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Andrew Bunner Declaration
In Support of Motion for Summary Judgment (Nov. 28, 2001)
RICHARD R. WIEBE (SBN 121156)
425 California Street, Suite 2025
San Francisco, CA 94104
Telephone: (415) 433-3200
Facsimile: (415) 433-6382
THOMAS E. MOORE III (SBN 115107)
TOMLINSON ZISKO MOROSOLI & MASER LLP
200 Page Mill Road, Second Floor
Palo Alto, CA 94306
Telephone: (650) 325-8666
Facsimile:(650) 324-1808
ALLONN E. LEVY (SBN 187251)
HS LAW GROUP
210 N. Fourth St., Second Floor
San Jose, CA 95112
Telephone: (408) 295-7034
Facsimile: (408) 295-5799
ROBIN
D. GROSS (SBN 200701)
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco CA 94110
Telephone: (415)436-9333
Facsimile: (415)436-9993
Attorneys for Defendant
ANDREW BUNNER
SUPERIOR
COURT OF THE STATE OF CALIFORNIA
COUNTY OF
SANTA CLARA
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DVD
COPY CONTROL ASSOCIATION, INC.,
Plaintiff,
v.
ANDREW THOMAS
MCLAUGHLIN; ANDREW BUNNER; et al.,
Defendants.
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Case
No. CV - 786804
DECLARATION OF
DEFENDANT ANDREW BUNNER
IN SUPPPORT OF HIS
MOTION FOR SUMMARY JUDGMENT
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I, ANDREW BUNNER, declare:
I am one of the
defendants in this action.
I had no involvement
in or first-hand knowledge of the creation or programming of DeCSS
or any other DVD descrambling program.
I had no involvement
in or first-hand knowledge of whatever reverse engineering or
technical analysis of CSS may have occurred in connection with the
creation of DeCSS or any other DVD descrambling program.
I had no involvement
in the original publication of DeCSS or any other DVD descrambling
program on the Internet.
I first learned of
DeCSS after CSS had been reverse engineered and after DeCSS had been
created and published in October 1999 on the Internet.
After the creation
and publication on the Internet of DeCSS, I then downloaded a copy
of DeCSS from an unrestricted, publicly available web site on the
Internet and placed it on my personal web site.
In December 1999,
before being served with the summons and complaint in this action, I
spoke by telephone by an attorney for plaintiff DVD Copy Control
Association, Inc. (“DVD CCA”). I immediately removed
DeCSS from my web site server during my telephone conversation with
DVD CCA’s attorney. I have not disclosed or distributed DeCSS
or any other DVD descrambling program since that time and I have
obeyed the Court’s preliminary injunction.
I,
ANDREW BUNNER, declare under penalty of perjury under the laws of the
State of California that the foregoing is true and correct.
Dated: ________________
Andrew Bunner
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