Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
426
NOTICE by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc. re 425 Reply to Response to Motion,, >>PLAINTIFFS' NOTICE OF FILING PUBLIC REDACTED VERSIONS OF REPLY DECLARATIONS IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT<< (Attachments: # 1 Affidavit Reply Dweclaration of Jennifer V. Yeh in Support of Plaintiffs' Motion for Summary Judgment (public redacted version), # 2 Exhibit 151 to Declaration of J. Yeh, # 3 Exhibit 152 to declaration of J. Yeh, # 4 Exhibit 153 to Declaration of J. Yeh, # 5 Exhibit 154 to declaration of J. Yeh, # 6 Exhibit 155 to Declaration of J. Yeh, # 7 Exhibit 156 to declaration of J. Yeh, # 8 Affidavit Reply Declaration of Dr. Ian Foster in Support of Plaintiffs' Motion for Summary Judgment (public redacted version), # 9 Exhibit A to Declaration of I. Foster, # 10 Exhibit B to Declaration of I. Foster, # 11 Affidavit Reply Declaration of Dr. Richard Waterman in Support of Plaintiffs' MSJ (public redacted version))(Stetson, Karen)
Yeh Exhibit 153
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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 IV
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
Thursday, December 8, 2011
Job #44430
AT: 9:10 a.m.
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A P P E A R A N C E S
ATTORNEY FOR THE PLAINTIFFS:
JENNER & BLOCK
BY: STEVEN FABRIZIO, ESQ.
1099 New York Avenue, NW
Washington, DC 20001
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ATTORNEY FOR THE DEFENDANTS HOTFILE CORP.,
AND ANTON TITOV:
FARELLA, BRAUN & MARTEL
BY: RODERICK THOMPSON, ESQ.
235 Montgomery Street
San Francisco, CA 94104
BOSTON LAW GROUP
By: VALENTIN GURVITS, ESQ.
825 Beacon Street
Newton Center, MA 02459
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Also present:
Court reporter:
Fiona Farson
TSG Reporting
Videographer:
Simon Rutson
TSG Reporting
Interpreter:
Assist. Prof. Boris Naimushin, Ph.D.
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downloading behaviors of the users from these
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54 countries are any different than the downloading
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behaviors of the users from the countries that are not
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on this list of 54?
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MR. THOMPSON:
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Objection, calls for speculation, lacks
foundation.
A.
Again, as I said before, obviously Hotfile thinks that
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these users are more -- users from these countries are
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more likely to obtain a premium account.
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BY MR. FABRIZIO:
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Q.
Does Hotfile believe that users from countries on the
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list of 54 are likely to download different files than
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users from countries that are not on the list of 54?
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MR. THOMPSON:
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A.
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BY MR. FABRIZIO:
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Q.
Objection, vague and ambiguous and overbroad.
I don't know.
Do you have any reason to believe that users from
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countries on the list of 54 download different files
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than uses from countries that are not on the list of 54?
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MR. THOMPSON:
Same objection.
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Q.
Are you aware of any factor or consideration that would
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lead you to believe that the downloading patterns of
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users from countries on the list of 54 are different
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from the downloading patterns of users from countries
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that are not on the list of 54?
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MR. THOMPSON:
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A.
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BY MR. FABRIZIO:
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Q.
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Same objection.
I can't think of anything.
Have the list of 54 -- well, have the same 54 countries
been on this list since the beginning of Hotfile?
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A.
No, I don't think so.
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Q.
So the list has changed over time?
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A.
Yes, I think so.
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Q.
How has the list changed?
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A.
I think that countries has been added -- added.
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Q.
Which countries have been added?
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A.
I don't know the full history of the list.
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Q.
Okay.
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Can you describe for us how the site operator's
affiliate program operates?
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MR. THOMPSON:
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answered.
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A.
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Objection, overbroad, also asked and
It is a program where site owners would get commission
of the sales, the users referred to by their website.
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BY MR. FABRIZIO:
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Q.
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CERTIFICATE OF COURT REPORTER
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I, Fiona Farson, with TSG Reporting, hereby certify that the
testimony of the witness Anton Titov in the foregoing
transcript, taken on Thursday, December 8, 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.
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.
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Signed:
........................
Fiona Farson
Dated: 12-20-2011
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TSG Reporting - Worldwide
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