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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1012012008 Horan Jerry UNITED FOR THE STATES DISTRICT DISTRICT OF COURT Figueir Deci. Thb SOUTHERN NEW YORK 315 VIACOM PARTNERS INTERNATIONAL COUNTRY INC. COMEDY MUSIC PARI1OUNT and TELEVISION PICTURES ENTERTAINMENT INC. CORPORATION BLACK TELEVISION LLC Plaintiffs Case vs. No. 107CV02103 YOUTUBE and INC. YOUTUBE LLC GOOGLE INC. Defendants. 10 THE FOOTBALL ASSOCIATION BOURNE PREMIER et al LEAGUE 11 LIMITED of CO. and on behalf themselves all others 12 similarly situated Plaintiffs 13 vs. 14 Case No. 07CV3582 15 YOUTUBE INC. GOOGLE INC. YOUTUBE LLC and 16 Defendants. 17 18 DEPOSITION NEW OF JERRY HORAN YORK NEW YORK 19 20 MONDAY REPORTED ERICA OCTOBER 20 2008 BY CSR RPR 15952 RUGGIERI 21 22 23 24 25 JOB NO 1012012008 Horan Jerry J. HORAN A. Im What sorry didnt hear was you. your Q. specifically to role with A. regard licensing fees. licenses. negotiated of the oversaw the preparation it. Thats basically Q. Did you negotiate besides any other license 10 provisions MR. fees form. mean. HART not Objection sure 11 A. Im With what to did you 12 Q. respect what the you preparation 13 of the A. licenses do people it. 14 assigned the licenses. various to 15 prepare Q. Thats any 16 Did you have involvement 17 negotiating A. the licenses 18 Yes. 19 Q. And what was in that involvement where were 20 A. Fees. And to instances terms that 21 licensee not part wished of our that have 22 standard licenses aspect some of it. 23 negotiating Q. particular give me 24 Can you examples of would 25 nonstandard licenses that customers 21 1012012008 Horan Jerry J. HORAN is profit they derive due to unauthorized content MR. HART Im sorry Bourne or unauthorized content content unauthorized generally MS. HERNANDEZ Unauthorized content generally. MR. HART Okay. Competence 10 foundation. 11 And MS. A. him personally right 12 HERNANDEZ personal Yes. 13 On You That to basis yes do. 14 said any do believe. that 15 Q. profit they derive 16 is due unauthorized MR. content objections. it. 17 HART you Same 18 think A. answered 19 Yes. 20 Q. How exactly has Bourne been 21 harmed by YouTube MR. Let Has 22 HART me Foundation. the question. 23 Q. rephrase been 24 Bourne harmed by 25 YouTube 162 1012012008 Horan Jerry J. HORAN Same MR. HART and objection and competence Go To prior testimony. ahead. Q. your understanding. use for of any A. Any loss Has to unlicensed of Bourne song is revenue Bourne. Q. Bourne conducted its loss any of analysis 10 as determine revenue you described MR. it 11 HART last Im sorry you 12 mumbled Q. the to what any of 13 Has to Bourne conducted its loss 14 analysis as determine revenue 15 you described MR. it Same 16 HART objection prior 17 foundation testimony. A. competence 18 19 dont Is it know understanding uploaded appeared any on that of the 20 Q. your 21 someone Bourne from works YouTube that have 22 23 YouTube MR. A. 24 HART Form know. 25 dont 163

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