Viacom International, Inc. et al v. Youtube, Inc. et al

Filing 290

DECLARATION of Micah Schaffer in Opposition 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 Youtube, Inc., Youtube, LLC, Google, Inc.. (Schapiro, Andrew)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) Plaintiffs, ) v. ) ) YOUTUBE, INC., ET AL., ) ) Defendants ) ) ) THE FOOTBALL ASSOCIATION PREMIER LEAGUE LIMITED, ET AL., ) ) on behalf of themselves and all others ) similarly situated, ) ) Plaintiffs, ) v. ) ) YOUTUBE, INC., ET AL., ) ) Defendants. ) VIACOM INT'L INC., ET AL., ECF Case Civil No. 07-CV-2103 (LLS) ECF Case Civil No. 07-CV-3582 (LLS) DECLARATION OF MICAH SCHAFFER IN SUPPORT OF DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTION FOR PARTIAL SUMMARY JUDGMENT I, Micah Schaffer, pursuant to 28 U.S.C. 1746, hereby declare as follows: 1. I am a former employee of YouTube, Inc. ("YouTube"). I submitted a declaration in support of YouTube's Motion for Summary Judgment in which I discussed a number of things, including various marketing activities by content owners that I learned of during the three and half years that I was employed at YouTube. 2. I recognize the YouTube video with video id HPB9tq7f_1k, which was uploaded to the YouTube account "clelltickle." It is a promotional video from the comedy team called "Human Giant." The agent of one of the group's members told me

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