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 74

To
From

Franck David Steve Date

Chastagnol [e-mail] King [e-mail]

74

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Sent

Chen

[e-mail]

BshaØhi

Seth

cshashisCgoogle.com

2007-02-20

182524
Vobile

GMT

Subject

Re

Fwd

VideoDNA

Ill

add

them
trial

to
in

the place

list

but

definitely

agree
ignorant

that

we
of

want

to

net

our
of

google
industry

first.

Remaining us to then on proceed

the intricacies by others against
IP.

solutions

allows
in

untainted

Once
others

we
are

have
doing

our service

place
call

we can compare

what

and

make

the

the best solution.

dk wrote
this to

ranek

Chastagnol

dave

can you add

your

list

of

video

fingerprinting

vendors
have
at third

steve

so far our position video

has

been

that

we

first

want
looking

to

pilot

with google party
let

fingerprintir

before

starting

solution.
if

us know

you

disagroo.

thanks
franck

Begin

forwarded

message Chen 17 [e-mail] [e-mail] 2007 72907 PM PST [e-mail]
Shashi Seth

From
tDate

Steve

tFebruary

To

Chastagnol

Franck

mailtofchastagnolyoutube.com
[e-mail] Subjed frFwd Vobile VideoDNAt
Video
tech.

[e-mail]

Fingerprinting

Feel free to

ignore

if

uninterested.

-s

Begin

forwarded

message

From

yangbin

Wang

[e-mail]

[e-mail] tFebruary 17 2007 121231

PM PSI
[e-mail] [e-mail]

ft

3jj Re
lpyTh
Hi

Steve

Chen

[e-mail]

Vobile

VideoDNA

[e-mail]

Steve

--

Best

wishes

to

you

for

happy Chinese VideoDNA

New

Year
our team

Attached

are two tiles
for

technology

while paper

and

background

your casual

reading

while traveling

Im

sure youre on days.

top of the content the best video

identification fingerprint

and

filtering

these

We

have

technology

called

DATE
DEPONENT CASE
Case

\.

04

EXHTBIT

r5
et

23
YcuTube
at al. v.

Viacom

a.

v.

eta.

The

Football

Association Not.

Premier

League
and

YouTube

eta.

07-CV-2203 Howard

07-CV-3582
No.

A. Ignacio

CLR RPR CSR

9830

Highly

confidential.

C0000l-021.91925

VideoDNA
small

for

content

identification

and

related

applications.

As

74-0002

company

30
we

development
your application

to VideoDNA people dedicated can become your video technology

software partner to serve

needs.

Seeing

is

believing.
in

only to

need
you

30 minutes
what

of

your

time whenever software can
do.

youre back Thanks
for

town

show

our VideoDNA

your

attention

and enjoy the

holidayt

Yangbin

408-396-9264

Steve
Hi

Chen

wrote
--

Yangbin

Its

difficult Is

to
it

coordinate
for

time with you to send

all

the traveling

that

Im
instead

doing.

possible

me

presentation

Thanks.

-s

On Feb 13 2007
Hi

at

Feb 13828

AM

Yangbin Wang

wrote

Steve

--

Can

we

schedule

time

to

meet

in

your office

Id
in

like

to

show
labs
in

you our VideoDNA
outstanding
online services.

technology.

Its

been
youll

tested

MPAA

with an

performance. Please
let

Im sure

see

application

your

me know

your

availability.

Thanks

Yangbin 408-396-9264

Steve
Hi

Chen

wrote
--

Yangbin

Im
to

going

to

be
with

leaving

for

Asia next content

week

and

we wont
to

be

ready
for

integrate

new Can

video
try

identification
in

back-end

few months.

we

connecting

February

evaluate

-s

On Dec 15 2006

at

1157

AM

Yangbin Wang

wrote

was great to catch Chad Chumby is really cool...
it

up with

you again

last

night.

The

Steve
with

wed

love to
called

technology
you.

show you our latest content VideoDNA. Chad suggested
set

identification

should

get together

CoUd we

up an appointment

Thanks.

Highly

Confidential

G00001-02191926

74-0003 --Yangbin cell

408-396-9264

Highly

Confidential

000001-02191927