UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`14 Civ. 2396 (PGG)
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`NETWORK-1 TECHNOLOGIES, INC.,
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` Plaintiff,
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` - against -
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`GOOGLE, INC., and YOUTUBE, LLC,
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` Defendants.
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`PLAINTIFF NETWORK-1 TECHNOLOGIES, INC.'S RESPONSES TO
`DEFENDANTS GOOGLE, INC. AND YOUTUBE, LLC’S
`FIRST SET OF INTERROGATORIES (NOS. 1-4)
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`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Network-1
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`Technologies, Inc. (“Network-1”), by and through its undersigned counsel, hereby responds to
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`Defendants Google, Inc. and YouTube, LLC’s (collectively “Defendants” or “Google”), First Set
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`of Interrogatories (Nos. 1-4) to Plaintiff Network-1, as follows:
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`PRELIMINARY STATEMENT
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`These responses are made solely for the purposes of this action. These responses are
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`subject to, and without waiver of, any objections as to the competency, propriety, authenticity,
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`relevancy, materiality, privilege, and admissibility, and to any and all other objections on any
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`grounds that would require the exclusion of statements contained herein.
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`The following responses are based upon the facts and information currently known and
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`available to Network-1 and given without prejudice to Network-1’s right to amend and/or
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`supplement to add any facts or information that it may later recall or discover as discovery and
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`Network-1’s investigation continues. Network-1 further reserves the right to amend and/or
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`supplement any or all of the matters contained in these responses with facts or information that it
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`Google Ex. 1019
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`learns were omitted by inadvertence, mistake, or excusable neglect; as additional facts are
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`ascertained and contentions are made in this litigation; and as terms used in the asserted claims
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`of the patents-in-suit are construed.
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`Specific objections to each Interrogatory are made on an individual basis in Network-1’s
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`responses below. In addition to the specific objections, Network-1 makes certain general
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`objections (the “General Objections”) to the Interrogatories. These General Objections are
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`hereby incorporated by reference into the specific response made to each separate Interrogatory.
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`For particular emphasis, Network-1 has, from time to time, expressly included one or more of the
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`General Objections as specific objections in the responses below. Network-1’s response to each
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`individual Interrogatory is submitted without prejudice to, and without in any respect waiving,
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`any General Objections not expressly set forth in that response. Accordingly, the inclusion in
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`any response below of any specific objection to a specific Interrogatory is neither intended as,
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`nor shall in any way be deemed, waiver of any General Objection or of any other specific
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`objection made.
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`The assertion of any objection to any of the Interrogatories is neither intended as, nor
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`shall in any way be deemed, a waiver of Network-1’s right to assert that or any other objection at
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`a later date. No incidental or implied admissions are intended by the responses below. These
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`responses are neither intended as, nor shall in any way be deemed, an admission or
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`representation that further information relevant to the subject matter of the Interrogatories does
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`not exist. Furthermore, these responses are given without prejudice to Network-1’s right to use
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`or rely on additional information at any time, including at trial.
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`GENERAL OBJECTIONS
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`1. Network-1 objects to the Interrogatories, DEFINITIONS, and INSTRUCTIONS
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`to the extent that they purport to impose on Network-1 obligations that differ from or exceed
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`2
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`Google Ex. 1019
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`those required by Federal Rule of Civil Procedure 26(b) or any other of the Federal Rules of
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`Civil Procedure, the Local Civil Rules of the United States District Court for the Southern
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`District of New York (“Local Civil Rules”), or any order or ruling by the Court in this action.
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`2. Network-1 objects to the Interrogatories to the extent that they seek information
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`protected by any privilege of Network-1 or its attorneys, including, but not limited to, the
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`attorney-client privilege and the work product doctrine. To the extent Network-1 responds to
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`these Interrogatories, its responses will not include information protected by the attorney-client
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`privilege, the work product doctrine, and/or other applicable privileges or protections. All
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`objections on the grounds of the attorney-client privilege and the work product doctrine are
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`expressly preserved. Moreover, the inadvertent disclosure of information protected by such
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`privileges and protections shall not constitute a waiver of the applicable privilege or protection
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`either as to the information inadvertently disclosed or as to any other information.
