Arista Records LLC et al v. Lime Wire LLC et al

Filing 117

DECLARATION of Steven Gribble in Support re: 108 MOTION for Summary Judgment (Vicarious).. Document filed by Lime Wire LLC. (Attachments: # 1 Exhibit 1-6, # 2 Exhibit 7-12)(Baker, Charles)

Exhibit 7

The three screenshots shown above show the configuration screens available to LimeWire software users.

These configuration screens allow a user to control which folder is used for sharing files, whether to share all files that are downloaded, whether to share dot-torrent files, and to specify constraints on the types of files that are shared or not shared.

Exhibit 8

This screenshot shows the basic file search user interface of the LimeWire client.

To search for a file, a user must type a search string in the "Filename" box on this page of the LimeWire user interface, and then press the "Search" button.

Exhibit 9

This screenshot shows a more advanced search user interface of LimeWire.

Using this interface, a LimeWire user can specify metadata attributes that constrain the files that LimeWire will find and present to the user. In this particular case, the screenshot shows the ability of the user to specify attributes about "document" file types, such as title, topic, or author.

Exhibit 10

This screenshot shows query results for the query "firefox".

As the LimeWire client learns of files shared by other peers on the Gnutella network that match the user's search query, LimeWire displays these results on a page such as this. Note that the user is able to see various kinds of metadata about matching files, but cannot (from this screen) observe any details about the peers that are hosting these matching files.

Exhibit 11

L L U
qu er
y

L
ery

query

qu

y

er

qu

U
er y

U

que

ry

L
r ue y

L L

qu

L L L

q

U
query

qu

er

y

L

L

L

···

L

L

A LimeWire client (the leaf node "L" in the bottom-left of this figure) issues a query into the Gnutella network.

The user's query is passed from the LimeWire client to its ultrapeer, and from there, the query propagates outwards to other peers and ultrapeers within the Gnutella network.

L L U
qu ery

L

hit

query h

it

U

U
qu er

y

L L

hi t

y

L

qu

que

er

hi

t

ry h

it

L L L

U
er qu y hi t

L

L

L

···

L

L

Some Gnutella peers within the network notice that they are sharing files that match the user's query, and they generate "query hit" response messages that flow back towards the LimeWire client that issued the query.

The query hit messages propagate back to the issuing LimeWire client; many query hit messages may arrive over time. Each query hit message describes a file that is shared by some other Gnutella peer (perhaps a LimeWire client, and perhaps some other Gnutellacompatible client software). These matching files are displayed to the user by the LimeWire client, and the user is able to select files to download.

L L U L

U L L L U

U

L L L

If the user decides to download any of the files contained in the query hit response messages, that file transfer occurs directly between the user's peer and the peer (or peers) that host the shared file.

Note that file transfer occurs directly between peers, rather than flowing through the Gnutella network.

file tra ns fer
L L L

···

L

L

Exhibit 12

A user searches for "linux torrent" using Google and their Web browser.

One of the search results is for a Web site called "LinuxTracker". This Web site provides users with dot-torrent files associated with the Linux open source operating system and applications. Using this Web site, a user can search for a particular piece of Linux software, and find resulting software packages that are available for transfer over BitTorrent.

This is an example of a Web page on LinuxTracker that shows a specific distribution of Linux (Fedora 9) that is available via a BitTorrent swarm. A user can click on the "Torrent" link near the top of the page to cause their Web browser to download the "dot-torrent" file associated with this BitTorrent swarm. If their Web browser and operating system are correctly configured, simply clicking on this link can cause the LimeWire client software to launch, receive the dot-torrent file, and begin transferring the Fedora 9 software package using the BitTorrent protocol capabilities of LimeWire.

This shows a screenshot of the LimeWire client transferring the Fedora 9 software package using the BitTorrent protocol.

Note that this transfer does not involve the Gnutella network or protocols in any way; LimeWire is interacting with other BitTorrent peers to perform this transfer.