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)

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Figueira Den. Tab 160 01 CYC Priorities List Feature Engine Target Feature Automate upload to Owner and Status Feature As we details System Project ering name policy Priority date 2/21/2007 scope Notes incoming rights CYC data DK process AM 2/21/2007 automatically build list upload Audible policies and DB to Magic view they of all Rev share scenarios CYC Deals DK Create comprehensive share liabilities rev and how disty interact including labels YT users partners music publishers etc. of video is providers ensuring ad networks that This deals vital to our range and programs with around other. CYC are compatible each Turn on fingerprinting 2/14/2007 FP DK Start with IJMG As and block add other labels as in to In general appropriate. revisit policies in come fingerprinting projects with associated will user experience and production sanity check optimize. of After target AM date management policy database increase priority if greatly in remains ongoing. Google looks fingerprinting unlikely. Video pilot fingerprinting 3/28/2007 FP DK Work VT with Jay and Jeremy on defining and Steve on specific requirements pushing priority AudioSwap Fixes Bug 2/21/2007 AudioSwa v2 ML Fix vi player least bugs 2. 1. Remove seeking default capability mute and bar on Add common denominator wired of status 3. Publishing ability on song catalog with Browse Taxonomy/Search for 2/21/2007 AudioSwa v2 ML Improve search navigation Add in auto- and browse features. complete approval pending by Editor Ops 160 Lfl New Flow for 2/21/2007 to AudioSwa v2 ML Users and need pro-active way to access selecting edit video select from audio for their videos before as new page and swapping messaging TestTube as well MyVideos page policy for Viacom takedown P50 ML to to Determine Viacom how we manage automation transfer takedowns as we music adding as much P50 team automation them by block can without letting fingerprints This is controlled other partners primarily relationship management problem work out with should clear the and until no engineenng be done we have will worked this policy Matt take up P50 team. Additional Features 1.5 2/21/2007 AudioSwa v2/v2.5 ML ML Audio slider offset fading of audio Publish New Video 2/21/2007 AudioSwa v2/v2 Pro active editing will allow users to to publish replacing new their video old for as opposed video Audible sr.lit Magic DB 3/21/2007 FP BK Data Separate videos DBs receive UGC vs. commercial Consolidate nghts publisher 3/21/2007 Cit DK We will fractional ownership information consolidate from publishers this We to must information track to rights. produce is V/N decision on This the barebones rights abilty manage publisher using data provided by labels. GYG tor CBS 3/1412007 CYC Deals ML Does CBS have any specitic requirements 160-0002 Lfl 01 LU Audible Magic accuracy 2.5 02 FP DK Does it make sense to of to improve audio entire audio if match fingerprinting track instead sample first 60 seconds we to dont have video fingerprinting soon Also scan improve comprehensiveness should we require entire table for every FP reference match instead of first check to return to best match improve accuracy Automate reception song 2.5 Audioswa Support ML ML Drop audio box for automated xml deliveries of Commerce Link 2.5 AudioSwa v2.5 Include commerce links Priority and implementation subject to change on depending discussions BD Prevent MF3 direct 2.5 AudioSwa Support ML DK Make expire play after buttons single virtual click URLs that downloads Audible delete Magic API 02 FP As we produce identify audio fingerprints that incorrect us to matches delete we want an those tables API allowing fingerprints from our reference and processing from ingest of Music policies reception 02 CYC data DK Drop excel box files xml and labels CYC data in projects priority of automate received to music their increase and publishers track as volume grows. deals policies N-way rev sharing 02 CYC Data DK Determine needed and to if N-way rev sharing publisher of is satisfy music deals spec out mechanics reporting 160-0003 Lfl P. Store Publisher 302 CYC Data DK Publishers artists will send us lists of blocked metadata i.J. metadata and split information. this We from must be able to store data received This is ft without overwriting sources featured rights information other full such as labels. to P. more ability manage by views publisher publishers using data provided those and mapping back to label data. Reporting international 02 Reporting DK partner Reporting region partners partner is by country required by or geographic some content with roadmap shared requirement roadmap are reporting or will Reporting publishers for 02 Reporting BK partner What requirements all for publishers reporting go through roadmap Upload roadblock labels Introduce flo AudioSwa v3 ML AudioSwap during initial upload process 160-0004 01 UI

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