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`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`TRADING TECHNOLOGIES INTERNATIONAL,)
`INC.,
`
`))
`
`))
`
`Plaintiff,
`
`)
`v.
`)
`eSPEED, INC., eSPEED INTERNATIONAL,)
`LTD., ECCO LLC, and ECCOWARE, LTD.,)
`)
`Defendants.
`)
`
`No. 04 C 5312
`
`Chicago, Illinois
`October 1, 2007
`1:45 o'clock p.m.
`
`14-B
`VOLUME
`TRIAL TRANSCRIPT OF PROCEEDINGS
`BEFORE THE HONORABLE JAMES B. MORAN, and a JURY
`
`APPEARANCES:
`Trading Technologies
`International, Inc., by:
`
`and
`
`TRADING TECHNOLOGIES
`INTERNATIONAL, INC.,
`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
`MS. JENNIFER M. KURCZ
`MR. MATTHEW J. SAMPSON
`MR. LEIF R. SIGMOND
`300 South Wacker Drive
`Chicago, Illinois 60606
`312-913-0001
`berghoff@mbhb.com
`kurcz@mbhb.com
`
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`eSpeed, Inc., eSpeed
`International, Inc.,
`Ecco LLC, Eccoware,
`LTD., by:
`
`Rosenthal Collins Group,
`LLC, by:
`
`3003
`
`WINSTON & STRAWN
`MR. GEORGE C. LOMBARDI
`MR. RAYMOND C. PERKINS
`MR. IMRON T. ALY
`MR. KEVIN BANASIK
`MS. ELIZABETH HARTFORD ERICKSON
`MR. ANDREW M. JOHNSTONE
`MS. TRACEY J. ALLEN
`MR. JAMES M. HILMERT
`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
`19103
`Philadelphia, Pennsylvania
`215-972-0600
`
`DOWELL BAKER
`MR. GEOFFREY A. BAKER
`201 Main Street
`Lafayette, IN 47901
`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
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`3021
`
`Mr. Perkins' testimony.
`THE COURT:
`MR. SAMPSON:
`the examination.
`THE COURT:
`
`about.
`
`It is --
`And it's outside the scope of
`
`It's not something he knows
`
`Thank you, your Honor.
`
`MR. SAMPSON:
`BY MR. PERKINS:
`And you don't know if the Trade Pad was shown at
`Q.
`that LIFFE ISV showcase?
`There's no electronic evidence that I have in my
`A.
`possession from the defendants that shows that.
`MR. PERKINS:
`No further questions.
`THE COURT:
`Thank you, sir.
`THE WITNESS:
`Thank you, your Honor.
`(Witness leaves the stand.)
`MS. KURCZ:
`Thank you.
`TT now calls as its
`Mr. Feltes was a CEO of
`next witness David Feltes.
`Marquette Partners, an international proprietary trading
`firm of futures traders.
`Mr. Feltes will describe his reaction upon
`first seeing the MD Trader product in 2000 and the
`reaction of traders also at Marquette in that time frame
`and thereafter.
`(Whereupon the videotape is played:)
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`3022
`
`After your graduation from Washington University,
`Q.
`can you just tell me a little bit about your work
`history?
`Sure.
`I worked on the family farm for a while in
`A.
`West Chicago, Illinois, and then in July of 1994 began
`working for MJM Trading, which was associated with
`Marquette Partners.
`I did -- I clerked on the floor and
`then did system trading and programming upstairs
`concurrently.
`In 1995, I began working half my time and half my
`salary was paid for by Marquette Partners in doing -- in
`working with their traders and their IT staff, basically
`doing trader support, as well as trading off the floor
`systems for them.
`In 1996, I went full-time with Marquette in
`Marquette Electronic Brokerage, which was a brokerage
`unit that they had formed.
`At that point I did the IT as well as brokering
`and clearing in the back office, as well as continuing
`doing trader support for Marquette, the main company.
`In 1998, I began doing IT full-time for
`Marquette.
`In September of '98, I came to Europe, to their
`Frankfurt offices, their Paris offices, and their London
`offices for about eight weeks.
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`3023
`
`And then it was decided that I would become
`general manager in IT for Marquette London in the
`consolidated offices in February of '99.
`So from
`February of '99 until 2000, I was the general manager.
`Late 2000 I became the managing director in
`charge of IT for London as well as the management of
`London, as well as some other global responsibilities.
`I remained in that role going back and forth to
`Chicago, as well as to Asia, for business development,
`ISVs, and macro business for Marquette.
`In April of 2006, I was named CEO of Marquette
`Partners, and that's my current role today.
`Thank you.
`Q.
`Can you just tell me, briefly, over the period of
`your work experience, what kind of experience, if any,
`you had with trading?
`I was a pit clerk for a top bond trader in the
`A.
`U.S. Treasury bonds.
