Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
450
RESPONSE in Opposition re 371 MOTION to Strike Defendants' Motion and Memorandum of Law to Strike the Declaration of Jennifer V. Yeh Filed in Support of Plaintiffs' Opposition to Defendant Anton Titov's Motion for Summary Judgment and to Defendant Hotfile Corp. >PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS HOTFILE CORPORATION AND ANTON TITOV'S SECOND MOTION TO STRIKE THE DECLARATION OF JENNIFER V. YEH (PUBLIC REDACTED VERSION)< filed by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc.. (Attachments: # 1 Affidavit Declaration of Jennifer V. Yeh in Support of Plaintiffs' Opposition to Defendants' Second Motion to Strike the Declaration of Jennifer V. Yeh (Public Redacted Version), # 2 Exhibit A to Declaration of J. Yeh, # 3 Exhibit B to Declaration of J. Yeh, # 4 Exhibit C to Declaration of J. Yeh, # 5 Exhibit D to Declaration of J. Yeh, # 6 Exhibit E to declaration of J. Yeh, # 7 Exhibit F to Declaration of J. Yeh, # 8 Exhibit G to Declaration of J. Yeh, # 9 Exhibit H to Declaration of J. Yeh, # 10 Exhibit I to Declaration of J. Yeh, # 11 Exhibit J to Declaration of J. Yeh, # 12 Exhibit K to Declaration of J. Yeh, # 13 Exhibit L to Declaration of J. Yeh)(Stetson, Karen)
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EXHIBIT A
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
DISNEY ENTERPRISES, INC.,
TWENTIETH CENTURY FOX FILM
CORPORATION, UNIVERSAL CITY
STUDIOS PRODUCTIONS LLLP,
COLUMBIA PICTURES INDUSTRIES,
INC., and WARNER BROS.
ENTERTAINMENT INC.,
vs.
Plaintiffs,
CASE NO. 11-20427-WILLIAMS-TURNOFF
HOTFILE CORP., ANTON TITOV,
and DOES 1-10,
Defendants.
__________________________
AND RELATED CROSS-ACTION.
_______________________________________________________
HIGHLY CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
VIDEOTAPED DEPOSITION OF LANCE R. GRIFFIN, ESQUIRE
PURSUANT TO FEDERAL RULE 30(b)(6)
Los Angeles, California
Thursday, December 22, 2011
Reported by:
LORI SCINTA, RPR
CSR No. 4811
Job No. 178940
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF FLORIDA
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12/22/2011
DISNEY ENTERPRISES, INC.,
TWENTIETH CENTURY FOX FILM
CORPORATION, UNIVERSAL CITY
STUDIOS PRODUCTIONS LLLP,
COLUMBIA PICTURES INDUSTRIES,
INC., and WARNER BROS.
ENTERTAINMENT INC.,
vs.
Plaintiffs,
CASE NO. 11-20427-WILLIAMS-TURNOFF
HOTFILE CORP., ANTON TITOV,
and DOES 1-10,
Defendants.
__________________________
AND RELATED CROSS-ACTION.
______________________________________________________
HIGHLY CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
Videotaped deposition of LANCE R. GRIFFIN,
ESQUIRE, pursuant to Federal Rule 30(b)(6), taken on
behalf of Defendants and Counterclaimant Hotfile Corp.,
at 633 West Fifth Street, Suite 3600, Los Angeles,
California, beginning at 9:47 A.M. and ending at
4:49 P.M. on Thursday, December 22, 2011, before
LORI SCINTA, RPR, Certified Shorthand Reporter No. 4811.
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LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
1
APPEARANCES:
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12/22/2011
For Plaintiffs:
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JENNER & BLOCK LLP
BY: STEVEN B. FABRIZIO
Attorney at Law
1099 New York Avenue, NW, Suite 900
Washington, D.C. 20001-4412
202.639.6000
Email: sfabrizio@jenner.com
-- and -THE WALT DISNEY COMPANY
BY: GORDON GOLDSMITH
Attorney at Law
500 South Buena Vista Street
Burbank, California 91521-0641
818.560.7893
For Defendants and Counterclaimant Hotfile Corp.:
FARELLA BRAUN + MARTEL LLP
BY: ANTHONY SCHOENBERG
Attorney at Law
235 Montgomery Street
San Francisco, California 94104
415.954.4400
Email: tschoenberg@fbm.com
Videographer:
VONYARN MASON
SARNOFF COURT REPORTERS
20 Corporate Park, Suite 350
Irvine, California 92606
877.955.3855
3
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
BY MR. SCHOENBERG:
10:17
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10:17
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notice and takedown program at Walt Disney Company,
10:18
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correct?
