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)

Download PDF

1/8/2010 Kacholia Varun 110247 which is MS. MAGUIRE understand little bit this of is complicated why Can Im you having talk me are trouble. bit more about through assigned little to how relative weights certain metadata fields MR. RUBIN Objection. Vague calls calls for speculation narrative. THE 10 incomplete hypothetical for WITNESS Because the search algorithm it uses all these different and fields others that the you have that and the user 11 12 identifies entered in how well they match the query 13 order to produce Okay. most relevant results. 14 MS. MAGUIRE WITNESS 15 110340 cannot THE Its to complex each of algorithm those in and 16 just assign weights 17 abstract. MS. 18 MAGUIRE this result Okay. What about -- maybe 19 something like This would in work of 20 front can us the word me an dog. example of that If of 21 typed what in the word dog you give in 22 would happen behind the scenes terms 23 matching MR. 24 RUBIN Objection vague. calls for speculation 25 incomplete hypothetical 57 1/8/2010 Kacholia Varun 110422 THE WITNESS videos So the first that step would be identifying MS. THE which contain term dog. MAGUIRE WITNESS the pieces the Mm-hmm. And of the second for step each would video be identifying that dog. MS. THE 10 metadata to contain word dog that the query MAGUIRE WITNESS the Okay. And then using all these of the as the input to determine the overall or You relevance first 11 video versus MS. second tenth. said the overall 12 MAGUIRE 13 importance THE 14 WITNESS MAGUIRE WITNESS MAGUIRE than Yes. Okay. Relevance. Are there pieces of of 15 110500 MS. THE MS. are more 16 17 metadata that 18 important MR. other pieces vague metadata asked and 19 RUBIN Objection and 20 answered. THE and the video. MS. THE 21 WITNESS It really depends on the query 22 23 MAGUIRE WITNESS Okay. For the 24 algorithm to make that 25 judgment. 58 1/8/2010 Kacholia Varun 160000 refine their search. Is it fair to say its way to filter the results to No. the original query So if for example it select the on the far righthand partner would corner where If says partners that video what what videos. selected option the search MR. functionality do vague. limit the results to RUBIN WITNESS are Objection It 10 THE would 11 only those that 12 MR. GALDSTON how would videos the 13 And determine search functionality 14 which MR. THE were partner videos 15 160000 RUBIN WITNESS Objection This is vague. 16 its 17 18 do not have definitive video upload some answer but on how video it is marked by the by 19 as partner that in by YouTube believe been is 20 users it if they have approved 21 YouTube way. 22 MR. So GALDSTON is it 23 fair to say then that 24 is one of the metadata that the search functionality 25 considers when returning search results 180 1/8/2010 Kacholia Varun 160000 MR. RUBIM Objection vague calls for speculation. THE MR. THE WITNESS GALDSTON WITNESS Considers When With when to user the query. responding the filter With MR. GALDSTON Well lets start THE 10 WITNESS GALDSTON with the Okay. is MR. So 11 that metadata in 12 field that to If the search user functionality can consider 13 response query 14 15 160000 MR. THE RUBIN WITNESS Objection. If the features 16 option is 17 returning MR. 18 GALDSTON Let me Okay. Turning your attention to 19 Exhibit 18. know when youre ready. 20 THE MR. the WITNESS GALDSTON search it Yes. Okay. on So 21 you see Ive selected 22 selected and options to the upper lefthand menu. 23 corner among appears is have dropped your down And 24 the options THE refine search by location. but 25 WITNESS Yes it didnt print out 181

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?