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

Filing 320

DECLARATION of Declaration of Scott B. Wilkens in Support of Viacom's Opposition to Defendants' Motion for Summary Judgment in Support re: 284 Memorandum of Law in Opposition to Motion,. 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, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46)(Kohlmann, Susan)

To: Jaimie Byrne .:[e-mail]::; Bordo, Sara .:[e-mail]::

From: Tipton, Kristina .:Kristina_ Tipton@ Paramount.com~

Cc: Andy Tress .:[e-mail]~; Caity Noonan .:[e-mail]::; Wahtera, Megan - Paramount .:[e-mail]:: Bcc: 2006-10-2622:23:38 GMT Received Date: RE: Confirmation Subject:
Hi Jamie,

We have a group set up at: http://youtube.com/group/beheard

This was set up using our profile at http://youtube.com/beheard

Username: beheard

Password:_
Let me know if you need any other information.

Thanks,
Kristina Tipton

323-956-8453

From: Jaimie Byrne (mailto:[e-mail]

Sent: Wednesday, October 25,20068:29 PM
To: Bordo, Sara Cc: 'Andy Tress'; 'Caity Noonan'; Tipton, Kristina; Wahtera, Megan -

Paramount
Subject: RE: Confirmation

Please let me know when this is set-up so i can make the URL change.

Thanks!

Highly Confidential

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Jamie

From: Bordo, Sara (maiito:[e-mail]
Sent: Wednesday, October 25,20069:14 AM To: Jamie Byrne Cc: Andy Tress: Caity Noonan; Tipton, Kristina: Wahtera, Megan-

Paramount
Subject: Confirmation

This note is 10 confirm that we do not want the brand channel and wish

our ww.youtube.com/beheard to direct to our Group asap. Thank you\

Sara Bordo
Director, Motion Picture Interactive Marketing

Paramount Pictures

323.956.8499
323.862.1107

From: Jamie Byrne (mailto:[e-mail]

Sent: Wednesday, October 18,20067:00 PM
To: Bordo, Sara Cc: 'Andy Tress'; 'Caity Noonan' Subjec: FW: Revised Freedom Writers Proposal

Sara:

Here is the overview for the Freedom Writers channel and group. It

should provide most of the information you need to help understand how
the different components work.

In thinking through our conversation earlier - you placed a lot of emphasis on the ability to have consumers talk about the clips and write comments on the channel; you also wanted the ability to moderate these comments. This functionality is really delivered on by Groups more than it is in the ChanneL. I'm pretty confident that between the Group and Channel, we can make sure we have a really interactive, immersive environment for the users.

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We might want to consider having the http://ww.youtube.com/beheard URL

actually drive consumers directly to the group instead of the channeL.
There will be more interactivity in the channel and I think it might be

the more natural hub.

We can discuss in more detail tomorrow or Friday.

Thanks.

Jamie

From: Caity Noonan (mailto:[e-mail]
Sent: Wednesday, October 18, 20066:37 PM
To: 'Jamie Byrne'

Subject: Revise Freedom Writers Proposal

Hey Sara-

Sorry for the delay, I have been working with Andy on the Freedom Writers proposal and he asked that I sent you this revised media plan. i have also attached our step by step document for creating a Brand ChanneL. It includes the specs for each unit and goes through the process so you will be able to completely customize your page. it also includes screenshots of the Group page. Andy and Jamie will walk you through the process of how these are related. Thanks\

Caity

Caity NoonanlAccount Managerl
1000 Cherry Ave. Suite 200lSan Bruno, CA 940661
cell:

fax:

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email: [e-mail]
http://www.youtube.com

Attachments:

image001.jpg

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