Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
81
MEMORANDUM of Law re 72 Plaintiff's MOTION to Compel RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES (Public Redacted Version)Plaintiff's MOTION to Compel RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS AND INTERROGATORIES (Public Redacted Version) Memorandum of Law of Defendants Hotfile Corporation and Anton Titov In Opposition to Plaintiffs' Motion to Compel Responses to Requests for Production and Interrogatories by Hotfile Corp., Anton Titov. (Attachments: # 1 Exhibit 1, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit 2, # 18 Exhibit 3, # 19 Exhibit A)(Munn, Janet)
EXHIBIT L
From: Pozza, Duane [DPozza@jenner.com ]
Sent:
Monday, June 13, 2011 1:40 PM
To:
Leibnitz, Andrew (21) x4932
Cc:
jmunn@rascoklock.com ; Platzer, Luke C; Fabrizio, Steven B; Thompson, Rod (27) x4445
Subject: RE: Disney v. Hotfile
Andy,
The motion seeks data about the content files, as part of the portion of the request that seeks data
"used to calculate the amounts of such [Affiliate] payment or determine their proper recipients." See p.
12. Request No. 3 does not seek the content files themselves. During our meet and confer, we
specifically talked about this data used to calculate Affiliate payments, and noted that it was similar to, if
not entirely overlapping with, the other content reference and user data that defendants objected to
producing (e.g., download counts of content files). In any event, we don't intend to have an entire email
exchange responding to open-ended ECPA questions—we could have discussed ECPA issues on any of
the three different meet and confer calls during which we discussed the requests for data. We can
respond to any specific arguments you make about ECPA as necessary in the briefing.
Regards,
Duane
From ALeibnitz@fbm.com [mailto:ALeibnitz@fbm.com]
Sent: Monday, June 13, 2011 3:49 PM
To: Pozza, Duane
Cc: jmunn@rascoklock.com ; Platzer, Luke C; Fabrizio, Steven B; RThompson@fbm.com
Subject: RE: Disney v. Hotfile
Duane:
Your motion explicitly calls for content files, at least in the Affiliate context, even for the smallest
participants in the Affiliate program. Mot. at 15. How is that consistent with the ECPA in your view?
Regards,
ANDY
Original Message
From: Pozza, Duane [rnailto:DPozza@jenner.conn]
Sent: Monday, June 13, 2011 11:09 AM
To: Thompson, Rod (27) x4445
Cc: jmunn@rascoklock.com ; Platzer, Luke C; Leibnitz, Andrew (21) x4932; Fabrizio, Steven B
Subject: RE: Disney v. Hotfile
Rod,
The content reference and user data we are seeking here does not constitute the "contents" of
any communication, so there is no issue under the ECPA provision you cite. The definition of
"contents" is relatively narrow - it is limited to "any information concerning the substance,
purport, or meaning of th[e] communication." 18 U.S.C. § 2510(8). Data that is not the actual
"contents" of the communications can still be disclosed under the statute under 18 U.S.C. § 2702
(c), which provides that a service provider "may divulge a record or other information pertaining
to a subscriber to or customer of such service (not including the contents of communications
covered by subsection (a)(1) or (a)(2)) ... to any person other than a governmental entity." The
legislative history also explains that "contents" do not include "such information as customer
6/16/2011
lists" S. Rept. 99-541, at 38, or "information about the customer's use of the service," id. The Crispin
decision, which dealt with actual user messages, has no applicability to the data we are requesting here.
So for that reason alone there is no bar to production of any the requested data under the ECPA statute.
Let us know if you have any contrary authority otherwise.
-Duane
Original Message
From: RThompson@fbm.com [mailto:RThompson@fbm.com]
Sent: Friday, June 10, 2011 4:58 PM
To: Fabrizio, Steven B
Cc: Pozza, Duane; jmunn@rascoklock.com ; Platzer, Luke C; ALeibnitz@fbm.com
Subject: RE: Disney v. Hotfile
Steve, are you familiar with Crispin v. Audigier 717 F. Supp. 2d 695 (CD Cal.
2010)? Please tell us if we are missing something but it would seem to hold that
Hotfile cannot provide to any person any contents of any communication (defined to
include "data") maintained on its service for a customer solely for the purpose of
providing storage or computer processing. 18 U.S.C. 2702(a)(2). There are no
exceptions for civil discovery.
