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)
matter
their
level
in
the organization.
Partner
focus.
started
out
my
career
as an investment
to deliver
in
banker
for
managing
clients
investments
for
high net worth
clients. at
Over
the last 20
years
ye never
taken
ceased
results building
my
and
that
skill
has served
me
well
YouTube
where
of
have
leadership
role
collaborative
to listen
relationships
with the top-level
management
answer know media what
to
the major media questions
to
companies
know
how
all
respectfully
ask
good
closely
of
questions
and
to
partners
companies
say how and
as completely as possible say it and what not to say.
respect
while
preserving
our most
Ive
now worked
contact
with the
at
CTOs
guarded secrets most of the major
they
me
of
as
their
main technical
Youlube.
Media
the
for to
expertise.
Starting
in
January
2000
was
the main
architect
of
the
content
management systems
pioneered
for
Rhapsody an
Intemet
to
music service
service Eight
Rhapsody
years
later
launched continue
almost
to build
year before
Tunes
and know
music
aboL.ft
licensing
on ye
that
built
expertise
enough
copyright profesaonal
that
law
lecture
content
build
most lawyers who focus on other areas both in the US and internationally Youlube
that
will
and
multiple systems for
is
managing companies
challenge over
their
to
convince
media
requires
systems and
about
give
them
fine-grained
rights lived of
control
content area
of
and and
that
understanding people
we can how they
as on
use
operate
exactly
this topic
what as
at
their
legal
are
This
is
complex
there
are few
who know
for
much
the
do
having
through
the entire
history
licensing
professional
content
Internet
always
the cutting
edge
of
the evolution
Priorities
and
vision.
By
to
the
nature
all
the challenge
YouTube
has taken
on
in
it
will
take
rriany
years
before
we
it
mature our systems
vital
handle
vision
the scenarios the overall
demanded
to
by our partners.
that to
to
maintain
cFear
of
plan and
keep
vector
situation like this is manage mind when making day-to-day plans.
To
With work
to
almost
in
the morning
20 years of experience under start everyday so that
my
belt
Ive clear
learned idea of
in all
formulate
plan of
to
attack
that
on
my
drive
into
with
what
want
get done
that
day. over
This allows your day.
me
accomplish
my
bigger
goals
without
getting
engulfed
the smaller
tasks
can take
Managing managing
almost
teams.
Ive
of
managed
at
cross
functional
teams The
for
years
bridging
many
the people
directly
myself
project
working
the gaps between groups and on requires heavy coordinetion between
every
department
the company.
Areas
plan to
for
Development
these
What areas
are the
major 3-5 areas
that
you
think
you can
improve
upon
and
how do you
develop
Public
speaking.
enjoy
speaking
this
with area
smaller simply
groups by taking
but
still
feel
some unease when
tor
addressing
large
audiences
plan to
develop
on opportunities
speaking
engagements
as every
time
on the podium
makes me more
the past
full
comfortable.
Managing because
taken
into
upwards. take
to
In
Ive
been
of
more
effective
at
it
managing
for
downwards
to
than
upwards The
to boil at
mostly
discipline
on the
compledty
front
is
my work
regularly
making
take stock
hard
of
me
summarize and
pnorities
quickly.
Ive
on
short
improve
lists
on
that
to
my
projects
and
them
down
written
That
has helped
is
me
keep
whenever
an executive
summary
needed.
make
tocused
for
on track with my work and kept this work with small amount
me
of
always
the ready
preparation.
User
interface
design. remains simple
Over the years
the primary user interfaces
Ive
primarily
on understanding
role but
to
it
and
solving to
complex
transform
business
that
problems. complexity
That
into
challenge
that
my
current our
will
be important
us.
encourage
partners
work with
OPTIONAL What
this position to
Slotting
You may be
think
slotted
dunng
slotted
this
review
to
position
best
matching
your
performance any
additional for
do you
explanation
time.
be you should and slotting help managers
to
Group
to
Product
Manager what
Please
position
provide
is
committees
best
evaluate
most
suitable
you
at
would
in
like
to of
be considered
vision
to
for
the level
ot
Group
Product
the level
leadership
and
ownership
aspects
is
required.
We
The Manager. have already Over
main
distinction
see
in
this
position
is
including large
me
as
manage
for
the various
of
the platform.
into to
agreed to grow my team to the last 10 years have consistently
that
PMs
had
teams
working
vital
me
My
goal
to
make YouTube
and
Ill
platform
the global
of
media
embraces
new
distribution
channel
need
build
on the contributions
community sizable team to make
Highly
confidential
G0000i01401528
that
happen.
Thankatt
Your
Friendly
Pert
Team
Highly
Confidential
G0000i01401529