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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12/17/2009 Walker Kent OUTSIDE HIGHLY CONFIDENTIAL COUNSELS EYES ONLY -- UNITED FOR THE STATES DISTRICT DISTRICT COURT OF SOUTHERN NEW YORK Tab VIACOM PARTNERS INTERNATIONAL COUNTRY INC. COMEDY Figueird Derl. MUSIC. 116 TELEVISION PICTURES INC. PARAMOUNT and BLACK CORPORATION ENTERTAINMENT TELEVISION LLC Plaintiffs vs. NO. 07-CV-2103 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. 10 11 THE 12 FOOTBALL ASSOCIATION BOURNE PREMIER et all LEAGUE on LIMITED of CO. and al. behalf themselves 13 others similarly situated 14 vs. 15 Plaintiffs NO. 07-CV-3582 YOUTUBE 16 INC. INC. YOUTUBE LLC and GOOGLE 17 Defendants. 18 VIDEOTAPED DEPOSITION OF KENT WALKER PALO ALTO 19 20 CALIFORNIA THURSDAY DECEMBER 17 CSR 2009 BY CSR JOB ANDREA M. IGNACIO 9830 HOWARD RPR CLR LICENSE NO. NO. 18312 21 22 23 24 25 12/17/2009 Walker Kent WALKER bullet notice has point or KENT 116-0002 reads when Youlube obtains receives of takedown clip that otherwise the knowledge it eluded not filtering clip or system or full of should in immediately but remove all only the work the question other versions excerpts in the the same in copyrighted to to programming hashing prevent 10 identified notice addition and fingerprinting unauthorized copyrighted as work future uploads discussed above. My question February of In 11 is did Google do that in 12 2007 for some 13 period it of time previous had to 14 that dont know MDS when started which when YouTube 15 system called copies of for hashing video identified we we unique DMCA other 16 given one and received would block 17 notice version also had believe that of same 18 versions the that hash which where is by we were the 19 way another or URL example situation without going 20 removing specific DMCA blocking items having beyond received what the 21 and believe 22 requires. The 23 other aspects is of this question the the its question 24 because is the sentence compound if you 25 derivatively compound will so its 130

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