The Football Association Premier League Limited et al v. Youtube, Inc. et al

Filing 274

DECLARATION of Elizabeth Anne Figueira, Esq. 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., Stage Three Music (US), Inc., Bourne Co.. (Attachments: # 1 Exhibit 15, # 2 Exhibit 16, # 3 Exhibit 21, # 4 Exhibit 22, # 5 Exhibit 24, # 6 Exhibit 41, # 7 Exhibit 54, # 8 Exhibit 55, # 9 Exhibit 56, # 10 Exhibit 57, # 11 Exhibit 58, # 12 Exhibit 72, # 13 Exhibit 78 Part 1, # 14 Exhibit 78 Part 2, # 15 Exhibit 82, # 16 Exhibit 129, # 17 Exhibit 131, # 18 Exhibit 132, # 19 Exhibit 162, # 20 Exhibit 179)(Figueira, Elizabeth)

1/8/2010

Kacholia

Varun

OUTSIDE HIGHLY CONFIDENTIAL COUNSELS EYES ONLY
--

UNITED
FOR THE

STATES

DISTRICT DISTRICT
EYES

COURT OF

SOUTHERN ATTORNEYS

YORK

ONLY

VIACOM

INTERNATIONAL COUNTRY

INC.

COMEDY
Figueird Den. Tab 56

PARTNERS
TELEVISION PICTURES

MUSIC PARAMOUNT and BLACK

INC.

CORPORATION

ENTERTAINMENT

TELEVISION

LLC

Plaintiffs
vs. Case No

l07CV02103

YOUTUBE
and

INC.

YOUTUBE

LLC

000GLE

INC.
Defendants.

__________________
THE
10

FOOTBALL

ASSOCIATION BOURNE

PREMIER
et all
al.

LEAGUE
on

LIMITED
of

CO.
and

behalf

themselves

11

others

similarly situated Plaintiffs

12

vs.

Case

No.

07CV03582

YOUTUBE
13

INC. INC.

YOUTUBE

LLC

and

GOOGLE

Defendants.
14 15 16 17 18 19

________________________________________

Deposition
Palo

of

VARUN

KACHOLIA

Alto

California
2010

Friday January

20 21
22 23 24

JOB

NO.

18544

25

1/8/2010

Kacholia

Varun

160000

help

you

understand

my

quest
the

Is

there

any

technical

limitation within
as it

search with
that

functionality youtube
these MR. do not of

exists the

today
videos

why include

exclude

kinds

information
repeat

RUBIN
one

Ill
about

my objections

about

scope

and

add

vagueness. Search
is

THE
it

WITNESS
am

complex
in

system

and

as

stands

today

not

confident

answering

this

10

question. MR. Okay.

11

GALDSTON
But the

12

search
omits this

functionality videos
that

does

not

13

contain language

any

function

that own

contain

14

like Correct.

dont

music

correct

15

160000

16

Okay.

But of that

the

functionality
that are

does

omit in

17

duplicate
to

copies
is

videos

returned

response

18

query

correct

19

Thats
And
at

correct. turn to the

20

if of

you the

second
see have

page that

of

Exhibit

21

the

bottom
that

exhibit search

youll

the

22

statement
that

some

results

been

omitted

23

contain How

duplicates.
does the

24

search videos

functionality
to

determine

25

which

of

the

duplicate

omit

163