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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112112009 Berrocal Marco ____________________ Figueir Deci. Thb 313 UNITED FOR THE THE STATES DISTRICT DISTRICT COURT OF SOUTHERN NEW YORK FOOTBALL ASSOCIATION BOURNE PREMIER et al LEAGUE on LIMITED of CO. and behalf themselves all others similarly situated Plaintiffs vs. Case No. 07CV3582 YOUTUBE GOOGLE INC. INC. YOUTUBE LLC and 10 Defendants. 11 12 13 14 15 16 17 18 19 VIDEOTAPE DEPOSITION NEW OF W\RCO YORK BERROCAL YORK NEW WEDNESDAY JANUARY 21 2009 REPORTED 20 BY CSR RPR ERICA JOB RUGGIERI 16343 NO 21 22 23 24 25 112112009 Berrocal Marco BEROCAL Q. And how about in Murbo do you know how long A. thats been existence specifically. International when you No Were Company in the Yes. dont they in know was Q. Music Bourne A. existence 1994 joined 1993 time period Q. How in about Murbo when was you that 10 already existence started with 11 Bourne A. 12 Yes. 13 Q. Lets go back to Bourne for 14 minute. Does from its A. 15 Bourne generate revenue 16 music Yes. Can of the in In publishing business 17 18 Q. you explain to me the 19 sources revenue the that of of Bourne its its 20 generates A. course course we business music revenue Also we we sell 21 the 22 publishing business music generate for use. sense to 23 by licensing sell sheet out so 24 music in 25 product specific product individuals 112 112112009 Berrocal Marco BEROCAL or as another Can you revenue tell me stream. Q. approximately of how much percentagewise are the come Bournes the of the total revenues of from licensing music portion business MR. to 10 A. HART of Im that. going to object the form No. 11 MR. HART rental Tern side you mean as 12 opposed to 13 MS. the sheet MR. A. No. MAZUR music No side. You as opposed to 14 15 HART can try. 16 17 MR. If MR. HART you can Can or you you -- 18 Q. cant. 19 HART With are you that able to 20 clarification it answer 21 or not All could say is 22 A. its lot 23 more. The 24 Q. licensing side of the 25 business 113 112112009 Berrocal Marco BEROCAL Q. Do you have any understanding of what been the used term in reposted Exhibit action there and was to means as its second Bournes amended A. class That was complaint was that put takedown after notice sent being or taken down the video on back on reappeared 10 Q. YouTube. the And takedown of notice is was that 11 sent by or on to behalf Bourne 12 correct YouTube 13 MR. HART in the Object first to form. for 14 Q. instance 15 these A. works Can Sure. Please. You you repeat. 16 17 Q. 18 A. 19 Q. testified notice was minute had been ago that to 20 after takedown the by sent 21 YouTube correct work actually taken down 22 YouTube HART up Just keep going. You 23 MR. are 24 setting MS. question. No. 25 MAZUR Actually 79

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