UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IBG LLC, INTERACTIVE BROKERS LLC, TRADESTATION GROUP, INC.,
`
`TRADESTATION SECURITIES, INC., TRADESTATION TECHNOLOGIES,
`
`INC., and IBFX, INC.,
`
`Petitioner
`
`V.
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`
`Patent Owner
`
`CBM2015-00161 (U.S. Patent 6,766,304 B2)‘
`CBM2015-00181 (U.S. Patent No. 7,676,411 132)
`CBM2015-00182 (U.S. Patent No. 6,772,132 B1)
`
`DECLARATION OF JAY KNOBLOCH
`
`1 Case CBM2016-00035 has been joined with this proceeding.
`
`PAGE 1 OF 46
`
`TRADESTATION, IBG, ET AL. V. TRADING TECH
`CBM2015-00161. CBM2015-00181.. CBM2015-00182
`
`TRADING TECH EXHIBIT 2172
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IBG LLC, INTERACTIVE BROKERS LLC, TRADESTATION GROUP, INC.,
`
`TRADESTATION SECURITIES, INC., TRADESTATION TECHNOLOGIES,
`
`INC., and IBFX, INC.,
`
`Petitioner
`
`V.
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`
`Patent Owner
`
`CBM2015-00161 (U.S. Patent 6,766,304 B2)‘
`CBM2015-00181 (U.S. Patent No. 7,676,411 132)
`CBM2015-00182 (U.S. Patent No. 6,772,132 B1)
`
`DECLARATION OF JAY KNOBLOCH
`
`1 Case CBM2016-00035 has been joined with this proceeding.
`
`PAGE 1 OF 46
`
`TRADESTATION, IBG, ET AL. V. TRADING TECH
`CBM2015-00161. CBM2015-00181.. CBM2015-00182
`
`TRADING TECH EXHIBIT 2172
`
`
`
`Table of Contents
`
`I.
`
`INTRODUCTION & BACKGROUND .................................................... .. 1
`
`II.
`
`PATENT LICENSING ............................................................................. .. 1
`
`III.
`
`CONCLUDING STATEIVIENTS ............................................................. .. 6
`
`PAGE 2 OF 46
`
`
`
`1, Jay Knobloch, declare as follows:
`
`I.
`
`INTRODUCTION & BACKGROUND
`
`1.
`
`I currently serve as the Director of Intellectual Property (“IP”)
`
`Licensing and Litigation for Trading Technologies International, Inc. (“TT”). In
`
`this role, I oversee TT’s licensing of its IP assets and assist in the management of
`
`all aspects of TT’s IP litigation matters. Prior to my role as Director, I served as
`
`Patent Counsel at TT from February 2010 until February 2012.
`
`2.
`
`Before joining TT, I was employed by Brinks Hofer Gilson and
`
`Lione LLP, an IP law firm located in Chicago, Illinois, as a patent agent starting
`
`in February 2005. Upon completion of my law degree from DePaul University
`
`College of Law in December 2007, I transitioned into my role as a patent
`
`attorney at Brinks Hofer until deciding to join TT. Prior to law school, I attended
`
`Arizona State University and graduated in 2003 with a degree in electrical
`
`engineering.
`
`II.
`
`PATENT LICENSING
`
`3.
`
`As I noted above, a portion of my role at TT involves overseeing the
`
`licensing of TT’s IP assets, including the licensing of TT’s patents. Though I
`
`was not employed by TT until 2010, I am knowledgeable regarding TT’s licenses
`
`dating back to 2004, and in particular those relating to the technology claimed in
`
`the patents-in-suit.
`
`PAGE 3 OF 46
`
`
`
`4.
`
`After U.S. Patent Nos. 6,766,304 and 6,772,132 issued in July and
`
`August of 2004, a number of companies in the industry were already copying TT’s
`
`MD Trader screen, which embodied the technology claimed in these patents. In an
`
`effort to protect its IP assets, TT entered into numerous types of deals with respect
`
`to the ‘304 and ‘ 132 patents and continuation patents (such as the ‘411 patent), as
`
`can be seen in the demonstrative used at the CQG trial shown below:
`
`Settlement & License Agreements
`
`Lawsuit
`
`Royalty rates
`
`$0.10 per trade/$0.05 (l“ year)
`$010 per trade/S0 051:1 ‘ year)
`$010 per trade {S50 rm m
`'
`$010 per trade (350 ll-Q rim’:
`
`per trade (SSO ll-»'J min user,
`
`$010 per trade
`
`$0.24 for past
`
`$0.10 per trade
`$0.09 for past
`
`$0.46 for past
`$0 10 for past
`
`$0.14 for past
`
`V V V V V V V V V V V V (
`
`Q
`
`Company
`
`Agrmt. date
`
`Goldenberg Hehmeyer & CO.
`Kingstree Trading, LLC
`Patsystems, PLC
`NinjaTrader, LLC
`RTS Realtime Systems AG
`
`Strategy Runner, Ltd.
`Rolfe & Nolan Systems, Inc.
