
that appeared -- that was announced after we started
13
using Mediawise would be more appropriate for a service
14
like Hotfile.
15
Q.
Okay, and is that product V, Cloud 9?
16
A.
Yes, it is.
17
Q.
The number "9."
18
A.
Currently no.
19
Q.
Why not?
20
A.
Mostly developer and especially my time constraint is
Has Hotfile implemented V, Cloud 9?
21
connected in connection with this litigation, there
22
is -- and has been for some time.
23
Q.
24
MR. THOMPSON:
25
A.
I did implement.
Did you personally implement the Mediawise technology?
Objection, vague.
With some help from Vasil Kolev.
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BY MR. FABRIZIO:
2
Q.
Does Hotfile intend to deploy the V, Cloud 9 technology?
3
A.
Yes, it does intend.
4
Q.
And I'm trying to make sure I understand this correctly;
5
the reason why Hotfile has not yet deployed V, Cloud 9
6
relates to your personally being busy with activities
7
related to this litigation?
8
A.
Yes, that's -- that is part of it.
9
Q.
Is there any other part of it?
10
A.
I can't think of any other part.
11
Q.
Has Hotfile done any testing of the performance of the
Mediawise service from Vobile?
12
13
A.
Can you be more specific?
14
Q.
Sure.
Has Hotfile done any analysis of how well Vobile
technology performs?
15
16
A.
Not for Hotfile's own pleasure.
17
Q.
Has Hotfile conducted such an analysis for the pleasure
of anyone else?
18
19
A.
For the counsel.
20
MR. THOMPSON:
Mr. Titov, please don't testify about
anything your counsel asked you to do.
21
22
A.
23
BY MR. FABRIZIO:
24
Q.
25
Okay.
But, just to clarify, did Hotfile, or has Hotfile
conducted analyses of the performance of Vobile
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technology that it considers to be work product in this
2
case?
3
MR. THOMPSON:
4
of work product.
MR. FABRIZIO:
7
Well.
That obviously goes to disclosing it.
I'm not asking what he found out.
I just want to know if there is one.
8
A.
9
MR. FABRIZIO:
10
I instruct him not to answer.
Steve, you can't ask if there is a particular piece
5
6
Objection.
A.
May I end the discussion?
Yes.
Everything that we've got from Vobile as responses and
11
everything was produced in the case, so I think that
12
Kelly can do some research, whatever -- does that make
13
sense?
14
BY MR. FABRIZIO:
15
Q.
Yes, it makes sense, and there's nothing -- there's no
16
analyses that you're withholding from production, is
17
that what you're saying?
18
MR. THOMPSON:
19
A.
20
BY MR. FABRIZIO:
21
Q.
Okay --
22
A.
-- any search analysis that we performed can be
23
If --
We produced the data, not the analysis, but --
performed on this data for any period or any...
24
MR. FABRIZIO:
I understand, okay, so...
25
MR. THOMPSON:
We should make -- just make it clear for the
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1
record, Mr. Fabrizio, I will not allow the witness to
2
answer the question as to what analysis he has performed
3
at the request of his counsel --
4
MR. FABRIZIO:
No, I wasn't asking him --
5
MR. THOMPSON:
-- whether on Vobile or any other subject.
6
MR. FABRIZIO:
I wasn't asking him what analyses he
7
performed.
8
a matter of fact there is something that defendants
9
consider work product.
You would have to disclose that
much in a privilege log.
10
11
I was simply trying to ascertain whether as
MR. THOMPSON:
Well, Mr. Fabrizio, this -- this is our work
12
product, and we're not going to disclose it, period, I'm
13
not going to tell you what it is.
14
MR. FABRIZIO:
15
if it is.
16
MR. THOMPSON:
I'm not asking what it is.
I'm just asking
Well, you're free to ask him any factual
17
information you want which does not disclose work
18
product communications or work product analysis.