`And then off the floor we would do
`system trading, which is essentially designing systems
`that would then -- on trade station software --
`writing -- coming up with the idea, writing the code,
`and then when that system would activate, we would then
`get on the phone and either phone to the floor or a
`broker, so basically phone trading.
`There were other discretionary trading that was
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`3024
`
`done on behalf of my bosses, with them making the
`decision, but I would be the one who would actually fill
`those orders.
`In my time with Marquette electronic brokerage, I
`would take clients' phone calls and trade on either the
`And I have
`Eurex front end or any software that we had.
`been -- I'm responsible in my risk management duties to
`exit trades when either an individual system goes down
`or if an office goes down.
`Tell me a little bit about Marquette Partners.
`Q.
`What is the business of Marquette Partners?
`Marquette Partners is a proprietary trading firm
`A.
`We do not
`based in Chicago with now a London office.
`trade client money.
`We are primarily electronic
`traders, although our business model has been arbitrage
`between Bund and the LIFFE floor, and on the Eurex
`machine.
`We're members of twelve to thirteen exchanges
`worldwide.
`We have multiple entities.
`There's a Hong
`Kong entity, an energy entity, et cetera.
`Essentially, we have, I think, probably about 60
`people now.
`So we have fluctuated in size over the
`years, but it's a limited partnership based in Chicago.
`And do the traders employed by Marquette, are
`Q.
`they on the floor of an exchange or do they trade
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`3025
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`primarily electronically?
`We're a proprietary
`They trade electronic.
`A.
`trading firm, not necessarily an arcade.
`All the
`traders are sole -- are employees of the firm, so
`there's no independent contractors or whatever.
`I'm just curious whether traders, end users of
`Q.
`the software products, have any role in the
`functionality that's involved in the product.
`Yes, frequently -- and using the word liaison --
`A.
`I would bring in the ISV rep and have them work with the
`various traders and have them sit down, watch them
`And then we
`trade, and they would give suggestions.
`would -- I would be responsible for helping follow up on
`those suggestions to get those ideas either in further
`releases or to tell traders that what they wanted is not
`possible in the current situation.
`And what ISVs has Marquette used since you became
`Q.
`involved in the software selection for electronic
`trading?
`GL, Ecco, Trading Technologies, a limited amount
`A.
`We have traded on
`of Orc, Patsystems, RTS, FfastFill.
`the eSpeed front end, among others.
`Which of the software vendors employ people that
`Q.
`you would consider to be friends?
`TT, PATS, Ecco, collegial with the GL folks, RTS,
`A.
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`3026
`
`FfastFill.
`Mr. Feltes, do you recognize that document?
`Q.
`I do.
`A.
`What is it?
`Q.
`This is a declaration that I wrote stating my
`A.
`story regarding the first time I found MD Trader and my
`experiences with MD Trader, among other things.
`If you turn to the second page of that document,
`Q.
`is that your signature at the bottom of the second page?
`That is my signature.
`A.
`And do you recognize this to be a true and
`Q.
`accurate copy of your declaration, excluding the legends
`that -- you know, the footers at the bottom of the
`pages?
`A.
`Q.
`exist?
`I was contacted by someone from TT London to ask
`A.
`if I would tell my story about how I first ran into
`MD Trader.
`In terms of Mr. MacDonnell asking you to prepare
`Q.
`a document like this, why did you do it?
`I have friendly relations with a lot of vendors
`A.
`and good -- and I'm -- as liaison, I try to stay on good
`And I didn't
`terms with the various vendors.
`
`Yes.
`How did this -- how did this document come to
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`3027
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`necessarily see a problem with telling the truth.
`Did you receive any compensation or promise of
`Q.
`any benefit, anything of value, for signing the
`declaration?
`No.
`A.
`Were you threatened -- on the other hand, were
`Q.
`you threatened or pressured in any way to sign the
`declaration?
`Not at all.
`I was told I didn't have to do it.
