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)

To
From

Jeff

Jay Yagnik [e-mail] Faust [e-mail]

Michele Covell

coveIl@googletom _____________________

Cc
Bce
Received Subject

Date

2007-04-25

001917

GMT
cost for

Figueira
hour of reference content

Den. Tab 10

Fwd

Fingerprinting

__________________________________________________
You guys might be Forwarded
interested.

message

From
Date
Subject

[e-mail] PM Apr 24 2007 411

Jeff

Faust

Re

Fingerprinting

cost for

hour

of

reference

content

To Cc

Ba [e-mail]
Franck

[e-mail]

david

king

[e-mail]

published

some

rough

numbers

here

http//trix.corp.google.com/pubkeypfZfCQU-ItyUc7HCh6x39fQ

This
will

is

just

storage chunk

estimate.

The

main componont
directly for those. to

of

machine

cost

be GFS

servers
not

which
to

correlates

the storage

estimates

but

Im

sure how

account

-Jeff

On

4/24/07
is

Bo [e-mail] $660 $90 $200 know

wrote

capex
opteron

RAMIGB
Disk/TB
btw
that

our pso
ingest

folks

perhaps

about

tv

recording.

they have

such

system

into

google

backend.

On
Hi

4/24/07
Jeff

Franck

Chastagnol

[e-mail]

wrote

and

Bo
get to the business
of that

rn trying

to

the hardware
fingerprint

and

maintenance

cost of

adding

hour
is

video

to

the reference
bill

database. wanting
to

The idea
content would
in

on YT. And
like

we may some of we would use this

the companies per hour

block
tag.

cost for as price

to

get conservative

numbers better

edge

on

the higher side

terms

of

costs.
is

Assumption
could
to

300000
tell

lookup

daily

with

5mm

long lockup

videos.

Jeff

you
be

us how hour of

much
ref

hard

disk

space and how
reason

much RAM
that

are

needed
It

handle

fingerprint
for

is

ok

to
in

conservative

and

performance

say

everything

has

to

be

RAM.

Ba

would you know

the capex

for

linux

server

in

datacenter

at

google

RAM

and what are the specs

of

such

server

in

terms

of

hard

drive

space and

gg/i
CASE
Case Viacorn Association Nos. A. 07-C

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EXHiBIT
19

G1i5FwI
et at. V.

YouTube
et at.
V.

et

al.

The

Football et

Ptemier V-2203

League
and

07-C

YouTube V-3582
No.

at.

fgnacio

Howard

CLR RPR CSR

9830

Highly

Confidential

00000l00103004

10-0002 For your
related.

reference

have

pasted

below

an email thread we had which

was

Let

me

know

any question

Thanks
Franck

On

4/5/07 hard

Jeff for

Faust
to

cjfaust google.

corn wrote
numbers
distinct
until

Its

me
is
It

come

up

with

good
are two are

the

design

for

the

LSH
that

engine design.

finalized.

There
like

paths
sublinear

we can
costs.

take

for

also looks the cost

there

some
is

One
intially

design

makes

per reference

second

much added

higher vary low video

with

the incremental increasing
to

cost as ref ernce
like

material

eventually

something

linear

cost per reference

second.

Ill

try

to

get

handle

on

this

as

soon as possible and

give you

some

real

answers.

-Jeff

On 4/4/07 wrote Jeremy Doig [e-mail] we chatted about this today briefly do we really need to keep the video Im intrigued by the idea of piece of software that looks at what is
coming
in

the video

card

and drops

out fingerprints

every

linterval.

if you
assume need
is all

broadcast

content

is

copyright

in

some

fashion

all

you

tribune think this

feed

we

should

on top be

of

that

something about saying

careful

more accurate. we can do something

like

though.

and

could

only

be done

when

the algo

is

stable.

On

4/4/07

Jay Yagnik

[e-mail]

wrote

Jeff
lately.
Ill

has been

plang

with the designs

for

disk

vs.

memory

systems

let

him

comment

on the estimates.

On
Hi

4/4/07

Franck

Chastagnol

[e-mail]

wrote

Jay asked

So the business add
this

if

we

could

record

some

TV

channels

24/7

and

content Besides

to

our reference

fingerprint

DB.

the technical

issues like

commercials

etc...

we wanted

to

also

have them

understand

the infrastructure

cost

of

this.

So assuming

1Gb

of

disk

storage

costs

dollars

Highly

Confidential.

300001-00103005

1Gb

of

memory
lockups

costs per day

dollars

10-0003 average video
length of

300000
Then
hour
of

with an

5mm

my

question

is

what

is

the infrastructure

cost

for

every

reference

content

we add
looking

to

the video

fingerprinting

reference

DB

Again edging

Im

not

at

detailed

number.

Just

rough

estimate

on the high smde Thanks
Franck
for

rather

then

low

side.

all

your help

Highly

Confidential

G0000100103006