`FFastFi|l, PLC
`
`TransMarket Group, LLC
`Orc Software AB
`
`NYFIX, lnc.
`
`Man Group, PLC
`Advantage Futures, LLC
`
`Peregrine Financial Group, Inc.
`TradeMaven Group, LLC
`Marex Trading Services, Ltd.
`
`Direct Trading Institutional, L P.
`Cunningham Trading Systems, LLC
`Tradehelm
`
`RCG
`Stellar
`
`OEC
`150 -oz
`
`09/29/04
`10/20/O4
`O5/19/OS
`07/O7/O5
`O7/28/05
`
`O7/29/O5
`08/01/05
`08/03/O5
`
`09/09/O5
`10/31/05
`
`11/11/O5
`
`11/21/O5
`O3/03/06
`
`03/15/06
`O3/15/O6
`O9/20/O6
`
`12/O6/06
`12/31/10
`4/18/11
`
`11/9/11
`12/7/12
`
`2/12/15
`
`PTX#
`
`PTX1334
`PTX1335
`PTX1338
`PTX1336
`PTX1342
`
`PTX1344
`PTX1343
`PTXl345
`
`PTX1346
`PTX1347
`
`PTX1339
`
`PTX1337
`PTX1348
`
`PTX1340
`PTX1341
`PTX‘|350
`
`PTXO748
`PTX1351
`PTX1352
`
`PTX1353
`PTX1354
`
`PTX2671
`
`5.
`
`It was apparent that the industry competitors recognized that their
`
`products infringed the patents.
`
`PAGE 4 OF 46
`
`
`
`6.
`
`For example, several companies agreed/to remove their version of the
`
`patented trading screen from their product offerings. Companies that chose this
`
`option include Patsystems, RTS, Strategy Runner, Rolfe and Nolan, FFastFill,
`
`TransMarket, ORC, NYFIX, Peregrine Financial Group, and TradeMaven.
`
`7.
`
`As an example, Patsystems and RTS were main competitors of TT
`
`that both decided to remove their version of the MD Trader trading screen around
`
`2004. Both of these competitors, along with others that followed in a similar
`
`fashion (FFastFil1, ORC, and NYFIX), changed the focus of their business to areas
`
`other than manual order entry and declined as competitors to TT.
`
`8.
`
`These agreements were particularly beneficial to TT on two fronts.
`
`First, it was beneficial to have a company agree that it would stop infringing and
`
`remove the infringing product from the market, thus directing customers back to
`
`TT. Second, since some of these companies were TT’s direct competitors, it was
`
`beneficial for TT to have them drop out and return the competitive edge to TT vis-
`
`a-vis the competitors themselves.
`
`9.
`
`As another option, several companies entered into a license agreement
`
`which would allow them to practice the patented technology. In return, these
`
`companies would pay TT royalties to continue using the copied trading screens.
`
`Companies that chose this option included Goldenberg Heymeyer, Kingstree,
`
`Ninja Trader, Direct Trading Institutional (“DTI”), RCG, OEC, Market Delta, 20
`
`PAGE 5 OF 46
`
`
`
`LLC, Trademonster, and Trade Exchange. In some instances, these companies
`
`entered into a license agreement wherein they agreed to pay for past damages
`
`based on prior use. Also, some companies entered into a license agreement
`
`wherein they agreed to pay TT a royalty based on future use. TT still collects
`
`royalty payments from several of these companies. Several of these companies
`
`approached TT requesting a license without having to be threatened by TT, e. g. ,
`
`Ninja Trader, DTI, Goldenberg Hehmeyer, Market Delta, 20 LLC, Trademonster,
`
`and Trade Exchange. Mr. Deux, the CEO of Ninja Trader, testified that I
`
`— Likewise, Goldenberg Hehmeyer admitted that—
`
`10.
`
`Finally, several companies, such as Patsystems and Strategy Runner,
`
`chose to sign a license agreement that would give them the option to license and
`
`practice the claimed technology in the future, however neither availed themselves
`
`of it.
`
`11.
`
`In total, TT has received more than‘ in royalty and
`
`settlement payments.
`
`12.
`
`Also, in 2004-2005, TT filed law suits against several competitors for
`
`infringement of the ‘ 132 and ‘304 patents based on their use of the patented
`
`PAGE 6 OF 46
`
`
`
`technology. Though most of the litigations settled, several did not and progressed
`
`into litigation in the Northern District of Illinois.
`
`13.
`
`One example was a company named eSpeed, which was not a
`
`traditional competitor of TT’s, however they coincidentally launched their
`
`electronic trading screen at the same time the ‘ 132 and ‘304 patents issued. We
`
`viewed them as a significant threat because they were able to leverage off of their
`
`exchange business and offer this software for free. Mr. Ryan (TT’s general
`
`counsel) testified that he and Mr. Borsand attended a launch marketing event for
`
`the eSpeed product that embodied the patented invention and that at that event an
`
`eSpeed representative stated that the product was just like TT’s MD Trader and
`
`would be offered for free. Ex. 1 (Ryan Testimony, eSpeed Trial Tr. at 587: 16-
`
`594:11, PTX 9)). In the lawsuit, several of eSpeed’s electronic trading screens
`
`were found to infringe TT’s patents.
