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

Filing 302

DECLARATION of Andrew H. Schapiro, Group 2, Exhibit 16, Part 6 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.. (Attachments: # 1 Exhibit 16, Part 7, # 2 Exhibit 16, Part 8, # 3 Exhibit 16, Part 9, # 4 Exhibit 16, Part 10, # 5 Exhibit 17 - 24)(Schapiro, Andrew)

Schapiro Exhibit 17

Schapiro Exhibit 18

Schapiro Exhibit 19

Schapiro Exhibit 20

Schapiro Exhibit 21

Subject:
From:
To: Cc:

Re: wolfmother youtube clip 3 "Tamar Teifeld" -::: @tmo.blackberry.net
Date: Fri, 11 Aug 2006 02:21:54 +0000

Amy told me to work with Andrew - 1m getting a hold of him tomorrow. Perfect that you already
know him.

----- Replied by Tamar Teifeld on 8/10/2006 7:21: 14 PM

From ~tmo.blackberry.net
08/10/200607: 19 PM

~tmo.biackberry.net
To: Tamar" -:Tamar _ [e-mail]::

Please respond to

cc: Subject: Re: wolfmother youtube clip 3
Great, thx. Who u working with? Ingrid? Andrew?

Sent from my BlackBerry@ wireless handheld

-----Original Message----From: [e-mail] Date: Thu, 10 Aug 200619:18:08
To: [e-mail]

Subject: Fw: wolfmother youtube clip 3
Hey Scott,

Check out the video clip attached. It is from the filming of the Wolfmother / Jackass video. I am going to work with Interscope and have them leak it. Once they do, you can use it as welL. I am going

to speak with them tomorrow, so I will keep you posted.
Thanks!
----- Forwarded by Tamar TeifeIdMarketing/MP/Paramount_Pictures on 08/10/2006 07: 16 PM
From:John Godocik

08/10/200612:50 PM

To: Karl Williams, Tamar Teifeld, Mickey Worsnup cc: Subject: Fw: wolfmother youtube clip 3
Carly asked us to clear some pictures, and we did. Now she wants permission for the attached

video clip. I thought you guys were the right people.
----- Forwarded by John Godocik/Marketing/MP/Paramount_Pictures on 08/10/2006 12:46 PM

From:Carly Vermes
08/10/2006 12:35 PM

To: John Godocik

cc: [e-mail], Randy Spendlove
Subject: Fw: wolfmother youtube clip 3

CONFIDENTIAL

VIA00911452

Hey John,

Per our conversation, can you please see if David / Marketing can approve this you tube video
clip!

Thank you!

Best,
Carly Vermes
Paramount Pictures 5555 Melrose Ave.

Crosby Bldg. Room 213
Hollywood, CA 90038 Phone: [phone] Fax: [phone] carly _ [e-mail] ----- Forwarded by Carly Vermes/Production/MP/Paramount_Pictures on 08/10/2006 12:34 PM

From: "Seyler, Anthony" -:[e-mail]::
08/09/200609:22 PM

To: -:randy [e-mail]::, -:Carly_ [e-mail]:: cc: "Angstadt, Kathy" -:[e-mail]::, "Hickey, Kerry" -: Kerry. [e-mail]:: Subject: FW: wolfmother youtube clip 3

Randy, We need to get into the attached video clip, the pictures from the video that were sent to you

recently as well as a handful of other marketing pieces. The September release date is coming up
very fast. I know my office is working with Carly to set up a meeting and screening for next week.

This is a short clip from one video camera that was at one location from our Wolfmother shoot. The band thought it would be a cool idea to leak a renegade style :30 piece on you tube or similar to get people wondering about and talking about the video.

We know this would need to get cleared by Jackass/Paramount/MTV folks, so please let us know
the best way to get this done. Ideally we would love to get this up by the weekend.

Let me know if you need anything from me. We appreciate the immediate attention,
TS

Tony Seyler VP Film and TV Music Marketing Interscope Geffen A&M DreamWorks 2220 Colorado Avenue Santa Monica, CA 90404
310-865-7962 phone

310-865-5003 fax

CONFIDENTIAL

VIA00911453

Schapiro Exhibit 22

Schapiro Exhibit 23

Subject: From: To: Cc:

RE: Flavor Flav Press Update/Requests Kadetsky, Deborah <EX:/0=VIACOM/OU=MTVUSA/CN=RECIPIENTS/CN=USER ACCOUNTS/CN=USER/CN=KADETSKD> Kelly, Kristen, Taylor, Benjamin Date: Wed, 30 Aug 2006 21:51:57 +0000

OF COURSE. What clip do we have, and where do you want it? Youtube and ifilm are no brainers, as well as promotion to flav's friends on myspace....

