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` UNITED STATES DISTRICT COURT
` FOR THE CENTRAL DISTRICT OF CALIFORNIA
` CASE NO. 2:20-cv-07872-GW-PVC
`
`NANTWORKS, LLC, a Delaware
`limited liability company, and
`NANT HOLDINGS IP, LLC, a
`Delaware limited liability
`company,
` Plaintiffs,
` VS.
`
`BANK OF AMERICA CORPORATION, a
`Delaware corporation, and BANK
`OF AMERICA, N.A., a national
`banking association,
` Defendants.
` ____________________________________/
`
` 2601 Bayshore Drive
` Miami, Florida
` April 5, 2024
` 9:02 a.m. - 6:53 p.m.
`
` VIDEOTAPED DEPOSITION OF CATHY GLASSMAN
` Taken before Lilly Villaverde, RPR and Notary
` Public in and for the State of Florida at Large,
` pursuant to Notice of Taking Deposition filed in the
` above-mentioned cause.
` Job No. CS6635638
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`800-567-8658
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`973-410-4098
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`Veritext Legal Solutions
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` APPEARANCES:
`
` ERIC HUANG, ESQUIRE
` erichuang@quinnemanuel.com
` YVONNE ZHANG, ESQUIRE
` yvonnezhang@quinnemanuel.com
` Quinn Emanuel Urquhart &
` Sullivan, LLP
` 51 Madison Ave
` 22nd Floor
` New York, NY 10010
` on behalf of the Plaintiffs
`
` WILL FOX, ESQUIRE
` wfox@winston.com
` JOHN T. SULLIVAN, ESQUIRE
` jsullivan@winston.com
` Winston & Strawn, LLP
` 2121 N. Pearl Street
` Suite 900
` Dallas, TX 75201
` on behalf of the Defendants
`
` ALSO PRESENT:
`
` EDWIN ARAGON, VIDEOGRAPHER
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` I N D E X
` E X A M I N A T I O N S
` WITNESS PAGE
` CATHY GLASSMAN
` DIRECT EXAMINATION BY MR. FOX 4
` CROSS-EXAMINATION BY MR. HUANG 213
` REDIRECT EXAMINATION BY MR. FOX 239
` RECROSS-EXAMINATION BY MR. HUANG 242
`
` E X H I B I T S
` NUMBER DESCRIPTION PAGE
` Exhibit 1 Notice of Deposition 9
` Exhibit 2 Expert Report 10
` Exhibit 3 Case List 15
` Exhibit 4 Letter - 2/29/2024 120
` Exhibit 5 Bank of America Website Printout 226
` Mobile Check Deposit FAQs
` Exhibit 6 GT&O Innovation Advisory Council 230
` - 10/3/2007
` Exhibit 7 Bates-stamped BOFA0073592 238
` Exhibit 8 Mobile Remote Deposit Capture 239
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` THE VIDEOGRAPHER: We are now on the record.
`
` The time is 9:02 a.m. Today's date is April 5, 2024.
`
` This is the video deposition of Cathy Glassman
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` in the matter of NantWorks, LLC, versus Bank of
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` America.
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` The videographer is Edwin Aragon, the court
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` reporter is Lilly Villaverde, here on behalf of
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` Veritext Legal Solutions.
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` This video deposition taking place at 2601
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` South Bayshore Drive, Suite 1550, Miami, Florida
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` 33133.
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` All counsel please identify yourself, and state
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` whom you represent.
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` MR. FOX: Will Fox and John Sullivan from
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` Winston & Strawn for the Bank of America defendants.
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` MR. HUANG: Eric Huang and Yvonne Zhang from
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` Quinn Emanuel for the plaintiffs and the witness.
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` THEREUPON:
`
` CATHY GLASSMAN
`
` called as a witness on behalf of the Defendant herein,
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` having been first duly sworn, was examined and testified
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` as follows:
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` THE WITNESS: I do.
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` DIRECT EXAMINATION
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` BY MR. FOX:
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`800-567-8658
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`973-410-4098
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`Veritext Legal Solutions
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` Q. Good morning, Ms. Glassman. Have we met
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`Page 5
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` before?
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` A. No.
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` Q. No. My name is Will Fox. I represent the Bank
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` of America plaintiffs in this case -- Bank of America
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` defendants in this case. I'm sorry. Have to get out of
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` the gate.
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` Do you under -- will you please state your name
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` for the record?
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` A. Cathy, C-A-T-H-Y, Glassman.
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` Q. Thank you. You understand you are under oath
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` today, Ms. Glassman?
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` A. Yes.