`
`14.
`
`For those that settled, some of the settlement agreements entered
`
`consent judgments as means for establishing finality in the lawsuit. These consent
`
`judgments set forth that the patents-in-suit are valid and enforceable, that the
`
`defendant infringed the patents-in-suit, and that the defendant was permanently
`
`enjoined from making, using, selling, offering for sale, importing, facilitating
`
`connectivity for, or otherwise distributing the infringing electronic trading
`
`product. The existence of the consent judgments put “more teeth” behind the
`
`PAGE 7 OF 46
`
`
`
`agreement and ensured that the matters would be put to rest. See, e. g., Ex. 2,
`
`Consent Judgment with NinjaTrader, LLC.
`
`III. CONCLUDING STATEMENTS
`
`15.
`
`In signing this declaration, I understand that the declaration will be
`
`filed as evidence in a contested case before the Patent Trial and Appeal Board of
`
`the United States Patent and Trademark Office. I acknowledge that I may be
`
`subject to cross-examination in this case and that cross-examination will take
`
`place within the United States. If cross-examination is required of me, I will
`
`appear for cross-examination within the United States during the time allotted for
`
`cross-examination.
`
`16.
`
`I declare that all statements made herein of my knowledge are true,
`
`and that all statements made on information and belief are believed to be true, and
`
`that these statements were made with the knowledge that willful false statements
`
`and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Dated:
`
`June 22 2016
`
`
`
`PAGE 8 OF 46
`
`
`
`
`
`
`
`Exhibit 1Exhibit 1Exhibit 1
`
`
`
`
`
`PAGE 9 OF 46PAGE 9 OF 46PAGE 9 OF 46
`
`
`
`489
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`TRADING TECHNOLOGIES INTERNATIONAL J
`INC.,
`
`) )
`
`) )
`
`Plaintiff,
`
`v.
`
`) No. 04 C 5312
`)
`
`INC., eSPEED INTERNATIONAL,)
`eSPEED,
`LTD., ECCO LLC, and ECCOWARE, LTD.,) Chicago, Illinois
`)
`September 12, 2007
`)
`1:30 o'clock p.m.
`
`Defendants.
`
`VOLUME 3-B
`TRIAL TRANSCRIPT OF PROCEEDINGS
`
`BEFORE THE HONORABLE JAMES B. MORAN, and a JURY
`
`APPEARANCES:
`
`Trading Technologies
`International, Inc., by:
`
`and
`
`TRADING TECHNOLOGIES
`
`INC.,
`INTERNATIONAL,
`MR. STEVEN F. BORSAND
`222 South Riverside Drive
`
`Chicago, Illinois 60606
`312-476-1000
`
`steve.borsand@
`
`tradingtechnologies.com
`
`MCDONNELL, BOEHNEN, HULBERT &
`BERGHOFF, LTD.
`MR. PAUL H. BERGHOFF
`MR. S. RICHARD CARDEN
`MR. CHRISTOPHER M. CAVAN
`MR. MICHAEL D. GANNON
`
`JENNIFER M. KURCZ
`MS.
`MR. MATTHEW J. SAMPSON
`MR. LEIF R. SIGMOND
`300 South Wacker Drive
`
`Chicago, Illinois 60606
`312-913-0001
`
`berghoff@mbhb.com
`kurcz@mbhb.com
`
`10
`
`11
`
`12
`
`13
`
`14
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`15
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`16
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`21
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`22
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`23
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`24
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`25
`
`PAGE1 OF46
`
`
`
`490
`
`eSpeed, Inc., eSpeed
`International, Inc.,
`Ecco LLC, Eccoware,
`LTD., by:
`1
`
`WINSTON & STRAWN
`MR. GEORGE C. LOMBARDI
`MR. RAYMOND C. PERKINS
`MR.
`IMRON T. ALY
`MR. KEVIN BANASIK
`MS. ELIZABETH HARTFORD ERICKSON
`
`JOHNSTONE
`MR. ANDREW M.
`MS. TRACEY J. ALLEN
`
`JAMES M. HILMERT
`MR.
`35 West Wacker Drive
`
`Chicago, Illinois 60601
`312-558-5600
`
`glombardi@winston.com
`rperkins@winston.com
`
`LAW OFFICES OF
`
`GARY A. ROSEN, P.C.
`MR. GARY A. ROSEN
`
`1831 Chestnut Street, Suite 802
`Philadelphia, Pennsylvania
`1910
`215-972-0600
`
`Rosenthal Collins Group, DOWELL BAKER
`LLC, by:
`MR. GEOFFREY A. BAKER
`201 Main Street
`
`IN 47901
`Lafayette,
`765-429-4004
`
`gabaker@dowellbaker.com
`
`Court Reporter:
`
`MS. CAROLYN COX, CSR, RPR, CRR
`Official Court Reporter
`219 S. Dearborn Street, Suite 1854-B
`Chicago, Illinois
`60604
`(312) 435-5639
`
`1
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`2
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`3
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`4
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`5
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`6
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`PAGE ll OF 46
`
`
`
`575
`
`THE COURT:
`
`You may.