10:18
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A
Yes.
10:18
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Q
Can you describe that program to me.
10:18
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10:18
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responsibilities and supervising?
10:18
9
MR. SCHOENBERG:
10:18
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10:18
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10:18
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THE WITNESS:
10:18
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It involves the finding and verification of
10:18
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content and sending notices on that content.
10:18
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BY MR. SCHOENBERG:
10:18
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Q
And when you say "notices," what do you mean?
10:18
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A
It could vary from a cease-and-desist letter, a
10:18
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10:18
19
10:18
20
10:18
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A
Yes.
10:19
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Q
And when you say "verification of content,"
10:19
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10:19
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MR. FABRIZIO:
10:19
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THE WITNESS:
Q
So you said that you -- you supervised the
MR. FABRIZIO:
MR. FABRIZIO:
The program or his -- his job
The program itself.
Mr. Griffin, you can describe it
at a high level.
Okay.
DMCA notice or a notice under local law.
Q
And when you say "DMCA," are you referring to
the Digital Millennium Copyright Act?
what content are you referring to?
Objection.
Vague.
As I explained before, it
28
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
Q
12/22/2011
And with respect to Hotfile, are there specific
linking sites that you use to find content on Hotfile?
10:28
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category of questions that the court ruled out of
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bounds.
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BY MR. SCHOENBERG:
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10:28
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10:29
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confidential pursuant to agreements we have with them.
10:29
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BY MR. SCHOENBERG:
10:29
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10:29
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10:29
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extent you're referring to vendors that Disney uses with
10:29
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regard to Hotfile or comparable download hubs, you can
10:29
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identify the vendors.
MR. FABRIZIO:
Again, I'll instruct the witness
not to answer the question.
Counsel, that squarely falls into the specific
Q
How do the vendors crawl linking sites?
MR. FABRIZIO:
Objection.
Calls for
speculation.
THE WITNESS:
Q
Some of their methods are
Who are the vendors that you're referring to?
MR. FABRIZIO:
Again, Mr. Griffin, to the
10:29
36
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
linking sites?
10:30
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10:30
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MR. FABRIZIO:
10:30
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Can you be more specific, Counsel, since we're
10:30
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in an area where we have highly sensitive information,
10:30
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some of which may be confidential?
10:30
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you get any information you're entitled to, but want to
10:30
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make sure that we don't inadvertently through a broad
10:30
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question get information -- into information "we're" not
10:30
9
entitled to get into.
10:30
10
10:30
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Q
10:30
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sites?
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10:30
14
10:30
15
10:30
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10:30
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10:30
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Objection.
Vague, ambiguous.
We're happy to let
BY MR. SCHOENBERG:
What are the vendors searching for on linking
MR. FABRIZIO:
You can answer at a high level,
Mr. Griffin.
THE WITNESS:
Links to Disney content.
BY MR. SCHOENBERG:
Q
And once they find that content, what do they
do with those links?
MR. FABRIZIO:
Objection.
Vague and ambiguous.
BY MR. SCHOENBERG:
Q
Let me actually ask -- once they find those
links, what do they do with them?
MR. FABRIZIO:
Same -- same objections.
37
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
10:31
1
those links to us and, at the same time, download the
10:31
2
content associated with the link.
10:31
3
BY MR. SCHOENBERG:
10:31
4
10:31
5
MR. FABRIZIO:
10:31
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calls for speculation.
10:31
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10:31
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including some other information, would be put into a
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web portal, which is a website that we can go to.
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10:31
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Q
10:31
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your team?
10:31
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A
Yes.
10:31
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Q
And what do you do with it?
10:31
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10:31
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And, again, it's -- this is a matter -- these are
10:32
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matters that have been ruled irrelevant by the court.
