Viacom International, Inc. et al v. Youtube, Inc. et al
Filing
214
DECLARATION of William M. Hohengarten (Part Eight) Ex. 160 in Support re: 176 MOTION for Partial Summary Judgment /Viacom's Notice of Motion for Partial Summary Judgment on Liability and Inapplicability of the Digital Millennium Copyright Act Safe Harbor Defense.. Document filed by Country Music Television, Inc., Paramount Pictures Corporation, Viacom International, Inc., Black Entertainment Television, LLC, Comedy Partners. (Attachments: # 1 Exhibit 161, # 2 Exhibit 162, # 3 Exhibit 163, # 4 Exhibit 164, # 5 Exhibit 165, # 6 Errata 166, # 7 Exhibit 167, # 8 Exhibit 168, # 9 Exhibit 169, # 10 Exhibit 170, # 11 Exhibit 171, # 12 Exhibit 172, # 13 Exhibit 173, # 14 Exhibit 174, # 15 Exhibit 175, # 16 Exhibit 176, # 17 Exhibit 177, # 18 Exhibit 178, # 19 Exhibit 179, # 20 Exhibit 180, # 21 Exhibit 181, # 22 Exhibit 182, # 23 Exhibit 183, # 24 Exhibit 184, # 25 Exhibit 185, # 26 Exhibit 186, # 27 Exhibit 187, # 28 Exhibit 188, # 29 Exhibit 189, # 30 Exhibit 190, # 31 Exhibit 191, # 32 Exhibit 192, # 33 Exhibit 193, # 34 Exhibit 194, # 35 Exhibit 195, # 36 Exhibit 196, # 37 Exhibit 197, # 38 Exhibit 198, # 39 Exhibit 199, # 40 Exhibit 200, # 41 Exhibit 201, # 42 Exhibit 202, # 43 Exhibit 203, # 44 Exhibit 204, # 45 Exhibit 205, # 46 Exhibit 206, # 47 Exhibit 207, # 48 Exhibit 208, # 49 Exhibit 209, # 50 Exhibit 210, # 51 Exhibit 211, # 52 Exhibit 212, # 53 Exhibit 213, # 54 Exhibit 214, # 55 Exhibit 215, # 56 Exhibit 216, # 57 Exhibit 217, # 58 Exhibit 218, # 59 Exhibit 219, # 60 Exhibit 220, # 61 Exhibit 221, # 62 Exhibit 222, # 63 Exhibit 223, # 64 Exhibit 224, # 65 Exhibit 225, # 66 Exhibit 226, # 67 Exhibit 227, # 68 Exhibit 228, # 69 Exhibit 229, # 70 Exhibit 230, # 71 Exhibit 231, # 72 Exhibit 232, # 73 Exhibit 233, # 74 Exhibit 234, # 75 Exhibit 235, # 76 Exhibit 236, # 77 Exhibit 237, # 78 Exhibit 238, # 79 Exhibit 239, # 80 Exhibit 240, # 81 Exhibit 241, # 82 Exhibit 242, # 83 Exhibit 243, # 84 Exhibit 244, # 85 Exhibit 245, # 86 Exhibit 246, # 87 Exhibit 247)(Kohlmann, Susan)
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EXHIBIT# 3
'D~~To~ , alt~Ryeose
CASE: Viacom, et al., v. YouTube, eral., The Football Association Premier League, et al., v. YouTube, et al.,
Case Nos. 07-CV-2203 and 07-CV-3582
A. Ignacio Howard, CLR, RPR, CSR No. 9830
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12:09:39 everyone's
AM
tunawarrior: talking to but larger that us ya, and since the larger,
12:10:05 AM maryrosedunton:
hah. oh totally. team is getting openly admit to people 12:10:24 freak AM you can't really
12:10:21 AM maryrosedunton:
out tunawarrior: i'd our efforts as we can in building up through whatever
if i were running the show, say, we concentrate all of our numbers as aggressively
however evil
tactics,
12:10:30 ie,
ya
AM
tunawarrior: myspace
scraping
12:10:33 AM maryrosedunton:
12:10:38 AM tunawarrior: up, views
but just get user metrics up, keep scaling out. 12:10:47 AM tunawarrior:
then 3 months, sell it with 20m per day and like 2m users or somethihng. 12:10:57 AM tunawarrior: because 12:11:02 to keep 12:11:05 things
control.
views
my fear is, AM tunawarrior: up with this AM tunawarrior: are AM going to
in
3 months.
growth. get so out of
12:11:14
tunawarrior: like 10% pushes or
we're going to be pushing of the traffic that google something. 12:11:20 AM tunawarrior:
with
blah
1/1000th
the
budget.
12:11:24 AM maryrosedunton:
12:11:37
hahaha
AM AM
that
tunawarrior: tunawarrior:
blah mean
12:11:39
what's
12:11:46 think
AM i'm
tunawarrior: pessimistic? that's a
12:12:02 AM maryrosedunton:
hah...oh no, I just mean crazy amount of traffic 12:12:06 AM tunawarrior:
see, between i think $250m we can $500m. sell
for
somewhere
12:12:08
AM
tunawarrior:
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in
the
next
3
months.
