The Authors Guild, Inc. et al v. Hathitrust et al

Filing 77

DECLARATION of LAURA ABELSON in Support re: 74 MOTION for Summary Judgment.. Document filed by Georgina Kleege, Blair Seidlitz, The National Federation of the Blind, Courtney Wheeler. (Attachments: # 1 Exhibit A - CCB Depo, # 2 Exhibit B - Google Clancy, # 3 Exhibit C - interrogatories, # 4 Exhibit D - Kleege, # 5 Exhibit E - Seidlitz, # 6 Exhibit F - Wheeler)(Goldstein, Daniel)

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Highly Confidential Pursuant to the Protective Order Page 1 1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 4 THE AUTHORS GUILD, INC., ASSOCIATION OF AMERICAN 5 PUBLISHERS, INC., et al., 6 Plaintiffs, 7 vs. 8 GOOGLE, INC., CASE NO. 9 05 CV 8136 (DC) Defendants. _________________________/ 10 11 12 13 H I G H L Y 14 C O N F I D E N T I A L PURSUANT TO THE PROTECTIVE ORDER 15 16 17 DEPOSITION OF DANIEL CLANCY 18 SAN FRANCISCO, CALIFORNIA 19 JUNE 1, 2012 20 21 22 BY: 23 CSR LICENSE NO. 9830 24 JOB NO. 50225 ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential Pursuant to the Protective Order Page 2 1 JUNE 1,2012 2 9:58 a.m. 3 4 5 6 DEPOSITION OF MICHAEL CLANCY, taken at 7 Kilpatrick Townsend & Stockton, LLP, 8 Two Embarcadero Center, San Francisco, 9 California, pursuant to Notice, before me, 10 ANDREA M. IGNACIO HOWARD, CLR, CCRR, RPR, 11 CSR License No. 9830. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential Pursuant to the Protective Order Page 3 1 A P P E A R A N C E S: 2 3 4 FOR DEFENDANTS: 5 KILPATRICK TOWNSEND & STOCKTON 6 By: 7 1100 Peachtree Street, N.E. 8 Atlanta, Georgia 30309 ALLISON SCOTT ROACH, Esq. 9 10 11 12 13 FOR PLAINTIFFS: 14 FRANKFURT KURNIT KLEIN & SELZ 15 By: 16 488 Madison Avenue 17 New York, New York JEREMY GOLDMAN, Esq. 10022 18 19 20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential Pursuant to the Protective Order Page 4 1 A P P E A R A N C E S: (Continued.) 2 3 4 FOR GOOGLE: 5 DURIE TANGRI 6 By: 7 217 Leidesdorff Street 8 San Francisco, California 94111 DARALYN J. DURIE, Esq. 9 10 11 12 FOR THE DEFENDANT INTERVENORS: 13 By: 14 BROWN GOLDSTEIN & LEVY 15 120 Baltimore Street 16 Baltimore, Maryland 21202 LAURA ABELSON, Esq. (Via Telephone) 17 18 19 ---oOo--20 21 22 23 24 25 TSG Reporting - Worldwide 877-702-9580 Highly Confidential Pursuant to the Protective Order Page 56 2 3 Q What is Google's estimated cost of scanning a book through this -- through the library project? 4 MS. DURIE: 5 Today? 6 MR. GOLDMAN: 7 THE WITNESS: Objection; vague. Today. The estimate REDACTED of the cost just 8 of the scanning of the book, not of the development of 9 the technology, would be $10, estimate. TSG Reporting - Worldwide 877-702-9580 Highly Confidential Pursuant to the Protective Order Page 63 1 Q And what about Cornell? Q Could you describe the steps that are taken 2 3 4 5 to digitize a book. A The -- the book is placed on the scan 6 station. 7 book open but not flat. The operator starts at the 8 beginning of the book. He has a pedal, and he clicks 9 the pedal. The scan station has a cradle that holds the A picture is taken of both pages. The 10 operator turns a page and clicks the pedal again. 11 Another picture is taken. 12 the -- all the pages in the book have been scanned. And it continues REDACTED 13 Q And then what happens? 14 A Then the images are processed. until There's a 15 process called dewarping, which is -- since the pages 16 are curved, it flattens out the image. 17 Then it -- a process of cleaning, which is 18 making the text or images -- and eliminating any other 19 spurious marks or other things that might be in there. 20 Then you do optical character recognition, 21 which processes the image and turns the words into 22 text. 23 24 And then there is a process which we call analysis, which is assessing the quality of the scan TSG Reporting - Worldwide 877-702-9580 Highly Confidential Pursuant to the Protective Order Page 64 1 REDACTED TSG Reporting - Worldwide 877-702-9580

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