`
`MR. CARDEN: Oops.
`
`I'm sorry.
`
`The binders
`
`are not all out.
`
`MICHAEL RYAN, DIRECT EXAMINATION
`
`BY MR. CARDEN:
`
`Q.
`
`A.
`
`Good afternoon, Mr. Ryan.
`
`Good afternoon.
`
`Q. Could you state your full name for the record,
`
`please?
`
`A. Michael Gerard Ryan.
`
`Q.
`
`And who do you work for, Mr. Ryan?
`
`A. Trading Technologies.
`
`15:
`
`50:
`
`28
`
`15:
`
`50:
`
`30
`
`15:
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`50:
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`31
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`15:
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`50:
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`31
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`15:
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`50:
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`31
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`15:
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`50:
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`31
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`15:
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`50:
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`48
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`‘
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`‘
`
`‘
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`‘
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`:50:
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`49
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`:50:
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`49
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`51
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`:50:
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`:50:
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`57
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`1O
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`11
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`12
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`13
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`‘
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`‘
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`‘
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`‘
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`‘
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`:51:
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`00
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`:51:
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`O2
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`:51:
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`O3
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`:51:
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`04
`
`:51:
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`07
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`:51:
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`O9
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`:51:
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`O9
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`:51:
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`11
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`11
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`12
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`15:
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`23
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`24
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`25
`
`Q.
`
`And if I refer to it as TT today, you'll
`
`understand that I'm referring to Trading Technologies?
`
`A. Yes.
`
`Q. Okay. And I don't know if maybe you could raise
`
`the microphone towards you a little bit,
`
`I
`
`think we
`
`might be having trouble.
`
`A.
`
`Is that better?
`
`Q. Very much better.
`
`Thank you.
`
`A. Okay.
`
`Q.
`
`A.
`
`How long have you been with TT?
`
`Since November of 1999.
`
`Q.
`
`And what is your current position there?
`
`PAGE 1 OF 46
`
`
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`586
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`16:
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`O3:
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`37
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`16:
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`03:
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`37
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`16:
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`03:
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`39
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`16:
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`03:
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`45
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`16:
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`03:
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`48
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`16:
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`O3:
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`16:
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`O4:
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`O6
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`16:
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`O4:
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`O6
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`16:
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`04:
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`11
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`16:
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`O4:
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`12
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`16:
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`O4:
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`16:
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`04:
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`20
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`16:
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`04:
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`16:
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`O4:
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`23
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`10
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`11
`
`12
`
`13
`
`BY MR. CARDEN:
`
`Q.
`
`And could you read the patent numbers for us?
`
`A. Yes.
`
`It's U.S.
`
`patent No.
`
`6,766,304 and
`
`6,772,132.
`
`Q. And is 6,76— —— —766,304 the number contained on
`
`Exhibit 2 in your binder?
`
`A. Yes.
`
`Q. And is 6,772,132 the number contained on
`
`Exhibit 1 in your binder?
`
`A. Yes.
`
`Q. Could we pull up 1989, please?
`
`And could you describe for the jury again,
`
`this
`
`screen?
`
`14
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`15
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`16
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`17
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`18
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`19
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`16:
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`O4:
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`25
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`16:
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`O4:
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`28
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`16:
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`O4:
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`31
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`16:
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`04:
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`34
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`16:
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`04:
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`16:
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`O4:
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`16:
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`O4:
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`16:
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`04:
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`16:
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`O4:
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`47
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`16:
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`O4:
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`52
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`16:
`
`O4:
`
`55
`
`A. Yes. This is the about box that I was talking
`
`about before that also has the patent numbers and also
`
`the date that the software was built.
`
`Q.
`
`And could you refer the jury to the date that you
`
`were referring —— you discussed earlier?
`
`A.
`
`Sure.
`
`It's right under the version number.
`
`It
`
`says, Built, and then July 28, 2004 and the time.
`
`Q. And, again, could you show the jury where the
`
`patent numbers are here?
`
`A. Yes. Right down here at the bottom.
`
`Q. And, again,
`
`'304 is Exhibit 2?
`
`A. Yeah,
`
`'304 is Exhibit 2 and '132 is Exhibit 1.
`
`PAGE 1 OF 46
`
`
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`587
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`16:
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`O4:
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`59
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`16:
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`O5:
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`O2
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`16:
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`05:
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`05
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`16:
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`O5:
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`O6
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`16:
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`16:
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`16:
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`O5:
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`05:
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`16:
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`05:
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`16:
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`21
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`16:
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`O5:
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`24
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`16:
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`05:
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`31
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`16:
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`O5:
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`35
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`10
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`11
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`12
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`13
`
`Q. And, finally, could you turn to Plaintiff's
`
`Exhibit 1991?