Thoughts?
Rod
Original Message
From: Fabrizio, Steven B [mailto:SFabrizio@jenner.com]
Sent: Wednesday, June 08, 2011 6:51 PM
To: Thompson, Rod (27) x4445
Cc: Pozza, Duane; Janet Munn; Platzer, Luke C; Leibnitz, Andrew (21) x4932
Subject: Re: Disney v. Hotfile
Rod - We've had a chance to consider your proposal (we based our analysis on the
attached file and did not compare that word for word with what is in your email,
but presume they match up).
We can live with your Point I as is.
We can live with your Point II as is except as follows: We need both the User ID
information and the number of downloads information in Step 2. Those are both
necessary to identify the content files that will be in suit. We also would tweak
your "good faith" clause. We have no problem with the clause per se, just its
wording. We can only make the good faith representation as to our ownership of
the copyright in the "work" that appears to be represented by the file, not as to
the "file" itself. I think that is probably what you meant to say anyway.
The big issue - which we cannot accept - concerns the stats study data, your Point
III. You incorrectly presume that the stats study is not relevant to the DMCA
defense. But the stats analyses are just as relevant to the DMCA defense as they
are to the underlying copyright issues, and serve almost the identical purposes.
First, the stats study is directly relevant to the "financial benefit" prong of
the DMCA contained in 17 U.S.C. § 512(c)(1)(B). Courts look to whether there is a
high proportion of infringement as evidence that infringement is a "draw" to
attract users. Almost every court beginning with Napster has relied on
6/16/2011
statistical evidence for the financial benefit analysis. Second, as courts have
held, the statistical data of the proportion of infringement is probative of
knowledge, which is obviously an important element in the DMCA analysis. Third,
the statistical evidence is relevant to the question of whether defendants have
induced infringement; as two courts (Fung and Usenet) have concluded, if
defendants are found to have induced copyright infringement under Grokster, then
they are not eligible for any DMCA safe harbor. While we recognize that
defendants will argue that YouTube came out the other way on inducement and the
DMCA, based on the conflicting precedents, our Court will need to make its own
decision, and, respectfully, we believe that we have the stronger argument by
far. Defendants cannot by fiat presume the Court will rule their way on a central
disputed legal issue and deny any discovery inconsistent with their legal argument
(what you are suggesting would result in piecemeal DMCA motions if our Court
agrees with Fung and Usenet on the inducement point). Accordingly, the stats
analyses are directly relevant to the DMCA in that regard as well.
Defendants simply have no legal basis to refuse to produce the stats data we
requested. It appears as if defendants objective is to impede plaintiffs' ability
to conduct a stats analysis because they want to suppress that evidence. In point
of fact, the stats analyses do not require substantially different data - in type
or volume - than the data that defendants are agreeing to produce in your
proposal. The following is the only marginal additional data that would be
necessary:
1. For all files: the User ID and number of downloads data. Even for all files
those two fields would be a trivial amount of data. 2. For each Stats Analysis
File - which would be a relative tiny subset of files, likely less than 3000
content files total: (i) a copy of the actual content file, and (ii) the IP
address of the uploading user and each downloading user (with the last octet
masked per the ESI plan), (iii) the date and time the file was uploaded, and (iv)
the file's status per the definition in 1 17m of plaintiffs' Requests.
Defendants have agreed to produce all of the same categories of data (and more)
for the Infringement Analysis Files, which will be a much larger set of files than
the Stats Analysis Files.
We frankly do not see how defendants can credibly justify denying us this limited
data given the obvious relevance of the stats analyses to defendants' DMCA
defense.
We would like to resolve this but cannot agree to defer the stats analyses. We
would ask you to reconsider and see whether we can have a resolution based on the
limited additional data we've outlined above.
SBF
From: "Roderick M. Thompson" ; Platzer, Luke
C; Leibnitz, Andrew (21) x4932
Subject: RE: Disney v. Hotfile
We see the events leading up to our motion quite differently but, as you say,
enough said.
As for your question:
- The data regarding the number of times a file is downloaded is necessary because
a file downloaded 100,000 times and a file downloaded 3 times would not be treated
the same in selecting a "representative" sample of files distributed by Hotfile.
