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)

To
From

Suzie

Reider Byrne

[e-mail] [e-mail] [e-mail]

Jamie Shiva

Rajaraman

Figueira

Den. Tab 79

Received
Subject

Date

2007-05-14

009155
to

CST
Monetization

Re

Path

YouTube

5.1407

Suzie

Hare
tactical

is

my
trial

revised.

think

that

the version
think Eric

and too

detailed.

dont

too you sent was actually needs actual details on he

the ad
level

sales

conference

etc.

Im guessing

needs

higher

overview.

Take
it

look at sent to

is

my attached. make sure is at
it

Id want the right

David
level.

Eun

to

weigh

in

on

it

before

It

needs

few numbers

to

be added

Ive

indicated

what numbers and

where.

Jamie

Suzie read

Reider
this to

wrote

and shoot

me

your thoughts.

Has
doc.

be VERY
Eric

high level
with
is

and

Dave

Eun says know

just

ore

page

word

that

gets bored
objective
in

PPT and
for

anything fancy.
to

many
together.

thanks..
Ill

just

him

we

have

our shit

add
ill

the modeling
to

from

dejelo

high

level and

once

have

yours

shoot

Shashi.

this

is

pretty think

basic

meaning
about

would

think

hed been

know
working

all

this

but

dont
to

much

anything

weve

on

has

made

it

up

omid/ericlemg.
reality
in is

and...
ill

even

it

we can do 90mm
to

this

year
etc.

its

not

material...

add

comparisons..

FB and

Myspace

Attachments

YouTube

Monetization

Rev.

doc

DATE
DEPONENT CASE Viacom
Association Case Nos. 07-C

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EXHIBIT
YouTube
et

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at.

The

Footbatt
et at.

Premier V-2203

League
and

aL

v.

YouTube

07-C

V-3582

A.

Ignacio

Howard

CSR RPR CCRR CLR

No.

9830

Highly

confidential

Expert

Advertising

G0000i.-01295801

Overview

YouTubes
focused

efforts four

at achieving

sustainable

scalable

and meaningful

revenue

are
79-0002

on

key areas

1.

Increasing Increasing

scale.and percentage
overafi

automation
of

of

media sales
can ad

efforts

inventory that
better

be monetized and innovation

3..

Increasing

RPM

through

units

Media

Sales
Project Janus
actively
will

NASOs
better

take effect

in

early to

July

and

will

iamp the number
will

of

sales

employees
advertisers.

selling

YouTube

from

over 50

This

advertiser

coverage

and increase

overall

YouTube

allow Google to achieve with brand sell-through

YouTube
the

will

also be opening
front-end platform.
to

up

new
all

auction-based

brand

advertising

opportunities to

in

AdWords
as

enable

AdWords

advertisers

an

opportunity

leverage

YouTube

Inventory

From YouTube

monetizaHon

perspective

the largest

opportunity

for

revenue

resides on the

Search

pages.

Projected

Search

revenue20072010
with

In is

addition highly

to

being

inline

Ooogle

core competencies

monetizing
to

YouTube
sharing

Search
with

protective partners.

of

the user experience

and

is

not subject

revenue

content

In

terms

of

monetizing are

actual

video

video

views

available

for monetization

14% views only approximately due to OMCA restrictions
chrome

of

VouTubes
While

total
is

YouTube

increasing content
it

this percentage

through
that

partnership deals

does

not

seem

in-stream

and programs to monetize user ad models on Watch pages will drive

as

significant

revenue

as Search

over the near term.

Projected

Watch

Page

revenue

20072010

Ad

Innovation
is

YouTube
increase

experimenting

with

variety

of

new

video-based
that

advertising

models

to

overall
is

RPM

and create video
executing

ad models
to

respect
the

the user experience
effective

YouTube
friendly to

currently

ad

trials

determine
include

most

and most userclick-

models

Models

currently

being Future

tested

Search

models oveilays
graphical

play

and video-based

models

models

for testing

include

overlays

and on-page models YouTube and Data Revenue
also developing models. non-ad

is

based

models

including

Promote-Your-Video

PYV

driven

Projections

2007 2008 2009 2010

fligbly

Confidential

Expert

Advertising

so000l-01295802