`
`A. Okay.
`
`Q.
`
`And tell the jury what this screen is again.
`
`A. This is the MD Trader window.
`
`Q.
`
`And could you describe for the jury where the
`
`marking occurs on this screen?
`
`A. Again,
`
`this occurs at the very bottom right here
`
`(indicating).
`
`Q.
`
`And if we could just blow that up a little bit,
`
`Brian?
`
`A little fuzzy,
`
`but,
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`again,
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`it appears to be the
`
`'304 patent and the ‘132 patent, which are Exhibits 1
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`and 2 or vice versa?
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`A. Yes, yes.
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`MR. CARDEN: Now, could you turn in your
`
`binder to PTX 9. And again, your Honor,
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`this is agreed,
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`so if we could have that on the screen?
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`BY MR. CARDEN:
`
`Q.
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`Can you tell me if you recognize this particular
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`document?
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`A.
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`I do.
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`Q. What is that document?
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`A. This is a sales brochure or marketing brochure
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`from espeed, which I picked up one day on the floor of
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`PAGE 1 OF 46
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`the Board of Trade.
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`It's a copy of it.
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`Q.
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`And you mentioned you picked it up on the Board
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`of Trade. Could you describe what the circumstances
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`were for you picking that up?
`
`A.
`
`Sure.
`
`I recall one morning in August —— I think
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`it was August 4th of 2004 —— my office at TT happened to
`
`be right outside of the sales group, which could be
`
`rather noisy from time to time. And on this particular
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`morning there was a lot of talk going on, and that talk
`
`was about a booth that was up at the Board of Trade on
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`the trading floor.
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`I —— one of the salesmen told me about it and
`
`asked if-I wanted to go see it. And I said, yes,
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`I
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`would. And the reason —-
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`the reason for it and the
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`reason for the booth is that they were displaying their
`
`new futures screen, which the sales people had been
`
`telling me looked like our MD Trader.
`
`Q. Okay. Could we turn to page 30003 in the
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`Exhibit 9?
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`Is this the screen that was being referred to?
`
`A. Yes, it is.
`
`Q.
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`And did you indeed see that screen on the floor
`
`of the Board of Trade?
`
`A.
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`I did, yeah.
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`What happened was this salesman
`
`asked if I wanted to go see it.
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`I indicated I did, went
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`PAGE 1 OF 46
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`over to the Board of Trade with him, signed in at the
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`security desk on the first floor at the Board of Trade
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`building, went I believe —— I believe we went down —— I
`
`think you have to go down to get to the trading floor,
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`signed in again at another security station, and walked
`
`into the trading floor.
`
`Q. What did you see there, Mr. Ryan?
`
`A. At
`
`the trading floor?
`
`Q. Yeah.
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`A. Well,
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`the first thing I saw was the trading pit
`
`for agriculture products, which was —— it was
`
`interesting at the time, because it was very active.
`
`There were a lot of people there buying and selling and
`
`yelling at each other and using their hand signals to
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`buy and sell the products.
`
`Q.
`
`So that was an open outcry pit?
`
`A. Yes,
`
`that was an open outcry pit; that's right.
`
`Q.
`
`A.
`
`And what did you do next?
`
`We
`
`then walked further on on the floor where
`
`we
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`—— where at the far end,
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`which we didn't quite get
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`to,
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`there was another open outcry pit, which I noticed,
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`even then, was not nearly as active. And it turns out
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`that that was one of the products that was actually
`
`being traded electronically more actively. But in
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`between those two pits we saw this stand that had been
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`PAGE 1 OF 46
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`set up by eSpeed.
`
`Q. Did you go up to the stand?
`
`A. Yes. When I first arrived there,
`
`I saw there
`
`were —— this was the stand. There were screens behind
`
`the stand where there was a display of software
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`products,
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`including the product that is displayed on
`
`this exhibit TT 30003. When I first walked up,
`
`there
`
`were other people right up at the stand getting a
`
`demonstration, and I recall kind of watching as they
`
`were getting their demonstration kind of looking over
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`their shoulder.
`
`Q. Could you describe for the jury what you saw as
`
`you were looking over the shoulders?
`
`A. Well, sure.
`
`On one of the screens I saw this
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`trading screen, which was notable to me, because,
`
`in
`
`fact,
`
`I agreed it looked a heck of a lot like MD Trader;
`
`as I noticed as the market would move,
`
`the bids and asks
`
`would move up and down,
`
`the price column and those
`
`prices would stay the same.
`
`Q.
`
`And just so we can maybe give a little refresher
`
`here, when you say bids and asks are moving, can you
`
`look at the screen here and remind us where you're
`
`talking about?
`
`A.
`
`Sure.
`
`The green column are the bids that are in
`
`the market; and the red column are the asks in the
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`PAGE 1 OF 46
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`market, which basically means —— now that I'm up here,
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`I'll probably screw this up,
`
`I'm not a trader —- but the
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`bids are the orders in the market that people are
`
`willing to buy the product for and the asks are the
`
`orders that are in the market that people are willing to
`
`sell the product for.
