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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4/22/2009 Hurley Chad UNITED FOR THE STATES DISTRICT DISTRICT COURT OF SOUTHERN NEW YORK VIACOM PARTNERS INTERNATIONAL COUNTRY INC. COMEDY MUSIC PARAMOUNT and FigueirdDecI.Tab 49 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 OF CHAD HURLEY CALIFORNIA 19 20 WEDNESDAY APRIL 22 2009 BY JOB ANDREA NO. N. IGNACIO HOWARD CSR RPR CLR 16789 21 22 23 24 25 9/6/2009 622 PM 4/22/2009 Hurley Chad HURLEY clip some clip we CHAD to 49-0002 would work together produce some the 40 version that includes to be only the about. that particular youre going asking to the Youve something Mr. that represented was part of of inc this is production reserve that all rights to Karim made. We course for challenge MR. authenticity foundation. Perfect. BROWNE Mr. Okay. 10 Now this is Hurley Im gonna play for you -- 11 very short Clip video. 12 Video playing on laptop. 13 Unintelligible. SPEAKER 14 It was like pretty impressed. like 15 Youre on the basically Internet right. you have Its anhere that can up 16 little 17 control and the you know of basically things serve tags 18 ads you the and whole our with have and 19 know flash. what viewers seen before 20 Its pretty 21 SPEAKER what So would if we we get them them involved our at 22 point tell is dirty just 23 little want to secret sell which that we actually 24 out quickly you 25 SPEAKER Are filming 9/6/2009 622 PM 107 4/22/2009 Hurley Chad HURLEY Youre SPEAKER after MR. CHAD have be to eraae this. until 49-0003 going to actually It No. wont released the acquisition. Q. BROWNE Mr. Now have Mr. -- stop that. that Now video Hurley you ever seen before dont Okay. 10 remember Did you it. recognize that and the two individuals that were on camera during Steve video and it 11 recognize like myself sounded 12 Jaweds Okay. voice. 13 And it sounded like and Mr. Karims 14 voice on the It video you like recognized it. that 15 sounded you 16 Did hear yourself have to say on on on like that 17 video that have to that you something 18 well erase the it file seemed like 19 mean sarcastic remark yeah to pretty 20 his sarcastic you comment. first about in the in Series 21 Okay. Now when were 22 discussions financing you with did Sequoia did Capital 23 Sequoia that the Capital had for value provide 24 with valuation they Youlube they would 25 Yeah through negotiation 9/6/2009 622 PM 108

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