The Football Association Premier League Limited et al v. Youtube, Inc. et al

Filing 166

DECLARATION of Elizabeth Anne Figueira in supoport of Class Plaintiffs' Statement of Uncontroverted Material Facts in support of Their Motion For Partial Summary Judgment in Support re: 158 MOTION for Partial Summary Judgment dismissing with prejudice Defendants' First Defense asserted in Defendants' Answer to the Second Amended Class Action Complaint... Document filed by The Music Force LLC, Cal IV Entertainment, LLC, Cherry Lane Music Publishing Company, Inc., The Football Association Premier League Limited, Robert Tur, National Music Publishers' Association, The Rodgers & Hammerstein Organization, Edward B. Marks Music Company, Freddy Bienstock Music Company, Alley Music Corporation, X-Ray Dog Music, Inc., Federation Francaise De Tennis, The Scottish Premier League Limited, The Music Force Media Group LLC, Sin-Drome Records, Ltd., Murbo Music Publishing, Inc., Bourne Co.. (Attachments: # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6, # 7 Exhibit Exhibit 7, # 8 Exhibit Exhibit 8, # 9 Exhibit Exhibit 9, # 10 Exhibit Exhibit 10, # 11 Exhibit Exhibit 11, # 12 Exhibit Exhibit 12, # 13 Exhibit Exhibit 13, # 14 Exhibit Exhibit 14, # 15 Exhibit Exhibit 15, # 16 Exhibit Exhibit 16, # 17 Exhibit Exhibit 17, # 18 Exhibit Exhibit 18, # 19 Exhibit Exhibit 19, # 20 Exhibit Exhibit 20, # 21 Exhibit Exhibit 21, # 22 Exhibit Exhibit 22, # 23 Exhibit Exhibit 23, # 24 Exhibit Exhibit 24, # 25 Exhibit Exhibit 25, # 26 Exhibit Exhibit 26, # 27 Exhibit Exhibit 27, # 28 Exhibit Exhibit 28, # 29 Exhibit Exhibit 29, # 30 Exhibit Exhibit 30, # 31 Exhibit Exhibit 31, # 32 Exhibit Exhibit 32, # 33 Exhibit Exhibit 33, # 34 Exhibit Exhibit 34, # 35 Exhibit Exhibit 35, # 36 Exhibit Exhibit 36, # 37 Exhibit Exhibit 37, # 38 Exhibit Exhibit 38, # 39 Exhibit Exhibit 39, # 40 Exhibit Exhibit 40, # 41 Exhibit Exhibit 41, # 42 Exhibit Exhibit 42, # 43 Exhibit Exhibit 43, # 44 Exhibit Exhibit 44, # 45 Exhibit Exhibit 45, # 46 Exhibit Exhibit 46, # 47 Exhibit Exhibit 47, # 48 Exhibit Exhibit 48, # 49 Exhibit Exhibit 49, # 50 Exhibit Exhibit 50, # 51 Exhibit Exhibit 51, # 52 Exhibit Exhibit 52, # 53 Exhibit Exhibit 53, # 54 Exhibit Exhibit 54, # 55 Exhibit Exhibit 55, # 56 Exhibit Exhibit 56, # 57 Exhibit Exhibit 57, # 58 Exhibit Exhibit 58, # 59 Exhibit Exhibit 59, # 60 Exhibit Exhibit 60, # 61 Exhibit Exhibit 61, # 62 Exhibit Exhibit 62, # 63 Exhibit Exhibit 63, # 64 Exhibit Exhibit 64, # 65 Exhibit Exhibit 65, # 66 Exhibit Exhibit 66, # 67 Exhibit Exhibit 67, # 68 Exhibit Exhibit 68, # 69 Exhibit Exhibit 69, # 70 Exhibit Exhibit 70, # 71 Exhibit Exhibit 71, # 72 Exhibit Exhibit 72, # 73 Exhibit Exhibit 73, # 74 Exhibit Exhibit 74, # 75 Exhibit Exhibit 75, # 76 Exhibit Exhibit 76, # 77 Exhibit Exhibit 77, # 78 Exhibit Exhibit 78, # 79 Exhibit Exhibit 79, # 80 Exhibit Exhibit 80, # 81 Exhibit Exhibit 81, # 82 Exhibit Exhibit 82, # 83 Exhibit Exhibit 83, # 84 Exhibit Exhibit 84, # 85 Exhibit Exhibit 85, # 86 Exhibit Exhibit 86, # 87 Exhibit Exhibit 87, # 88 Exhibit Exhibit 88, # 89 Exhibit Exhibit 89, # 90 Exhibit Exhibit 90, # 91 Exhibit Exhibit 91, # 92 Exhibit Exhibit 92, # 93 Exhibit Exhibit 93, # 94 Exhibit Exhibit 94, # 95 Exhibit Exhibit 95, # 96 Exhibit Exhibit 96, # 97 Exhibit Exhibit 97, # 98 Exhibit Exhibit 97 part 2, # 99 Exhibit Exhibit 98, # 100 Exhibit Exhibit 99, # 101 Exhibit Exhibit 100, # 102 Exhibit Exhibit 101, # 103 Exhibit Exhibit 102, # 104 Exhibit Exhibit 103, # 105 Exhibit Exhibit 104, # 106 Exhibit Exhibit 105, # 107 Exhibit Exhibit 106, # 108 Exhibit Exhibit 107, # 109 Exhibit Exhibit 108, # 110 Exhibit Exhibit 109, # 111 Exhibit Exhibit 110, # 112 Exhibit Exhibit 111, # 113 Exhibit Exhibit 112, # 114 Exhibit Exhibit 113, # 115 Exhibit Exhibit 114, # 116 Exhibit Exhibit 