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` Q. And do you intend to keep your oath?
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` A. Absolutely.
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` Q. And you understand I represent the defendants
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` in this case, Bank of America Corporation and Bank of
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` America, N.A.?
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` A. Yes.
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` Q. And is it okay if -- with you if I refer to
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` those as Bank of America during this deposition?
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` A. Sure.
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` Q. Okay. And is it okay if I refer to the
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` plaintiffs collectively as plaintiffs?
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` A. Yes.
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` A. Uh-huh.
`
` Q. So first off, I made the printout of this
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` document and I will represent to you that that's the
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` date and time that this document was printed from the
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` website.
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` However, let me ask you this: You mentioned in
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` your answer just now that you believe that a set of
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` terms and conditions would have been in place during the
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` time period that mobile check deposit is accused of
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` infringing, so 2014ish through 2021.
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` Why do you believe that?
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` A. Because banks, as a rule, don't roll out
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` technical deposit products like this without knowing
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` what all the terms and conditions are first. There's a
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` big section on liability and warranties and -- the bank
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` just is not going to put that out -- put out that
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` product without having all that -- all those ducks in a
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` row before they do it.
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` Q. Right. And then earlier we talked about your
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` understanding of the control that a bank has over the
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` use of mobile check deposit by a user.
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` A. Yes.
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` Q. Do you recall that?
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` A. Yes.
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` Q. And you had testified regarding some of the
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` passages that are actually in this terms and conditions.
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` Were there any of the passages within those
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` terms that we looked at, and one of them being on
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` page 5, the capture device definition, but really any of
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` the passages we looked at in this document that you --
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` you -- that you believe were -- would likely have been
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` in place during the time period between 2014, 2021?
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` MR. FOX: Objection, calls for speculation.
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` THE WITNESS: I think all the definitions would
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` have been there. Definition of the service.
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` The hardware and software requirements are
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` quite vague. So they would probably have been there
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` as well.
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` Image quality, processing images, limits, I'm
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` sure they had some of these that may have also been
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` covered in the deposit agreement, if they weren't in
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` the terms and conditions for mobile. Like deposits
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` of other items, return items.
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` Let's see.
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` So this one -- so handling of transmitted
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` items, that's not in the -- in the regular deposit
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` agreement. So it would have to have been just in
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` the -- just in the mobile agreement.
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` Item processing, these would -- number ten, the
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` item -- the payment processing, these would have had
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` to have been only in the -- in this mobile agreement,
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` because this is not discussed in the -- in the
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` primary deposit agreement.
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` Use of your GO location is only a mobile
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` deposit item.
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` And then the representations and warranties,
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` these are all, more than likely, the same that -- the
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` stuff that's in the deposit agreement, but they
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` probably would have reprinted.
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` Right. And then they go back and refer to the
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` deposit agreement, because if you look at 18,
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` governing law, it's the same -- according to the
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` governing law in the deposit agreement.
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` BY MR. HUANG:
`
` Q. And that's on page 11?
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` A. Yes. So, yeah.
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` Q. Okay. Let me -- let me ask you this, you --
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` why do you believe that these passages you referred to
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` would likely have been in place during that time period?
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` A. Because a bank like Bank of America, one of the
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` largest banks in the United States, would not roll out a
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` deposit service where they were taking customers' funds
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` and -- and clearing them and depositing them
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` electronically and not have all of their warranties in
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` place, all of their indemnifications. They just don't
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` roll out products without having this stuff already up
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` on the website.
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` Q. And what's your -- what's the basis for your
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` opinion that you just stated?
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` A. So I've worked with all -- most of the top ten
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` banks in the United States and every one of them always
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` has this disclosure statement or an agreement ready to
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` go before the product. They work in parallel with the
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` product people so that this is ready to go up on the
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` website, and it's already been reviewed by outside
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` counsel and inside counsel and everybody has looked at
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` it, and then it goes up on the website.
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` So I've never seen a bank roll out a product
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` and not have their legal ducks in a row.
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` Q. Okay. And one of the things that's in this
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` agreement, this terms and conditions that are in this
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` document, we looked at earlier the capture device
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` definition?
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` A. Yes.
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` Q. Okay. Now, is that something you think would
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` have been in place throughout this time period that
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` we're talking about?
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` A. Yes, because they were --
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` MR. FOX: Objection, calls for speculation.
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` THE WITNESS: What page was that on?
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` BY MR. HUANG:
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` Q. Five.
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` A. Yeah.
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` So it doesn't say you have to have this kind of
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` camera or you have to have this kind of phone. It just
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` says you're responsible for the security of it. You
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` have to make sure that you don't give it to anybody and
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` you have all the internal security you're supposed to
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` have.
