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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no via currently we do not give user strike if content is taken down CYC. franck Thank Ken you Forwarded message -- From Jamie Byrne cjbyrne@youtube.com cmailtojbyrneyoutube.com Date Mar12 2007 732 AM Re CBS March Madness Warner Subject To Cc Chi David King dgking@google.com .cmailtodgking@google.com Aiwin kenm@google.com cmailtokenm@google.com Matthew Liu alwingoogle.com mailtoalwin@google.com Motoyama cmailtomatthew@youtube.corn cmailtoshivar@google.com mailtokenji Kenji Ken matthew@youtube.com shivar@google.com kenji@google.com Shiva Arai Rajaraman cgoogle.com Ah good Actually point. -- think change strikes the we can get around the removed display message communications -- part can we BUT --will the users receive That is the bigger issue. later that will two weeks Jamie we encourage be problematic. If upload and then strike them David King claim wrote will The database in allow us to get back it to the list of claimed videos. users. USC only videos part the same way about is leads us to their licensed The Im worried On the one the other explaining well hand we end up de-publishing them few weeks This could cause some real confusion why. can is messaging what going on to want them to upload their favorite clips and on without later for our users. explanatory Perhaps email or we somewhat it mitigate their this by sending users an messaging wrote -- on account page. Jamie think Byrne by Web just clips. but we can confirm with them. They will terminate the account -- that will take down all the uploaded Would too. be good if the CYC tool made it easy to take down claimed clips Jamie Ken Hi Motoyania wrote David Highly Confidential G0000102604741 Please see questions/comments below in bold On 3/9/07 David madto dgking@google mailto King cdgking@googlecom mailto dgking@googie corn corn dgking@google corn wrote Alwin just spoke off with Jarnie and we are little concerned about leaving the CBS demo until Thursday to as that is the day March Madness begins and CSSto start to CS them has exclusive rights tne tournament our goal is to get dairning as much as possible as soon as posable We want claim this content because we can only monetize content that has bean claimed content to Of course CBS is also dependent on daiming the make money uploads will We are confident that the thousands of hkely user dnve much more traffic than the clips uploaded by CBS directly. Will CBS be uploading the March Madness be using clips via the web or $FTP Please login for note that CBS should their specific NCAA tourney fit type of claiming allowing us to take this content down expire. within weeks of the end of the tournament when their rights We in probably timely that want to push the onus on is CBS how to will take down their content UGC In The bigger issue assume they claim which fashion of we takedown be done all needs to as well Lets one the smails it sounded like CBS can do Wednesday push for that instead. Kenji can you help with this Thanks David Aiwin Chi wrote Hi ra David has been believe Kenji working on setting up the call with Rebecca Borden on and it GYC next Thursday just sync ed up with Ken sounds Highly Confidential C0000l026o4742 like this is the same call discussion. Let touch base next Tue/Wed before we have this and decide to drive this conversation with sounds lawyers this like we are talking to quite few executives and on upcoming call. Regards Aiwin On mailtodgking 3/9/07 David King dgking@google.com rnailtodgking@google.corn cmailtodgking@google.com @google.com dgking@google.com dgking@google.com corn crnailto -mailto mailto cmailtodgking @google. dgking@google.com Aiwin is wrote Thanks work with him for the heads up. the TAM on CBS so Ill on gethng demo out early next week. Alwin training can you please reach out to CBS and sot up time Tuesday Ill would be ideal. Please invite me along and do the demo with you. Ken just setup well run Webex CBS. demo today with NBA-Id suggest will we do the same thing with Im sure Ken be happy to that help you set before. up if you havent done it that way Thardcs dk Jamie Byrne wrote On offon the phone it sounds like they are not totally bought CYCand seem Would in confused about legal terms around it. be good to get appropriate folks trained as early the week as possible. Tip-off site is at 9am on Thursday. Clips will be on the by 1200 PST. Thanks Jamie Highly confidential G0000102604743 Matthew Liu wrote We ready. are giving CBS access to CYC before then. It is BBC and NBA already have access. David when need were you planning on days handing over the login/password CBS trained will couple to get acquainted with the tools and so sooner is better. On Mar 2007 at 1246 PM Jamie Byrne wrote Warner However content via is not involved in the March Madness thing. -- we do need to get CBS ready to Claim NCAA CYC. The Tournament on Thursday. starts What our our next steps there Jamie Matthew Hey Liu wrote gis met with Yesterday that Vu in from Warner. He mentioned he heard might be some March Madness rumors that Warner involved in the CBS campaign clarity it was running. This is news to me. Can you this is or is not the case Man Matthew Product Liu Manager matthew@youtube.com cmailtomatthew@youtube.com cmailtornatthew@youtube.corn czmailto mailtomatthew@youtube.com mailtomattriew@youtube.com cmailtomatthew@youtube.coni cmailtomatthew@youtube.coni niatthew@youtube.com cmailtomatthew@youtube.coni mailtomatthew@youtube.com crnailtornatthewc@youtube.com czmailto matthew@youtube.com cmailtomatthewyoutube.com mailtomatthew@youtube.com mailtomatthew@youtube.com mailto Highly confidential G0000102604744 Regards Aiwin clii Technical Account Manager P50 Google -- Best Regards Ken Motoyana Sales Enginoer Google -- Best Regards Ken Sales Motoyama Engineer Google Higbly Confidential G0000102 604745

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