12:12:16 and there
AM
tunawarrior: *is* a potential to get
to
Slb
or
AM
something.
tunawarrior: going to take work and probably round of funding. like dilution and
12:12:28
but, man, that's 2 years of hard getting another
12:12:29 AM maryrosedunton:
and honestly, I can't imagine we could make enough just in advertising operating costs for something that 12:13:56 AM tunawarrior: to large cover
ya, none of these internet companies that get a lot of traffic with a revenue model based on purely advertising make 12:14:02 AM tunawarrior: thinking
myspace
that
much
money.
like AM it AM
friendster tunawarrior:
and
even
12:14:20 i think
model
has
to
be
a more
unique
12:14:25
tunawarrior: is unique tunawarrior: we can try like that to but to pull still and a google off highly lot
like google's 12:14:38 AM i *think* something ya,
of
risky
12:14:54 AM maryrosedunton:
and
work.
a AM
lot
of
time,
12:16:14 hmm we're
in traffic
tunawarrior: beating friendster nowadays
12:18:04 AM maryrosedunton:
nice. hrm, but you know, think to make us attractive us, we've got to really 12:18:39 AM tunawarrior: agreed 12:18:52
and user
i build
still to
someone up users
purchasing
AM AM other
more
tunawarrior: tunawarrior: than
videos
retention
12:19:05 in
to
ways
watch
just
returning
12:19:26 AM maryrosedunton:
yup.
someone
the
views
at the
are
end
awesome.
of the day
but
I
don't knowhow much that's
12:20:14 AM maryrosedunton:
oh oh shit, i we passed
AM tunawarrior:
really worth to
.:
flicks think it's
too still
12:20:16 highly HIGHLY
personally
valuable
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12:20:18
but
AM AM there
do for
tunawarrior: tunawarrior: are
the
12:20:30 i
we
think
can
some
next
easy
3 months
things
12:20:33
that will
AM AM the
tunawarrior:
make us worth a lot more
12:20:37 using
as a
tunawarrior: huge # of
to
uunique
build from
visitors
12:20:42 AM tunawarrior:
foundation
i
12:21:37 AM maryrosedunton:
right. I'm the groups
do
actually stuff, tunawarrior:
it
I
pleased wasn't
with sure
how
that
would
12:21:45
oh i love
AM AM
12:22:00
tunawarrior: a look at in passing it on the QA
i didn't really take much pre-push except playground 12:22:04 AM tunawarrior: but
it
i'm
happy
that
people
are
using
12:22:10 AM maryrosedunton:
ya, totally 12:22:11 AM tthe profile tunawarrior: stuff will see I be my do cool email think too
12:22:30 AM maryrosedunton:
agreed. oh, did you about the blog stuff. good point actually
and the wonder wheel if with we all want that
Mike
has
a
12:22:51 AM maryrosedunton:
to reinvent stuff?
12:22:55 AM maryrosedunton:
(the blog stuff) 12:23:04 AM tunawarrior:
hmm
12:23:09 the
is
AM
tunawarrior: that i'd contend with
only
point AM
12:23:14 for every
tunawarrior: person using the blog functionality
12:23:19 we'd
content
AM tunawarrior: getting more user generated i want
that if
'
be
12:23:27 and
to right,
AM tunawarrior: person
it, but I so
that
read
will
on,
others
cycle
12:24:21 AM maryrosedunton:
wonder we would gain
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more users from integrating instead of trying to duplicate 12:24:43 AM tunawarrior:
with
livejournal, them?
right,
12:25:04 but the content minutes 12:25:08 is
hm
ya
AM
i
see
that
point
too
tunawarrior: 30+
bulk of the user generated that these guys are spending to write each day AM tunawarrior: to AM be hosted elsewhere,
going
12:25:13
tunawarrior: go either tunawarrior: way market faster
well, i can 12:25:16 AM
if it can get us to 12:25:30 AM tunawarrior:
i really like the whole dropdown to integrate address book thing 12:25:55 AM tunawarrior: wondering
like
if AM
we
can
put
rizzo
on
12:26:04 permanent,
out next
tunawarrior: small-features, going
week.
12:26:11 and
live
AM
branch.
tunawarrior: always be working on the
he'll
12:26:28 AM maryrosedunton:
oh hrm. stuff
the
probably. the premium though, do
live branch?
12:26:51 AM maryrosedunton:
content we want provider that going out on
12:26:58 AM maryrosedunton:
that's
12:27:03 hm it's
on rizzo's
AM pretty tunawarrior: big,
plate
isn't it? all needs to figure out
12:27:31 AM maryrosedunton:
actually, the flow isn't really that complicated. it's just rizzo how to deal with the images. 12:27:46 AM tunawarrior: ah right. users to upload images for
12:27:47 AM maryrosedunton:
allowing
their
ya big
watch
pages
to
and profile
tackle seeing
so our much current trouble machines.
f
12:28:12 AM tunawarrior:
problems
we're out AM as how serving 12:28:19 already having the images on tunawarrior: have no
ji
it's funny how we serving out videos
problems
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The following is a true and correct copy of this instant message conversation as produced by Defendants.