115, # 117 Exhibit Exhibit 116, # 118 Exhibit Exhibit 117, # 119 Exhibit Exhibit 118, # 120 Exhibit Exhibit 119, # 121 Exhibit Exhibit 120, # 122 Exhibit Exhibit 121, # 123 Exhibit Exhibit 122, # 124 Exhibit Exhibit 123, # 125 Exhibit Exhibit 124, # 126 Exhibit Exhibit 125, # 127 Exhibit Exhibit 126, # 128 Exhibit Exhibit 127, # 129 Exhibit Exhibit 128, # 130 Exhibit Exhibit 129, # 131 Exhibit Exhibit 130, # 132 Exhibit Exhibit 131, # 133 Exhibit Exhibit 132, # 134 Exhibit Exhibit 133, # 135 Exhibit Exhibit 134, # 136 Exhibit Exhibit 135, # 137 Exhibit Exhibit 136, # 138 Exhibit Exhibit 137, # 139 Exhibit Exhibit 138, # 140 Exhibit Exhibit 139, # 141 Exhibit Exhibit 140, # 142 Exhibit Exhibit 141, # 143 Exhibit Exhibit 142, # 144 Exhibit Exhibit 143, # 145 Exhibit Exhibit 144, # 146 Exhibit Exhibit 145, # 147 Exhibit Exhibit 146, # 148 Exhibit Exhibit 147, # 149 Exhibit Exhibit 148, # 150 Exhibit Exhibit 149, # 151 Exhibit Exhibit 150, # 152 Exhibit Exhibit 151, # 153 Exhibit Exhibit 152, # 154 Exhibit Exhibit 153, # 155 Exhibit Exhibit 154, # 156 Exhibit Exhibit 154 Part 2, # 157 Exhibit Exhibit 154 Part 3, # 158 Exhibit Exhibit 154 Part 4, # 159 Exhibit Exhibit 155, # 160 Exhibit Exhibit156, # 161 Exhibit Exhibit 157, # 162 Exhibit Exhibit 158, # 163 Exhibit Exhibit 159, # 164 Exhibit Exhibit 160, # 165 Exhibit Exhibit 161, # 166 Exhibit Exhibit 162, # 167 Exhibit Exhibit 163, # 168 Exhibit Exhibit 164, # 169 Exhibit Exhibit 165, # 170 Exhibit Exhibit 166, # 171 Exhibit Exhibit 167, # 172 Exhibit Exhibit 168, # 173 Exhibit Exhibit 169, # 174 Exhibit Exhibit 170, # 175 Exhibit Exhibit 171, # 176 Exhibit Exhibit 172, # 177 Exhibit Exhibit 173, # 178 Exhibit Exhibit 174, # 179 Exhibit Exhibit 175, # 180 Exhibit Exhibit 176, # 181 Exhibit Exhibit 177, # 182 Exhibit Exhibit 178, # 183 Exhibit Exhibit 179, # 184 Exhibit Exhibit 180, # 185 Exhibit Exhibit 181, # 186 Exhibit Exhibit 182, # 187 Exhibit Exhibits 183 - 187, # 188 Exhibit Exhibit 188)(Figueira, Elizabeth)

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To From Tim Armstrong lim@google.com Suzie Reider Kurt Abrahamson kurt@google.com sreider@youtube.com Cc Bcc Received Subject Date 2007-03-21 022400 CST 2007. ppt Figueira Den. Tab VT monetithtion March Sharing the PPT has that was shared with Susan Gokul Rajas and Joan today. Shashi Seth joined the YT team focused on monetization and led this discussion. Hes drMng Susan could much hear of this development development and todays check-in support as largely so about Again by early summer ready we to should have large the ad concepts in baked to sell like the systems/back-end crazy. go and team place It feels like it is coming along. Itll be fun to see the usability testing this week for the instream.. YouTube one.. through it treasury really just is referenced paying in here... will dont think to we have be done means the users need adsense. Were getting closer. The other tension which review is Ill highlight to in our next quarterly business and the our commitment of monetize on it. the partner content challenge low page views Attachments YT monetization March 2007.ppt Highly confidential GO000i00906824 YouTube Monetization Strategy VC1UA1 cUu Yofl Ni Ii. C. Ni Ii -S -4 -S YS -c -4 -S C- ci 4as -C 4- Highly Cohfdentia. 