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)

30b

Deposition of

Do

Cuong

9/12/2007

OUTSIDE HIGHLY C0NnDENTIAL EYES ONLY COUNSELS
--

11

Page ________________
Den. Tab

UNITED FOR THE

STATES

DISTRICT
OF

COURT

Figueira

SOUTHERN

DISTRICT

NEW

YORK

VIACOM INTERNATIONAL INC. COUNTRY MUSIC COMEDY PARTNERS TELEVISION INC. PARAMOUNT PICTURES and CORPORATION BLACK ENTERTAINMENT TELEVISION

LLC
Civil

Action

Plaintiffs
vs. No.

07-CV-2103

YOUTUBE

000GLE

INC. INC.

YOUTtJBE

LLC

and Pages thru 141

Defendants.

THE

FOOTBALL LIMITED of

ASSOCIATION
and BOURNE and

PREMIER

LEAGUE behalf

CO.
all

on

30b

Deposition CUONG DO

of

themselves

others

similarly situated Plaintiffs
vs.

September Volume

12

2007

YOUTUBE

GOOGLE

INC. INC.

YOUTUBE

LLC

and

Defendants.

JAN

BROWN

ASSOCIATES

REPORTING
LIVENOTE 221 San Main

FOR
SERVICE Suite 1250 94105 321-2301

WORLD Street

Francisco

California

Phone

415

321-2311

Fax

415

LiveNote

World Service

800.548.3668

Ext.

30b

Deposition

of

Do

Cuong

9/12/2007

11-0002

Page

134

A.
Q.

Im
The

sorry. full

What

do

you some

mean
portion
of yes. it.

file not
byte

A.
Q.

Every
Pxid

single for

in

the

file
can

just

laerson

you

quickly

say

what

an A.

MD5

Hash

is
Hash
is meaxit it to

An MD5

be

guess direction. takes whatever fixed

crtographic

meaning

that

goes

in one that

Its

complex

mathematical
amount
of

function data
of

arbitrary
10 11 12 13
14

number

and that

generates data. that

size

guess

representation
sort
of

Its
of

like up that

number that
if

basically kind And

very

approximately sums
to

information. you change one

its
then

meant the
Q.

be

the

case

byte

whole
So

task

changes.
go

15 16 17 18 19 20 21 22 23 24 25

you

could you

from the

the

original

video

file

and

apply
A.

this
Yes.

and

get

Hash

correct

Q.

You

cant

go

backwards

from

the

Hash

to

the

video

file
A.

That

is

correct. you said
as if

Q.

And

think

you

have

exactly video

the

same
it

content

in another the

file

the

original
Is

file

would produce
A.
Q.

exact

same

Hash.

that

right

Thats
But
if

right. you change the content one

iota

it

LiveNote

World

Service

800.548.3668

Ext.

30b

Deposition

of

Do

Cuong

9/12/2007

11-0003

Page

135

produces
A.
Q.

different

Hash

Thats
What That some

right. the audio content some by

about
is

ID
software the provided

A.

generated using
that
is

by

the

software

used

Audible

Magic

Company.
Q.

Audible Magic
Yeah.
Piid

A.

we

generate the time

that that

for we

every started

video using

going
10 11 12 13
14

forward

like

since

it. Is of it

Q.

also

the
it

same

that

if

you

change

one

tiny

bit

the

video

creates

whole to

new
object

ID
to

MR.

HOHENGPTEN

Im

going

this.

Ive

given need

you
to

pretty broad
stay not with
go

latitude

here

but

we

15 16 17 18 19 20 21 22 23 24 25

really

the

electronicallystored
the content of these

information various

and

off

frito

identifying
MR.

technologies.

HOHENGARTEN
the

Well
is

Im

just
is

trying being

to stored

figure and
so

out

what

information

that

MR.

HINDERJCER
getting and off not

Well
into into the the

ask

him those
of

questions

then. various

Were

content storage

these data.

systems THE
MR.

of

WITNESS
HINDEPAKER

Its
Well
wait minute.

Lets

LiveNote

World

Service

800.548.3668

Ext.