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

Filing 316

DECLARATION of Susan J. Kohlmann 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 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29)(Kohlmann, Susan)

To:

"Rami Bitar" <ramiQgoogle.com>

From: Cc:
~matthewQyoutube.com>
Bcc:

"[e-mail]" <[e-mail]> "[e-mail]' <shashisOgoogle.com>, 'Matthew Liu"
Date: 2007-08-14 Re: Warner 00:39:36 CST Music search

Received Subject:

results

Thanks

Rami.

Shashi, I know the google search product is never to change our search algorithms to favor partner content - I would never suggest this nor would
Warner expect it. My point is --

when a user types in a set of keywords "Artistname+ song' shouldn't the
official content show up first ahead of pirated versions? in what instance can we justify showing a copyrighted version above the
official one?

a call would be helpful regardless of how useful we think it would be -- I guarantee from a relationship management standpoint, they will greatly value any background we can give. On 8/13/07, Rami Bitar <rami ~google.com> wrote:

> ~z Just so I can explain my thinking here: we should never be in the > business of changing our search algorithms to favor content based on who the
> owner is.

> Agreed, our current plan is to use

> We also plan to launch a partner one box that willtrigger a channel > result when a query highlymatches a channel tie, "BBC")-- but this won't
> be release until v24 (October 31) at best.

~ >> But they have requested we set up a call with their engineers and a few > folks from our product team so they can find out anything else they can be > doing to better the search e~q~erience their video results show up at the so > top when say someone types in "madonna like a prayer"
~ Sure thing -- we should include David Stoutamire who is the Tech Lead in

~ MountainView on search quality. Myonly hesitation is that they have > strict policies against discussing ranking (even at a high-level)with
z anyone at Google much less outside of Google, so I'm not sure how useful the
> discussion will be.

> David might still be on vacation but I'IIstart a thread land CC you) to
> setup a time for this call.

> Best,

DeposltlonofVG,ui
Testimonyol
E~L)Y

PlalnUR yrt I~endant Ca/ O

Highly

ConfidentidL

600001-00833914

~ Rami

:On Shashi<shas~isegwgle.com> 819/07, Selh wrole·
,>

> > Just so I can e~p~lainmy thinking here: we should never be in the > ' business of changing our search algorithms to favor content based on who the · > owner is. In search the same requests come to us from NY Times and Wall

> > Street Joumal - who claim that their content should always be placed higher
· s than anybody else.

~ z The onebox achieves this by keeping, the search results the same because · ' our algorithm picked it based on raking/relevance, etc. - yet lets the user > r know that the onebox simply points out where the 'original"content lives.
>r Shashi

> > On 8/9/07, Shashi Seth < shashisQgoogle.com>
zir

wrote:

> > > I willlet Rami reply to this, but in my opinionthe only way we can > > > do this through a "onebox"which shows "original" content first when an
· > > exact (or very high confidence) match happens. I think this is on Rami's
z > > roadmap
z>>Shashi

- but not sure when.

> > > On 8/9/07, Ali < alizaQyoutube.coml
>ri>

wrote:

> , > > Hey Rami, Shashi,
>>>z

· , z ~ Warner Musichas been askingfor some time now,for furtherclarity
> > ' > around our TT search results. As you can imagine, they are a bit frustrated · z > > with copyrighted versions of their videos showing up first in search > ' > r results. I know this is not an easy fixand part of a much larger effort we > > ' > continue to work on. But they have requested we set up a call with their > ' > > engineers and a few folks from our product team so they Can find out s ~ ~ s anything else they can be doing to better the search experience so their > > z > video results show up at the top when say someone types in "madonna like a
> > ' > prayer"

· , , > http.//www.youtube com/results?search_query=madonna+like+a+prayer&search=Search
>>ri

~ > > > Or "the white stripes"
>2>~

> > > , http.//www.youtube com/results?search_query=the+white+st ripes&search=Search
>~>1

> > , z they seem to come up second, or furtherdownthe chainalmostevery > ' > > time. Inthese cases, theirvideosshouldbe showing first. Areyouthe up
> > > ' correct person to involve? They understand we willnot be givingthem a r , > 1 clear solution on this call, but want to better understand our product and > > ' > vision. Let me know who else I should include. Hoping to set this up for
> > > ~ Monday or Wed of next week.
z>rr

> ~ > > Thanks,
~ > z ~ Ali

Highly

ConfidentidL

600001-00833915

>>>>

>>>

>,>--

> , z Shashi

Seth

> > > What Primetime? There is no more Primetime! YouTube users decide when

> > > it is primetime - and that willchange the dynamics of TV and Video
> z > advertising.
z>
,r

>>--

> > Shashi

Seth

> > What Primetime? There is no more Primetime! YouTube users decide when it

z z is pn'metime - and that willchange the dynamics of TV and Video
> advertising.

~ Rami
>

Bitar

> YouTube-Google
> ramiQgoogle.com

Highly

ConfidentidL

600001-00833916