`
`Q. And the center column again?
`
`A. That's the price column (indicating).
`
`Q.
`
`So could you remind the jury what portion of the
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`screen was moving?
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`A.
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`Sure.
`
`Well,
`
`the center column the prices stayed
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`the same.
`
`So,
`
`in other words,
`
`this 60 stayed right
`
`there. And then the bid and the ask quantities would
`
`either move up or down as the market moved up or down.
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`16:
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`Q.
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`Do you recall who was giving the demonstration?
`
`A.
`
`I —— I don't recall who was giving the
`
`demonstration to the people in front of me, no. But --
`
`I mean, what happened next —— shall I?
`
`Q. What happened next, Mr. Ryan?
`
`A. What happened next was that when those people
`
`were finished,
`
`I walked up to the booth -- and I was the
`
`first person in line —- and before I said anything, one
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`of the people behind the counter asked me if I was
`
`familiar with Trading Technologies.
`
`Q.
`
`And what did you say?
`
`PAGE 1 OF 46
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`A. Well,
`
`I was a little surprised, but I said, Well,
`
`yes,
`
`I am. And he said, Well, our screen is the exact
`
`same thing, which was --
`
`Q.
`
`A.
`
`I'm sorry.
`
`I didn't mean to cut your answer off.
`
`I was just going to say which was, again, a
`
`little bit surprising.
`
`Q. Did you get the gentleman's name by any chance?
`
`A. Yeah. His name was Scott Arnold.
`
`Q. Was anyone else at the booth?
`
`A.
`
`There were other people at the booth, but I don't
`
`recall
`
`the names.
`
`I remember two or three other people
`
`behind the booth.
`
`Q. Did you speak to any of them?
`
`A. No.
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`Q.
`
`So what happened after Mr. Arnold told you that
`
`the screen was just like TT's?
`
`A.
`
`I mean —- again, he said it was the exact same
`
`thing, but he —- he gave me a little demo of it as I
`
`recall, again,
`
`just kind of showing me the same thing
`
`that I had already seen. But that didn't take very
`
`long, because what happened shortly after that is that
`
`I —— I saw somebody that I knew who was on the floor,
`
`somebody who used to work at TT with me, and I walked
`
`over and started to talk to him.
`
`In fact, he gave me a
`
`little bit of a tour of the trading floor.
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`PAGE 1 OF 46
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`Q. And I don't think I've heard.
`
`How did you get
`
`the brochure?
`
`A. Well,
`
`after that tour,
`
`I remember coming back to
`
`the booth and I
`
`remember, again,
`
`Mr. Arnold indicating a
`
`couple things.
`
`One was the price of the product that
`
`was coming out,
`
`the futures product,
`
`as well as he also
`
`showed a cash screen, which was to be used for trading
`
`the cash product that eSpeed provided on their exchange.
`
`Q. Why don't we talk about that, because I
`
`think you
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`16:
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`said a couple things. Let's try to break it up a little
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`bit.
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`You mentioned the price of the futures product.
`
`What did he tell you about the price of the futures
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`product?
`
`A.
`
`He told me that for people who were going to
`
`license the futures trading screen alone that the price
`
`was going to be $300 a month per screen.
`
`But that for
`
`those who would trade both the cash product and the
`
`futures product, it would be free.
`
`Q.
`
`And can you remind us a little bit about the
`
`difference between the cash and the futures product?
`
`A. Yeah.
`
`I mean —— again,
`
`I'm not a trader,
`
`so this
`
`is just my very basic understanding. But basically the
`
`futures product is a derivative of the cash product, or
`
`it's a -— yeah, it's a derivative of the cash product.
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`PAGE 2 OF 46
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`So on eSpeed people would trade actual bonds and
`
`notes, it's my understanding,
`
`treasury bonds and
`
`treasury notes, and then at the Board of Trade some of
`
`the most successful products that they trade are
`
`actually the future contracts of those exact same cash
`
`bonds and notes.
`
`Q. Okay.
`
`So returning to Mr.
`
`Arnold's discussion of
`
`price, it was people who traded cash on the eSpeed
`
`exchange would get a rebate, essentially, of the fee for
`
`10
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`
`trading on the futures side of the coin?
`
`A. Yeah.
`
`I mean, he said it would be free, yeah.
`
`Q.
`
`And the other thing you mentioned was a cash
`
`product.
`
`Can you tell us what you meant by that?
`
`14
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`15
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`16
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`16:
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`14:
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`16:
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`14:
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`16:
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`16:
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`14
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`:52
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`16:
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`14
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`:55
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`16:
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`14
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`:58
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`16:
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`O1
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`16:
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`15:
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`O1
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`16:
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`O6
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`16:
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`15:
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`10
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`A.
`
`The cash product?
`
`Q.
`
`That Mr. Arnold told you about.
`
`A.
