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 Cc
Fcc
Received Subject
David
Eun cdeun@google.com Bhanu Narasimhan cbhanungoogle.com
Figueira
Den. Tab 93
Date
2006-06-28
171309
Uploads
CST
Re
Illegal
Hi
Dave
catch around
We
rest
these
approdmately
10% of 90%
porn
and so
all
online
user uploaded
videos
copyright
during
review.
Of the
is
disapproved etc.
due
to
violation stats
this
and
in
due
to
policy
violence
We
discuss
these trom
weekly
tneops team meeting
slides
am
enclosing
stats.
our slides
week
see
3-9 for review
takedown
Please data
let
me know
so
if
if
you would
like
more
raw
information
or
in
if
you and
let
need
is
this
summarized
weekly
differently.
Also
like
the to
data
is
our
this
filer
updated
you would
get access
to
do
me
know.
To be
honest
dont
have
insight
into
youtube
stats
but
believe
they
on playbacks in the last Xrnins if video is the video has porn or other bad getting very popular and takedown content. am not sure they do anything about copyright other than take these down when they get dmca. can try to ask around and find out more.
proactively
review
videos
based
if
Thanks Bhanu
On
6128/06
David
Fun deun@google.com
wrote
Bhanu
the swirl of
In fell
discussions
illegal
around
copyright
enforcement every
poIicies
can
you what
me how many
videos they
fall
we
into
catch
week
on average
and
teMdnds/categories
How
Your
do
they correspond
to
the stuff that
gets uploaded
to
VouTube
info
and
insight
would
be
appreciatedI
Dave
David
Fun
2-589-8070
NY
21
MV
650-253-1993
Attachments
Video
Meeting
06-26-06.ppt
Highly
confidential
00000100794737
Google Video Team Meeting
Agenda
Updates
for 6126/06
Welcome
Video Reviews
Dubhn
Team
Amy
Take
Katrina
Downs
Sarah
DMCA
Stephanie
Emails
Frankie
CBG
meeting cancelled
Harappa Meeting
Boo Boos and Warm Fuzzies Our Google Video
Special
STARs
Topics
CD
T-shirts/jerseys
Two
Truths
Lie
Sarah
Confldit
-1
-J
VNdeo
Stahstucs
El
Revww
1.
Vdeo
BFTA
Search
recent
TV programs
onfine
CD
Cnflde3ntkd
Sj
ID
-1
ID
nt
Google Video Team
Total Videos
than
last
Reviewed 42679
week
of
Thats 4187 more
Number
Videos Reviewed
Per
Week
45000
40000
35000
30000
25000
20000
l5000
1000
5000
uIIIIIIIuIIuIIIIIIIIIIIII
Contdmt
cb
-1
ic
3640
last
Video
Team
Total
Disapprovals
week and 8.5%
of total
Thats 424 more than
reviews
That means
we approved $$O39
videos
this
Rate
weekl
Disapproval
12.00%
10.00%
8.00%
6.00%
4.00%
2.00%
CD
000%
88
01 U-
Cofflk1eiflS
.3
I-.
Google Video Team
Disapprova
Reason
of total
Reasons
Disapproved
This week
Disapproved
This week
1532
1955
TV General
53.7%
722
Sports
TV
Music
6.0%
23.5%
19.8%
ffl
-u4o
total
396
Film
10.9%
Copyright
violations
IS
Porn/Nudity
218
297
285
7.8% 0.7%
9.6%
to ta l
22
27
Bad
Quality
Obscenity
0.1%
0.1% 0.8%
Policy
violations
7S
28
Violence
Drug Use
ft
0.1% 0.1%
CD so
Illegal
Content
-J
-4
Google Video Team
Disapprova
Disapproval Reasons
April
Trends
24th-
3000
2 8 th
May
1-5
2500
2000
ii
May 8-12
1500
May 13-19 May 20-26 May 27-Jun
June 3-9
1000
500
Porn/Nu ht
dity
Copyrig
Copyrig ht
Sports
Copyrig ht TV ht Film
Copyrig Violenc
Obscen
ity
Bad
Illegal
Music 523
TV
233 175 819 954 967 933 822 755 119 135 251 251 176 197
Quality/
Drug Use
Content
11
S pam
WJune
37
18 14
10-16
April
24th-28th
85
2199 2788 1210 1410 1738 1699 1764 1532 1955
Mayl-5
156 110 216 193 230 357 290 377 396 246 297 285 381 537 196 301
48 33 20 32 25 25 29 27 38
21
June 17-23
Co
May8-12
0May1319
May20-26
DMay27-.Jun2
June3-9
27 22 722 218 28 27
10
DJunelO-16
JuneI7-23
-4
-4
DMCA
Takedown Updates by
Katrina
Steph
DMCAs
complaints with 110 takedowns
total
Notable
DMCAs
UFC
Playboy
Grateful
Hollywood
Byrds
at
Licensing
Dead Mansion
More
fighting
clips
AFV
content
Playboy
.s
CD
nn
Co
Cont1deanta
Co
gte
including
Take Iowns...
