Maho Taniguchi-Speller
`
`February 17, 2015
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TD AMERITRADE HOLDING CORP., TD )
`AMERITRADE, INC., and TD )
`AMERITRADE ONLINE HOLDINGS CORP.,)
` )
` Petitioners, )
` ) Case No.
` V. ) CBM2014-00131
` )
`TRADING TECHNOLOGIES ) Patent No.
`INTERNATIONAL, INC., ) 7,533,056
` )
` Patent Owner. )
`_________________________________)
` )
`TD AMERITRADE HOLDING CORP., TD )
`AMERITRADE, INC., and TD )
`AMERITRADE ONLINE HOLDINGS CORP.,)
` )
` Petitioners, )
` ) Case No.
` V. ) CBM2014-00133
` )
`TRADING TECHNOLOGIES ) Patent No.
`INTERNATIONAL, INC., ) 7,676,411
` )
` Patent Owner. )
`_________________________________)
`(Caption continues on following page.)
`
` VIDEOTAPED DEPOSITION OF MAHO TANIGUCHI-SPELLER
` LOS ANGELES, CALIFORNIA, FEBRUARY 17, 2015
`
`MARLA D. SHARP, RPR, CLR, CCRR, CSR No. 11924
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`TRADING TECH EXHIBIT 2095
`TD Ameritrade v. Trading Technologies
`CBM2014-00137
`
`Page 1 of 54
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`

`Maho Taniguchi-Speller
`
`February 17, 2015
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`TD AMERITRADE HOLDING CORP., TD )
`AMERITRADE, INC., and TD )
`AMERITRADE ONLINE HOLDINGS CORP.,)
` )
` Petitioners, )
` ) Case No.
` V. ) CBM2014-00135
` )
`TRADING TECHNOLOGIES ) Patent No.
`INTERNATIONAL, INC., ) 6,772,132
` )
` Patent Owner. )
`_________________________________)
` )
`TD AMERITRADE HOLDING CORP., TD )
`AMERITRADE, INC., and TD )
`AMERITRADE ONLINE HOLDINGS CORP.,)
` )
` Petitioners, )
` ) Case No.
` V. ) CBM2014-00136
` )
`TRADING TECHNOLOGIES ) Patent No.
`INTERNATIONAL, INC., ) 6,766,304
` )
` Patent Owner. )
`_________________________________)
` )
`TD AMERITRADE HOLDING CORP., TD )
`AMERITRADE, INC., and TD )
`AMERITRADE ONLINE HOLDINGS CORP.,)
` )
` Petitioners, )
` ) Case No.
` V. ) CBM2014-00137
` )
`TRADING TECHNOLOGIES ) Patent No.
`INTERNATIONAL, INC., ) 7,685,055
` )
` Patent Owner. )
`_________________________________)
`VIDEOTAPED DEPOSITION OF MAHO TANIGUCHI-SPELLER,
`taken on behalf of Patent Owner, at TransPerfect
`Translations, Inc., 2049 Century Park East, Room A,
`Los Angeles, California, commencing at 9:48 a.m.,
`Tuesday, February 17, 2015, before Marla D. Sharp,
`RPR, CLR, CCRR, CSR No. 11924.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Page 2 of 54
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`
`February 17, 2015
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`A P P E A R A N C E S:
`FOR PETITIONERS:
` STERNE, KESSLER, GOLDSTEIN & FOX
` BY: JONATHAN M. STRANG, ESQ.
` LORI GORDON, ESQ.
` MARK EVENS, ESQ.
` 1100 New York Avenue, NW
` Washington, DC 20005
` 202-371-2600
` jstrang@skgf.com
` lgordon@skgf.com
` mevens@skgf.com
`
`FOR PATENT OWNER:
` FINNEGAN, HENDERSON, FARABOW, GARRETT &
` DUNNER, LLP
` BY: KEVIN D. RODKEY, ESQ.
