DECLARATION OF CORBIN E. KIDD
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`I, Corbin E. Kidd, declare that:
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`I am personally familiar with the facts set forth herein, and, if called as a witness,
`1.
`I could and would testify thereto of my own personal knowledge.
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`I began working in the financial industry at ED&F Man International, a futures
`2.
`clearing merchant. I worked there from February of 1998 until November of 1998.
`During that time, I worked as a runner, as a floor clerk and as a trade clerk at the Chicago
`Board of Trade ("CBOT"). From November of 1998 until August of 1999, I worked as a
`broker's assistant for an independent trader in the Dow Futures pit. From August of 1999
`until December of 2000 I worked at EasyScreen doing technical support and installation.
`EasyScreen is an independent software vendor ("ISV") that sells trading applications to
`electronic traders. From January of 2001 until March of 2003, I worked as a trader at
`Kingstree Trading, LLC, professionally trading equity index futures. Kingstree is a
`proprietary trading firm that trades various futures and other financial instruments
`electronically.
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`3.
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`I reside in Chicago, Illinois.
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`I first heard of Trading Technologies' ("TT") MD Trader product sometime in
`4.
`2000 when I was working at Easyscreen. I recall Easyscreen scrambling to come up with
`a product to compete with MD Trader.
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`I first used MD Trader when I started working at Kingstree. When I first saw it, I
`5.
`thought it was revolutionary for active traders. At the time I knew about a variety of
`different front-ends for electronic trading, including the Project A (the CBOT's first
`electronic trading platform) front-end and software offered by Patsystems, GL,
`Easyscreen, YesTrader, RTS and TT. MD Trader was very different than these
`preexisting systems. For example, MD Trader provides a much more intuitive display
`than the preexisting systems by displaying the market data relative to a fixed column of
`prices on the screen. This results in the market data moving up and down on the screen
`when the market moves. The preexisting systems displayed the best bid and best ask
`prices at designated locations on the screen such that when the market changed, the
`numbers in those locations changed. In those systems, movements in the market were not
`visualized. Rather, to detect such movements, the trader needed to recognize that
`numbers had changed and mentally calculate how much they changed.
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`MD Trader also provides for the ability to enter orders with one click and without
`6.
`the risk of the order being sent to the exchange at an incorrect price. This is done by
`providing the ability to click on cells aligned with the fixed prices to send orders. In the
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`TRADING TECH EXHIBIT 2030
`TD Ameritrade v. Trading Technologies
`CBM2014-00136
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`Page 1 of 2
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`preexisting systems, to send orders without risk of error required multiple steps. To the
`extent they permitted one-click order entry, the trader risked having the order sent in at an
`incorrect price if the prices changed on the screen at the moment the trader clicked. MD
`Trader also provided the ability to see working orders in the same window in which the
`trader was viewing market information and trading. In addition, MD Trader had a unique
`one click recentering feature that allowed a trader to easily bring the market back to the
`center of the trading window in a volatile market. This allowed the trader to set a point
`of reference from which to view the market going forward.
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`I had never seen any of the features described above in a trading application
`7.
`before seeing MD Trader.
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`Because of the unique features discussed above, MD Trader has been a
`8.
`revolutionary product providing great benefit to electronic traders. The main benefit is
`speed. Because of its more intuitive display and its fast order entry, MD Trader allows
`traders to react quicker and enter orders with less error. The previous systems were far
`slower and much more labor intensive. When I first saw MD Trader, I as struck by how
`different it was than the many existing systems available at the time. It was not just an
`incremental improvement. Another benefit of MD Trader is that it is far easier to use and
`learn, especially for new traders.
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`Easyscreen initially responded to TT's MD Trader with a vertical screen in which
`9.
`the market prices were displayed vertically. The problem with this initial response was
`that it did not keep the prices fixed on the screen. The best bid and best ask prices were
`still displayed at designated locations on the screen. Because of this, market movement
`could not be visualized and it still had the same order entry problems as the previous
`systems.
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`Over the years, most every independent software vendor ("ISV") has replicated
`10.
`MD Trader. I have been involved with many meetings or demonstrations in which
`representatives ofiSVs have tried to sell their trading applications. I recall that these
`sales representatives would often describe their offerings as something similar to or just
`like TT' s MD Trader.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed on
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`& ~ -1&
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`August_!L, 2004.
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`Corbin E. Kidd
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`Page 2 of 2
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