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

Filing 276

DECLARATION of Elizabeth Anne Figueira, Esq. in Opposition re: 167 MOTION for Summary Judgment.. 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 189, # 2 Exhibit 190, # 3 Exhibit 191, # 4 Exhibit 192, # 5 Exhibit 193, # 6 Exhibit 194, # 7 Exhibit 195, # 8 Exhibit 196, # 9 Exhibit 197, # 10 Exhibit 198, # 11 Exhibit 199, # 12 Exhibit 200, # 13 Exhibit 201, # 14 Exhibit 202, # 15 Exhibit 203, # 16 Exhibit 204, # 17 Exhibit 205, # 18 Exhibit 206, # 19 Exhibit 207, # 20 Exhibit 208, # 21 Exhibit 209, # 22 Exhibit 210, # 23 Exhibit 211, # 24 Exhibit 212, # 25 Exhibit 213, # 26 Exhibit 214, # 27 Exhibit 215, # 28 Exhibit 216, # 29 Exhibit 217, # 30 Exhibit 218, # 31 Exhibit 219, # 32 Exhibit 220, # 33 Exhibit 221, # 34 Exhibit 222, # 35 Exhibit 223, # 36 Exhibit 224 Part 1, # 37 Exhibit 224 Part 2, # 38 Exhibit 225, # 39 Exhibit 226, # 40 Exhibit 227 Part 1, # 41 Exhibit 227 Part 2, # 42 Exhibit 227 Part 3, # 43 Exhibit 227 Part 4, # 44 Exhibit 228, # 45 Exhibit 229, # 46 Exhibit 230, # 47 Exhibit 231, # 48 Exhibit 232, # 49 Exhibit 233, # 50 Exhibit 234, # 51 Exhibit 235, # 52 Exhibit 236, # 53 Exhibit 237, # 54 Exhibit 238, # 55 Exhibit 239, # 56 Exhibit 240, # 57 Exhibit 241, # 58 Exhibit 242, # 59 Exhibit 243, # 60 Exhibit 244, # 61 Exhibit 245, # 62 Exhibit 246, # 63 Exhibit 247, # 64 Exhibit 248, # 65 Exhibit 249, # 66 Exhibit 250, # 67 Exhibit 251, # 68 Exhibit 252, # 69 Exhibit 253, # 70 Exhibit 254, # 71 Exhibit 255, # 72 Exhibit 256, # 73 Exhibit 257, # 74 Exhibit 258, # 75 Exhibit 259, # 76 Exhibit 260, # 77 Exhibit 261, # 78 Exhibit 262, # 79 Exhibit 263, # 80 Exhibit 264, # 81 Exhibit 265, # 82 Exhibit 266, # 83 Exhibit 267, # 84 Exhibit 268, # 85 Exhibit 269, # 86 Exhibit 270, # 87 Exhibit 271, # 88 Exhibit 272 Part 1, # 89 Exhibit 272-2, # 90 Exhibit 272 Part 3, # 91 Exhibit 272 Part 4, # 92 Exhibit 272 Part 5, # 93 Exhibit 272 Part 6, # 94 Exhibit 272 Part 7, # 95 Exhibit 272 Part 8, # 96 Exhibit 272 Part 9, # 97 Exhibit 272 Part 10, # 98 Exhibit 272 Part 11, # 99 Exhibit 272 Part 12, # 100 Exhibit 272 Part 13, # 101 Exhibit 272 Part 14, # 102 Exhibit 272 Part 15, # 103 Exhibit 272 Part 16, # 104 Exhibit 272 Part 17, # 105 Exhibit 272 Part 18, # 106 Exhibit 272 Part 19, # 107 Exhibit 273, # 108 Exhibit 274, # 109 Exhibit 275, # 110 Exhibit 276, # 111 Exhibit 277, # 112 Exhibit 278, # 113 Exhibit 279, # 114 Exhibit 280, # 115 Exhibit 281, # 116 Exhibit 282, # 117 Exhibit 283, # 118 Exhibit 284, # 119 Exhibit 285, # 120 Exhibit 286, # 121 Exhibit 287, # 122 Exhibit 288, # 123 Exhibit 289, # 124 Exhibit 290, # 125 Exhibit 291, # 126 Exhibit 292, # 127 Exhibit 293, # 128 Exhibit 294, # 129 Exhibit 295, # 130 Exhibit 296, # 131 Exhibit 297, # 132 Exhibit 298, # 133 Exhibit 299, # 134 Exhibit 300, # 135 Exhibit 301, # 136 Exhibit 302, # 137 Exhibit 303, # 138 Exhibit 304, # 139 Exhibit 305, # 140 Exhibit 306, # 141 Exhibit 307, # 142 Exhibit 308, # 143 Exhibit 309, # 144 Exhibit 310, # 145 Exhibit 311, # 146 Exhibit 312, # 147 Exhibit 313, # 148 Exhibit 314, # 149 Exhibit 315, # 150 Exhibit 316, # 151 Exhibit 317, # 152 Exhibit 318, # 153 Exhibit 319, # 154 Exhibit 320, # 155 Exhibit 321, # 156 Exhibit 322, # 157 Exhibit 323, # 158 Exhibit 324, # 159 Exhibit 325, # 160 Exhibit 326, # 161 Exhibit 327, # 162 Exhibit 328, # 163 Exhibit 329, # 164 Exhibit 330, # 165 Exhibit 331, # 166 Exhibit 332, # 167 Exhibit 333 Part 1, # 168 Exhibit 333 Part 2, # 169 Exhibit 334, # 170 Exhibit 335, # 171 Exhibit 336, # 172 Exhibit 337, # 173 Exhibit 338)(Figueira, Elizabeth)