` 3500 Suntrust Plaza
` 303 Peachtree Street, NE
` Atlanta, Georgia 30308
` 404-653-6400
` kevin.rodkey@finnegan.com
`
` FINNEGAN, HENDERSON, FARABOW, GARRETT &
` DUNNER, LLP
` BY: JOSHUA L. GOLDBERG, ESQ.
` 901 New York Avenue, NW
` Washington, DC 20001
` 202-408-4000
` joshua.goldberg@finnegan.com
`
`ALSO PRESENT:
` Ryan Wong, videographer
` Harold Abilock
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`February 17, 2015
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` I N D E X
`EXAMINATION PAGE
`MAHO TANIGUCHI-SPELLER
` BY MR. RODKEY 6
`
` PREVIOUSLY MARKED EXHIBITS
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1007 Japanese version of Exhibit 27
` 1008 (335 pages, Bates Nos.
` TSE0000000647 - TSE0000000981)
`Exhibit 1008 Futures/Option Purchasing 24
` System Trading Terminal
` Operation Guide, Tokyo Stock
` Exchange, Operations Systems
` Division (335 pages, Bates Nos.
` TSE0000000647 - TSE0000000981)
`Exhibit 1018 Declaration of Maho 23
` Taniguchi-Speller (1 page)
`Exhibit 1037 Declaration of Maho 23
` Taniguchi-Speller (1 page)
`
` (retained by counsel)
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`February 17, 2015
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` LOS ANGELES, CALIFORNIA; TUESDAY, FEBRUARY 17, 2015
` 9:48 A.M.
` * * *
` THE VIDEOGRAPHER: Good morning. We are
`going on the record at 9:48 a.m. Today's date is
`February 17th, 2015. This is Volume No. I, media
`unit 1, of the video deposition of
`Maho Taniguchi-Speller in the matter of
`TD Ameritrade Holding Corp versus Trading
`Technologies International, Inc., filed in the
`United States Patent and Trademark Office. And the
`case number is CBM2014-00131.
` This deposition is being held at
`2029 Century Park East, Conference Room A,
`Los Angeles, California 90067.
` My name is Ryan Wong. I am the
`videographer, representing Henderson Legal Services.
` Will counsel and all present state their
`appearances and affiliations for the record, please.
` MR. RODKEY: Kevin Rodkey with Finnegan,
`Henderson, Farabow, Garrett & Dunner for Trading
`Technologies.
` MR. GOLDBERG: Joshua Goldberg with
`Finnegan for Trading Technologies.
` MR. ABILOCK: Harold Abilock of JapanLink
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Page 5 of 54
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`

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`Maho Taniguchi-Speller
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`February 17, 2015
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`Translations.
` MR. STRANG: Jonathan M. Strang of
`Sterne Kessler for TD Ameritrade. And with me today
`are Lori Gordon and Mark Evens, also with
`Sterne Kessler.
` THE VIDEOGRAPHER: The court reporter is
`Marla Sharp, representing Henderson Legal Services,
`and will now swear in the witness.
` MAHO TANIGUCHI-SPELLER,
` having been first duly sworn,
` was examined and testified as follows:
` EXAMINATION
`BY MR. RODKEY:
` Q Good morning.
` A Good morning.
` Q Would you please state your name and
`address for the record.
` A Okay. My name is Maho Taniguchi-Speller.
`My address is 574 Vista Miranda, Chula Vista,
`California 91910.
` Q And, Ms. Taniguchi-Speller, do you
`understand that you're under oath today?
` A Yes.
` Q And you understand that that means you must
`tell the truth?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`February 17, 2015
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` A Yes.
` Q And we have a reporter here today with us.
`So our conversation is being taken down, and it's
`also being video recorded.
` A Okay.
` Q And for that reason I ask that you speak
`clearly.
` A Okay.
` Q And you can do that for me?
` A Yes.
