KING,
HOLMES, PATERNO & BERLINER,
November 17, 2014
VIA E-MAIL (kentwalken@google.com) VIA E-MAIL (co}
AND FACSIMILE (650-887-2421,
Kent Walker, Esq. ‘YouTube (Google, Inc.)
General Counsel 900 Cherry Ave.
You Tube (Google, Inc.) Fifth Floor
1600 Amphitheatre Parkway San Bruno, CA 94066
Mountain View, CA 94043
LLP
10) 232-499)
ing@kpbiaw com
jutube.com)
Re: Unauthorized Public Performance of Compositions Controlled
by Global Music Rights
Dear Mr. Walker:
AND FACSIMILE (650-253-0001)
‘YouTube has failed to comply with our two letters of November 14, 2014 demanding the
immediate cessation from public performance of almost 20,000 songs (the “Songs”) through
YouTube services based upon YouTube's failure to obtain public performance licenses from
Global Music Rights (“GMR”), the exclusive licensor of those rights. In defiance of our
demands, it appears that YouTube continues to broadcast videos containing the songs controlled
by GMR, with each broadcast constituting a willful copyright infringement.
Obviously, if YouTube contends it has properly licensed any of the songs for public
broadcast, a contention we believe to be untrue, demand is hereby made that we be furnished
with documentation of such licenses.
‘Nothing contained in this letter is intended or shall be construed as an admission of any
fact, nor a waiver of any rights, claims or remedies which our client has asserted or may assert in
170. 003827408.1KING, HOLMES, PATERNO & BERLINER, LLP
Kent Walker, Esq.
General Counsel
‘You Tube, Inc. (Google, Inc.)
‘November 17, 2014
Page 2
the future, in connection with this matter or any other matter. All such rights, claims and
remedies are hereby expressly reserved.
of King, Holmes, Paterno & Berliner, LLP
HEK:dw
cc: Global Music Rights
Peter T. Paterno, Esq.
rrp o0se27408.1