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`3. Network-1 reserves the right to object that some information is so confidential
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`and sensitive that it should not be provided absent additional protections adequate to ensure its
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`confidentiality.
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`4. Network-1 objects to the Interrogatories to the extent they are vague and
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`ambiguous.
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`5. Network-1 objects to the Interrogatories to the extent that they contain express or
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`implied assumptions of fact or law with respect to matters at issue in this case. Network-1’s
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`responses to the Interrogatories are not intended to be, and shall not be construed as, an
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`agreement or concurrence by Network-1 with Defendants’ characterization of any facts,
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`circumstances, and/or legal obligations, and Network-1 expressly reserves the right to contest
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`any such characterizations.
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`3
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`Google Ex. 1019
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`6. Network-1 objects to the Interrogatories to the extent that they are compound,
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`having multiple separate subparts. Each subpart will be counted as an individual interrogatory in
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`determining the number of Interrogatories served upon Network-1.
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`7. Network-1 objects to the Interrogatories, DEFINITIONS, and INSTRUCTIONS
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`to the extent that they purport to require Network-1 to search for and provide information that is
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`not within its possession, custody, or control.
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`8. Network-1 objects to the Interrogatories to the extent that they are harassing,
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`overbroad, unduly burdensome, oppressive, unintelligible, argumentative, duplicative, and/or
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`require Network-1 to speculate as to the meaning intended.
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`9. Network-1 objects to the Interrogatories to the extent that they seek information
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`that is neither relevant to the subject matter of this action, nor reasonably calculated to lead to the
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`discovery of admissible evidence. Network-1’s responses to the Interrogatories are not intended
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`to be, and shall not be construed as, an admission by Network-1 that any matter referenced in the
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`Interrogatories is relevant to any issue in this action.
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`10. Network-1 objects to the definition of “NETWORK-1,” “PLAINTIFF,” “you,”1
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`and “your” to the extent it purports to impose duties beyond those imposed by the Federal Rules
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`of Civil Procedure, the Local Civil Rules, or any order or ruling by the Court in this action.
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`Further, Network-1 objects to the definition of “NETWORK-1,” “PLAINTIFF,” “you,” and
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`“your” as broader than permissible under Local Civil Rule 26.3(c)(5). Network-1 also objects to
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`this definition as unduly burdensome, harassing, oppressive and overbroad to the extent it
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`purports to include entities other than Network-1 or to seek discovery from individuals or entities
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`over whom or which Network-1 has no control. Network-1 also objects to the definition of
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`1 Defendants’ “DEFINITIONS” capitalize certain defined terms and do not capitalize others. For
`purposes of Network-1’s responses, Network-1 will treat both the capitalized and lowercase
`versions of the terms “you” and “your” as defined terms.
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`4
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`Google Ex. 1019
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`“NETWORK-1,” “PLAINTIFF,” “you,” and “your” as vague and overbroad with respect to its
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`inclusion of “affiliates, parents, divisions, joint ventures, licensees, franchisees, assigns,
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`predecessors and successors in interest, and any other legal entities, whether foreign or domestic,
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`that are owned or controlled by PLAINTIFF, and all predecessors and successors in interest to
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`such entities or to the PATENTS-IN-SUIT, and any entity owned in whole or in part by,
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`affiliated with, or controlled in whole or in part.” Network-1 also objects to the definition of
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`“NETWORK-1,” “PLAINTIFF,” “you,” and “your” as including “without limitation, Network-1
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`Security Solutions, Inc.; Mirror Worlds Technologies, LLC; and Mirror Worlds LLC” as
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`overbroad by placing discovery obligations on entities that are either unrelated to this litigation
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`and/or third parties. Network-1 will treat the terms “NETWORK-1,” “PLAINTIFF,” “you,” and
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`“your” according to the definition set forth in Local Civil Rule 26.3(c)(5).