` Q And also, because we have a reporter, since
`she's trying to take down what we're saying, if we
`talk over each other it's very hard for her to
`accurately transcribe what we've said.
` So can we agree that I'll try not to
`interrupt you when you're answering a question if
`you will not interrupt me when I'm asking a
`question?
` A Okay.
` Q And do you understand that the transcript
`of this deposition can be used in a court or other
`administrative proceeding?
` A Yes.
` Q And, Ms. Taniguchi-Speller, have you ever
`been deposed before?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`February 17, 2015
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` A In this position, never.
` Q So you've never been deposed before?
` A Deposed?
` Q Yeah. Have you ever been part of a
`deposition before?
` A I was interpreter for the witness sometime.
` Q Okay.
` A Yeah.
` Q But you've never been the witness being
`deposed?
` A Never.
` Q Okay. So I just want to explain what we're
`going to do and make sure that you understand just
`so everything is clear.
` A Okay.
` Q We're here to discuss part of a translation
`that you made and also to discuss your affidavit
`attesting to the accuracy of that translation.
` A Okay.
` Q And I'm going to ask you some questions.
`Hopefully you can provide me some answers. And
`we're just trying to get more information.
` A Okay.
` Q So I'm not trying to trick you. If you
`don't understand a question, will you please let me
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Page 8 of 54
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`Maho Taniguchi-Speller
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`February 17, 2015
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`know?
` A I will.
` THE COURT REPORTER: I'm sorry?
` THE WITNESS: I will.
`BY MR. RODKEY:
` Q And if you don't ask me to clarify a
`question, can I assume that you understood the
`question that I asked?
` A Okay. I will.
` Q And you have a very soft voice. Can you
`please try and speak a little louder so we can also
`get it on video recording?
` A I will try.
` Q Okay. Thank you.
` A Yeah.
` Q And from time to time TD Ameritrade's
`counsel may object to a question.
` Do you understand that you still have to
`answer the question unless they instruct you not to
`answer?
` A Yes.
` Q And I'll try and take a break every
`45 minutes to an hour. But if you need a break
`another time, feel free to let me know.
` A Okay.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`

`Maho Taniguchi-Speller
`
`February 17, 2015
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`10
` Q The only thing I ask is that if you ask for
`a break and I've asked a question, will you please
`answer the question; then we'll take a break?
` A Yes.
` Q And do you understand that during the
`breaks you're not allowed to discuss your testimony
`with anyone?
` A Anyone, okay.
` Q And that includes TD Ameritrade's counsel.
` A Mm-hmm.
` Q And is there any reason that you cannot
`testify truthfully and accurately today?
` A No.
` Q And you haven't taken any medications or
`anything else that might impair your ability to
`testify?
` A No, I didn't.
` Q And if anything happens that changes your
`ability to testify accurately, will you let me know?
` A No. Could you ask me again?
` Q Yes. If anything happens that prevents you
`from testifying accurately, will you let me know?
` A Yes.
` Q And have you done anything to prepare for
`this deposition?
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`

`Maho Taniguchi-Speller
`
`February 17, 2015
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`11
` A Actually, no.
` Q Did you meet with anybody?
` A If I need anybody?
` Q Did you meet with anybody?
` A Yes.
` Q Okay. Who did you meet with?
` A These three people.
` Q When you say "these three people," are you
`indicating Mr. Strang?
` A Mr. -- yes. They are new for me, so I
`don't memorize their name.
` Q Yes. So if I identify them, will you
`please say yes or no you met with them?
` A Okay.
` Q Did you meet with Mr. Strang, who's sitting
`next to you?
` A Yes.
` Q Did you meet with Ms. Gordon, who is down
`the table?
` A Yes.
` Q And did you meet with Mr. Evens at the end
`of the table?
` A Yes.
` Q Did you meet with anybody else?
` A No.
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Maho Taniguchi-Speller
`
`February 17, 2015
`
`12
` Q And when did you meet with Mr. Strang?
` A Yesterday.
