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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Figueir Deci

David King Shashi Seth

Franck

Chastagnol

Highly

Confidential

G00001-02081141

Goals
Educate
Work
with

users

community

encourage

good behavior

offer alternatives

Identify
Improve
auto-identification of copyrighted

materials

apply

policy

set by content

owner

Collaborate
Provide
tools to partners

and

non-partners

to

manage

their content

Promote partners content

Penalize
Repeated
infringements

from same user

Highly

Confidential

600001-02081141.0001

System Overview
User Uploads
Educate

Partner scenario
YouTube.com

Auto
ft

Identif

Ads
iIS4

ft

_________
1.0

Policy

Watch

Cflflt1

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Video
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Repository

Reference
Fingerprints

Content
Policy

Licensed Content

SQUAD

Ad Revenues

Partner

Tcc
Content Partner

Highly

Confidential

600001-02081141.0002

System Overview
User Uploads
Alternatives
.2

Non-partner scenario
touTuba
corn

Educate

Auto Identif
LL IL

Apply
Policy

Watch

Don

Ii

Video
Repository

Content
Policies

Licensed Content

SQUAD
review Non-licensed content
ref

Ad Revenues

Ps

IL

Non-Partner
Highly

Confidential

G0000102081141.0003

Fingerprinting
Licensing Audio

Current

FP from Audible Magic
.2M from Labels Music content

Large set of Music ref FP
Identification

rate satisfactory for

Issue with other content

types length of ref

no lookup against Working with
partitioning

entire

FP

AM

on improving solution
Lic vs

Music vs

UGC
incur extra costs

update

to

lookup algo

may

No video

fingerprinting

Highly

Confidential

600001-02081141.0004

Fingerprinting

Objectives
fingerprinting

Use Google Video and Audio Video

Google Video research team implementing
Integration

plans started

One

of the challenge

is

to build ref fp set

Highly

Confidential

600001-02081141.0005

Content policies
Music
rights are

complex

Label owns sound recording
Publishers

own composition

rights

Music Pub

rights not cleared yet

Blocking us from turning on audio fp on music content

Need deals And then

with
will

major publishers asap
still

there

be hundreds

of minor

publishers

Highly

Confidential

600001-02081141.0006

Timelines
Copyr Formed
Update up
cross-functional
to partner tool

vch-Qn
team Google video Google audio
Consolidate
fingerprinting fingerprinting
rollout

opening

pilot

to partners

admin/CYC

tools

Offer alternative

AudioSwap

Qetect and penalize
infringers Start

repeating

yph

ot

Qar
fingerprinting
pilot

Google video
Improve

opening

up

tool

to

non-

AM
in

partners

audio fp solution

EphotQn
System
rights

place

for publisher

mgmt
pilot

Google audio
incent
to

fingerprinting

rollout

User rev share

upload genuine user content

Highly

Confidential

600001-02081141.0007

QA

Highly

Confidential

600001-02081141.0008