The process is more complicated than a simple random sample. There would be
weighting of files as part of the sample selection protocol.
- The user ID is needed because of the prevalence of RAR files, especially for
larger sized files. A movie, for example, might be uploaded to Hotfile as three
separate RAR files. For statistical purposes, we don't treat each RAR file
separately, but rather measure "content" files. So in my example the three RAR
files constituting a single movie would count as one "file" for purposes of the
stats analysis. We do this as part of our taking every precaution to ensure that
the sample is not biased in our favor. (An infringing movie uploaded as three RAR
files counts once, not three times.) The user ID is necessary to associate the
RAR files into their constituent content files. The RAR files are identified by
part (part 1, part 2, part 3). Without the user ID we might associate the wrong
parts together (since files might be named the same); with the user ID we can be
confident that we have associated the right RAR files to make up the content file
that will be part of our study.
If I haven't explained that clearly enough, just give me a call tonight or over
the weekend (my cell is 703-307-7125).
I'm glad you are
however, that we
be reached. That
intention to try
6/16/2011
giving the proposal some consideration. I need to emphasize,
didn't make that as an opening salvo from which a compromise can
is really the bottom line of what we need. If it is defendants'
to chip away at the data we've proposed, don't waste a lot of
your own time. We cannot take less than what is in that proposal.
Have a good weekend.
SBF
Original Message
From: RThompson@fbm.com [mailto:RThompson@fbm.com]
Sent: Friday, June 03, 2011 7:27 PM
To: Fabrizio, Steven B
Cc: Pozza, Duane; jmunn@rascoklock.commailto:jmunn@rascoklock.cow; Platzer, Luke
C; ALeibnitz@fbm.com
Subject: RE: Disney v. Hotfile
Steve, first, I saw no productive reason to rehash in my letter what happened.
(Andy had explained our views to Duane, I believe very clearly.) But since you
are baffled--we were not happy with what can only be called a blatant sandbag.
When you asked us to preview the grounds for our motion to dismiss so your team
could make vacation plans (we told you we dold not challenge personal jurisdiction
and therefore you did not need to worry about immediate discovery), we obliged
even though we did not have to and might have thus inconvenienced your team. But
that is not the kind of "tactical" advantage we seek and is not productive in the
long run to efficient case resolution. When we asked last Friday, the day before
a long holiday weekend, if your team would be filing a motion to compel we got a
non-answer. Instead the call ended with setting a date for further meeting and
conferring. That is why we were surprised and disappointed by the filing the next
business day. Enough said.
I will also resist responding to the many unnecessary accusations in your email
and will not attempt to correct the recounting of who said what when, as that
would be a still further waste of time and probably prompt another long response
from you. Just remember this is not Fung or Bunnell and it really doesn't matter
what happens in what you believe are "comparable" file sharing cases. This is a
legitimate file hosting service, more comparable to YouTube and Rapidshare.
Let me clear up one misperception: when I said your motion hit "shortly after I
had confirmed" that hotfile would agree to the compromise I outlined, I meant they
had confirmed to me that I had the authority to offer the compromise. (We were
still under the impression that our meeting and conferring was ongoing and that it
was a good use of our time to look for a compromise.) I did not mean to imply I
had confirmed it with anyone on your team; I never had a chance to.
Notwithstanding the content of the long preamble, we appreciate your detailed
proposal and will give it serious consideration. That will take some time because
of the weekend, time zone differences and the complexity of what you propose. One
question--why is the number of times a file is downloaded and the uploading user
ID needed to select a random sample of files?
Enjoy your weekend.
Rod
Original Message
From: Fabrizio, Steven B [mailto:SFabrizio@jenner.com]
6/16/2011
Sent: Thursday, June 02, 2011 8:25 PM
To: Thompson, Rod (27) x4445
Cc: Pozza, Duane; Janet Munn; Platzer, Luke C; Leibnitz, Andrew (21) x4932
Subject: Re: Disney v: Hotfile
Rod - I've had a chance to review your June 1 letter and discuss it with my team
to make sure all of our recollections were consistent. I have to tell you that I
am baffled by your comment in your cover email that your team "was not happy"
about our motion. Why? We could not have been clearer (or more repetitious in
saying) that, on the core issues, where we had received essentially categorical
refusals to produce by defendants, we intended - and needed - to move to compel as
quickly as possible. You certainly could not have been surprised.
