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)

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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 -J S0 -J 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. .0 .4 10 I. -J Googte $1. Gold Stars P. Who helped you out this week CD CD Contk1e.mtei GoogleVideoTashirt Soccer Jerseys http//www. soccer.cornflWCatProductPage.processMerchant Id 1Sectjon Id 1265 pcountProduct Id1 59547 http//www.whoesale-patches.com/galery.Iitni CD Ni Ia Confldemta -J cD -J 01 Oi Go igic Two Truths Lie Sarah A. ./ Ni Confldemta .E I. -.1 -J Next Weeks Meeting Meeting Leader Harappa Team Meeting Lie Two Truths CD Cmdita.

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