Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
449
NOTICE by Hotfile Corp., Anton Titov Defendants' Notice of Filing the Publicly Filed Version of the Declaration of Andrew Leibnitz and Exhibits Thereto Filed In Support of Defendants' Opposition to Plaintiffs' Motion to Strike Portions of Boyle, Cromarty and Titov Declaration (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, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16)(Munn, Janet)
Exhibit 7
From:
Sent:
To:
Subject:
Pozza, Duane [DPozza@jenner.com]
Thursday, June 23, 2011 8:56 AM
Leibnitz, Andrew (21) x4932; Schoenberg, Tony (28) x4963
Plaintiffs' discovery requests - follow-up to Tuesday call
Andy, Tony,
Following up on our Tuesday call, here are suggested reports to run for Google Analytics, in order to satisfy the portion
of Request No. 19 for data generated from Google Analytics.
Visitors > Visitor Trending > Absolute Unique Visitors
Traffic Sources > Overview
Traffic Sources > Referring Sites
Traffic Sources > Keywords
Content > Content by Title
We would request each report as a PDF and, where available, CSV for Excel, both generated using the "Export" function
provided by Google Analytics. The report would be run for any available data from February 2009 to now.
Regarding Request No. 28, I urge you to reconsider your position on our call that the Stored Communications Act would
bar disclosure of content files uploaded to or downloaded from Hotfile, if the copies were retrieved from the individuals
rather than from the location to which they are uploaded on Hotfile’s servers. We disagree that the SCA bars disclosure
of content files on Hotfile’s servers, as we have discussed. But even accepting your argument, copies of those files
maintained by employees are plainly not “carried or maintained on that [remote computing] service” under the
conditions in 18 U.S.C. 2702(a)(2)(A)‐(B). Your response to Request No. 28 also does not indicate you are withholding
uploaded files, and it contains no privacy objection as to downloaded files.
For our call today set for 1 pm Pacific, I am not in the office and will need to call in, so please let me know what number
to call. Also, I can still talk at that time, but it would be helpful for me to move it earlier to 12 noon Pacific if that would
work for you. Please let me know if so. Otherwise I will speak to you at 1:00.
Thanks,
Duane
Duane Pozza
Jenner & Block LLP
1099 New York Avenue, N.W.
Suite 900
Washington, DC 20001-4412
Tel (202) 639-6027
Fax (202) 661-4962
DPozza@jenner.com
www.jenner.com
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