19
MR. FABRIZIO:
20
A.
Okay.
I don't think Hotfile ever created documents as part of
this analysis.
21
22
MR. THOMPSON:
23
BY MR. FABRIZIO:
24
Q.
25
Okay.
That does help.
When did Hotfile begin using the Vobile Mediawise
technology on the live Hotfile site?
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10
Q.
Have you formed a personal opinion as to the
11
effectiveness of the Vobile technology in identifying
12
copyrighted video content?
13
MR. THOMPSON:
Objection, calls for opinion.
You can
answer.
14
15
A.
No, I don't think I did.
16
BY MR. FABRIZIO:
17
Q.
Either way -- well, strike that.
18
Have you formed an opinion -- well, strike that.
19
Have you personally given any consideration to
20
whether the Vobile technology is effective in
21
identifying copyrighted video content?
22
A.
No, I don't think so.
23
Q.
Has Hotfile been receiving fewer DMCA notices from video
24
content owners since it began using the Vobile
25
technology?
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Page 553
HIGHLY CONFIDENTIAL
CERTIFICATE OF COURT REPORTER
1
2
3
4
5
6
I, Fiona Farson, with TSG Reporting, hereby certify that the
testimony of the witness Anton Titov in the foregoing
transcript, taken on Wednesday, December 7, 2011 was
reported by me in machine shorthand and was thereafter
transcribed by me; and that the foregoing transcript is a
true and accurate verbatim record of the said testimony.
7
8
9
I further certify that I am not a relative, employee,
counsel or financially involved with any of the parties to
the within cause, nor am I an employee or relative of any
counsel for the parties, nor am I in any way interested in
the outcome of the within cause.
10
11
12
13
14
Signed: _____________________
15
Fiona Farson
16
Dated: 12-19-2011
17
18
19
20
21
22
23
24
25
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Page 552
HIGHLY CONFIDENTIAL
CERTIFICATE OF DEPONENT
1
2
3
4
5
6
I, ANTON TITOV, hereby certify that I have read the
foregoing pages of my deposition of testimony taken in these
proceedings on Wednesday, December 7, 2011, and, with the
exception of the changes listed on the next page and/or
corrections, if any, find them to be a true and accurate
transcription thereof.
7
8
9
10
Signed:
11
Name:
12
Date:
ANTON TITOV
/O(J /itJ/J-
13
14
15
16
17
18
19
20
21
22
23
24
25
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Page 554
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HIGHLY CONFIDENTIAL
2
NAME OF CASE: Disney' Enterprises Inc. v. Hotfile Corp.
3
DATE OF DEPOSITION: 12-7-2011
4
NAME OF WITNESS: ANTON TITOV
5
Reason Codes:
6
1.
To clarify the record.
7
2.
To conform to the facts.
3.
8
To correct transcription errors.
Page
396
10
From
no
11
Page
402
12
From
Googles
13
Page
402
14
From
Googles
15
Page
418
16
From
17
Page
439
18
From
Lucyan
19
Page
458
20
From
onl:x:: the
21
Page
Line
Reason
19
483
3
to upload down the file from
From
to will pull down the file from
22
Line
16
9
Reason
3
to
to
Line
Line
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13
to
15
Reason
to
5
user field field
Line
Reason
24
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5
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to
3
cookies
3
cookies
3
user inQut field
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5
only if the
23
24
25
ANTON TITOV
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HIGHLY CONFIDENTIAL
2
NAME OF CASE: Disney Enterprises Inc. v. Hotfile Corp.
3
DATE OF DEPOSITION: 12-7-2011
4
NAME OF WITNESS: ANTON TITOV
5
Reason Codes:
6
1.
To clarify the record.
7
2.
To conform to·the facts.
To correct transcription errors.
3.
8
436
9
Page
Line
10
From
11
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12
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13
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14
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15
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16
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17
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18
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23
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23
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24
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TSG Reporting - Worldwide
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