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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211212009 Kordestani Omid UNITED FOR THE STATES DISTRICT DISTRICT COURT OF SOUTHERN NEW YORK VIACOM PARTNERS INTERNATIONAL COUNTRY INC. COMEDY MUSIC. FigueirdDecI.Tab 61 TELEVISION PICTURES ENTERTAINMENT INC. PARI1OUNT and CORPORATION BLACK TELEVISION LLC Plaintiffs vs. NO. 07CV2203 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. 10 11 THE 12 FOOTBALL ASSOCIATION BOURNE PREMIER et al LEAGUE on LIMITED of CO. and behalf themselves all 13 others similarly situated Plaintiffs 14 vs. 15 NO. 07CV3582 16 YOUTUBE INC. GOOGLE INC. YOUTUBE LLC and 17 Defendants. 18 HIGHLY 19 CONFIDENTIAL OF VIDEOTAPED SAN DEPOSITION FRANCISCO OMID KORDESTANI CALIFORNIA 20 21 THURSDAY FEBRUARY BY JOB ANDREA NO. M. IGNACIO HOWARD 12 CSR 2009 RPR CCRR CLR 16382 22 23 24 25 211212009 Kordestani Omid IKORDESTANI So 81-0002 if an on advertiser wants to understand the how to advertise that Google this explains process isnt right Yes. And to the theres page of in addition to Adwords there is if you go last this document is something called AdSense that correct Yes. 10 And how does is AdSense differ from Adwords owners or 11 AdSense publishers on who the to program that have so website 12 want Google earn on advertisers money appear our 13 their website have use ads they by using 14 system to our appear earn their site. from on 15 And does Google revenue ads 16 contextualized contextualized thirdparty 17 sites MR. 18 MANCINI WITNESS KOHLMANN how how the Objection Yes. Okay. to form. 19 THE MS. 20 21 And Can you exactly to does AdSense work 22 describe process me identifies to on have ads an area 23 Its basically on and website they like 24 their website ads are where appear if 25 either targeted based keywords they 68 211212009 Kordestani Omid IKORDESTANI have search we have on for 81-0003 page or if they have content on their ads to page the system that that page. if identifies relevant content So of the this example that it you put go in to the last of page in Exhibit page Ive says front for you middle of AdSense of are content pages and to your automatically delivers 10 crawls and the content ads that your text and Yes. Is image site relevant audience your content. 11 12 that what you were describing it crawls 13 the content Yes. And 14 15 what are the factors that about go into an ads to 16 AdSense display for on MR. content determination which 17 particular site Objection to form. do 18 MANCINI WITNESS is 19 THE What what you mean by 20 that What MS. the question Q. 21 KOHLMANN your So how -- what -- if the last 22 understood page of testimony there an is and understand crawl of the 23 Exhibit generates it content 24 which then Is ad correct 25 69 211212009 Kordestani Omid KORDESTANI 81-0004 MS. KOHLMANN split Q. But -- and -- and there is revenue between Google as result of AdSense and the advertiser is that correct AYes. And is there traditional revenue split MR. MANCITNI Objection to form. THE WITNESS our publishers. Majority of the revenue goes to 10 MS. KOHLMANN in Q. Is there percentage 11 thats typical your deals 12 MR. MANCITNI Objection to form. 13 THE WITNESS the size Percentages depend on the -- on 14 of the customer typically and how they work 15 with us. 16 MS. KOHLMANN Theres also Q. And thats AdSense for 17 content. something called AdSense for 18 search. How Its does that work on Google. So if 19 similar to searches 20 site has web search where user is searching on 21 different lets say Ask.com then ads are triggered 22 based on search terms. 23 And is -- is there again revenue split 24 between Google and the advertiser if one uses AdSense 25 for search 71

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