000001- 00 90 682 Consolidated Roadmap for YT Monetization UGC Monedzaton II 2007 Launch. FuU program UGC Test Content PYV Phase MonedzaUon PUot instream Ads Test Start DoubeciicktoGAM MqraUon New Ad Formats 02 04 03 on \f Search from instream Ads and Mkjration Usabifity CW Ads Compiete integraUon Pubflsh resufts Doub.ecUcktoGAM GAM Compete to Adsense PYV Phase if tbC dt .4 1-0005 cDc 00 Wc a C .00 Highly Confidentiil G00001-00906828 Probem we are addressing are Top useNpubflshers ookng for ways to monetize their content Corn pethors have started revenue sharing and our taient attracting some of away 4t d4 Oi N3 Goats We wifi provide patform for our users that wifi aVow them to make Hying out of their creativity Attract retain and taent on YOUTLthC of higher Encourage quahty creation and quantity UGC iaws on YouTube Provides top taent carrot for foflowing copyright Focus the top taent on creating new content and YouTube wifi take care of business PHot details Top 50 users nvited 1.o parficipate .Aflow users to teD us which content or at this time can be monefized in the upbad process my accounts Only dspay ads used Ads served oy if CAM can be monetimd and Ensure at only oriqina content fingerprinfing Also ensure that duplicated manua review monetizabftcontent cannot be upioaded Provide simpe reportng on daily basis on my accounts Payment through YouTube treasury 1.. 0. cn Highly Confidential G0000t- 00 906832 Key Dates and Roadmap I-. 3/28/2007 Launch PUot 4130/2007 Pubhsh resuRs from the Pot flesuRs froni instream Ad experiments back 5/30/2007 G.AM to Adsense ntegraton compiete $/14/2007 Launch FuU UGC Revenue Sharing 1-0011 fl ci cci Cc E0 Highly Confidential Go000l-00906834 Monetization Models Available Available Now 2H07 CPM $8 Floor 728x90 Display Sanner CPM TBD Ni Ui YouTube Saes Phuosophy dftect YouTube pursung seies for biue reseivation-based sales strategy chip brand advertisers inventory DeUvers on promise of VouTube protects vaiue of Maximizes revenue and Obt.anng sponsoshps ro painers arhsts track record or inventoy traffic ndvdua forecasts events is scabie No proven VouTube becomes Habie for non guarantees inventory not aUractive to advertisers GeneraHy partner low volumes of per YouTube wifi maximize revenue arger pocs of inventory avaflable through by leveragnq content category targefing AVows increased Creates scalable program benefit CPM rates through audience sIzes for iarge of targeting advertising commitments aggregated inventory Smafler partners from scale OUT CategoryBased Saes Approach 9QY.i14Iigthg. Vehdes Autos Comedy Entertainment Animation Film Gadgets Games How To MuSc PoflUcs News E3ogs Peope Ankmas Pets Sports Trave Paces Yu ubc Ui -J E2 Qfl tm cRd tu .w CL0 bt wn Cl c3j tScl 02 ec iii 0T3E s. Oca Eca D z0 . a cZ Highly Confidential G0000i.00906838 ft Key Dates and Roadmap NOW GAM Mgrafion nMonetization of Partner Content March May 2007 -___-___--i nStream Ad Tra March 2007 Apr11 2007 Prernum Content Saes Tranng iii I. Video Ads Test cO 0\ Goas severa ad icr user TESI effectiveness mods innovation hiqh response ad penorma.nce and brand step niidsize First scaabe adverUsers. contentgeo4argeting bar for creative enabtina optimal wifi Discover models this test to consider for broader roflout aD models survive metrics Estabflsh performance Co I. Overview and key dates When week test hi March March 28 tentative for Objecflve Evaiuate user response and ad performance several ad mods induding combinations of pacement companion units geo/content-tarqeting advertisers .Afl Scope 5i 5070 videos Management to soecific tarae.ted campaigns wifi be frequencycapped videos and in some cases geota.raeted consumption reotdng and user study Measurement Detailed responsa/brand effectiveness CD What are testing to test variety of we Go is innovations targeting ad rnods and pursue potenti and adverfiser enabement Muffipe CTP image text video postrolls /1 N. Bumper Post.roll nterstitias Mods CTP videos on search Companion vs. Ita rgefing Banner Overlay e.g. visitors Bay Areas Am oeba Records on music Targetinq Keyword targeting videos for SF Search Ia Mo nd om W.M BM JA 9i idsize Ad Enable E.g. small/rn Creaton brands to create video ads using UGC UGCI American Apparel AG Jeans ................. ...... Amoeba L............. 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