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`11. Network-1 objects to the definition of “NEC” to the extent it purports to impose
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`duties beyond those imposed by the Federal Rules of Civil Procedure, the Local Civil Rules, or
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`any order or ruling by the Court in this action. Network-1 also objects to the definition of
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`“NEC” as unduly burdensome and overbroad to the extent it purports to include entities other
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`than Network-1 or to seek discovery from individuals or entities over whom or which Network-1
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`has no control. Specifically the definition of “NEC” impermissibly includes “officers, directors,
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`current and former employees, counsel, agents, consultants, representatives, and any other
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`PERSONS acting on behalf of any of the foregoing, and NEC Corporation and NEC Research
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`Institute's affiliates, parents, divisions,
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`joint ventures,
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`licensees, franchisees, assigns,
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`predecessors and successors in interest, and any other legal entities, whether foreign or domestic,
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`that are owned or controlled by NEC, and any entity owned in whole or in part by, affiliated
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`with, or controlled in whole or in part by NEC Corporation and NEC Research Institute.”
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`5
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`Google Ex. 1019
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`12. Network-1 objects to the definition of “TECHNOLOGY-IN-SUIT” to the extent
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`it mischaracterizes the technology accused by Network-1. Network-1 will treat the term
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`“TECHNOLOGY-IN-SUIT” as referring to “products and services that extract features of media
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`works and compare them against extracted features of reference media works.”
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`13. Network-1 objects to the definition of “DOCUMENT” to the extent it purports to
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`impose duties beyond those imposed by the Federal Rules of Civil Procedure, the Local Civil
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`Rules, or any order or ruling by the Court in this action. Network-1 will treat the term
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`“DOCUMENT” according to the definition set forth in Local Civil Rule 26.3(c)(2).
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`14. Network-1 objects to the definition of “COMMUNICATION” to the extent it
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`purports to impose duties beyond those imposed by the Federal Rules of Civil Procedure, the
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`Local Civil Rules, or any order or ruling by the Court in this action. Network-1 will treat the
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`term “COMMUNICATION” according to the definition set forth in Local Civil Rule 26.3(c)(1).
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`15. Network-1 objects to the definition of “PERSON” to the extent it purports to
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`impose duties beyond those imposed by the Federal Rules of Civil Procedure, the Local Civil
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`Rules, or any order or ruling by the Court in this action. Network-1 will treat the term
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`“PERSON” according to the definition set forth in Local Civil Rule 26.3(c)(6).
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`16. Network-1 objects to the definition of “or” and “and” to the extent it purports to
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`impose duties beyond those imposed by the Federal Rules of Civil Procedure, the Local Civil
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`Rules, or any order or ruling by the Court in this action. Network-1 will treat the terms “or” and
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`“and” according to the rules of construction set forth in Local Civil Rule 26.3(d)(2).
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`17. Network-1 objects to the definition of “INFRINGE” and “INFRINGEMENT” to
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`the extent the definition includes infringement claims that are outside the scope of this case and
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`thus not relevant to the litigation.
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`6
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`Google Ex. 1019
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`18. Network-1 objects to the definition of “PRIOR ART” to the extent the definition
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`includes “publications, patents, physical devices, prototypes, uses, sales, and offers for sale, and
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`any DOCUMENTS or other items” that are not within the scope of 35 U.S.C. §§ 102 and 103.
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`19. Network-1 objects to the definition of “RELATED PATENT LITIGATIONS” to
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`the extent the definition includes cases that are unrelated to the litigation here. Defendants list
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`19 cases as being “RELATED PATENT LITIGATIONS.” However, none of these 19 cases
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`involves the patents-in-suit. Thus, Defendants’ request to refer to these cases as “RELATED
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`PATENT LITIGATIONS” is improper as it would place discovery obligations on Network-1
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`that go beyond the scope of the Federal Rules of Civil Procedure and the Local Civil Rules.
