throbber
UNITED STATES DISTRICT COURT
`NOR~DISTMCTOFaLfflOIS
`EASTERN DMSION
`
`Trading Technologies futernational, Inc.,
`
`Plaintiff,
`
`v.
`
`Goldenberg, Hehmeyer & Co.,
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`
`)
`)
`)
`)
`
`Civil Action No. 04 C 6278
`
`Judge Blanche M. Manning
`
`Magistrate Martin C. Ashman
`
`CONSENT JUDGMENT
`
`As a result of settlement of this action by virtue of a settlement agreement
`
`between the parties dated September 29, 2004 which shall become effective upon entry of
`
`this Consent Judgment and upon consent of Plaintiff, Trading Technologies International,
`
`Inc. ("TT') AND Defendant, Goldenberg Hehmeyer & Co. ("GH"), judgment is hereby
`
`entered against GH upon IT's Complaint, and it is hereby ORDERED, ADJUDGED,
`
`and DECREED that:
`
`1.
`
`TT commenced this action for patent infringement against GH on September 28,
`
`2004, alleging that GH infringes U.S. Patent Nos. 6,766,304 ("'304 patent") and
`
`6,772,132 ('"132 patent"). GH has received and reviewed a copy of the Complaint filed
`
`by TT in this action.
`
`.··
`
`1
`
`TT 030247
`
`TTX00030247
`
`Page 1 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`2.
`
`This Court has jurisdiction over the parties to this action and over the subject
`
`matter of the Complaint.
`
`3.
`
`TT is the sole and exclusive owner of the '304 patent and the '132 patent, and has
`
`the right to sue upon, and recover damages for past infringement and enjoin future
`
`infringement of the '304 and '132 patents.
`
`4.
`
`5.
`
`All claims of the '304 and '132 patents are valid and enforceable.
`
`GH has directly infringed the '304 and '132 patents by making and using
`
`electronic trading software currently referred to as "GH Trader," screenshots included in
`
`Exhibit A.
`
`6.
`
`Defendant GH, its officers, directors, partners, affiliates, subsidiaries, assigns, and
`
`successors-in-interest are hereby permanently enjoined during the terms of the '304 and
`
`'132 patents from the making, using, selling, offering for sale, importing and otherwise
`
`distributing in the United States the electronic trading software products referred to in
`
`paragraph 5 above.
`
`7.
`
`Any claims of infringement that TT has against GH based on GH's use and/or
`
`distribution of electronic trading software provided by Patsysterns, CQG, Rolfe & Nolan
`
`and Strategy Runner prior to entry of this judgment are dismissed without prejudice. The
`
`parties have addressed this issue in the Settlement Agreement by 'IT granting to GH a
`
`limited covenant not to sue. TT is not waiving any rights to assert the '304 and '132
`
`patents against GH based on GH's use and/or distribution of such third party software in
`
`the future if the limited covenant not to sue is terminated. GH is not waiving any rights
`
`2
`
`TT 030248
`
`TTX00030248
`
`Page 2 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`to assert that such third party software does not infringe the '304 and '132 patents if the
`
`limited covenant not to sue is terminated.
`
`8.
`
`IT waives its rights to damages from GH arising from the manufacture, use, sale
`
`or offers to sell the electronic trading software products referred to in paragraph 5 above
`
`prior to entry of this Judgment.
`
`9.
`
`Notwithstanding the terms of this Consent Judgment, GH expressly reserves the
`
`right to contest infringement if the GH software is modified so as to not infringe the
`
`patents-in-suit. In the event that GH contests infringement based on GH software that is
`
`modified, IT reserves the right to assert any and all claims against GH including without
`
`limitation a claim of contempt of court based on a violation of this Consent Judgment in
`
`the event that the Court finds there is no colorable difference between the modified GH
`
`software and the software that is the subject of this Consent Judgment.
`
`10.
`
`This Court shall retain jurisdiction over this case for purposes of enforcing the
`
`Consent Judgment and the Settlement Agreement between the parties pursuant to which
`
`the Consent Judgment is filed.
`
`ll. Each party shall bear its own costs and attorneys' fees.
`
`SO ORDERED
`
`Dated: ~}y I
`
`.
`
`1Jwk)/l.~
`. - - .
`.. ..
