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)

1211212008

King David

___________________

UNITED
FOR THE

STATES

DISTRICT DISTRICT COMEDY

COURT OF

Figueir

Deci.

Thb

SOUTHERN

NEW

YORK

320

VIACOM

INTERNATIONAL INC. COUNTRY MUSIC. PARTNERS

TELEVISION INC. PARI1OUNT and BLACK PICTURES CORPORATION ENTERTAINMENT TELEVISION

LLC

Plaintiffs
vs. NO.

07CV2203

YOUTUBE INC. YOUTUBE and GOOGLE INC.

LLC

Defendants.

10

THE
11

FOOTBALL behalf
of

ASSOCIATION BOURNE themselves

PREMIER
et al

LEAGUE
on others

LIMITED

CO.
and

all

12

similarly situated Plaintiffs

13 vs. 14

NO.

07CV3582

15

YOUTUBE INC. GOOGLE INC.

YOUTUBE

LLC

and

16

Defendants.

17

HIGHLY
18

CONFIDENTIAL
OF

VIDEOTAPED
SAN

DEPOSITION DECEMBER

DAVID
2008

KING

FRANCISCO

CALIFORNIA

19 20

FRIDAY

12

BY
21

ANDREA LICENSE
NO.

M. NO.

IGNACIO
9830

HOWARD

CSR

RPR

CCRR

CLR

CSR JOB

16211

22 23 24 25

1211212008

King David

KING
MS.

LACAVERA HART
Bill

Catherine

Lacavera

for

Google.

MR.

Hart

Proskauer

Rose

plaintiffs
MR.

DESANCTIS
the

Michael

DeSanctis

Jenner

Block

for
MS.

Viacom

plaintiffs.
Sarah

MAGUIRE

Maguire

Jenner

Block

for

the

Viacom
MR.

plaintiffs. Kelly Truelove consultant
for

TRUELOVE
plaintiffs

10

the

Viacorn

11

THE

VIDEOGRAPHER
the court

Thank

you.

12

Would
witness.

reporter

please

swear

in

the

13

14

DAVID having been

KING
as

15

sworn
as

witness

16

testified

follows

17

18

EXAMINATION
MR.

BY MR.

HART King.

19

HART

Q.

Good

morning Mr.

20

Good Are

morning. you

21

employed

22

am.

23

By By How

whom
Google
long have you

24

25

been

employed

by Google

1211212008

King David

KING
Since How

January
did you up

2007. to

come some and

work

for

Google
that

called working
there and

people
said that

knew

were
in

was

interested

exploring

employment what were

opportunities.
you

And

told
interested them
and we and

was

told

that and

they were
met

went
10

by their
from And
So

office
there.
is

with

proceeded

11

them
the

who
met

12

people

with

you

would

like

13

Yes

please.

14

complete
Who Who did did you

list

of

names

or

15

meet

with

16

meet met and

with
Franck Chris and

17

Okay.

with with

Chastagnol

and

with

18

Zahavah

Levine
and
at

Maxcy
those

and are

with
the

Steve

19

Chen
recall

with
this

YiLing
moment.

Su

names

20

21

Okay. did you meet

And with

all

the
at

folks one

you

just

mentioned
this

22

them
of

meeting

or was

23

through
It

series

meetings know
with
in an

24

was

you met

interview individually

situation. and thei

25

So

typically

people