` Q And how long did you meet with Mr. Strang?
` A Just couple hours.
` Q About two, three hours maybe?
` A Mm-hmm.
` Q And when did you meet with Ms. Gordon?
` A Where?
` Q When?
` A When? Yesterday.
` Q Yesterday. Was that at the same time as
`Mr. Strang?
` A Yes.
` Q And when did you meet with Mr. Evens?
` A At the same time.
` Q And did you meet with any of them
`separately at another time?
` A Nope.
` Q And did you review any documents preparing
`for this deposition?
` A Nope.
` Q When you met with Mr. Strang, did you look
`at any documents?
` A No.
` Q And have you discussed your testimony with
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`Maho Taniguchi-Speller
`
`February 17, 2015
`
`13
`anyone before this deposition?
` A No.
` Q And have you discussed the testimony of any
`other witnesses?
` A No.
` Q And are you being paid for your time today?
`Are you receiving some form of compensation?
` A I'm not sure.
` Q Okay. Is someone paying for your hotel
`rooms or your flights?
` A I hope so.
` Q Okay. And, Ms. Taniguchi-Speller, what do
`you consider to be your native language?
` A My native language is Japanese.
` Q Do you have any other native languages?
` A No.
` Q And so your native language is not English?
` A Nope.
` Q And when did you first learn English?
` A Elementary -- sorry. Seventh grade in
`Japan. So...
` Q And how long did you study English?
` A Three years in middle school, three years
`in high school, and four years in college. So ten
`years in school.
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`

`Maho Taniguchi-Speller
`
`February 17, 2015
`
`14
` Q And where did you study English in college?
` A College, in Kyoto, Japan.
` Q And what was the name of that college?
` A University of Ritsumeikan.
` Q And so the reporter gets that correctly,
`can you spell the name of that university, the last
`word?
` A R-i-t-s-u-m-e-i-k-a-i -- k-a-n.
` Q Thank you. And you said you studied
`English. What was your major?
` A My major was English and American
`literature.
` Q And did you study English anytime after
`college?
` A After college, yes. Online.
` Q And when did you graduate from college?
` A 1989.
` Q And how much online study have you done?
` A That was, like, six-month course for
`translation.
` Q And when did you have the six-month course?
` A That was last year to reinforce my ability.
` Q So you had the course in 2014?
` A Yes.
` Q And you said it was a six-month course for
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`Maho Taniguchi-Speller
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`February 17, 2015
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`translation?
` A Yes, translation.
` Q And have you studied translation at any
`other time?
` A Focused on translation, no.
` Q And was it -- what -- was it specific to
`any languages when you took this course?
` A What do you mean?
` Q Did it focus on any particular --
`translating any particular languages?
` A Translating English into Japanese --
` Q Okay.
` A -- only.
` Q And do you remember what time in 2014 you
`took this course?
` A I think first six months, so January
`through June.
` Q So January through June of 2014?
` A Yes.
` Q And is working as a translator your primary
`occupation?
` A Yes.
` Q And do you have any other occupations?
` A I am a notary public and interpreting also.
` Q And any others?
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`Maho Taniguchi-Speller
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`February 17, 2015
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` A Sometimes I teach Spanish and Japanese when
`required.
` Q And anything else?
` A That's it.
` Q What percent of your time do you spend
`doing translations?
` A One hundred -- 99 percent.
` Q And about how many hours a week do you
`spend doing translations?
` A Yeah, I always say 24/7, all the time, no
`stop. Sometime weekend and all day. So hours I
`spend.
` Q Okay.
` A Yeah.
` Q But you have to eat and sleep sometime,
`right?
` A Yeah. Sometime I forget to eat, but -- so
`I'm so crazy.
` Q I do too.
` A Yeah.
` Q So if you had to guess a number of hours,
`could you --
` A Average?
` Q Yeah.
` A Ten hours, ten hours daily.
