For the purposes of
com's Statement of
Undisputed Facts in Support ofIts Motion for
Partial Summary Judgment on Liabilìty and Inapplicabilìty of
the Digital Millennium CopyrightAct Safe Harbor Defense, the following abbreviations shall be used:
"Hohengarten DecL." shall refer to the declaration ofWì1iam M. Hohengarten, datedMarch 5, 2010, filed herewith.
"Hohengarten i1_ & Ex. _," shall refer to the paragraphs of
the HohengartenDeclaration and the Exhibits attached thereto, respectively. Any Exhibit attached to theHohengarten Declaration that was produced during the course of this litigation and marked withBates numbers is identified by its beginning Bates number, followed by a pinpoint citation.
Pinpoint citations shall refer to the page number(s), and paragraph or line numbers, of
document. In some instances Hohengarten Declaration Exhibits have been manually paginated
for ease ofthe Court's reference. Where used, parentheticals indicate the nature of
the item cited
- e.g., deposition transcripts ("Dep.") or other declarations ("DecL."). Thus, by way of
illustration, "Hohengarten i17 & Ex. 4, G00001-00011355, at G00001-00011356" would refer
to Exhibit 4 to the Hohengarten Declaration, which has the beginning Bates number GOOOO 1-
00011355, and would refer specifically to the page of
that Exhibit marked with Bates number
G00001-00011356. And, "Hohengarten i1366 & Ex. 332 (Eun Dep.) at 200:1-10" would refer
to the deposition of Google employee David Eun, which is referenced at Paragraph 366 of andattached as Exhibit 332 to the Hohengarten Declaration.
"Solow Decl." shall refer to the declaration ofWarren Solow, a representative of
dated March 3, 2010, filed herewith. The Solow Declaration is attached as Exhibit 2 to the