1 United States District Court for The
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ________________________________________ ) VIACOM INTERNATIONAL INC., ) COMEDY PARTNERS, ) COUNTRY MUSIC TELEVISION, INC., ) PARAMOUNT PICTURES ) Case No. 1:07-CV-02103-LLS CORPORATION, ) (Related Case No. 1:07-CV-03582-LLS) and BLACK ENTERTAINMENT ) TELEVISION LLC, ) DECLARATION OF WARREN ) SOLOW IN SUPPORT OF Plaintiffs, ) PLAINTIFFS’ MOTION FOR v. ) PARTIAL SUMMARY JUDGMENT ) YOUTUBE, INC., YOUTUBE, LLC, and ) GOOGLE INC., ) Defendants. ) ________________________________________ ) I, WARREN SOLOW, declare as follows: 1. I am the Vice President of Information and Knowledge Management at Viacom Inc. I have worked at Viacom Inc. since May 2000, when I was joined the company as Director of Litigation Support. I make this declaration in support of Viacom’s Motion for Partial Summary Judgment on Liability and Inapplicability of the Digital Millennium Copyright Act Safe Harbor Defense. I make this declaration on personal knowledge, except where otherwise noted herein. Ownership of Works in Suit 2. The named plaintiffs (“Viacom”) create and acquire exclusive rights in copyrighted audiovisual works, including motion pictures and television programming. 1 3. Viacom distributes programs and motion pictures through various outlets, including cable and satellite services, movie theaters, home entertainment products (such as DVDs and Blu-Ray discs) and digital platforms. 4. Viacom owns many of the world’s best known entertainment brands, including Paramount Pictures, MTV, BET, VH1, CMT, Nickelodeon, Comedy Central, and SpikeTV. 5. Viacom’s thousands of copyrighted works include the following famous movies: Braveheart, Gladiator, The Godfather, Forrest Gump, Raiders of the Lost Ark, Breakfast at Tiffany’s, Top Gun, Grease, Iron Man, and Star Trek.
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