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`20. Network-1 objects to the definition of "Reflect," "reflecting," "relate to," "refer
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`to," "relating to," and "referring to" to the extent it renders the Interrogatories overbroad and
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`unduly burdensome and places obligations on Network-1 beyond the scope of the Federal Rules
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`of Civil Procedure and the Local Civil Rules, including Local Civil Rule 26.3(c)(7).
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`21. Network-1 objects to Defendants’ definitions pertaining to the term “IDENTIFY”
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`as requiring Network-1 to provide information beyond the scope of the Federal Rules of Civil
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`Procedure and the Local Civil Rules, including Local Civil Rule 26.3(c)(3) and 26.3(c)(4).
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`22. Pursuant to Federal Rule of Civil Procedure 26(b)(2)(B), Network-1 objects to
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`any Interrogatory seeking electronically stored information that is not reasonably accessible
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`because of the undue burden and cost associated with retrieving and producing such information.
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`Electronically stored information that is not reasonably accessible will not be preserved and such
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`sources will not be searched in responding to these Interrogatories.
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`23. To the extent that Network-1 responds to any Interrogatory, its responses reflect
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`only the current state of knowledge, understanding, and belief of Network-1 with regard to
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`matters about which inquiry has been made. Network-1 reserves the right to modify or
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`7
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`Google Ex. 1019
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`supplement its responses at a later time with whatever pertinent information it may subsequently
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`discover. Furthermore, these responses are provided without prejudice to using or relying on at
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`trial any subsequently discovered information or facts, or information omitted from these
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`responses because of mistake, oversight, or inadvertence. Network-1 further reserves the right to
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`object on appropriate grounds to the introduction into evidence of any portion of these responses.
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`RESPONSES TO INTERROGATORIES
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`INTERROGATORY NO. 1
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`Explain in detail how PLAINTIFF contends that each ACCUSED INSTRUMENTALITY
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`practices each element of each ASSERTED CLAIM.
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`RESPONSE TO INTERROGATORY NO. 1
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`Network-1 objects that this Interrogatory is vague. Network-1 also objects to this
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`Interrogatory as unduly burdensome and overbroad to the extent that it purports to impose
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`discovery obligations on or with respect to entities or persons that are not parties to this action
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`and over whom Network-1 does not exercise control through the use of the defined term
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`“PLAINTIFF.” Network-1 will treat this term as having the meaning set forth in Local Civil
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`Rule 26.3(c)(5). Network-1 further objects to this Interrogatory in its use of the term
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`“ASSERTED CLAIM.” Network-1 will respond to this interrogatory with respect to claims
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`identified in the Infringement Contentions served pursuant to the Local Rules of this Court,
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`without prejudice to Network-1 subsequently adding to, or withdrawing any claims from its
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`Infringement Contentions. Network-1 also objects to this Interrogatory on the ground that
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`Google has produced no substantive documents relating to the accused instrumentalities to date.
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`Network-1 further states that discovery in this case is not yet complete and its investigation and
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`analysis of the facts is still ongoing. Network-1 anticipates that, as the action proceeds, further
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`facts relating to this Interrogatory may be discovered and, without in any way obligating itself to
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`do so, Network-1 expressly reserves the right to supplement the information in this response with
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`8
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`Google Ex. 1019
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`such pertinent information that it may subsequently discover. Network-1 further reserves the
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`right to amend and/or supplement any or all of the matters contained in these responses with
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`facts or information that it learns were omitted by inadvertence, mistake, or excusable neglect; as
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`additional facts are ascertained and contentions are made in this litigation; and as terms used in
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`the asserted claims of the patents-in-suit are construed. Network-1 further incorporates its
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`General Objections set forth above into its specific response to this Interrogatory.
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`Subject to and without waiving any of the foregoing general and specific objections,
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`Network-1 responds to this Interrogatory as follows:
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`The accused instrumentalities for purposes of this response consist of Google’s Content
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`ID system as implemented and operated with www.youtube.com, m.youtube.com and related
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`mobile applications, and the Google Play online store. The accused instrumentalities are
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`collectively referred to herein as the “Content ID System.”