`A.
`I was just asked if I wanted to do it, and so I did.
`Could you review that for us a little more
`Q.
`carefully, and let me know if you believe it's still
`accurate, the contents of that document, today.
`Do you recall the first time that you saw
`MD Trader?
`I do.
`A.
`And let me take a step back from that, actually.
`Q.
`What is MD Trader?
`MD Trader is a Trading Technologies product that
`A.
`allows a scalping trader, or any trader, access to the
`markets in a very efficient way.
`And can you just generally describe the
`Q.
`interface?
`It's a vertical ladder that has, you know,
`Sure.
`A.
`prices, bids on the -- you can customize it in any way,
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`3028
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`but the bids are in blue, offers are in the red, and
`there's boxes and there's single clicking to put your
`orders in.
`There's a ladder with the various prices.
`That ladder is static, meaning that it doesn't
`move, and so when the bids move up and the offers move
`up, you can visually see the exchange in the -- not only
`in the numbers, but also visually you can see bullish or
`bearish movement in a market.
`When did you first see MD Trader?
`Q.
`I believe it was fourth quarter of 2000.
`A.
`Do you remember the circumstances?
`Q.
`Robbie MacDonnell, who was, I believe, sales --
`A.
`in sales at the time that TT London called me up and
`said, I've got some new software, can you come on by?
`So that afternoon, I went by his office and he
`He was very excited about it,
`showed me the product.
`explained to me what the product was about; and that was
`the first time I saw it.
`What was your initial impression on seeing
`Q.
`MD Trader?
`Robbie was very excited, and he's a very good
`A.
`salesperson and I was excited as well.
`I came back to
`the office that afternoon, and I think I had some
`documents or pictures, and I showed them to my traders.
`And not only with Robbie's enthusiasm, but with
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`3029
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`the potential for single click and visualization, I was
`excited.
`What trading screens were you familiar with
`Q.
`before you saw MD Trader?
`GL, Ecco, TT in its previous form, market grid,
`A.
`if you will; I had seen an Orc screen; I had seen
`exchange-native front ends, such as Eurex, and I had
`seen some other ones, but I was not overly familiar, per
`se.
`
`I guess, my question is:
`
`If you look at your declaration, the third
`Q.
`sentence of paragraph 4.
`Could you read that for me?
`MD Trader also provided for fast one-click-order
`A.
`entry that was accurate and in that the trader could be
`confident that the order was going in at the intended
`price.
`Q.
`what?
`In exchange of the price being 66 bid at 67.
`A.
`Again, I can -- I had a guarantee that if I wanted to
`buy 67s, that I would get 67s.
`There wasn't the chance
`that the column next could change and I would be being
`filled on a worse price.
`So the fact that you could visually see the
`market -- the fact that you had a one-click limit bid
`and you could see your working order right there, gave
`
`Fast as compared to
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
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`3030
`
`more -- gave traders more assurance of what price they
`were attempting and/or getting.
`More assurance compared to what, the prior
`Q.
`screens?
`Some of the prior screens, yes.
`A.
`And the first time that you saw MD Trader, had
`Q.
`you seen the features of static prices and single-click
`order entry in a single order product?
`No.
`A.
`I'm just curious if it struck you as unusual that
`Q.
`TT was showing you a product that was so different from
`what you were aware of?
`While I had seen new
`Yes, it was different.
`A.
`versions of multiple ISV softwares and new versions of
`TT software, this seemed to be a new paradigm or a
`change that we hadn't requested, but it seemed different
`than previous systems that we had seen.
`Were you, at Marquette, motivated to improve the
`Q.
`trading screens that you had?
`Without a doubt.
`A.
`And what efforts did you take at Marquette to try
`Q.
`to improve the trading screens?
`Not only having -- not only with me as the
`A.
`liaison between the various different reps, our Chicago
`ISV reps, as well as our London ISV reps, of -- having
`
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

