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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11/132009 Liu Matthew OUTSIDE HIGHLY CONFIDENTIAL COUNSELS EYES ONLY -- UNITED FOR THE STATES DISTRICT DISTRICT COURT OF SOUTHERN NEW YORK Figueir Deci. Thb VIACOM INTERNATIONAL COUNTRY INC. COMEDY PARTNERS TELEVISION PICTURES MUSIC. INC. PARAMOUNT and BLACK CORPORATION ENTERTAINMENT TELEVISION LLC Plaintiffs vs. NO. 07-CV-2103 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. 10 11 THE 12 FOOTBALL ASSOCIATION BOURNE PREMIER et all al. LEAGUE on LIMITED of CO. and behalf themselves 13 others similarly situated 14 vs. 15 Plaintiffs NO. 07-CV-3582 YOUTUBE 16 INC. INC. YOUTUBE LLC and GOOGLE 17 Defendants. 18 VIDEOTAPED SAN DEPOSITION FRANCISCO OF MATTHEW LIU CALIFORNIA 19 20 21 22 23 24 25 FRIDAY JOB NO. 17826 NOVEMBER 13 2009 11/13/2009 Liu Matthew flU use to target in MATTHEW Search does not PVAs actually target YouTube Okay. on behalf of advertisers advertisers. but it offers targeting abilities to So Okay. the advertiser is selects how they want to do the targeting that correct Yes. 10 Okay. What options does YouTube provide for 11 targeting On the 12 Search PVA 13 Uhhuh The run of correct. 14 targeting which is options show on an advertiser search has are or 15 site any pages 16 they can do again theres technical also term called vertical 17 targeting and geographic and it targeting. is 18 Theres do more demographic than Okay. one of targeting these at possible to 19 one time. 20 Can you define what run of 21 site means Run of to site run 22 essentially means the advertiser the to is 23 just wants of the ad and and they also specify goes 24 number the ad impressions that the this in information 25 server this case YouTube 24 11/13/2009 Liu Matthew flU using can run snd on the sd MATTHEW sees these ads as server ads that it untargeted is inventory. also in trade Inventory can then term and these the ad ads run guess whatever for instance server sees Okay. MR. availability inventory. MANCINI present Just to be clear we are talking 10 about MS. tense Correct. correct MAGUIRE 11 Mr. flu ads can it ask can did run you on say the ad server 12 sees or these that targeted inventory 13 untargeted Sorry. That inventory That was 14 poor but description. 15 is what said its little hard 16 to describe. What is 17 inventory again is 18 Inventory technical to areas can the term. term used. Its it 19 Its an industry term but refers 20 where run where advertising publisher on also of technical so 21 term behalf advertisers 22 its location. Okay. The 23 And whos is the publisher term and in 24 publisher YouTube is technical publisher. 25 this case the 25 11/13/2009 Liu Matthew flU Okay. You What MATTHEW Thank the you. uaed is term vertical earlier. vertical once In Vertical technical category term. of What again case is very specific it as this we defined been do search is queries search that have classified. query What you mean by that 10 search query very is an industry term that but 11 again theres is specific the definition my one bar or 12 definition more its that string of into keords search 13 keyvords Okay. in user enters 14 15 order to run search query 16 Okay. on Okay. 17 search And in engine. do you run 18 how how do you run 19 search query search the best engine person to 20 Im question. not answer that 21 22 Okay. vertical vertical search is is Mr. flu in you this testified case as 23 earlier that category of What defined that of have 24 queries category been classified. 25 search query 26

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