Regrettably, your letter contains material factual inaccuracies and, in its
omission of other facts, is misleading. We accept that this was not done
deliberately, but it does put an inaccurate and unfair spin on what, to us, are
pretty clear-cut facts. The facts, as we recollect them, are as follows:
First, our meet and confer on all issues we raised with the Court was completed,
exhaustively so, and that fact was acknowledged by both sides. We had exhausted
discussion, negotiation and the possibilities of compromise, and had mutually
concluded that there was simply no agreement to be reached on those categories of
discovery. You personally had all but told us that your clients would never allow
you to voluntarily produce those categories of data, documents and information.
In conversations in which you did not participate, Andy confirmed, unequivocally,
that, on those topics, defendants were standing on their objections and no further
discussion would change that. So, while the parties may be continuing discussions
on other (wholly different) categories of discovery, on which further discussion
may result in compromises acceptable to both sides, it is inaccurate to suggest
that the meet and confer on the topics that are the subject of our motion was
anything but fully completed.
Indeed, our respective teams met and conferred on those topics no less than four
separate times, on May 11, May 16, May 19, and May 20. You will also recall that
plaintiffs tried very hard to meet and confer even before the parties exchanged
written responses, so as not to waste time on objections that readily could be
avoided. Defendants refused. The topics on which we moved go to the heart of
discovery and defendants' failure to produce this discovery is materially impeding
our case preparation. Plaintiffs have been trying to keep discovery moving apace
for the obvious reason that their copyrighted works are being infringed thousands
of times over every day by defendants. On top of that, defendants have insisted
on moving for leave to file an "early DMCA motion" by July 15. In light of the
pendency of that motion, how long would you expect plaintiffs could wait to ask
the Court to order discovery of key categories of information, categories which
are routinely produced in comparable cases?
Second, your account of the "idea" you "floated" does not conform to our
recollection (except insofar as you made abundantly clear that your clients had
not approved it). The proposal you make in your letter is not even the same as
the proposal you suggested during our May 16 meet and confer. On May 16 you asked
whether we could accept data containing far fewer fields than we requested and
need. We told you that we needed the data for multiple analyses, most notably a
statistical study and a direct infringement analysis (as we also explain in our
motion). Your letter continues to misapprehend the purposes for which we need the
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data and, therefore, continues with proposals that cannot work.
Nevertheless, during the May 16 meet and confer, we examined the requested fields
and identified the minimum fields we would need: the Hotfile URL (on assumption,
to be confirmed, that the URL systematically included the Hotfile identifier and
the file name), the file size in bytes, the location and/or IP address of the
uploading user, the number of downloads, the location or IP address of the
downloading users, and the status of the file. That was the minimum we believed
we needed just to conduct our direct infringement and stats analyses (we would
need additional subsets of data for other important analyses, e.g., a repeat
infringer analysis and an analysis of compliance with takedown notices). On our
May 16 call, you immediately dismissed producing the data we identified and
instead said you would check with your clients as to whether they would produce
just the Hotfile URL and file size data. As we told you, that suggestion would
complicate the direct infringement study and likely would compromise the
statistical analyses. On the direct infringement front, it would require a
multiple step process in which we first identify innumerable URL links that appear
to correspond to plaintiffs' copyrighted works (a process that would likely result
in our identifying tens of thousands of links). Then we would have to make a
subsequent request for defendants to produce the remaining fields of data for
those identified URL links. It is worth observing that on May 16 you would not in
fact commit to producing those other fields in the second part of the process and your June 1 letter remains studiously silent on that key question. As for the
statistics study, we told you that the way our expert would identify a
representative sample would require having some of the other fields of data.
That said, we said we would work with our statistics expert to consider
alternative sampling protocols - but only after you first confirmed with your
clients and advised us that your clients would agree to your proposal, including
committing to the necessary follow-up production of data. Since you opened the
May 16 discussion of this "idea" by saying that you doubted your clients would
agree to produce any of this data, it hardly made sense for us to work with our
expert on sampling protocols if your clients were going to reject your
recommendation.
