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)

Figueira

Den. Tab 153

To
From Cc

Hunter

Walk

[e-mail]
153

[e-mail] corn corn cdps@google Jay Yagnik jyagnikOgoogle Franck corn Steve Chen corn Chastagnol cfchastagnol@youtube .csteve@youtube Hurley Chad corn Thomas Williams corn Rod Chavez corn chadh@youtube thaw@google Jeremy crod@google corn Louis Perrochon corn Karen Seto Doig jerernydo@google clouis@google
Chastagnol
David Stoutamire

Franck

ckseto@youtube

corn

Bindu

Reddy

bindu@google 220011
Area

corn

Ivan

Davtchev

ivand@gooqle

corn

Bcc
Received Subject Date
2007-1 1-12

CST
review narrative

Re

Video

Focus

doc

explaining

our future

Here are sorne

cornrnents

Section
easily
In

FA
and

Technical

Opportunities

Itern

Allow add
for

anybody

to

rnonetize

quickly

the technical

implement broadcast open and
up

solution

chatenges paragraph for fresh content

would
filtering

the following instance
live

TV

the content

ID

platforrn

by exposing

APIs

usable

both

by internal

external

customers
filtering

pre-publish systern
build to

handle

reference able to

content

conflicts to

frarnework

report

back and

partners

aggregated

data

from

all

the video

rnonetizalion

sources

playback

sources

Section
In

II

Focus Area Health
metrics
of

the Success
total

would

add
broken
out by
tiers rnost irnportant

nurnber
to

partners

using VID
of Tierl
in

being

get large
of

number
content

partners

onboard

hours vs video

reference

the fingerprinting

DB
which

broken

out by

audio

percentage
in

of

US

Music

Labels

catalog

for

we

have

publishing

data

YT DR
number
of

UPP

partners

In

the risks business

would
rnay
not

add
succeed
signing

up large

content

owners

to

use Video

or

Audio

ID

business
rnusic

may may
with

not

succeed

having

Music

Labels

agreeing

to

provide

us with

publisher

data
not

business collaborate Audible services

succeed
clear

in

getting

3d music
to

party

such as
rights

Harry

Fox

to

us to

remaining
at

publisher

Magic rnay decide

any

tirne

stop providing

us with

Audio

ID

Franck

On
hi

Nov

2007

1036PM

Hunter

Walk

chunter@googlacorn

wrote

folks

httpsI/docs.google.comlalgoogle.comlDocidcgw9b4pc_1
the Video

0c6j79x

this

link

displays

the narrative 11/16.

for

Focus

Area

review

occurring

on Friday

As you might

know

the Focus

Area

review

is

like

Highly

Confidential

G0000i00980438

an engineering-driven
will

OPS

where

the

engineering direction

PA
risks

leads etc

jeremy

and

louis 153-0002

talk

about

the technical

innovation

associated

with the Video

Focus Area

which

includes

Youlube

and

Google

Video. have
this

first

draft

of

the narrative

has been
of to

completed

but

the goal

is

to

it

represent very

the shared

wisdom
re trying

the senior lock
Bill

engineering the narrative review

team

so

group

is

important
for pre-1
is

We
1/16

down

by early
input

next
of

week

review

with

your the better

and

by End

Weekend
folks feel

appreciated

the

earlier

If

we

should
set

pull

together
up.

for

real

time discussion
pls reply to

let

me
thread with

know
notes.

and

we can

something

Otherwise

this

Bindu

think

its

still

little

light

on

Google

Video

related

OKRs
internal

and
All
risks

product
think

perspective

we

could

be

little

more

introspective

on the

we

face

Focus area
projects

review
offices

also
for

includes
this

engineering are

project listed

allocation

The

and

Focus Area

here

http//effort/index.phporgengofficeeditmodeOvpdownloadQcategoryVideo
page
is

Area

landing

http//effort/

thanksl

hw

--

Hunter

Walk
Produci

YouTube

Management

[e-mail] Check most popular videos

out todays

http//www.youtube.com/browsesmp

Highly

Confidential

G0000i00980439