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`Maho Taniguchi-Speller
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`February 17, 2015
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`17
` Q Ten hours?
` A Yeah.
` Q Ten hours daily, you said?
` A Mm-hmm.
` Q And do you translate -- you mentioned your
`course was Japanese --
` A Into -- no. English into Japanese.
` Q English into Japanese.
` A But actually 90 percent of my translation
`is Japanese into English because of their demand. I
`don't know why.
` Q So you translate Japanese into English.
`And you mentioned you took a course on English into
`Japanese.
` Do you translate any other pairs of
`languages?
` A Yes. Spanish into Japanese, vice versa,
`also.
` Q Do you translate any others?
` A No others.
` Q And do you consider yourself an employee of
`TransPerfect? Do you know who TransPerfect is?
` A Yes.
` Q Do you consider yourself an employee of
`TransPerfect?
`
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`Maho Taniguchi-Speller
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`February 17, 2015
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` A If I am a employee?
` Q Yes.
` A No.
` Q How would you describe your relationship
`with TransPerfect?
` A TransPerfect is one of my largest clients
`for years.
` Q And who are your other clients?
` A Yes.
` Q Who are they?
` A It's confidential --
` Q Oh, I'm sorry.
` A -- I think, yeah. I have many.
` Q Companies like TransPerfect that do
`translation services, not the individual companies.
`Does that make sense? I'll rephrase.
` Do you do translations for any companies
`other than TransPerfect?
` A Yes.
` Q And what companies are those?
` A I cannot mention the company name, but I
`counted about 40 other companies.
` Q Forty? Four zero?
` A Forty.
` Q And what percent of your translations would
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`Maho Taniguchi-Speller
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`you say are for TransPerfect?
` A It's quite high and maybe 33 percent income
`base.
` Q And when you say "income base," do you get
`paid by the word --
` A Yes.
` Q -- in your translations?
` A Mm-hmm.
` Q And for Japanese-to-English translations,
`how much do you get paid per word?
` A I think it's confidential also. I can't
`tell.
` Q And when you receive translation
`assignments or -- yes. When you receive translation
`assignments from TransPerfect, how do you know they
`want you to perform a translation?
` A How do I --
` MR. STRANG: Objection to form.
` You can answer.
` THE WITNESS: How do I know?
`BY MR. RODKEY:
` Q Do they contact you when they want you to
`perform a translation?
` A Yeah. Usually they send me e-mail. And
`they ask me availability and then show me the
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`Maho Taniguchi-Speller
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`document, and I review and tell them yes or no.
` Q When they send you the e-mail, do they tell
`you the pages that they want you to translate in the
`document?
` A If they divide one document, they tell me
`the page. But most of the time, entire document,
`they are asking me.
` Q What percent of the times do they ask you
`to divide a document?
` A Divide a document is very rarely. Maybe
`3 percent.
` Q Is that 3 percent of all your translations
`or 3 percent of your TransPerfect translations?
` A TransPerfect translation.
` Q And does TransPerfect usually ask you -- or
`do they usually provide a turnaround time or a
`deadline --
` A Yes.
` Q -- for the translation?
` A Mm-hmm.
` Q And are those deadlines usually very short?
` A Yes.
` Q How short can they be?
` A Sometime it's couple hours only.
` Q On average, how long would you say those
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`deadlines are?
` A Average? Hmm. Maybe ten hours average.
` Q And you said they send you the document
`with that e-mail?
` A Document is not attached to the e-mail.
`They have a special link for protection of document.
` Q Okay. And the link is part of that e-mail?
` A No.
` Q No, it's not?
` A They have provided my link separately and
`password and PIN.
` Q Okay. So after you receive the e-mail, how
`do you get the document?
` A I sign in their document control site and
`go and look and open.
` Q And do they usually provide you the entire
`document?
` A If they want me to translate the document,
`yeah, they show -- they won't cut one document into
`some pieces.
` Q And if the document's been divided -- I
`thi