DECLARATION OF PATRICK LEONE
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`I, Patrick Leone, declare as that:
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`I am personally familiar with the set of facts set forth herein , and, if c alled as a
`1.
`witness, I could and would testify thereto of my own personal knowledge.
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`I started my career professionally trading-in 1987 011 the floor of the Chicago
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`Board of T rade ("CBOT''). In 1991, I started trading for myself. I trade the futures o n
`the 2. 5, 10 and 30-year treasuries. I began trading electronically in around 1997 on
`Project A (the CBOT' s first electronic trading platform). In the fall of 2000 1 started
`trading electro nically on the CBOT's new A/CIE electronic trading platform using a
`front-end provided by Future Dynamics. In De~ember of 2000, I started using TT' s MD
`Trader to trade electronically and have been using this as my orde r entry and
`management tool ever since. Prior to seeing MD Trader, I was aware of various front(cid:173)
`ends including the Eurex front-end, the Project A front-end, TT's previous software and
`software from various other vendors including Future Dynamics. These previous systems
`displayed the best bid and best ask prices in designated locations on the screen so that the
`best bid and ask prices changed when the market changed. Also, to the exten t these
`previous systems allowed for single cJick order entry, a trader had to risk the order being
`sent in at an unintended price because a price on the screen could change at the moment a
`trader clicked to send an order.
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`MD Trader was much different than front·end trading tools I had seen before .
`3.
`MD Trader allowed a trader to see the bids and offers in a fluid way by displaying the
`bids and offers relative'to a column of fixed prices so that the bids and offers moved up
`and down along the column when the market changed. MD Trader also provided for one
`click order entry in areas along the column of fixed prices. This eliminated the risk of
`t>rders being sent in at unintended prices without sac..Tifi.cing speed. I had never seen.
`these features in a trading tool prior co seeing MD Trader.
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`Because of these differences, MD Trader provided a great advantage to traders.
`4.
`MD Trader made it easier to execute orders quickly and efficiently. Speed is of primary
`importance in electronic trading and MD Trader made a big difference in increasing the
`speed in which traders could recognize trading opportunities and enter orders. Because
`of its ease of use and speed, MD Trader also causes traders to enter more orders than they
`would have with older style screens.
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`5.
`MD Trader also provided a unique feature in the ability to manually recenter the
`trading window with a single mouse click. This was important because it allowed a
`trader to easily bring the market back in v iew if it ran off the screen. Also, it allowed
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`TRADING TECH EXHIBIT 2046
`CQG & CQGT v. Trading Technologies
`CBM2015-00057
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`traders to set a point of reference from which to view market movements. This is
`especially useful when trading multiple products side-by-side.
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`Based on the benefits described above, in December of 2000 I switched over to
`6.
`TI's MD Trader despite the fact that it was much more expensive than other software
`available at the time. The advantages of MD Trader far outweighed the higher cost.
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`In the years following TT's introduction of MD Trader, many companies have
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`released products with similar features. I have seen many demonstrations on the floor of
`the CBOT and in my office over the past several years, including demos from
`Patsystems, EccoWare, Yes Trader, and Future Dynamics. The representatives from
`these companies often pitched their company's product as being like IT's MD Trader but
`cheaper. Such pitches were also often made by representatives of Futures Commission
`Merchants ("FCMs") who tried to convince traders to take cheaper software.
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