We never heard back from you. It is a little over the top for you to complain in
your June 1 letter that you never heard back from us. We told you that we did not
think your proposal would work. We also told you that we could not see any reason
not to produce all the data fields we requested so that we could conduct our
studies without potentially compromising them. You made it abundantly clear that
your clients would never go for that and probably would reject the idea of
producing even the much narrower set of data. Frankly, from the way you described
the prospects of getting approval from your clients, we didn't really expect to
hear back from you. Still, our teams had three meet and confer teleconferences
after that May 16 discussion and before we filed our motion, including one on May
27 that you personally participated in for some of the discussion. No one from
your team ever mentioned the idea that defendants might agree to produce a
narrower data set.
To the contrary, on May 19, we had a meet and confer call with Andy, in which Andy
made it clear that defendants were standing on their objections as to the Content
Reference and User Data. We did our best to persuade him otherwise, reminding him
that the courts in the Fung and Bunnell cases had ordered defendants to produce
comparable data. Andy asked us to send him the orders, while simultaneously
telling us unequivocally that defendants' position would not change. The next
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day, May 20, in an email time-stamped 10:57am, Duane forwarded the two orders,
with an email that confirmed the state of affairs:
"We also indicated that we would send copies of orders compelling production of
user activity data. I am therefore attaching orders from the Bunnell and Fung
cases. The Bunnell order was upheld by the district court at 245 F.R.D. 443. As
we discussed, the parties are currently at an impasse on producing complete
Content Reference, User, and Affiliate Data, and defendants have given no
indication of changing their position. We are sending these as a courtesy but do
not understand that our meet-and-confer is being reopened on this issue."
(Emphasis added.)
No one from your team ever took issue with that statement because it accurately
reflected what had been mutually concluded in the meet and confer. Certainly no
one ever mentioned your "idea" from the May 16 meet and confer.
Third, your June 1 letter implies that you confirmed to us the day before we filed
our motion that your client had agreed to produce a narrower set of data. That of
course is not the case. The first we heard of that was on June 1 - the day after
we filed our motion - when Andy so advised Duane. Even if your clients had agreed
to produce the full data set that plaintiffs need, agreeing to produce discovery
after forcing the other side to file a motion does not excuse the non-production.
Fed. R. Civ. P. 37(a)(5)(A). But, here, defendants have not offered to produce
the data set we requested and need. You are suggesting producing just the "file
name and unique identification number" for Hotfile-hosted content, which is even
less than you suggested in the May 16 meet and confer. As we told you more than
two weeks ago, that framework would not allow us to conduct our statistical
analysis. It also creates a needlessly cumbersome multiple step discovery
process. Defendants notably also have not committed to the follow-on discovery
that we discussed would be necessary. Bottom line: Your proposal, as stated in
your June 1 letter, simply does not move us closer to a compromise that plaintiffs
can accept, as we suspect you already knew.
Maybe we have become jaded but we cannot help but think that defendants have made
an offer they knew would be unacceptable for whatever tactical value defendants
believe it might have in connection with our pending motion to compel.
Nevertheless, genuinely hoping we are wrong, we've developed a proposal that could
work. It is far more complicated than simply producing the full data sets that
plaintiffs have requested. And there is no reason for this more complicated,
multi-step approach because, as a practical matter, producing the full data sets
would almost certainly be far less burdensome for both sides. Still, subject to
consultation with our clients and statistics expert, which we will do if and when
you advise us that defendants would produce discovery according to this plan,
plaintiffs would agree to the following plan - involving data production in three
steps - to resolve all outstanding issues with regard to our Request Nos. 1
(Content Reference Data) and 2 (User Data).
HOTFILE DATA PRODUCTION - STEP 1
For all files on Hotfile, regardless of the file's status (e.g., active,
*
inactive), defendants would produce the following data: (i) file name, (ii)
unique Hotfile identifier, (iii ) the Hotfile user ID for the uploading user, and
(iv) the total number of times each file has been downloaded. (The data regarding
uploading user ID and number of downloads is necessary for plaintiffs to conduct
their statistical analyses.)
