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.. 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5/6/2009 Schmidt Eric UNITED FOR THE STATES DISTRICT DISTRICT COURT OF SOUTHERN NEW YORK VIACOM PARTNERS INTERNATIONAL COUNTRY INC. COMEDY MUSIC PARAMOUNT and FigueirdDecI.Tab 111 TELEVISION PICTURES INC. CORPORATION BLACK ENTERTAINMENT TELEVISION LLC Plaintiffs vs. NO. 07CV2203 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. 10 11 THE 12 FOOTBALL ASSOCIATION BOURNE PREMIER et LEAGUE on LIMITED of CO. and al. behalf themselves all 13 others similarly situated 14 vs. 15 Plaintiffs NO. 07CV3582 YOUTUBE 16 INC. INC. YOUTUBE LLC and GOOGLE 17 Defendants. 18 VIDEOTAPED SAN DEPOSITION FRANCISCO MAY OF ERIC SCHMIDT CALIFORNIA 2009 19 20 WEDNESDAY JOB NO. 16802 21 22 23 24 25 5/6/2009 Schmidt Eric SCHMIDT If ERIC see the little be civil website. 111-0002 you says look below it Then you caret offense It from. It the would to create see. Okay. be thats from Wire.com So to incredibly wrote precise were on these Digital cmails the only words that the Millennium Copyright see. Got Act. it. Okay. 10 Now instruct Mr. when Google and purchased Mr. Chen YouTube that to did you 11 Hurley their primary grow the user 12 goal base at least reach MR. immediate one goal views was 13 and billion per lacks day foundation. the 14 MANCINI WITNESS Objection 15 THE dont recall very 16 specific goal. MR. 17 BASIKIN you said to Q. Does it sound like generally their 18 something them be that to their the that user 19 primary objective Our our base. should policy That grow base to 20 from is acquisition was 21 grow the user And -- correct 22 23 dont You recall recall the specific they numbers. 24 dont one that should grow it to 25 playbacks of billion day 109

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