10:32
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10:32
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a deposition and you may just want some of this for
10:32
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general background, but we're going to be very careful
10:32
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about how -- what depth of information you're entitled
10:32
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to here, Counsel.
10:32
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10:32
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Q
And then what do they do with it?
THE WITNESS:
Objection.
Vague, ambiguous,
That information, perhaps
BY MR. SCHOENBERG:
And do they make that web portal available to
MR. FABRIZIO:
Objection.
Vague, ambiguous.
I'm giving you a little leeway because we're at
So if you can answer at the very highest
38
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
THE WITNESS:
12/22/2011
Could you repeat the question?
10:32
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available to your team, and I said, "What do you do with
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it?"
10:32
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10:32
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MR. FABRIZIO:
10:32
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THE WITNESS:
10:32
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We would review the links and the downloaded
10:32
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content and any other information on the site.
10:32
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BY MR. SCHOENBERG:
10:32
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10:32
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10:32
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A
Yes.
10:32
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Q
Okay.
10:32
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10:33
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10:33
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BY MR. SCHOENBERG:
Q
A
Q
You said the vendors make a web portal
We would -Same objections.
Yes.
How many people are involved -- when you said
"human review" earlier, is that what you meant?
Yes.
How many people are involved in that
human review?
MR. FABRIZIO:
Pause just for one second.
39
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
MR. FABRIZIO:
12/22/2011
I'm going to instruct you not to
10:35
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the next step in this process that you've been
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describing?
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on content identified as infringing the Disney content.
10:36
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BY MR. SCHOENBERG:
10:36
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10:36
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10:36
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MR. FABRIZIO:
10:36
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THE WITNESS:
10:36
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cease-and-desist notice, it could be a notice compliant
10:36
18
with local law or it could be a DMCA notice.
10:36
19
answer, Mr. Griffin.
(Instruction not to answer.)
BY MR. SCHOENBERG:
Q
After the human review is completed, what is
MR. FABRIZIO:
Again, at a high level,
Mr. Griffin.
THE WITNESS:
Q
Notices would be sent to the site
When you say "notices," do you mean DMCA
takedown notices?
Objection.
Asked and answered.
It's -- it could be the
42
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
A
12/22/2011
I think recently we sent one to "221.com."
10:40
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10:41
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MR. FABRIZIO:
Did you get that, Lori?
10:41
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THE REPORTER:
"221.com"?
10:41
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10:41
5
Q
Any others?
10:41
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A
Yes.
10:41
8
Q
Did you ever send that type of notice to
10:41
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10:41
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MR. FABRIZIO:
10:41
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THE WITNESS:
10:41
12
10:41
13
10:41
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MR. GOLDSMITH:
I think that's privileged.
10:41
15
MR. FABRIZIO:
You think that's privileged?
10:41
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Okay.
10:41
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notices to send to which type of services is based on
10:41
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privileged analysis and communications internally at
10:41
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Disney.
10:41
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10:41
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10:41
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10:41
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10:41
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Q
Have you sent DMCA takedown notices to Hotfile?
10:41
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A
We have sent notices to Hotfile which meets
BY MR. SCHOENBERG:
I can't recall their names.
Hotfile?
Objection.
Vague.
No, I don't believe so.
BY MR. SCHOENBERG:
Q
Why not?
The determination as to what types of
And I'm going to instruct the witness not to
answer.
(Instruction not to answer.)
BY MR. SCHOENBERG:
46
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
requirements of the DMCA.
10:42
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10:42
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Q
10:42
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you've sent?
10:42
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A
10:42
5
10:42
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10:42
7
10:42
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MR. FABRIZIO:
10:42
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Again, at a high level, Mr. Griffin.
10:42
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the content was taken down.
10:43
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BY MR. SCHOENBERG:
10:43
13
10:43
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10:43
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see if it's still active.
10:43
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BY MR. SCHOENBERG:
10:43
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10:43
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is that the end of the process?
10:43
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MR. FABRIZIO:
10:43
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THE WITNESS:
10:43
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"the end."
10:43
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BY MR. SCHOENBERG:
And how many -- could you estimate how many
I don't have an accurate number.
I would
imagine thousands.
Q
What is the next step in this process after
you've sent one of these notices?
THE WITNESS:
Q
Objection.
