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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712212008 Walker Patrick UNITED FOR THE STATES DISTRICT DISTRICT COMEDY OF COURT SOUTHERN NEW YORK FigueirdDecl.Tab 122 VIACOM PARTNERS INTERNATIONAL COUNTRY INC. MUSIC TELEVISION PICTURES INC. PAR1OUNT and CORPORATION BLACK ENTERTAINMENT TELEVISION LLC Plaintiffs vs. Case No. l07CV02103 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. THE FOOTBALL ASSOCIATION BOURNE PREMIER et al LEAGUE on LIMITED of CO. and behalf themselves all others similarly situated Plaintiffs vs. Case No. 07CV3582 YOUTUBE GOOGLE INC. INC. YOUTUBE LLC and Defendants. DEPOSITION SAN OF PATRICK WALKER FRANCISCO JULY CALIFORNIA TUESDAY REPORTED YVONNE JOB NO. 22 2008 BY FENNELLY 15375 CRP CSR NO. 5495 712212008 Walker Patrick 122-0002 answer. BY MR. SHAFTEL thought you had. Q. A. dont And you know. Q. didnt ask recall A. dont MR. INGBER WITNESS Object asked and answered. THE 10 dont recall. BY MR. SHAFTEL And if you did 11 Q. ask you dont recall what the 12 answer was MR. 13 INGBER Objection. He testified already 14 to this question. MR. 15 SHAFTEL He has. 16 BY MR. SHAFTEL You owners What said to that 17 Q. YouTube makes tools available to 18 content monitor are their rights. referring 19 tools you to Do they have 20 names A. 21 There is the standard DMCA notification in bulk or on an to be 22 process which URL is submitting the either 23 individual basis we do tool content And we they would there CVT is like the 24 removed which of remove. that 25 development call or content 222 712212008 Walker Patrick 122-0003 verification search to the tools program to pull that which up would that allow them had to use clips that respoided queries Then they insert. be to able their that or not use. to look at they would in those clips that came then and up be response search queries. They those would videos able to within tool it review in determine an whether was fact tick in their opinion 10 unauthorized click to us They could we box have indicating batch removal list sent button that and be would 11 would automatically 12 removed. You Yes. Are refer to that 13 Q. program as CVP correct 14 A. 15 Q. you familiar with the CMS term CMS. 16 A. Im What familiar with does that 17 Q. refer to think it. 18 A. Content management system of if 19 thats Q. thats Is my understanding specific content CMS 20 there to technology that YouTube 21 made available A. owners we 22 CMS is term that suite on of began using as an holders to 23 umbrella manage Q. term for content what tools for rights 24 their the platform. 25 Now is CYC 223

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