I.
Total increase
last
Takedowns
DMCAs
186
increase
last
from 60
week
Total
Takedowns
from Sparrow
Total
61
from 51
of
week
Number Takedowne
per
Week
450
400
350
300
250
200
150
IOU
50
CD
\D
\Ok
CD
if
Coifdmfl
-1
UI
Copyright on sparrow
16. equal
last
to
16 from
week
Policy
17 Video
Quality
Illegal
on sparrow
last
45
increase
Drugs
Obscenity HaEeIAnli
from 35
week
Porn 22 Violence
Takedowns
by Category per
Week
350
300
250
200
150
100
50
Co
11
13
15
17
19
21
23
25
27
29
31
33
35
37
39
41
43
--Total
Copyright on
Sparrow
Total
Policy
on Sparrow
Confide
nfia
-a
to
Is
-a
F1
Notable Takedowns
ft
It
CD
Contk1emtkd
.l.
deo Team
Email Updates
June
681
17th
June 23rd
emails Received
633
last
week week
day
emails Sent
512
last
442
Average
102 emails
CD
Ni
Conidnta
C.
VDEO
Uploader
33% emaHs
Tech Transcoding
Failed
23
Googlemail
Error Security
Uploader
Upload
Issues
13
Technical
Difficulties
Uploader
Tech Reload
Settings
25%
Connection
Issue Error Audio
emafls Playback
20 Access
Purchased
GyP
Video
13
GVP
DMCAITooIs Auto Email
Videos
Proxy and Password
Auth.
Issues
25%
for
emails Policy
40- responses
Removed
for Policy
URL
Copyright
Violations
CD
ContkIenS
4.
St
CBG
Video Buyer Questions
Multiple
8% emails
Purchase
Technical
Difficulties
8- refunds
Online
Refund
General
16
Cant See IP
Requirement
Can
Charge
Oneofts
Video One-offs User asked about using Video API
CD so
Cnhdemt
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S0
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ii
Coite
\fi
Ier\shares\Goog
IeVideoOperations\Ops
Stats
I.
ogIe
Video per Emails
Week
2500
2000
1500
Received Sent
Lu
.0
Oosed
1000
500
Weeks
Confldemthd
Google Video Team
I.
UPLOADER
513399Response
expected got from server
Bad 200
with
Grnail login/Googlernail
OK
RTTP/1
.1
403 Forbidden
Occurs
101770Upload
Issue
Mac
OS
fails lOB
Multiple Files at
Upload
Uploading Niko
of
once under review
videos corrupted
in
created
1.
new
version Transcoding
in
Windows Uploader
Progress
Videos Stuck
uploads
link
Neptune
bandwidth
2.
Web
based
not
working
not enough
CD
Contidentki
-J
-J
CBG
Meeting Notes
Bugs
Cancelled order cannot be repurchased
511269
Nothing
new
to report
CBG
launch
is
Updates
planned
is all to
the
for late
CBG
next of their sure
week 6/29
In preparation
CBG
going through
CRc
make
they reference
the external
name Google Checkout
Escalating created
for bugs.
If
Bugs
to
CBG
we
are routing
ticket
CBG
new queue
Renorts
related to
bug we should now
route to
CBG Bug
ROUTE HERE
24 hrs
we may
route
status
Types
of bugs related tft eta
Pending orders needing
check
Bug
in
UI frying to place
when
an order
receipt
Bug
in
account
S.. Seeing garbled data on
page
CD
ContkkmBa
itt
Google Video Team
OO BOO
Share your
Boo-Boo moment
Warm
Hi Google
is
fuzzy responses
just
it
Video
think of
one
of
those services
you cant get
enough of community Thank
you so Outstanding watching
as an onflne video sharing
other videos
for the
and uploading your own.
support prompt
reply.
much
service
Superb service
feature
in
just
stumbled sending
is
across the
video.
easily
embed HTML
This
is
great feature overlooked. blog
It
that
really
CD so
unfortunately
added FLAIR
and
to
Co
my
web pages.
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10
I.
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Googte
$1.
Gold Stars
P.
Who
helped
you out this
week
CD
CD
Contk1e.mtei
GoogleVideoTashirt
Soccer Jerseys
http//www. soccer.cornflWCatProductPage.processMerchant
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1Sectjon
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http//www.whoesale-patches.com/galery.Iitni
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Confldemta
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Two
Truths
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Next
Weeks
Meeting
Meeting
Leader
Harappa
Team Meeting
Lie
Two
Truths
CD
Cmdita.