To whom it may concern:


This counter-notification is filed in response to the takedown notice filed by the National Center for Policy Analysis (NCPA) against the YouTube video entitled “Priceless”.  On its face, the owner of the video entitled “Priceless” is C-SPAN, not NCPA.  Further, NCPA forfeited any rights they may have had, if any, to John Goodman and/or the Goodman Institute.


NCPA and the undersigned have been involved in on-going legal disputes and we believe that NCPA has filed their takedown notice in bad faith.  The filing is in bad faith because NCPA knows, or should have known, that they have no legal right to the “Priceless” video, absent a legal writing from C-SPAN transferring the copyright of the video to NCPA.


We ask that you demand from NCPA written proof that they have a legal right to the “Priceless” video and include a deadline to respond.  Absent a signed writing from C-SPAN transferring the copyright to NCPA, we request that the video be made available on YouTube no later than June 7, 2015.