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`U.S. Patent No. 8,010,988 (“’988 Patent”)
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`Claim 15: Google’s Content ID System practices the method of associating an electronic
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`work with an action, the electronic work comprising at least one of audio and video, as follows:
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`The Content ID System electronically extracts features from each audio and/or visual
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`work uploaded by a YouTube user to generate its digital “fingerprint.”
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`The Content ID System then attempts to electronically determine the identity of the user-
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`uploaded audio and/or visual work by comparing this fingerprint of the work with similarly-
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`generated digital “fingerprints” of reference works containing copyrighted content submitted to
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`Google by rights holders using, on information and belief, a non-exhaustive search to identify a
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`neighbor.
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`When the Content ID System identifies a match between a user-uploaded audio and/or
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`visual work and a reference work submitted by a rights holder, it electronically determines the
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`9
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`Google Ex. 1019
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`action or actions that it needs to take with respect to the user-uploaded audio and/or visual work,
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`including, but not limited to, actions based on the policy the rights holder has chosen to apply to
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`user-uploads matching its reference work, whether blocking, tracking, or monetizing, and/or
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`displaying “click-to-buy” links for the purchase of a song, movie, or other product related to the
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`reference work.
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`Once the Content ID System identifies a user-uploaded audio and/or visual work and
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`determines the action or actions that it needs to take with respect to that work, it performs the
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`action or actions electronically. For instance, upon identifying a user-uploaded audio and/or
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`visual work as a match for a reference work submitted by a rights holder, the Content ID System
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`automatically performs the action corresponding to the policy specified by the rights holder for
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`matches to that reference work, whether it is to block, track, or monetize. When the rights
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`holder’s content is blocked, the Content ID System prevents the user-uploaded audio and/or
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`visual work from either going live or continuing to be viewed, or it mutes the audio. It may also
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`penalize the user who attempted to upload the copyrighted content by restricting the user’s
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`access to various YouTube features. If the rights holder chose the “track” policy, the user-
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`uploaded audio and/or visual work remains unaffected but the Content ID System gives the
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`rights holder access to the viewership statistics. If the policy is “monetize,” the user-uploaded
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`audio and/or visual work remains available on YouTube and the Content ID System displays
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`with it advertisements and/or promotional information relating to the creator of the reference
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`work, and tracks its viewership statistics. Similarly, on information and belief, if the rights
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`holder has enabled YouTube’s “click-to-buy” feature for user-uploaded matches to the reference
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`work, the user-uploaded audio and/or visual work remains available on YouTube and the
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`Content ID System will display links for the purchase of a song, movie, or other product related
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`to the reference work together with it.
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`10
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`Google Ex. 1019
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`Claim 17: Google’s Content ID System practices the method of claim 15 using an
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`algorithm to perform a non-exhaustive search that is sublinear.
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`Claim 31: Google’s Content ID System practices the method of claim 15, wherein the
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`action comprises providing and/or displaying additional information in association with the user-
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`uploaded audio and/or visual work as follows:
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`When the Content ID System identifies a match between a user-uploaded audio and/or
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`visual work and a reference work for which the rights holder has set a policy of “monetize” for
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`matching user-uploaded works, the user-uploaded audio and/or visual work remains available on
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`YouTube and the Content ID System displays additional information such as advertisements and
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`promotional information relating to the creator of the reference work in association with it. The
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`Content ID System also tracks its viewership statistics. Similarly, on information and belief,
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`when the Content ID System identifies a match between a user-uploaded audio and/or visual
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`work and a reference work for which the rights holder has enabled the “click-to-buy” feature for
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`matching user-uploaded works, the user-uploaded audio and/or visual work remains available on
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`YouTube and additional information in the form of links for the purchase of a song, movie, or
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`other product related to the reference work will be displayed in association with it.