`

`3031
`
`them interact with the various traders, interact with
`the management.
`We
`We also would regularly -- not regularly.
`would solicit various different ideas for improvements
`or what we call edge, which is opportunity to create
`profits in the markets.
`We also polled our traders and, you know, asked
`them for any discussion suggestions that they may have
`in order to help us -- you know, help us get better
`access to the markets.
`Is that polling of your traders, is that what you
`Q.
`referred to here in paragraph 8 of your declaration that
`we just marked as Exhibit 1?
`Yes.
`A.
`And so tell me a little bit about the results of
`Q.
`the poll.
`The traders -- we asked the traders to come up
`A.
`with various ideas that they had, in terms of what would
`make the better product, what would be more efficient,
`to visually draw a new display or basically come up
`with, you know, your ideal system.
`And I would -- they -- I would say they had some
`marginal suggestions, changes, but we -- I did receive
`from both Chicago and London traders ideas and
`suggestions on ways to improve the software that we used
`
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`Page 13 of 17
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

`

`3034
`
`immediately on what the price action was, could click to
`try to get it and end up being filled at a worse price.
`I don't want to confuse you by jumping around.
`Q.
`But I'm going to jump back to paragraph 5 and --
`actually, paragraph 4.
`There's a sentence, and we've talked a little bit
`MD Trader also provided
`about it already, that says:
`for a fast one-click-order entry that was accurate and
`that the trader could be confident in the order going in
`at the intended price.
`Where does the confidence come from?
`The fact that you can see, you know, the grid box
`A.
`that you're clicking in.
`You know what -- you know what
`price you're going to get, because it's the -- it is
`horizontal to a static price.
`And does that have any effect on traders'
`Q.
`confidence?
`Because they would -- they know what
`Yes.
`A.
`price -- they have more control over what price they're
`trading at, as opposed to an unknown fill.
`Why, if at all, is confidence important to a
`Q.
`trader?
`Confidence is, in my opinion, the name of the
`A.
`game in trading and that basically traders learn the
`markets, develop confidence.
`That confidence then gives
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`14:36:56
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`14:37:01
`
`14:37:04
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`14:37:05
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`14:37:07
`
`14:37:09
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`Page 14 of 17
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

`

`3035
`
`them extra edge and success.
`And if they don't -- and
`they can lose their confidence very, very quickly.
`So a trader cannot only have a losing day because
`they made the wrong decisions outside of software, but
`because of exchanges going down or because of, you know,
`getting bad fills.
`Anything can damage the trader's
`confidence.
`And it's -- my job is to try to minimize that
`happening.
`In your experience, do confident traders trade
`Q.
`more?
`Yes, sometimes too much.
`A.
`After you first saw the MD Trader screen at TT's
`Q.
`offices, did you bring it in-house to Marquette, the
`product, the MD Trader product?
`Yes.
`A.
`So tell me about that.
`What was the initial
`Q.
`reaction to MD Trader at Marquette?
`Traders were initially skeptical, because
`A.
`profitable traders are hesitant towards change, because
`change can alter confidence.
`And if you're successfully making money, they're
`skeptical that -- that they would be able to make more
`money elsewhere -- with additional functionality.
`So when I first came back and described
`
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`14:38:10
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`14:38:53
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`14:38:58
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`14:39:12
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`Page 15 of 17
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

`

`3036
`
`MD Trader, after initially seeing it, to several of the
`traders, it was interesting.
`Some traders who were debt
`traders thought this would be very good for equity
`markets.
`And equity traders thought it would be very
`good for debt markets.
`But, initially, people were skeptical because
`they don't -- traders don't like change.
`But,
`gradually, over the course of the next six to -- six
`months to a year, more and more traders moved, because
`it took one trader experimenting, finding very good
`success, and then once success is proven, other traders
`will move over.
`So there was a fairly quick takeup on the new
`We still have one
`MD Trader after initial skepticism.
`trader who held out and liked the market grid, because
`their style and stubbornness were, they felt, more
`conducive to the market grid.
`You mentioned kind of an aversion to change among
`Q.
`traders.
`Was the MD Trader-style screen immediately
`recognized as a change?
`Yes.
`A.
`Let me rephrase it.
`Q.
`Are there any negatives associated with the
`MD Trader-style screen?
`
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`Page 16 of 17
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

`

`3037
`
`I've alluded to
`
`Yes, I think that there are.
`A.
`some in my statement.
`If the market moves very, very quickly and a
`trader does not recenter, and even if they do recenter
`very quickly, it is difficult to sort of chase the
`market.
`So on very, very volatile screens, it's
`difficult to chase.
`Initially, I think the first version of MD Trader
`did not have a condense functionality, which condenses
`market prices.
`And so if the market moved upward very,
`very quickly, you would have to be centering and trying
`to bid or, you know, if it moved down quickly, centering
`And if the market got very wide,
`trying to offer.
`because generally people would have the ladder being 20
`to 25 prices vertically high, if the market got to be
`too wide, you would not be able to see the bid and the
`ask.
`Are there any other negatives with that screen
`Q.
`that you can recall?
`I think that some traders felt that it wasn't an
`A.
`At the time we had
`efficient use of screen real estate.
`to add a lot more dual screen monitors, because a lot of
`people liked the MD Trader, but they would have multiple
`markets up in a grid where you can see multiple products
`that you weren't necessarily trading.
`You can have that
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`Page 17 of 17
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`TRADING TECH EXHIBIT 2220
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

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