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

Filing 446

NOTICE by Hotfile Corp., Anton Titov Defendants' Notice of Filing the Publicly Filed Version of Defendants' Memorandum of Law In Opposition to Plaintiffs' Motion to Strike Portions of Boyle, Cromarty and Titov Declarations (Attachments: # 1 Exhibit A)(Munn, Janet)

EXHIBIT A

PUBLIC VERSION
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-CIV-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.,
Plaintiffs,
v.
HOTFILE CORP., ANTON TITOV, and
DOES 1-10.
Defendants.
/
HOTFILE CORP.,
Counterclaimant,
v.
WARNER BROS. ENTERTAINMENT INC.,
Counter-Defendant.

/

MEMORANDUM OF LAW OF DEFENDANTS HOTFILE
CORPORATION AND ANTON TITOV IN OPPOSITION TO
PLAINTIFFS’ MOTION TO STRIKE PORTIONS OF
BOYLE, CROMARTY, AND TITOV DECLARATIONS

26501\3005566.5

FILED UNDER SEAL

CASE NO.: 11-CIV-20427-WILLIAMS/TURNOFF
CITATION LEGEND

1.

“PSUF” shall refer to specific paragraph numbers of Plaintiffs’ Statement of

Uncontroverted Facts.
2.

“DSUF” shall refer to specific paragraph numbers of Statement of Undisputed

Material Facts In Support of Motion of Defendants Hotfile Corporation for Partial Summary
Judgment Based on the Digital Millennium Copyright Act Safe Harbor.
3.

“TSUF” shall refer to specific paragraph numbers of Statement of Undisputed

Material Facts In Support of Motion of Anton Titov’s Motion for Summary Judgment.
4.

“DRSF” shall refer to specific paragraph numbers of the Statement of Facts of

Defendants Hotfile Corporation and Anton Titov In Opposition to Plaintiffs’ Statement of
Uncontroverted Facts and Defendants’ Statement of Additional Material Facts.
5.

“Foster Decl.” shall refer to the declaration of Dr. Ian Foster in support of

Plaintiffs’ Motion for Summary Judgment Against Defendants Hotfile Corp. and Anton Titov,
dated February 17, 2012.
6.

“Zebrak Decl.” shall refere to the declaration of Scott Zebrak Foster in support of

Plaintiffs’ Motion for Summary Judgment Against Defendants Hotfile Corp. and Anton Titov,
dated February 17, 2012.
7.

“Yeh Decl.” shall refer to the declaration of Jennifer V. Yeh in support of

Plaintiffs’ Motion for Summary Judgment Against Defendants Hotfile Corp. and Anton Titov,
dated February 17, 2012.
8.

“Titov Decl.” shall refer to the declaration of Anton Titov in support of

Defendants’ Motion for Summary Judgment.
9.

“Titov Opp. Decl.” shall refer to the declaration of Anton Titov in support of

Defendants’ Opposition to Plaintiffs’ Motion for Summary Judgment.
10.

“Leibnitz Decl.” shall refer to the declaration of Andrew Leibnitz in support of

Defendants’ Opposition to Plaintiffs’ Motion to Strike Portions of Boyle, Cromarty, and Titov
Declarations.
11.

“Gupta Decl.” shall refer to the declaration of Deepak Gupta in support of

Defendants’ Motion for Summary Judgment.

-i-

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