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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
`September 11, 2007
`1:30 o'clock p.m.
`
`VOLUME 2-B
`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:
`
`235
`
`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
`Philadelphia, Pennsylvania
`19103
`215-972-0600
`
`Rosenthal Collins Group, DOWELL BAKER
`LLC, by:
`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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`316
`
`(The witness was sworn by the judge.)
`- - -
`TIMOTHY GEANNOPULOS, DIRECT EXAMINATION
`BY MR. SIGMOND:
`Give us your full name for the record.
`Q.
`Yes.
`My name is Timothy Nicholas Geannopulos.
`A.
`And where do you live?
`Q.
`I live in Chicago, Illinois.
`A.
`And where do you work?
`Q.
`I work at Trading Technologies International.
`A.
`We're known as TT in the industry.
`So if I use TT today -- I'm sure the jury's
`Q.
`already heard it -- but if I use it, you'll know what
`I'm talking about?
`Yes, I will.
`A.
`How long have you been with TT?
`Okay.
`Q.
`I've been with TT since 2000 full time, and then
`A.
`I worked at TT part time for a couple years prior.
`And what's your current position with TT?
`Q.
`Today I'm Executive Vice President of global
`A.
`sales for TT.
`And where is TT located?
`Q.
`TT's headquarters are in downtown Chicago, and
`A.
`then we have branch offices in New York, Houston,
`London, Frankfurt, Geneva, Switzerland, Moscow, Sydney,
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`317
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`Singapore, Tokyo, and Hong Kong.
`Wow.
`Q.
`How many employees in Chicago?
`We have approximately 440 employees in Chicago.
`A.
`And how many worldwide?
`Q.
`Worldwide over 500.
`A.
`Okay.
`Before we start talking about TT,
`Q.
`Mr. Geannopulos, I was wondering if we could get some of
`your background.
`So could you tell us about your
`education?
`Yes.
`I have a degree in political science at
`A.
`Principia College, which is in Elsah, Illinois and I
`have a law degree at Northwestern University, which is
`located here in Chicago.
`What year did you get your law degree?
`Q.
`I graduated in 1989.
`A.
`Okay.
`And are you still a lawyer today?
`Q.
`No, I'm not.
`A.
`Following law school what was your first job?
`Q.
`My first job out of law school is I went to work
`A.
`at a big law firm in Chicago.
`And what type of law were you practicing?
`Q.
`I practiced tax law, business transactional,
`A.
`corporate transactional law.
`Were you a courtroom lawyer, like a courtroom
`Q.
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`like today?
`No, I was not.
`A.
`And what type of clients did you work for back
`Q.
`then?
`I worked for various trading shops that are based
`A.
`here in Chicago.
`I worked for some software companies,
`and I also worked for various financial institutions.
`And how long did you practice law?
`Q.
`I practiced approximately eleven years.
`A.
`Okay.
`And how did you first learn about TT?
`Q.
`TT was a client of mine when I was a lawyer, and
`A.
`that's how I first got introduced to TT and the various
`people at TT.
`When was that?
`Q.
`That was back in 1987 -- excuse me -- 1997.
`A.
`And back then how many people were at TT, do you
`Q.
`remember?
`Approximately ten to 20 people at TT at that
`A.
`point.
`Q.
`them?
`Corporate work, labor, negotiating agreements for
`A.
`them, all kinds of overall corporate legal stuff.
`Now, I think you mentioned that at some time you
`Q.
`started working for TT part time, correct?
`
`And what kind of legal work were you doing for
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`319
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`Yes.
`A.
`When was that?
`Q.
`That was approximately in 1998 and 1999 to 2000.
`A.
`I was working part time, kind of as a part-time legal
`counsel for TT.
`So kind of an in-house lawyer; is that right?
`Q.
`Exactly.
`A.
`And how did it -- you know, why did you start
`Q.
`working as a part-time general counsel for TT?
`Because at that point TT's business was growing
`A.
`and they needed more hands-on legal help, so they wanted
`me to be there at least part time helping out with some
`of the matters that would come up.
`Now, in this 1998 time frame when you
`Okay.
`Q.
`began working part-time, what was the business of TT
`back then?
`The business of TT was actually divided into two
`A.
`separate businesses.
`The first was selling a product.
`The second business -- and obviously the product was a
`software product.
`The second business was providing
`consulting services on a one-office basis for various
`clients.
`And what was the product back then?
`Q.
`The product was what's referred to as X_Trader,
`A.
