`TD Ameritrade v. Trading Technologies
`CBM2014-00133
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`Page 1 of 2
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`burden on the trader compared to the older style screens in which the trader need to make
`mental calculations to determine how the market was moving and the extent of the
`movement. The MD Trader product also had a one-click recentering feature that was
`valuable because it allowed the trader to quickly bring the display of the market to the
`center of the screen and set a point of reference.
`I had never seen any of these features in
`preexisting electronic trading tools.
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`The MD Trader product initially met with some resistance. For example, because
`6.
`of the fixed nature of the prices there is a risk in MD Trader of the market information
`floating off of the screen. This is impossible with the preexisting systems. Also, traders
`were so used to using the preexisting systems and did not perceive any problems with
`those systems. Prior to the release of MD Trader, TT’s X_Trader product included an
`older style order entry screen. We were using this as our order entry screen and TT was
`regularly making incremental improvements and enhancements to the screen. MD
`Trader, on the other hand, was a complete departure from this typical older style order
`entry screen. It was only after seeing the benefits of this new unusual screen that people
`like myself realized the shortcomings of the preexisting systems.
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`After TT launched MD Trader, almost every other independent software vendor
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`(ISV) released products with similar features, such as the static price, the improved order
`entry and the recentering features.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed on July
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`a? 22 , 2004.
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`Rob Moore
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