>From: Kelly, Kristen >Sent: Wednesday, August 30, 2006 5:49 PM >To: Kadetsky, Deborah; Taylor, Benjamin >Subject: FW: Flavor Flav Press Update/Requests

>
>FYI, love this idea... can you help?

>
>Kristen Kelly >Manager, VH1 Series Production

>Office [phone]

>From: Olde, Jeff >Sent: Wednesday, August 30, 2006 2:37 PM >To: Cox-Hagan, Nigel >Cc: Delhomme, Chris; Wozniak, Maura; Kelly, Kristen >Subject: FW: Flavor Flav Press Update/Requests

>
>Nigel,

> >

>Am thinking we should get out end of this week with sneak of new york's return to the house to build audience for Sunday. Agree? Then next week we sneak all the drama she causes in 206. >Jeff Olde >SVP, Production & Programming VH1 >2600 Colorado Ave, 3rd Floor >Santa Monica, CA 90404

>P: 310-752-8255 F: 310-752-8553 > > > >
>From: Delhomme, Chris >Sent: Wednesday, August 30, 2006 2:21 PM >To: Olde, Jeff; Wozniak, Maura >Cc: Kelly, Kristen >Subject: RE: Flavor Flav Press Update/Requests > >We were thinking of releasing a clip next week, but if we can get something tomorrow or Friday, I'm sure it will get some play.

> >
>From: Olde, Jeff >Sent: Wednesday, August 30, 2006 2:12 PM >To: Wozniak, Maura >Cc: Kelly, Kristen; Delhomme, Chris

Highly Confidential

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>Subject: RE: Flavor Flav Press Update/Requests > >Sounds great. Let me know if I can help press clifton. Was going to give him and flav a call just to show some love. Happy to push, if needed. > >Would we want to leak the clip of ny returning to the house before Sunday??? Since the buzz is already out there, wondering if we play that card now to build ratings on next ep. Thoughts?

>
>Jeff Olde >SVP, Production & Programming VH1 >2600 Colorado Ave, 3rd Floor >Santa Monica, CA 90404 >P: 310-752-8255 F: 310-752-8553

> > > >
>From: Wozniak, Maura >Sent: Wednesday, August 30, 2006 1:19 PM >To: Olde, Jeff >Cc: Kelly, Kristen; Delhomme, Chris >Subject: Flavor Flav Press Update/Requests > >Hi Jeff,

>
>Hope all is going well. Below is a list of the press requests that have come in for Flav. We are still trying to confirm dates and times with Clifton but no luck so far. If we can get most of these done within the next week or so it would make for a nice mid-season press push, in addition to what we are looking to do for New York's return (see bullets below).

>
>* Tons of radio requests so we should do another 2 radio tours. One ASAP and another right before the finale. >* El's "The Daily 10" would like to have Flav in-studio for their "Shameless Plug" segment where they'll ask Flav a few questions and he can plug FOL2. >* Maury Povich would like to have Flav on as a guest -- still sussing this out. May not be feasible. >* Carson Daly would like to have Flav on as a guest.

>

>NEW YORK PRESS OPS. >* Leak to blogs on Wednesday, August 30 or Thursday, August 31 e.g. PerezHilton, Pink, TMZ, People.com, Vibe.com, Essence.com etc. >* Send out clip of NY coming back virally to YouTube, TMZ etc.on Tuesday, Sept. 5 >* Pitch weeklies for interviews/Q&A with New York and/or Flav. >* Pitch "At-Home" piece with New York for InTouch or OK Mag. (Production is checking on New York's living space.) >* Radio tour week of Sept. 12 to discuss having a second chance at winning Flav's heart. >* Continue to send out key viral clips of New York throughout the rest of the series.> >* Pitching LA-based talk shows. > >Thanks, > Maura

Highly Confidential

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Schapiro Exhibit 24