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` So it's very -- in a way, I hate to use the
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` term "generic," but it's very non-specific to any one
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` kind of product or one kind of level of --
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` Q. Well, you're talking about number two, the
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` hardware and software --
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` A. Right.
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` Q. No. My question was actually about the
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` definition up above. The definition of "capture
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` device."
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` A. Oh, okay.
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` Q. You read it earlier?
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` A. Yes.
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` Q. Is that something you think would have been in
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` place during the time period we're talking about?
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` A. Yes.
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` Q. Okay. And why?
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` A. Because the bank wants to be able to set
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` controls around the quality of the image it's going to
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` get. So the capture device has to be acceptable to the
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` bank. You can't use a -- I'm sure people tried, but the
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` old, you know, 4 megapixel cameras in the original
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` iPhone would not be acceptable. The -- the clarity
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` probably wouldn't be there.
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` Q. Also, is it your understanding that in order to
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` actually use mobile check deposit you need to have a
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` camera on your phone?
`
` A. Yes.
`
` Q. Okay. And is it -- do you understand whether
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` there are any -- well, let me just ask you this: Let's
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` take a look at the representations on page, starts on
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` page 8.
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` A. Okay.
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` Q. Okay. So one of the representations here that
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` is made, I think by the user, right, and these are
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` written from the user; is that right?
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` A. Well --
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` MR. FOX: Objection, lacks foundation.
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` THE WITNESS: -- "you" is the user.
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` BY MR. HUANG:
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` Q. Okay.
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` A. Yes.
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` Q. All right. So one of the representations they
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` make is that you will use the service to transmit and
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` deposit images of items only, right?
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` A. Right.
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` Q. And that "items" are defined as an original
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` check and there's a limited set of those on page 5,
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` right?
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` A. Right.
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` Q. Okay. And then the other thing that the --
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` that the user is asked to represent is that items have
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` not been altered, that's subsection E, right?
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` A. Yes.
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` Q. Okay. Now, I think we talked earlier -- I
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` believe we may have -- you may have been asked this, but
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` let me just ask this.
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` Are users allowed to send an image for deposit
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` that is not based on an original check, a paper check?
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` A. No.
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` MR. FOX: Objection, form. Objection, calls
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` for speculation. Objection, lacks foundation.
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` Objection, calls for a legal conclusion.
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` BY MR. HUANG:
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` Q. And why not?
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` MR. FOX: Objection, calls for speculation.
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` Objection, lacks foundation.
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` THE WITNESS: So the bank wants to make sure
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` that you actually have the paper -- that you own the
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` paper check before you take the picture of it.
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` If I just have a picture of a check in my
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` camera roll, I could just send that in and pretend
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` it's a deposit and I don't really have the check. So
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` it has to -- you have to have a real check in your
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` hand and then take a picture of it and send it to the
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` bank.
`
` BY MR. HUANG:
`
` Q. Okay. And one of the things that you're
`
` restricted from doing is, for example, submitting for
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` deposit a check that was -- or an item that was --
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` actually, let me just rephrase that.
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` Okay. Actually let me just -- let's look on
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` page 7, item ten A. There's an item that says, "Payment
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` processing, item processing."
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` A. Yes.
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` Q. Okay. So it says there in the first sentence,
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` "At our sole discretion, we may process the image you
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` send us electronically through other banks or we may
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` create an IRD"; do you see that?
`
` A. Yes.
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` Q. It then goes on and says, "If you send us
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` images that are incomplete, that fail to satisfy our
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` image quality requirements or otherwise do not allow us
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` to meet the requirements of Check 21 or any image
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` exchange agreement that would cover our further
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` electronic transmission of images that you send us, or
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` we are otherwise unable to process images that you send
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` us, we may charge the images back to your account"; do
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` you see that?
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` A. Yes.
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` Q. Now, when they say charge the images back to
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` your account, what does that mean?
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` A. They're going to --
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` MR. FOX: Objection, lacks foundation.
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` Objection, calls for speculation. Objection, form.
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` BY MR. HUANG:
`
` Q. What do you understand to be meant when it says
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` we may charge the images back to your --
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` A. They are going to deduct the amount of --
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` MR. FOX: Same objections.
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` THE WITNESS: They are going to deduct the
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` amount of the check deposited from your account.
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` BY MR. HUANG:
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` Q. Okay. That's another way that the bank can
`
` control the user's access to this service, right?
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` MR. FOX: Objection, lacks foundation.
`
` Objection, calls for speculation.
