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)

needs

to

change

to

document.getEementByldFLASH_myObjName.SetVariable

dcPVAurl
To
test

we

just

http//webl .sjl.youtube.com/pv need to make sure that the video
having network
that

plays

on

all

browsers.
to

Im

hard

time

testing

IF

while so

also connected
if

the google

and

dont have be
great.

mac

anyone

else

could

help with that

would

Thanks
nadine

On 10/27/07
Sounds

Mike
to

Solomon me.

[e-mail]

wrote

good

On

Oct

27 2007
with

at

1136AM

Franck

Chastagno

wrote

talked

Nadine.

She
noon.

is

working

on

quick

fix

for

the get_video_token

ETA

is

This quick
not

fx

may

break

PVA

rating

in

some cases

if

user does

play video.

Im

going
is

to

discuss

with

FM OPS

to

find

out

how bad
fix

it

is

if

FVA
later

rating
If
it

broken. ask
to

is

bad we may

push

for

PVA

rating

this

afternoon

or evening.

Thanks
Franck

On was my
swf.

10/27/07

Nadine

Hank

[e-mail]

wroteYes
to

this

change.
In

Before
to

we were
the swf loaded.
isnt
is

passing

the token
it

in

the

call

for

the

order
after

cache

made
It

so that

we

request

the

token
right
Ill

the swf so that
ii

away

there
it

delay

do was suggested that when user clicks
only when

this play.

change
play.

so that

requests

the token

user

clicks

On
call fix

10/27/07

Mike

Solomon and

[e-mail]
started

wrote Can someone want

Nadine or Aaron
no
later

get them

on this

than

noon.

On Oct 27 2007
Nadine

at

1023

AM

Geoff

Stearns

wrote

Ah
Nadine

you are

right

it

must be the pva then

maybe Aaron

changed

it

recently

Highly

Confidential

G00001-00718496

On

10/27/07 Geoff

Vijay Karunamurthy noticed the

[e-mail]

wrote
for

Hey

homepage

makes

the requests

me

in

Firebug

http//www.youtube.com/api2_restmethodyoutube%2Evideos%2Eget% 5Fvideo

%5Finfovideo_idzLn3X%2DmzpUc
http//www.youtube.com/api2_rest methodyoutube.videos.get
video

tokenvideo

idzLn3X-mzpUc
wrote

On Oct 27 2007
looked player so
that at

at

1017AM
page and

Geoff

Stearns

the Casio

they are

using the

relO

page

should

never

even

request

token...

and

its

not
ust

checked.

noticed the old player so

its

on the homepage wont be making

pva as well

but

that

uses

that

that

request

either.

On

10/27107

Geoff

Stearns player uses

[e-mail]
get_video_token before
it

wrote
plays

The
video only

new
but after

embed
the
first

video

the

first

token

is

sent back

as

url

param The
playing video
that

when

the

users

requests

the swf.

custom

player

and

acdc

players

also

use

this

before

we were
players

having

caching

issues

in

the cafe

response

the

acdc
could

were

using

the tokens

were expired

before

they

be
which

used

means

players

that

cant play any videos.

can
concern.

roll

back

the change

on the embed

player

if

its

On
In

10/27/07 recent

Mike

Solomon
found

sampling

[e-mail] few things

wrote

Top
uris

Requested

Items

naive

not

normalizing

stupid

vanity

111017/get_video 109270/watch 38026 37297 14858/
12256/user_info 10251
/tracker

/set_awesome
/api2_rest

Highly

Confidential

G00001-00718497

/api2_rest

is

way up
stand

there.

few

entries

out

7493

GET

api2_rest

methodyoutube.videos.get_video_tokerivideo_idzLn3X-

mzpUc

HUFf
1.1

7477 bFvideo%
bFinf

GET api2_restmethodyoutube%2Evideos%2Eget%
idzLn3X%2DmzpUc HTTF1
.1

ovideo

697 5Fvideo%

GET

/api2_restmethodyoutube%2Evideos%2Eget%

SFinfovideo 680

idne9OAB949SM
/api2_rest

HTTF1.1

GET

methodyoutube.videos.get_video_tokenvideo_idne9OAB949SM
1.1

HTTF/

The top two have

something

to

do with

Casio

contest.

Interestingly hits

enough.

these

top two

have

only generated

100

to
get_video actual
to actually

watch

something

and

zero

hits to

the

embed
At leaning towards

page.

first

though

it

was some
would

kind of

gamng
7000 50
calls calls

but

now Im

bug.

Why

you need
for

to to

youtube.videos.get_video_token

get_video ask because

If

someone can eqlain
in

that

would

be

great.

this

an aberration
normal

traffic

and

could

explain the

higher than

cpu

utilization

on the webs.

-Mike

Highly

confidential

G000 01-00718498