`which is a futures trading screen.
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`320
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`Now, this other business, the consulting
`Q.
`business, tell me how did -- you know, what kind of work
`did TT do for clients?
`Well, TT did all kinds of one-office consulting
`A.
`projects for clients that -- especially clients that did
`not have any developers working for them in their own
`shop.
`So what they would do is hire TT's developers on
`an hourly basis to go ahead and develop various projects
`for them.
`Then they could part and would not be involved in
`All they would do is
`any kind of selling the products.
`go ahead and develop and work on projects for their
`various clients.
`Now, as part-time general counsel, did you have
`Q.
`any involvement in these two business units of TT?
`Yes.
`What I would do is I would negotiate
`A.
`software license agreements for the product company, and
`that would include things like support provisions,
`And then on
`update provisions, license fees, et cetera.
`the consulting side I would negotiate consultant
`agreements, which would get into hourly rates and issues
`like that.
`Did you do all of the agreements at that time?
`Q.
`No, I did not.
`A.
`And why were there two different kinds of
`Okay.
`Q.
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`321
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`The
`
`agreements?
`They had two different kinds of agreements
`A.
`because they had two different types of businesses.
`first business was licensing software.
`The other
`business was, once again, providing consulting work,
`which entailed being paid for on an hourly basis to do
`various projects for our client.
`Now, at some point, Mr. Geannopulos, you went to
`Q.
`work full time for TT, correct?
`Yes, I did.
`A.
`And when was that?
`Q.
`It was October 2000.
`A.
`What was your first position with TT as a
`Q.
`full-time employee?
`My first position was Executive Vice President of
`A.
`Business Development.
`Now, were you a lawyer at that point for TT?
`Q.
`No, I wasn't.
`A.
`And why did you leave the practice of law?
`Q.
`I left the practice of law and chose to work
`A.
`full-time at TT because I felt like TT was a company
`that was at the right place at the right time.
`It was pretty clear that the exchanges would be
`closing or phasing out their trading pits and would be
`going to more electronic.
`And so I thought TT and its
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`software business, which provides futures trading
`screens, was an ideal fit and it seemed all this was
`happening right at the point I was making that decision.
`Another factor in my decision was two of the
`people at TT -- or not at TT, but one person at TT, one
`person who was an investor in TT, Gary Kemp, was the CEO
`And I thought he had a lot
`at the time and the founder.
`of knowledge about the business and he had a lot of
`charisma.
`Harris Brumfield at that time was an investor,
`and I thought Harris was a proven winner.
`He was a
`And I also
`successful trader.
`He was a proven winner.
`was very interested and intrigued by an invention that
`he worked on, that was MD Trader.
`And at the time that
`I came on right then, MD Trader was assigned by Harris
`over to TT.
`And I thought that would have a good
`possibility of taking the industry by storm.
`Now, Mr. Geannopulos, you said -- let's take it
`Q.
`one by one.
`Gary Kemp, who is Gary Kemp?
`Gary Kemp was the CEO of TT when I came on in
`A.
`2000.
`And Harris Brumfield, tell us who that was.
`Q.
`Harris Brumfield was, No. 1, a customer of TT,
`A.
`but this was dating back to, I think, '97, '98.
`Secondly, Harris was an investor at the time that I came
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`on, and he wasn't an employee, but he was an investor,
`and he was an active investor, someone who was
`constantly in touch with Gary Kemp.
`Now, Mr. Geannopulos, let's talk a little bit
`Q.
`about your responsibilities as Executive Vice President
`of Business Development.
`What did you do in that job?
`I negotiated with various exchanges.
`I negotiate
`A.
`with various third-party participants in the futures
`industry, and I also negotiate strategic deals with
`banks who wanted to do business with TT.
`And what was your next position at TT?
`Q.
`My next position was Executive Vice President of
`A.
`Global Sales.
`And when did that occur?
`Q.
`That happened first quarter of 2002.
`A.
`Okay.
`And that's your -- the job you have today,
`Q.
`right?
`Yes, it is.
`A.
`And what are your responsibilities in that job?
`Q.
`My responsibilities are basically to manage
`A.
`global sales for TT and also to manage the various sales
`offices in the cities that I mentioned previously.
`Okay.
`Mr. Geannopulos, I want -- I want to talk
`Q.
`a little bit about the history of TT and its formation.
`You mentioned Gary Kemp.
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`Could you tell us a little bit about the
`formation of TT?
`Yes.
`Gary Kemp started TT back in 1994 and he
`A.
