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)

Business Requirements

Document

for

New

Features

Feature

Name

Gec-filtering

1gLIeiId
204

Deci.

Tab

Requester Department Date Created Eng Estimate Design Estimate

Donahue/Chris Maxcy Business Development
Kevin

asap From Steve From Maryrose

IS
What
This

Description
is

this

feature would enable us
global/territorial

feature

to

filter

partner

video

content

and control

where Canada

it

is

delivered

on
etc..

basis

US only US

Canada.

US

Mexico

Goal Why
are

we

developing

this

feature

To control necessary

the
in

delivery

of video

on
the

territory-by-territory constraints
of

basis worldwide
rights

This related

is

order video

to work

within

the

distribution

to

much

of

the

we want

to acquire

from professional

content

provider/partners.

by offering
universe
to this

the

ability

to Geo-filtervideo video content
limiting

we
the

will

gain

access

to

much
video

larger related that

of professional

Territorial

rights

issues
of

and controls
content

has been
content

major cause
providers so far.

type

and

amount

professional provide

studios

networks

labels

etc

have

been able to

to YouTube

12

Scone
as well as any
constraints

General feature scope implemented

on

how

the

ftature

should be

The

feature

should

allow

us

to

assign

specific

territories

on

video-by-video

basis

and only deliver

certain

videos
for

to certain global

approved
distribution

territories

and not

to others

Some
Only only

videos or
etc.

will

be allowed Canada

while

others

might be Canada Mexico

only

or

Mexico

only

or

We
so

should

define

territories

in

the

same way
traditional

traditional definitions to

television of

broadcasters as these

do
are

we can deliver
by the

video

in

sync with

territories

currently

defined defined

television

industry

We

II

have
or

look

into

exactly

how

Le.

specific

European
to

countries

EU etc.
like zip

Well
create

also want

to be able

define

regions
basis state
in

code
the the

or other case that

designation certain

we
the

Perhaps on
not

state-by-state to certain

the

US

in

content

may

be delivered

or zip

code.

In

case of sports rights

Rigbiy

confidential

Bert

Ads

tics

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Yougjj
Business Requsrements
zip

code

filter

will

most

likely

be necessary
regions

Document for New Features as is common for sports rights
it

to

include

black-outs

of certain

like states

or particular

cities

and

zip

codes.

jQ
Long

Future term

Directions

vision

and
build

future

considerations

for the

feature

We may

want
or

to

some
it

flexibility

into

this

feature
point.

so that

we can

redefine

territories

regions

we need

tQ at

some
codes
in

Could be international
states
in

territories at

or zip point

in

US

or states

in

US

or counties

or

another

country

some

future.

Priority General
priority

of the

feature

and expectancy
as possibIe as
it

fbr time to

market

We
that

need

this

feature
at

as soon
request

is

necessary based on

to be able
their

to geo-filter
rights for

video

content
particular

the

of content

partners

distribution

videoS

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