TJORIGINAL ee .
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UNITED STATES DISTRICT COURT.
SOUTHERN DISTRICT OF NEW YORK

VIACOM INT'L INC., ET AL.,

Plaintiffs, ECF Case

v.
Civil No. 07-CV-2103 (LLS)
YOUTUBE, INC., ET AL.,

Defendants,

THE FOOTBALL ASS'N PREMIER
LEAGUE LTD., ET AL., on behalf of
themselves and all others similarly
situated,

ECF Case

Civil No, 07-CV-3582 (LLS)
Plaintiffs,

Vv.

YOUTUBE, INC., ET AL.,

Defendants.

STIPULATION AND ORDER

WHEREAS on March 5, 2010, this Court issued a Memorandum
Endorsement in the action Viacom International, Inc., et al. v. YouTube, Inc., et al.,
Civil No. 07-CV-2103 (LLS) directing the parties to comply with the protocol set
forth therein with respect to the filing of materials relating to the parties’ summary
judgment motions under seal;

WHEREAS the parties in the related action The Football Association Premier
League Limited, et al. v. YouTube, Inc, et al., Civil No. 07-CV-3582 have agreed to
proceed in accordance with the Memorandum Endorsement and any related
agreements reached by the parties in the Viacom action;

WHEREAS, pursuant to the Memorandum Endorsement, the parties and
relevant third parties have objected to those portions of the filings they contend
should remain under seal;

WHEREAS, pursuant to the Memorandum Endorsement, those portions not
identified by parties as those which should remain under seal shall promptly be
unsealed;


NOW THEREFORE IT IS HEREBY STIPULATED AND AGREED, by and
between the undersigned counsel of record, for the parties hereto, that the
unsealing of the materials relating to the parties’ summary judgment motions in
the above referenced actions shall be implemented as follows:

1 To the extent practicable and with the express exception of exhibits in
a format that cannot be filed via ECF and overly voluminous exhibits (e.g., large
Excel] spreadsheets), the parties intend to file all materials related to the parties’
summary judgment motions via simultaneous ECF submissions on Thursday,
March 18, 2010 at lpm EDT with those portions of the materials the parties
contend should remain under seal redacted;

2. To the extent any ECF “filing event” that occurs pursuant to
Paragraph 1 would exceed 15MB, the parties will, unless they are unable to, break
it into subparts with subsequent parts clearly identified. Those materials shall
remain on the ECF system to allow continued public access.

3. So as to further facilitate public access to the parties’ summary
judgment submissions, the parties shall also file a complete set of all materials
related to the parties’ summary judgment motions, with those portions of the
materials the parties contend should remain under seal redacted, manually with
the Clerk of the Court in hard copy to the extent possible and CD/DVD as
necessary, promptly after this Stipulation and Order is so-ordered by the Court, but
in no event earlier than the filing in Paragraph 1;

. 4, The original materials filed under seal in connection with the parties’
summary judgment motions shall remain under seal unless the Clerk of the Court
is otherwise directed by the Court;

AGREED and STIPULATED Attorney for Viacom International Inc.,
Comedy Partners, Country Music
Television, Inc., Paramount Pictures
Corporation, and Black Entertainment
Television, LLC

March [F, 2010 <a t-
“<O



AGREED and STIPULATED

March }7, 2010

AGREED and STIPULATED

March 17, 2010

SO ORDERED:

Attorneys for Lead Plaintiffs The
Football Association Premier League
Limited and Bourne Co., Named
Plaintiffs Murbo Music Publishing,
Jnc., Cherry Lane Music Publishing
Company, Inc., Robert Tur d/b/a Los
Angeles News Service, X-Ray Dog
Music, Jnc., and Fédération Francaise
de Tennis

Attorney for YouTube; Inc., YouTube,
LLC and Google Inc.

we idl Ql

Lara's Ls Stomcbone

Hon. Louis L. Stanton
United States District Judge /”\

118/16