`started in Frankfurt, Germany.
`And why then and why there?
`Q.
`He --
`A.
`
`MR. ROSEN:
`
`Objection, your Honor,
`
`foundation.
`
`case.
`
`THE COURT:
`MR. ROSEN:
`
`I think he can testify to that.
`Mr. Kemp's a witness in the
`
`He's been at the company as
`
`He's certainly's intimately
`THE COURT:
`involved with the company.
`MR. SIGMOND:
`long as anyone.
`Go ahead.
`THE COURT:
`Gary Kemp started TT in
`THE WITNESS:
`Frankfurt because at the time he started the German
`exchange, EUREX was going electronic or starting its
`And Gary Kemp was there to work
`electronic exchange.
`with the exchange and also to start TT and the whole
`process of futures trading with the EUREX.
`BY MR. SIGMOND:
`And why did -- what was the reason for Gary Kemp,
`Q.
`if you know, forming TT?
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`345
`
`was using the word dominate, TT was a small little
`company that was just really making a little bit of
`traction into the ISV space.
`It was -- if I were to characterize dominate, I
`think it was much more a hope someday that we become
`something special versus us actually dominating at the
`We were losing quite a bit of money at the time
`time.
`that he was using -- that he sent this e-mail.
`Now, did Mr. Brumfield have any input into the
`Q.
`creation of this job?
`Yes, he did.
`A.
`And could you tell us about that?
`Q.
`Yeah.
`Harris had known Mike Burns from the
`A.
`trading floor.
`Harris knew that Mike Burns was someone
`who was very excited about his MD Trader idea.
`And so
`Harris thought that Mike Burns, with his charisma, with
`the fact that he was a trader in the past, and with his
`knowledge of the MD Trader product and his benefit and
`his buy into the MD Trader product, Harris believed that
`Mike would be the perfect person to have in this
`position.
`Now, fast-forwarding a little, Mr. Geannopulos.
`Q.
`Did the attitude towards MD Trader within Trading
`Technologies change at all?
`Yes, very much.
`As I said, at first there was a
`A.
`
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`346
`
`little bit of skepticism even among the sales people.
`But as the MD Trader product started really taking off
`and sales started coming in, sales people -- being
`traditional sales people -- liked the idea, liked
`selling the product, and the sales people started
`reaping the rewards of an explosive growth in both
`revenues and screen sales.
`Did MD Trader become a success?
`Q.
`MD Trader became a massive success for TT and, in
`A.
`fact, it would have become a bigger success if TT's
`competitors didn't copy it.
`But it was amazing success
`for TT just in terms of overall new growth and screen
`growth alone.
`And what features --
`Q.
`MR. ROSEN:
`Your Honor, move to strike the
`remark about the competitors copying it.
`THE COURT:
`I will strike that.
`MR. SIGMOND:
`I'd like to use PTX 782.
`not sure if there's an objection to that or not.
`put it up yet, because ...
`MR. ROSEN:
`No objection, your Honor.
`MR. SIGMOND:
`Can I have it admitted into
`evidence, your Honor?
`THE COURT:
`
`Then it will be admitted 1992
`
`I'm
`Don't
`
`and 782.
`
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`347
`
`MR. SIGMOND:
`
`And could I publish it to the
`
`jury?
`
`THE COURT:
`MR. SIGMOND:
`BY MR. SIGMOND:
`Mr. Geannopulos, do you know what this document
`Q.
`
`You may.
`Can we see 782?
`
`is?
`
`When was the launch of
`
`This is a document that tracks TT's global
`Yes.
`A.
`revenue from 1996 to 2006.
`Remind me now.
`Okay.
`Q.
`MD Trader?
`The launch of MD Trader was in August -- the end
`A.
`of August 2000.
`Okay.
`Now, this thing has a lot of numbers on
`Q.
`it, so help me through it, Mr. Geannopulos.
`What -- can you tell me what the number of
`screens and revenues were for the month of August 2000,
`the month that MD Trader was launched?
`And if you could
`tell us where to look in this document, we'll try to
`blow it up for the jury.
`Yes.
`I think you have to flip the page from the
`A.
`TT global revenue, and then you have to go to the next
`page, and there's a bunch of dates on the other page.
`If you look at August of 2000 -- is that what you
`wanted, August 2000?
`
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`Page 14 of 14
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`TRADING TECH EXHIBIT 2222
`IBG et al. v. TRADING TECH. - CBM2016-00054
`
`

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