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)

From
Sent

Copyright Saturday
Ti

Service
April

copyrghtsupportyoutube.com

28 2007 223

AM cGMT
clips

To
Subject

mCDnr-onl

inc .com

Re

Premier

League

Dear

Tim
much
for alerting

Eiueiia

Deci.

Tab

255 Thank you very and
it

us to this had

looked

into

the

problem

appears

that

some

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by our email
having
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system
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warn

filters.

am unsure what caused
into
it.

am

team look
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to

pull

of

all

your

emails
sincerely

and

verify

any this

missed

have

now

been

removed.

apologize

dont know what would have caused you
to

this to

happen.

would
will

like

again invite

the Content

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Program
for

which

greatly

increase

response

time and eliminate

the need

email

notifications.

YouTubes
where
check

Content

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provides

an

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interface

content boxes

owners
and

may

request

removal After

of infringing content

by using
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select all functions.
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one page
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in order to

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the

your

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the

way
days

ensure

removal

of content

from

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day
owner
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365

year.

All

content
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complete

and submit

Youlube

program and gain short form that

be found

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site

me know

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have any

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The

YonTube ieam
Follows

Original

Message

From Tim Cooper
Subject

RE

Premier

League

clips

Date

Fri 27

Apr 2007

183201

0100

Dear

Sirs

CONFIDENTIAL

PL00025679

The

below

clips

are

still

online

sent

an

email on the 24th

April requesting

their

removal.

Please

remove

immediately

Regards

Tim

from Tim To

Cooper 1134

On

Behalf

Of Tim Cooper

Sent 24 April 2007
Copyright

Seivice

Subject

Premier

League

clips

Importance

High

Dear YouTube

Please find included
the

below
signed

list

of infringing under
clips arc

clips

found on
of clips
the

YouTube.
and
rights

have
notice at

declaration

the

list

end

of the

email.

These

infringing

of our client

the Premier

League. been

Please remove

immediately

and

advise

me

by email

when

these have

removed.

http//wtivw.youtube.com/watchvwqw8K99pwffl

http//www.youtube.com/watchvBTaSc2WAyGY
http//www.youtubc.coni/watch9vtllaEBP2FkNIM

http//www.youtubc.com/watch9vpjILvEaCpZyO

http//www.youtube.com/watchvlHOxSZdySjg

CONFIDENTIAL

PL00025680

http/iwwwyoutuhe.com/walchvmPBCyGMNk

hereby
rights

state

that

the Premier

League

is

the

owner

of the exclusive

referenced with
respect to

above and

that

NetResult

is

authorised

to

act

on

its

behalf

internet

monitoring
state that

and compIiance good
of
is

On
belief

behalf
that

of the Premier use of the Premier

Leanue
content League.
its

hereby
in the

have

faith

manner

complained

not authorised

by the

agents

or the

law.

urn Cooper
e-mail message
States

as

representative

of NetResult

hereby the laws

digitally

sign this United

under

penalty

of peijury under

of the

of America information

with
in

the

additional
is

statement

under

penalty

of perjury that

the

the

notice

accurate

Regards

Tim

NetResult

Tim

Cooper

Account

Manager

Projector Netkesuit

Ltd

Mulberry House
583

Fulham

Road

London

CONFIDENTIAL

PL00025681

SW6

SUA.

[e-mail]
httpf/www.nr-onli

ne.com

tel

44020

7471

1735

CONFIDENTIAL

PL00025682