Vague and ambiguous.
Generally, we would confirm that
And how do you do that?
MR. FABRIZIO:
Again, Mr. Griffin, at a very
high level here.
THE WITNESS:
Q
Someone would check the link to
And assuming that the link is no longer active,
Objection.
Vague and ambiguous.
I don't know what you mean by
47
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
do you do next?
10:43
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A
I think it would be classified as removed.
10:43
3
Q
Okay.
10:43
4
10:43
5
10:43
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10:43
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10:44
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the sending of a takedown notice and when you check to
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see whether the link has been deactivated?
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witness not to answer that question as it reveals highly
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sensitive antipiracy material information that has been
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deemed out of bounds by the court's order.
10:44
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10:44
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10:44
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A
It's a second notice on the same link, or it
10:45
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Q
Has Hotfile ever not taken down a file after
10:45
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10:46
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10:46
23
10:46
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10:46
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What if the link is still active?
What
is the next step in the process?
A
Our general policy is to send a follow-up
notice.
Q
And is there a specific amount of time between
MR. FABRIZIO:
I'm going to instruct the
(Instruction not to answer.)
BY MR. SCHOENBERG:
Q
When you say "follow-up notice," what do you
mean?
10:45
receiving a takedown notice from Disney?
MR. FABRIZIO:
Objection.
Calls for
speculation.
THE WITNESS:
I don't think I have data that
would enable me to answer that question.
48
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
BY MR. SCHOENBERG:
10:46
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10:46
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10:46
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Hotfile did not take a file down after receiving a
10:46
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takedown notice from Disney?
10:46
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10:46
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10:46
7
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10:46
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Q
When was that?
10:46
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A
I'm sure we've had to send follow-up notices
10:46
11
10:46
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10:46
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Hotfile did not after receiving a follow-up notice take
10:46
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down a link that you had given it notice of?
10:46
15
10:46
16
10:46
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THE WITNESS:
10:46
18
asked for data concerning that.
10:46
19
BY MR. SCHOENBERG:
10:47
20
10:47
21
remove content that you've identified in takedown
10:47
22
notices?
10:47
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10:47
24
10:47
25
Q
Can you think of any specific instance in which
MR. FABRIZIO:
Objection.
Objection.
Calls
for speculation.
THE WITNESS:
Yes.
BY MR. SCHOENBERG:
several times.
Q
Has there ever been an instance in which
MR. FABRIZIO:
Objection.
Calls for
speculation.
Q
I -- I have never analyzed or
How quickly do you expect cyberlockers to
MR. FABRIZIO:
Objection.
Overbroad and calls
for a legal conclusion.
THE WITNESS:
I believe Disney's position on
49
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
10:48
1
MR. FABRIZIO:
10:48
2
THE WITNESS:
10:48
3
than that, yes.
10:48
4
BY MR. SCHOENBERG:
10:48
5
10:48
6
10:48
7
10:48
8
10:48
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10:48
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10:48
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down files expeditiously in response to your takedown
10:49
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notices?
10:49
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10:49
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compound and overbroad and vague as to timeframe, as
10:49
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well.
10:49
21
10:49
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notices on many files.
10:49
23
BY MR. SCHOENBERG:
10:49
24
Q
And you're speaking of Hotfile, specifically?
10:49
25
A
Yes.
Q
Same objections.
I imagine it would be much less
Would it be less than 24 hours?
MR. FABRIZIO:
Same objections.
Asked and
answered.
THE WITNESS:
Again, I'm not certain.
BY MR. SCHOENBERG:
Q
So it could be more than 24 hours?
MR. FABRIZIO:
Objection.
Calls for
speculation.
THE WITNESS:
I -- I can't recall.
BY MR. SCHOENBERG:
Q
Did you have issues with Hotfile not taking
MR. FABRIZIO:
THE WITNESS:
Objection.
Vague and ambiguous,
We have had to send follow-up
Yes.
51
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
Q
12/22/2011
Where a takedown notice to one cyberlocker
11:22
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2
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3
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5
11:22
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11:22
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Q
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happening?
11:22
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11:22
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11:23
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MR. SCHOENBERG:
11:23
15
This will be Disney 3.
11:23
16
(Disney Exhibit 3 was marked for
11:24
17
identification by the court reporter.)