`
`Oh, yeah. Yeah,
`
`they didn't have that product up
`
`on a computer screen, but what he showed me was a
`
`printout of the layout of what that product was going to
`
`look like. And he indicated that that was going to be
`
`available within a couple of weeks.
`
`I think he said two
`
`to three weeks.
`
`Q. What did the screen shot look like?
`
`A.
`
`It looked —-
`
`to me it looked identical to the
`
`futures screen that we see here up on the screens.
`
`Q.
`
`And did he tell you anything else that day?
`
`PAGE 21 OF 46
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`
`
`595
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`‘
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`’
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`‘
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`:15:
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`15
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`:15:
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`18
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`:15:
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`22
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`24
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`28
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`30
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`33
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`39
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`39
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`45
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`16:
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`15:
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`45
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`16:
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`16:
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`O3
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`16:
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`16:
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`O7
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`1O
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`11
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`12
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`13
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`14
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`A. Not that I recall, no. But it was at that time
`
`that I picked up a brochure and other things that they
`
`had -~ whatever they had at the booth,
`
`I picked up,
`
`including this brochure.
`
`Q. Was that the —— did you do anything else at the
`
`Board of Trade that day?
`
`A. No,
`
`I think I -*
`
`I think that was it.
`
`MR. CARDEN:
`
`I have no further questions for
`
`Mr. Ryan at this time.
`
`MICHAEL RYAN, CROSS-EXAMINATION
`
`BY MR. ALY:
`
`Q. May it please the Court, good afternoon,
`
`Mr.
`
`Ryan.
`
`My name is Imran Aly.
`
`I represent the espeed
`
`15
`
`16
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`17
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`18
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`19
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`16:
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`16:
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`16:
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`16:
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`O9
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`16:
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`16:
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`12
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`16:
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`16:
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`16
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`16:
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`16:
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`16:
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`21
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`16
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`:16:
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`24
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`16:
`
`16:
`
`27
`
`defendants in this case.
`
`A.
`
`Good afternoon.
`
`Q.
`
`You were describing to the jury a meeting that
`
`you had at the Chicago Board of Trade on August 4th,
`
`2004; is that right?
`
`A.
`
`I mean,
`
`I don't know if —— I wouldn't call it a
`
`meeting, but, yeah,
`
`I was describing when I was there
`
`and what happened, yes.
`
`Q.
`
`And when you went
`
`to the Chicago Board of Trade,
`
`you said that you went
`
`through some security and then
`
`16:
`
`16:
`
`30
`
`25
`
`you saw some trading pits; is that right?
`
`PAGE 2 OF 46
`
`
`
`
`
`
`
`
`
`
`
`TT 029998 TT 029998
`
`
`
`
`
`Un-ri-valed Li-quid-ity
`
`\un rl'va Id ll kwId’r' téi > > > law‘. mm The product ofa partnership between
`a global futures exchange and the leader in electronic trading ol fixed income. 2. Available only
`on espeed.
`
`A combined marketplace cf this size can o'niy bé delivered by the two most established players
`in these markets. Ami It an only he found an espoud.
`
`wuh eSneed'5 trading engines behrnd the lrrawalla cl 1'hE-J world’; iargest firrarrcral rrrstrrutrons and
`CBOT! '5 cnncal mass and dtstubuuon. customers w1lI have access In marker dawn and Irqurdrw
`|rkeIhE!\r‘T‘»auer1-Ever seen Seamless rnregralrun from the C801 back-and tnru r.-Speed's tuntpletelv
`rreuhal markats and uracncal rnterlace ensures customers wr1la1ways trade the best prrces
`
`Risk Man rage-men:
`
`2 2 2- ml 1' Leave less to ctrartce by rradrng rest: and lredgrng.
`In 6 H “U I11 6 n r I
`1 r l 9 it
`yctur przrsrrror-rs wrrlr cash anrrl CBCJT Treasury futures on esneed
`
`Tncla\.r's market volarrlny has made nsk management a ;:rr'o-uy e5;ue=ed‘5 Superfluads delivers a
`unique hedging and rrsli managrng oprxortrrnily that has never been srmpier.
`
`Whether you are a cash trader who makes mar Uccasrunal iulures play, or a iulufflg trader laokmg
`in ccrrtpferrront your p.rJ_Il|0JIU. tradrng eSpeer.| cash and CBOT Treasury futures from CBOT can
`rfrawnsrze your marker ruck whrle upgradrng WJLJI performer.-rm
`
`PAGE 24 OF 46
`
`TT 029999
`
`
`
`
`
`In-no-Va-tive Tech‘-nol-o-gy
`lin '3 vi’ tlv tek noI'a [at > > > (adj. tn.) 1. Powers espaetfs electronic market-
`place to make trading faster, smarter. and more efficient than ever. 2; synonymous with eSpe9d.
