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

David
Suzie

Eun Reder

[e-mail]
[e-mail]

Cc
Bce
Received Subject

Figueira
Date
2007-05-20

Den. Tab 100

194700 CST
to

RE

Path

YouTube

Monetization

5.14.07

another

long

flight

for

you
from from
at that Jeff

take

look

at

the note

Dejelo
1f

we
and

spent he

while looking
lot in

the

what

for

the search

results

pages

captured

doe.

we
it

believe

search such

will

be stronger than watch
time for
to
all

for nowcontent
all

simply because claimed
inventory at
will

will

take

long

the watch today

to

be

and
that

for inventory can be
sold
is is

levels less

get huge
2Omillion
split

watch

page

than

impressionsfrnonth

so even
this

$10

cpm

that

$200000

70/30

among

all

partners

change

as content

gets claimed
strive to

AND we
more
stages

program

the user experience

better/more

and

create
in

inventory

aorund

premium
at

content.

new ad

concepts

are just

early

as
unit

you

saw

meeting

the 300x250

in

search
or

is

really fledble static

any
rich

length

commerical/content
targeted.

ad

can

accpet

media and

it

can

be

so for now

it

shows

lot

more promise.

hope

this

makes

sense.

From
Sent

David

Eun May
Path
to

Sunday

20 2007
YouTube

1204

PM
5.14.07

To

Suzie

Reider

Subject

Re

Monetization

Suzie
from the Conference

Hope

you

are recovering

Am

about

to

leave

for

London

and am wondering

if

you

had

any

additional/new

thoughts

youd want
think

me

to

share.

Im

still

not

clear

on

what we
source
of

the search-driven revenues
inherent

ads are going watch pages. results

to
Is
it

be such

stronger

ad

than
in

from

because theres Drop me Thanks Dave

natural

packaging
shot.

the search

line

when

you

get

On

5/14/07

Suzie

Reider

wrote

you can

look

at

this

on the

ride

West. DATE.

ExHIBIT

DEPONENT

bEC
eta.
v.

CASE
Case

Viacom

YouTube
et at. v.

et

al.

The Football
et al.

Association

Premier

League
and

VouTube

Nm. 07-CV-2203
A. Tgnacio

07-CV-3582
No. 9830

Howard

CLR RPR CSR

Highly

confidential

G00001-00907818

its

very early
thing if

look at how
if

to

present

this.

100-0002

Heres the
outsiders ear.
to critque

we

give

too much

info to

were
those

just

inviting

we assume
is

ES may hand
really that

who

have

his

So my question
really high level
all

do you

want

to

show
in

detail

or just

that
this.

will

demonstrate

we do

fact

have

our act

together

on

My
well

gut

says

high-level

launch

ad

in

search

on

july

1st

revenue

proejctions

are
will

watch slower
in

page be

concepts

are being
ot

tested

and the revenue
currenlly

be

coming there
will

as only

.14%

watch
selling

big

team

pages can all this when

be

monetized.

the sales

re-org

is

complete
it

early July
all

takes

resources

and

to to

compete
bLAld

with

Yahoot programs

MSN

and AOL
within

we need

world class

Myspace Facebook ad strategy and

team

GMS
all

and YouTite.

but

you

know
have
but

that...

anyway
or keep design the detail and have

look either

and

Ill

either

take

it

to

bigger picture
lot

one

way we can represent pager that we feel good about

wth good
around the

floating

company.
-Suzie

David

Eun

NY

212-565-8070 650-253-1993

CA

CONFIDENTIALITY.
the intended
privileged

This communication

is

intended

only that

for
is

the use of

recipients
confidential.

and
If

may

contain
not

information

and

you are

the intended

recipient
is

please

note

that
If

prohibited.

any dissemination of this communication this communication in you have received
of

error

please

erase
also

all

copies

the message

including

all

attachments

and please

notify

the sender

immediately.

Thank

you for your cooperation.

Highly

confidential

G0000l-00907819