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Page UNITED FOR THE STATES DISTRICT DISTRICT OF COURT NEW YORK SOUTHERN VIACOM INTERNATIONAL INC. COMEDY COUNTRY MUSIC PARTNERS PARMIOUNT TELEVISION INC. PICTURES and BLACK CORPORATION ENTERTAINMENT TELEVISION LLC Plaintiffs vs. NO. 07-CV-2203 YOUTUBE INC. YOUTUBE and GOOGLE INC. LLC Defendants. THE FOOTBALL ASSOCIATION PREMIER LEAGUE BOURNE LIMITED of themselves on behalf others similarly CO. and et al. all situated Plaintiffs vs. NO. 07-CV-3582 YOUTUBE GOOGLE INC. INC. YOUTUBE LLC and Defendants. VIDEOTAPED DEPOSITION OF JAWED KARIM CALIFORNIA ALTO JUNE 2009 TUESDAY JOB NO. PALO 16798 Figueir Deci. Thb 280 DAVID 805 FELDMAN New WORLDWIDE New York INC. Third Avenue York 10022 212705-8585 259c25ef-fd4e-4fb6-808d-35a1 f24e5aal Page 119 KARIM 141919 141920 141920 141930 141931 141932 141936 141940 141941 141942 141943 141946 141949 141953 141956 142000 142001 142005 142008 142013 142015 142015 142017 142018 10 JAWED particular BY MR. Q. e-mail. BASKIN Well towards that -- the bottom of Exhibit videos on 29 theres flooded about before code -- sentence with begins then If it get to porn could are and goes talk we always approve videos first one-line they shown anywhere. Thats change. Do A. you see that sir 11 Uhhuh. Is that the 12 Q. sentence that youre telling us 13 is now A. simplification 14 mean code you know most changes as an are not 15 one-line to changes. is Its used expression but it 16 say be Q. that one something line. as -- fairly simple may 17 not 18 But understand for it to make this change have 19 would been have very been someone to like you would 20 simple thing undertake vague right and 21 MR. INGEER Objection 22 ambiguous. THE 23 WITNESS It would have been pretty 24 simple BY MR. change. 25 BASKIN DAVID 805 FELDMAN New WORLDWIDE New York INC. Third Avenue York 10022 212705-8585 259c25ef-fd4e-4fb6-808d-35a1 f24e5aal Page 120 KARIM 142018 142024 142031 142037 142042 142047 142055 142059 142101 142106 142109 142109 142114 142119 142124 142129 142131 142139 142143 142145 142149 142152 142155 142158 10 JAWED decision of to 2005 Q. Now in was there made not within to YouTube the and around April permit from administrative -- interface viewed block to videos going from being MR. THE prior review and PAGE WITNESS site Objection vague this So ambiguous. Um so was discussed before the Web we launched. at this actually is we everything subject discuss point and really were to you know changing 11 considering BY MR. Q. different possibilities. 12 BASKIN My question 13 is Was interface the decision went to made -- 14 when the administrative made not to live permit was review 15 decision of write code to 16 videos by the to the interface prior their being 17 displayed A. public know of if -- 18 Um dont so youre asking of the me -- 19 about of the initial kind implementation 20 this interface think it 21 probably the varied. site think launched. you 22 know think So -- this is before Web 23 we probably be tried out surprised different if we approaches. tried both of 24 wouldnt had 25 those approaches. DAVID 805 FELDMAN New WORLDWIDE New York INC. Third Avenue York 10022 212705-8585 259c25ef-fd4e-4fb6-808d-35a1 f24e5aal Page 121 KARIM 142200 142203 142205 142207 142210 142211 142213 142214 142217 142218 142221 142222 142224 142227 142228 142230 142232 142232 142232 142237 142242 142244 142301 142303 10 JAWED was to Q. Well they one possibility publicly of the review videos before A. became one available correct Thats And to MR. THE was possibilities. ever adopted by Q. that possibility YouTube your knowledge INGEER WITNESS Objection vague. dont we remember both but think its very possible that used approaches. BY MR. Q. BASKIN When did you use 11 both approaches 12 Mr. Karim MR. 13 PAGE Objection misstates his prior 14 testimony. MR. THE 15 INGEER WITNESS the Same objection. remember exactly pretty when 16 dont 17 but sure. these -- approaches changed Im 18 19 BY MR. Q. BASKIN Can you was set tell us to 20 any period of time when they the 21 interface became A. up review videos before 22 publicly available know that the was time the frame. 23 dont that think some its 24 very likely Q. case for time. 25 What time sir DAVID 805 FELDMAN New WORLDWIDE New York INC. Third Avenue York 10022 212705-8585 259c25ef-fd4e-4fb6-808d-35a1 f24e5aal

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