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`Claim 32: Google’s Content ID System practices the method of claim 31, wherein the
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`additional information provided or displayed in association with the user-uploaded audio and/or
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`visual work is an advertisement as follows:
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`When the Content ID System identifies a match between a user-uploaded audio and/or
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`visual work and a reference work for which the rights holder has set a policy of “monetize” for
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`matching user-uploaded works, the user-uploaded audio and/or visual work remains available on
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`YouTube and the Content ID System may display additional information in the form of
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`advertisements on, around, and/or before it.
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`11
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`Google Ex. 1019
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`Claim 51: Google’s Content ID System practices the method of claim 31, wherein the
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`electronic work is an audio work and the additional information comprises at least one of a song
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`title, an album title, and a performer name as follows:
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`On information and belief, when the Content ID System identifies a match between a
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`user-uploaded audio work and a reference work for which the rights holder has enabled the
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`aforementioned “click-to-buy” feature for matching user-uploaded works, the user-uploaded
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`audio work remains available on YouTube and additional information comprising at least one of
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`a song title, an album title, and a performer name is displayed in association with it, typically just
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`below it.
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`Claim 52: Google’s Content ID System practices the method of claim 31, wherein the
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`electronic work is a video work and the additional information comprises at least one of a title of
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`the video work, a director of the video work, and names of performers in the video work as
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`follows:
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`On information and belief, when the Content ID System identifies a match between a
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`user-uploaded video work and a reference work for which the rights holder has enabled the
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`aforementioned “click-to-buy” feature for matching user-uploaded works, the user-uploaded
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`video work remains available on YouTube and additional information comprising at least one of
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`a title of the video work, a director of the video work, and names of performers in the video work
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`may be displayed in association with it, typically just below it.
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`U.S. Patent No. 8,205,237 (“’237 Patent”)
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`Claim 25: Google’s Content ID System is a computer system that includes at least one
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`computer. When YouTube users upload media works to the Google owned and operated Internet
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`site, www.youtube.com, through client devices such as computers and mobile devices, the
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`12
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`Google Ex. 1019
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`Content ID System electronically extracts features from each such media work to generate its
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`digital “fingerprint.”
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`The Content ID System then attempts to determine the identity of the user-uploaded
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`media work by using its fingerprint to perform, on information and belief, a non-exhaustive
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`search of similarly-generated digital “fingerprints” of reference media works containing
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`copyrighted content submitted to Google by rights holders to identify a near neighbor.
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`When the Content ID System identifies a match between a user-uploaded media work
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`and a reference media work submitted by a rights holder, it determines the action or actions that
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`it needs to take with respect to the user-uploaded media work, including, but not limited to,
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`actions based on the policy the rights holder has chosen to apply to user-uploads matching its
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`reference media work, whether blocking, tracking, or monetizing, and/or displaying “click-to-
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`buy” links for the purchase of a song, movie, or other product related to the reference media
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`work.
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`Claim 26: Google’s Content ID System practices the method of claim 25, wherein the
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`action comprises providing to and/or displaying, at another client device, additional information
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`in association with the media work as follows:
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`When the Content ID System identifies a match between a media work uploaded by a
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`user and a reference media work for which the rights holder has set a policy of “monetize” for
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`matching user-uploaded works, the user-uploaded media work remains available on YouTube,
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`and additional information such as advertisements and promotional information relating to the
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`creator of the reference work will be displayed in association with it when it is accessed by
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`another YouTube user through his or her computer or mobile device (i.e., another client device).
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`Similarly, on information and belief, when the Content ID System identifies a match between a
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`user-uploaded media work and a reference media work for which the rights holder has enabled
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`13
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`Google Ex. 1019
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`the “click-to-buy” feature for matching user-uploaded works, the user-uploaded media work
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`remains available on YouTube and links for the purchase of a song, movie, or other product
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`related to the reference media work will be displayed in association with it when it is accessed by
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`another YouTube user through his or her computer or mobile device (i.e., another client device).