,
6/16/2011
* Through analysis of this data, plaintiffs will identify for defendants two
sets of files: files that appear to contain plaintiffs' copyrighted works
("Infringement Analysis Files") and files that may be used in plaintiffs'
statistical analyses ("Stats Analysis Files").
HOTFILE DATA PRODUCTION - STEP 2
* For each Infringement Analysis File, Hotfile would produce the following: (i)
the Hotfile URL, (ii) the file size in bytes, (iii) the IP address of the
uploading user and each downloading user (with the last octet masked per the ESI
plan), (iv) the Hotfile username for the uploading user, (v) whether the file was
a copy made using the Hotfile multiple copy feature, (vi) the date and time the
file was uploaded and of each download, and (vii) the file's status per the
definition in 5 17 of plaintiffs' Requests. Through analysis of this data,
plaintiffs will identify for defendants a subset of files for which plaintiffs'
need the actual content file ("Selected Content Files").
* For each Stats Analysis File, Hotfile would produce the following: (i) a copy
of the actual content file, and (ii) the IP address of the uploading user and each
downloading user (with the last octet masked per the ESI plan), (iii) the date and
time the file was uploaded, and (iv) the file's status per the definition in 9 17
of plaintiffs' Requests.
* In addition, for each "DMCA Analysis File" (defined below), Hotfile would
produce the following: (i) the file name, (ii) the unique Hotfile identifier,
(iii) the Hotfile URL, (iv) the file size in bytes, (v) the IP address of the
uploading user and each downloading user (with the last octet masked per the ESI
plan), (vi) the Hotfile username for the uploading user, (vii) the status of the
user (e.g., active, terminated, suspended) and, for any status other than fully active, data indicating the date of and reason for each status change, (viii) the
file's status per the definition in 1 17 of plaintiffs' Requests, and (ix) as
applicable, the date the file was rendered inactive. This is the minimum data
necessary for plaintiffs to analyze whether defendants have complied with DMCA
notices and the DMCA's threshold requirement that defendants reasonably implement
a repeat infringer policy, 17 U.S.C. § 512(c)(i)(1)(A).
A "DMCA Analysis File" means each of the following files: files for which Hotfile
has received a takedown notice on behalf of any copyright holder ("Takedown Notice
Files"); files for which Hotfile has received an instruction to remove a file
through any Special Rights Holder Account ("Rights Holder Account Files"); files
that are a component of the same multi-part archive (e.g., RAR) of a Takedown
Notice File or a Rights Holder Account File; files that are copies of a Takedown
Notice File or Rights Holder Account File made using the Hotfile multiple copy
feature; and files otherwise disabled for copyright infringement.
HOTFILE DATA PRODUCTION - STEP 3
For each Selected Content File, Hotfile would produce a copy of the actual
•
content file.
We cannot emphasize enough that this is a far more complex and burdensome process
- for both sides - than what plaintiffs had requested or, frankly, would prefer.
Nevertheless, if defendants will stipulate to produce the data identified in each
step on an expeditious basis, so that plaintiffs are not unduly prejudiced by the
6/16/2011
multi-step approach, then this could be a basis for plaintiffs to withdraw their
motion to compel as to RFP Nos. 1 and 2, i.e., Section I of our motion to compel.
Let us know if defendants are prepared to so stipulate.
SBF
From: "Roderick M. Thompson"
mailto:rthompson@fbm.com »
Date: Wed, 1 Jun 2011 22:36:59 -0500
To: Steven Fabrizio
mailto:DPozza@jenner.com », Janet
Munn
mailto:LPlatzer@jenner.com »
Subject: Disney v. Hotfile
Steve, please see the attached and call me if you'd like to discuss. Our team was
not happy about this . . .
Rod
Roderick M. Thompson
Attorney at Law
Farella Braun + Martel LLP
RUSS BUILDING
235 MONTGOMERY STREET
SAN FRANCISCO / CA 94104
T 415.954.4400
D 415.954.4445
F 415.954.4480
www.fbm.com
Steven B. Fabrizio
Jenner & Block LLP
1099 New York Avenue, N.W.
6/16/2011
Suite 900
Washington, DC 20001-4412
Tel (202) 639-6040
Fax (202) 661-4823 SFabrizio@jenner.com
www.jenner.com
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6/16/2011
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