`Blanche:M.:ManiHA%--·, --~.:.· ..•. ·
`United States District Court Judge
`
`3
`
`TT 030249
`
`TTX00030249
`
`Page 3 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`AGREED TO:
`
`Dated: jb-~ ZCI:J(
`
`Paul H. Berghoff (ID No. 6180462)
`LeifR. Sigmond, Jr. (ID No. 6204980)
`Matthew J. Sampson (ID No. 6207606)
`McDonnell Boehnen Hulbert
`& Berghoff LLP
`300 South Wacker Drive
`Chicago, IL 60606
`Tel.: (312) 913-0001
`Fax: (312) 913-0002
`
`Attorneys for Plaintiff
`TRADING TECHNOLOGIES
`INTERNATIONAL, INC.
`
`Suite 3700
`Chicago, illinois 60606-1698
`Tel.: 312.569.1000
`Fax: 312.569.3000
`
`Attorneys for Defendant
`GOLDENBERG HEHMEYER & CO.
`
`TT 030250
`
`4
`
`TTX00030250
`
`Page 4 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`Working
`
`Bid
`
`Position
`0
`
`Change
`111_065
`
`153084
`Volume
`
`High
`
`Low
`
`1
`
`10
`
`0/1
`
`0/1
`
`121 ...
`
`1
`
`2
`1090
`600
`500
`
`389 ...
`
`TT 030251
`
`TTX00030251
`
`Page 5 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`. ~· .. . ···- -
`
`10
`
`7
`
`. ~
`
`..
`
`52_19+
`52 192
`-
`52_19
`52_186
`52 18+
`-
`52 182
`52_18
`
`52_ 17+
`
`52 172
`.. - .
`52_ 17
`52 166
`-
`52_ 16+
`52 162
`52_16
`
`1 • • . . • •
`
`52_15+
`52_152
`52_ 15
`
`..
`
`I
`
`j EXHIBIT
`f -A3
`
`... <
`
`TT 030252
`
`TTX00030252
`
`Page 6 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`Minu~ 0tdtt Form (06197) Case 1 :04-cv-067 40 Document 4 Filed 10/21/2004 Page 1 of 6
`United States District Court, Northern District oflllinois
`
`N•= of Assigned Judge
`or Maelltrnle Judee
`
`CASE NUMBER
`
`CASE
`TITLE
`
`MOTION:
`
`Suzanne B. Conlon
`
`Sitting Jud&e If Olhcr
`lhan Assigned Judge
`
`04 C6740
`--
`TRADING TECHNOWGIES INTL vs. KINGSTREE TRADING
`
`10/21/2004
`
`DATE
`
`[In tl1e followma bcx (a) ind1cnte the party filing the motion, c g., plaintiff, defendant, Jrd party plninliff, and (b) slatebriclly lhellllture
`oflhc motion being presented J
`
`DOCKET ENTRY:
`.------------··-·--------------·---------.
`0
`(I)
`Filed motion of[ usc listing in "Motion" box above.]
`
`{2)
`
`(3)
`
`(4)
`
`(5)
`
`(6)
`
`(7)
`
`(8)
`
`(9)
`
`0
`
`0
`
`0
`
`0
`
`0
`
`0
`
`0
`
`0
`
`Brief in support of motion due ___ .
`
`Answer brief to motion due __ . Reply to answer brief due ___ .
`
`Ruling/Hearing on--· set for ___ at _ _ .
`
`Status hearing[held/continucd to] [set for/re-set for] on ___ set for ___ nt ___ .
`
`Pretrial confcrence[heldlcontinued to] [set for/re-set for] on ___ set for ___ at __ .
`
`Trial[ set for/re-set for) on ___ at _ _ .
`
`[Bcncb/Jury trial) [Hearing] held/continued to _ _ . nt __ .
`
`This case is dismissed [with/without] prejudice nod without cos!S[by/agreementlpursuont to)
`0 FRCP4(m)
`0 Loc:al Rule 41 1 0 FRCP4l(a)(l)
`0 FRCP4l(n)(2).
`
`(10)
`
`II
`[Other docket entry]
`JUDGMENT.
`
`This action is dismissed pursuant to settlement. ENTER CONSENT
`
`--------.---.,..----1
`Ji.ohim~n!
`:.
`. N~inbi(
`i.:;;:. ;_; :\~ ': ": .. ~· ;
`
`II
`No notices required, advised in open court
`
`[For further detail sec order uttached to the original minute order.)
`
`No notices required
`
`Nolices mailed by judge's sll!Cf.
`
`Notified counsel by telephone.
