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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41212009 Levine Zahavah UNITED STATES DISTRICT OF COURT SOUTHERN DISTRICT NEW YORK Figueird Den. Tab 68 VIACOM PARTNERS INTERNATIONAL COUNTY MUSIC INC. COMEDY TELEVISION PICTURES INC. PARI1OUNT and CORPORATION BLACK ENTERTAINMENT TELEVISION LLC Plaintiffs vs. No. 07CV2203 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. 10 THE 11 FOOTBALL ASSOCIATION BOURNE PREMIER et LEAGUE on LIMITED of CO. and al. behalf others themselves 12 13 all similarly situated Plaintiffs vs. No. 07CV3582 14 YOUTUBE 15 16 INC. YOUTUBE LLC and GOOGLE INC. Defendants. 17 HIGHLY 18 CONFIDENTIAL OF VIDEOTAPED SAN DEPOSITION FRANCISCO ZAHAVAH LEVINE CALIFORNIA 2009 19 20 21 22 23 24 25 THURSDAY APRIL CSR BY Job KATHERINE No. E. LAUSTER 1894 RPR CRR CLR 16721 41212009 Levine Zahavah LEVINE got Q. 88-0002 Uh-huh. was A. much to less than the market share that they Q. purported Okay. Do represent. you for Thank recall clarifying of that. the you what proportion Harry Fox market they purported to Not they at purported 10 A. represent exactly. that time 11 Q. Ballpark. Approximately. between are of you the 65 12 A. Somewhere Okay. what to and 75 percent what Harry maybe. 13 Q. And aware of Harry Fox 14 Fox proportion represent what market 15 purports A. today 16 For For you purpose of 17 Q. clearance publishing ago. rights in the 18 manner A. described So moment it 19 think Fox kinds depends on the context publishers for for 20 because for Harry represents of different 21 different may have licensing. So share example licensing 22 they different market 23 downloads Q. 24 Uh-huh. than 25 A. they do for audio only streaming 19

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