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`Case 2:20-cv-07872-GW-PVC Document 560-2 Filed 06/14/24 Page 16 of 19 Page ID
`#:77417
`UNDER PROTECTIVE ORDER
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`Page 252
`
` THE WITNESS: Right. It's the way that they
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` also control the quality of the service or people who
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` abuse the service or might commit fraud using the
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` service, if they're not, you know, just sending you
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` correct images.
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` BY MR. HUANG:
`
` Q. Are -- are terms and conditions, like the ones
`
` we just looked at in Exhibit 5, important to the bank?
`
` A. Absolutely.
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` MR. FOX: Objection, lacks foundation.
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` Objection, calls for speculation.
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` BY MR. HUANG:
`
` Q. And what is your basis for that?
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` A. Well, in a lot of the cases, almost all the
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` cases I work on that involve checks or deposit
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` processing, the bank relies on the deposit agreement,
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` and so do I, to determine whether or not the customer
`
` has fulfilled their obligation and the bank has
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` fulfilled theirs, because both sides have obligations.
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` And I have never had a bank not have one or not have one
`
` that protected -- protected them.
`
` Q. Okay. And let me just ask you, so based on
`
` what you just said, does that -- I mean, do you have
`
` confidence in this document, Exhibit 5, as describing,
`
` at least, the terms and conditions that you identified
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`Veritext Legal Solutions
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`Case 2:20-cv-07872-GW-PVC Document 560-2 Filed 06/14/24 Page 17 of 19 Page ID
`#:77418
`UNDER PROTECTIVE ORDER
`
`Page 253
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` and talked about today for the time period of 2014
`
` through 2021 for mobile check deposit at Bank of
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` America?
`
` MR. FOX: Objection, form. Objection, vague.
`
` Objection, lacks foundation.
`
` THE WITNESS: Yes, because I didn't see
`
` anything that was technologically specific that would
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` have not been there in 2014. They purposely wrote a
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` very broad and open agreement that just talked about
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` the -- the capture device rather than a specific kind
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` of phone.
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` BY MR. HUANG:
`
` Q. Okay.
`
` MR. HUANG: Okay. I pass the witness.
`
` MR. FOX: No further questions today.
`
` MR. HUANG: Okay.
`
` MR. FOX: Thank you very much.
`
` THE WITNESS: Thank you.
`
` MR. HUANG: Thank you.
`
` THE VIDEOGRAPHER: This concludes the
`
` deposition. Going off the record. The time is 6:53.
`
` (The videotaped deposition was concluded at
`
` approximately 6:53 p.m. Signature and formalities
`
` were not waived.)
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`Veritext Legal Solutions
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`Case 2:20-cv-07872-GW-PVC Document 560-2 Filed 06/14/24 Page 18 of 19 Page ID
`#:77419
`UNDER PROTECTIVE ORDER
`
`Page 254
`
` C E R T I F I C A T E
`
` STATE OF FLORIDA :
`
` COUNTY OF MIAMI-DADE :
`
` I, the undersigned authority, certify that
`
` CATHY GLASSMAN personally appeared before me on
`
` April 5, 2024, and was duly sworn.
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` WITNESS my hand and official seal this 10th day
`
` of April, 2024.
`
` <%3309,Signature%>
`
` Lilly Villaverde
`
` Registered Professional Reporter
`
` My Commission HH016865
`
` Expires July 23, 2024
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`Veritext Legal Solutions
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`Case 2:20-cv-07872-GW-PVC Document 560-2 Filed 06/14/24 Page 19 of 19 Page ID
`#:77420
`UNDER PROTECTIVE ORDER
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`Page 255
`
` C E R T I F I C A T E
`
` STATE OF FLORIDA :
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` COUNTY OF MIAMI-DADE :
`
` I, Lilly Villaverde, RPR, a Notary Public in
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` and for the State of Florida at Large, hereby certify
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` that I reported the deposition of CATHY GLASSMAN; and
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` that the foregoing pages constitute a true and correct
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` transcription of my shorthand report of the deposition
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` by said witness on this date.
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` I further certify that I am not an attorney or
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` counsel of any of the parties, nor a relative or
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` employee of any attorney or counsel connected with the
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` action nor financially interested in the action.
`
` WITNESS my hand and official seal in the State
`
` of Florida, this 10th day of April, 2024.
`
` <%3309,Signature%>
`
` Lilly Villaverde
`
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` Registered Professional Reporter
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` My Commission HH016865
`
` Expires July 23, 2024
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`25
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`800-567-8658
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`973-410-4098
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`Veritext Legal Solutions
`
`
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