`
`the masslve global fixed-
`eSpeefI‘5 rnnavattve nlatiorrrl ls: the preferred sun! at the trade lot
`uncc-me marketplace The wrnxlcls leaclmg tlnanctal lnsmutluns trust us to put more than $200
`hlllaon worth at lhetr |laL'IE.'$- on our platlorm daily lnncl that's |t.l5t a hactiun at what espeed
`ls lnullt
`to handle] Dun clients know our Fully rE:[.|urldaI'll systems have Held up Lmrler the most
`dliilfltlli test arr-agmable
`
`We employ hundreds oi the wctrlrfs best and brightest telzl-lnolngv developers ta allaw you Ill:
`Ifikfi advantage cl espaeds
`
`.- Fully FBUL|l'1dal‘!1 global systems
`.-
`2 It 2 Global prwale network 5 = 1- End-to-and ptocesstng 1-
`. p . lrtlelact-ive matal-ung engines» a I 241-hour
`teclmlcal asarstance : s 2 F’rot:malaw.t3lF’l or
`access lhmllgh Java. \Nrr‘ll1(Iwfi an LININ 5 .
`» Aututnaletl cletltl and malt management
`
`Cost Ef-f1-c1en-cy
`
`lkoot i flnh’on cél >>> tn.) 1. A by-prod'uctoI'CB0lT’s futures trading on espeed.
`
`espeed -defines eifscierlcie-5 and cost sawrags lav ptowdtng -mt: wall mulltseaoncl trade execution
`3|'lf?FI'B'd'1-Tlfl‘lB slralghl through procasslng.
`
`The same efftcrencv ant: reltalntltw luunrl JFI our electmmc marketplaces ate also lourtd in the mldclle
`and back oflice. Our automated management systems support seamless cleartng. settlement.
`tract-:m_g and reporting cl trades. at;-lving'vcIu the tartrlecessaw C0515 cal n-lulttpla vendors
`
`PAGE 25 OF 46
`
`TT 030000
`
`
`
`|srT5’par kw./odz\ >>:
`
`Su-pe1-Quads
`;-
`-I
`‘;
`'-;— -
`
`_.
`
`_-
`
`--
`
`--_-
`
`
`
`|-
`nea=_.s..' execuze uasr. er-4:: "_:?u!€-5
`'.I:3{:
`EL-g>evOi.'aa's aiso :2‘-fers Ba:
`
`"1
`‘ ev to'1.:1.emer:a.r,' sec-.:-at es ‘me
`-1 r 5:: -at as new
`.'/mm-_,1a!'ie.:1:nL_) we (‘.~J\reg'
`.vher=-Assuecfl sway;-5., eff-the-Iuvns a-‘vs chearnast-to-dezwe-I Tabs '0: awtzonai esp-eed pvccucis
`-Ae fcvveugn exchange, ag-3-noes and m‘u_=ves'. rate 5 maps
`a so .1251 a dick ax-'a-4'
`
`‘c,-necliv’
`Zmec: Desi.-mg cum !a1e~;1 Irau-'~'-g er'wa":=.1'r»em. us aiso a«a:iaL::e on Sun:-e.'Ouads Bea:
`one 10 one‘ one to a few av c-vie ‘n'..' ma“, me an e «=,c‘..ro"m: neouest 10: v.
`tern-251 m SEeCIfI’_‘ sea,-rntzes
`aw’ '.'.n-uses r.or=uac1s
`
`PAGE 26 OF 46
`
`TT 030001
`
`
`
`Queue aunts-mm
`mummified—“ma
`
`
`
`
`
`PAGE 27 OF 46PAGE 27 OF 46
`
`
`
`TT 030002TT 030002
`
`
`
`Fm ffiladiable 0/69! Enm Ocmon
`
`PAGE 28 OF 46
`
`TT 030003
`
`
`
`
`
`e -Speed and CBOT
`, , .,
`(compound n) The M/ure has arr/ved, and ar‘s only
`it‘? fipeaed and CEO?!
`on 95/Jeed.
`
`The world's largest cash and iutures marketplace I5 here You are ]us1 a duck away from a 0ne—wav
`llcket 1ha1 wnli take you 1u|| speed «mo the future
`
`Vrsnr www espeed com/futures or emari lu1LIres@espeed com to lnnd oul how you can get the
`best ol both worlds on a srngle platform
`
`If you are currently an eSpeed customer. Contact your espeed Relefcionship
`IV1anager or email 531:-:I'us;:»:.=m:é com to get our latest technclogy retea-ee and to
`sign up for CE-OT futures ‘trading on espeed.
`
`PAGE 29 OF 46
`
`TT 030004
`
`
`
`
`
`
`
`
`
`1-.0...I|n-J.-r‘
`
`3\
`
`....J_-no-.-.1-..-.-.-».4L..........-»-..-..vI«.-.-...—«..._.,......1-
`
`
`
`
`Iuqly-‘i'_ug-‘c-1--n-Iuuonmlvragaulinetlifilfl In Iiflnjw "
`-i
`-- '
`_
`hymn 1H‘co-uh.-Mu!-I-'
`
`'
`
`PAGE 30 OF 46
`
`
`
`
`
`
`
`Exhibit 2Exhibit 2Exhibit 2
`
`
`
`
`
`PAGE 31 OF 46PAGE 31
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