11:24
18
THE WITNESS:
11:24
19
11:24
20
11:24
21
11:24
22
11:24
23
11:24
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11:24
25
provided a link for a file on a different cyberlocker.
MR. FABRIZIO:
Objection.
Lacks foundation
that it occurred.
THE WITNESS:
I am not.
BY MR. SCHOENBERG:
So this is the first you've ever heard of that
MR. FABRIZIO:
Objection.
Mischaracterizes his
testimony, lacks foundation.
THE WITNESS:
I believe it is the first time
I've seen it.
Okay.
Okay.
BY MR. SCHOENBERG:
Q
What is the document we just marked as
Disney 3?
A
It appears to be a follow-up notice that we
talked about before.
Q
And can you just remind me, when you say
"follow-up notice" what do you mean?
68
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
A
12/22/2011
That would be a notice that we send after we've
11:24
1
11:24
2
11:24
3
11:24
4
11:25
5
A
The copyrighted work?
11:25
6
Q
Correct.
11:25
7
A
FLASHFORWARD.
11:25
8
Q
And does this document indicate when the
11:25
9
11:25
10
11:25
11
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12
11:25
13
11:25
14
11:25
15
11:25
16
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11:25
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11:25
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anyway, it appears that the follow-up notification was
11:26
22
sent less than 24 hours after the original notice; isn't
11:26
23
that right?
11:26
24
That's correct, isn't it?
11:26
25
MR. FABRIZIO:
sent a previous notice.
Q
And looking at this document, what is the work
that -- that that -- this follow-up notice relates to?
original notice was sent?
A
It appears to.
Notification Date:
Q
It says, "(Original
9/17/2009 3:56:10 PM)."
And when was this re- -- follow-up notification
sent?
A
Well, the header at the top says it was sent
9/18/2009, at 11:01:29 A.M.
Q
And just so we're clear, this -- this is a
follow-up notification to Hotfile, correct?
A
Yes.
It's -- in the "To:" line it says,
"abuse@hotfile.com."
Q
And so based on the face of this document,
Objection.
Lacks foundation.
69
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
THE WITNESS:
12/22/2011
So 9/17 at 3:56 P.M. to 9/18 at
11:26
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11:26
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11:01 A.M. I think would be less than 24 hours, if
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they're on the same time zone.
11:26
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BY MR. SCHOENBERG:
11:26
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11:26
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11:26
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notification because it felt like Hotfile hadn't
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responded in an adequate amount of time to the original
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takedown notice?
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11:27
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11:27
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MR. SCHOENBERG:
11:27
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THE WITNESS:
11:27
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can't recall this exact notice, but I -- I would suspect
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that's the case.
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BY MR. SCHOENBERG:
11:27
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11:27
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this, the original takedown notice, in order to have
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done so in an adequate amount of time?
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11:28
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MR. SCHOENBERG:
11:28
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THE WITNESS:
11:28
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9/18.
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BY MR. SCHOENBERG:
Q
Assuming they're on the same time zone.
Is -- did Disney send this follow-up
MR. FABRIZIO:
You're referring to this
specific notice?
Q
Yes.
I did not send the notice, and I
How quickly should Hotfile have responded to
MR. FABRIZIO:
You're referring, again, to this
individual instance?
Yes.
Well, obviously, before 11:01 on
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LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
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I, the undersigned, a Certified Shorthand
Reporter of the State of California, do hereby certify:
That the foregoing proceedings were taken
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before me at the time and place herein set forth; that
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any witnesses in the foregoing proceedings, prior to
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testifying, were duly sworn; that a record of the
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proceedings was made by me using machine shorthand
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which was thereafter transcribed under my direction;
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that the foregoing transcript is a true record of the
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testimony given.
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Further, that if the foregoing pertains to
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the original transcript of a deposition in a Federal
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Case, before completion of the proceedings, review of
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the transcript [X] was [ ] was not requested.
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I further certify I am neither financially
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interested in the action nor a relative or employee
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of any attorney or party to this action.
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IN WITNESS WHEREOF, I have this date
subscribed my name.
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Dated: 12/29/2011
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________________________________
LORI SCINTA, RPR
CSR No. 4811
209
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