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`Claim 27: Google’s Content ID System practices the method of claim 26, wherein the
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`action comprises providing to and/or displaying, at another client device, additional information
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`in the form of an advertisement in association with the media work as follows:
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`When the Content ID System identifies a match between a user-uploaded media work
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`and a reference media work for which the rights holder has set a policy of “monetize” for
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`matching user-uploaded works, the user-uploaded media work remains available on YouTube
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`and the Content ID System may display additional information in the form of advertisements on,
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`around, and/or before it when it is accessed by another YouTube user through his or her
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`computer or mobile device (i.e., another client device).
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`U.S. Patent No. 8,640,179 (“’179 Patent”)
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`Claim 13: Google’s Content ID System is a computer system that practices a computer-
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`implemented method of maintaining one or more databases comprising: (1) a digital
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`“fingerprint” for each reference electronic work containing copyrighted content that is submitted
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`to Google by a rights holder, which fingerprint is generated from features extracted from the
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`reference electronic work (i.e., first electronic data comprising a first digitally created compact
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`electronic representation of one or more reference electronic works); and (2) on information and
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`belief, second electronic data related to actions that the Content ID System will perform when it
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`matches a user-uploaded electronic work to one of the reference electronic works, including, but
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`not limited to, providing and/or displaying one or more display, video, and/or click-to-buy
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`advertisements corresponding to each of the one or more reference electronic works where their
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`14
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`Google Ex. 1019
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`respective rights holders have specified a policy of “monetize” and/or enabled the “click-to-buy”
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`feature.
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`When a user uploads an electronic work to YouTube (i.e., a first electronic work), the
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`Content ID System also obtains its digital “fingerprint” (i.e., a second digitally created compact
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`electronic representation) using features that are extracted from it.
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`The Content ID System then attempts to identify a matching reference electronic work
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`that matches the user-uploaded electronic work (i.e., the first electronic work) by comparing its
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`digital fingerprint (i.e., the second digitally created compact electronic representation) with the
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`stored digital fingerprints of rights holders’ reference electronic works (i.e., the first electronic
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`data) using, on information and belief, a non-exhaustive neighbor search.
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`When the Content ID System matches the user-uploaded electronic work and a reference
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`electronic work, it looks up an action or actions to perform corresponding to the matching
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`reference electronic work based on the second electronic data in the Content ID database(s),
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`which include, but are not limited to, actions based on the policy the rights holder has chosen to
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`apply to user-uploads matching its reference electronic work, whether blocking, tracking, or
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`monetizing, and/or displaying “click-to-buy” links for the purchase of a song, movie, or other
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`product related to the reference electronic work.
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`Once the Content ID System matches the user-uploaded electronic work (i.e., the first
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`electronic work) and a reference electronic work, and determines the action or actions
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`corresponding to the matching reference electronic work, it associates the action or actions with
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`the user-uploaded electronic work. For instance, if the rights holder’s content is blocked, the
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`Content ID System prevents the user-uploaded electronic work from either going live or
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`continuing to be viewed, or it mutes the audio. It may also penalize the user who attempted to
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`upload the work by restricting the user’s access to various YouTube features. If the rights holder
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`15
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`Google Ex. 1019
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`chose the “track” policy, the user-uploaded electronic work remains unaffected but the Content
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`ID System gives the rights holder access to the viewership statistics. If the policy is “monetize,”
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`the user-uploaded electronic remains available on YouTube and the Content ID System displays
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`with it advertisements and/or promotional information relating to the creator of the reference
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`electronic work, and tracks its viewership statistics. Similarly, on information and belief, if the
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`rights holder has enabled YouTube’s “click-to-buy” feature for user-uploaded matches to the
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`reference electronic work, the user-uploaded electronic work remains available on YouTube and
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`the Content ID System will display links for the purchase of a song, movie, or other product
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`related to the reference electronic work together with it.
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`Claim 24: Google’s Content ID System practices the computer-implemented method of
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`claim 13 wherein the method further comprises obtaining, by the Content ID System, the digital
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`“fingerprint” of a second user-uploaded electronic work (i.e., a second electronic work to be
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`identified) using features that are extracted from it (i.e., second extracted features).
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`The Content ID System then searches, by the Content ID System, for an identification of
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`the second user-uploaded electronic work (i.e., the secon