`
`Docketing to mail notices
`
`Mnll AO 450 fonn
`
`Copy lo judge/magistmtc judge
`
`CB
`
`courlroom
`deputy's
`initials
`
`81 :Zl !!d I Z DO ~ODZ
`. pn.&-~~iin~'olc!:iv.tliffi>
`conlml Clerk's Office
`
`(11)
`-
`-
`-
`7
`
`--
`
`TT0055508
`TTX00055508
`
`Page 7 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`..,
`
`Case 1 :04-cv-067 40 Document 4 Filed 10/21/2004 Page 2 of 6
`
`UNTI'ED STATES DlSTRICT COURT
`NORTI:IERN DlSTRICf OF U...LINOIS
`EASTERN DMSION
`
`DU~{{fltD
`OCT Z 2 2004
`
`Trading Technologies International, Inc.,
`
`Plaintiff,
`
`v.
`
`Kingstree Trading L.L.C.,
`
`Defendant.
`
`)
`)
`)
`}
`)
`)
`)
`)
`)
`)
`
`Civil Action No. 04 C 6740
`
`Judge Conlon
`
`Magistrate Judge Ashman
`
`CONSENT .JUDGMENT
`
`As a result of settlement of this action by virtue of a settlement agreement
`
`between the parties dated October 20, 2004 which shall become effective upon entry of
`
`this Consent Judgment and upon consent of Plaintiff, Trading Technologies International,
`
`Inc. ("'IT") and Defendant, Kingstree Trading L.L.C. ("KINGSTREE"), judgment is
`
`hereby entered against KINGSTREE upon 'IT's Complaint, and it is hereby ORDERED,
`
`ADJUDGED, and DECREED that:
`
`1.
`
`Tr conunenced this action for patent infringement against KINGSTREE on
`
`October 19, 2004, alleging that KINGSTREE infringes U.S. Patent Nos. 6,766,304
`
`("'304 patent") and 6,772,132 ("' 132 patent"). KINGSTREE has received and reviewed
`a copy of the Complaint filed by Tr in this action.
`
`1
`
`TT0055509
`TTX00055509
`
`Page 8 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`Case 1 :04-cv-067 40 Document 4 Filed 10/21/2004 Page 3 of 6
`
`2.
`
`This Court has jurisdiction over the parties to this action and over the subject
`
`matter of the Complaint.
`
`3.
`
`IT is the sole and exclusive owner of the '304 patent and the '132 patent, and has
`
`the right to sue upon, ;md recover damages for past infringement and enjoin future
`
`infringement of the '304 and '132 patents.
`
`4.
`
`5.
`
`All claims of the '304 and '132 patents are valid and ~nforceable.
`
`KINGSTREE has directly infringed the '304 and '132 patents by making and
`
`using electronic trading software currently referred to as "KINGSTREE's user interface
`
`software developed by Kingstree for Trading," screenshots included in Exhibit A.
`
`6.
`
`Defendant KINGSTREE, its officers, directors, partners, members, affiliates.
`
`subsidiaries, assigns, and successors-in-interest are hereby permanently enjoined during
`
`the terms of the '304 and '132 patents from the making, using, selling, offering for sale,
`
`importing and otherwise distributing in the United States the electronic trading software
`
`products referred to in paragraph 5 above.
`
`7.
`
`Any claims of infringement that IT has against KINGSTREE based on
`
`KINGSTREE's use and/or distribution of electronic trading software provided by any
`
`third party software provider prior to entry of this judgment are dismissed without
`
`prejudice. The parties have addressed this issue in the Settlement Agreement by IT
`
`granting to KINGSTREE a limited covenant not to sue. IT is not waiv.ing any rights to
`
`assert the '304 and '132 patents against KINGSTREE based on KINGS1REE's use
`
`and/or distribution of such third party software in the future if the limited covenant not to
`
`2
`
`TT0055510
`TTX00055510
`
`Page 9 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`Case 1:04-cv-06740 Document4 Filed 10/21/2004 Page4of6
`
`sue is tenninated. KINGSTREE is not waiving any rights to assert that such third party
`
`software does not infringe the '304 and '132 patents if the limited covenant not to sue is
`
`terminated.
`
`8.
`
`TI waives its rights to damages from KINGSTREE arising fr~m the manufacture,
`
`use, sale or offers to sell the electronic trading software products referred to in paragraph
`
`5 above prior to entry of this Judgment.
`
`9.
`
`Notwithstanding the terms of this Consent Judgment, KINGSTREE expressly
`
`reserves the right to contest infringement if the KINGSTREE software is modified so as
`
`to not infringe the patents-in-suit. In the event that KINGSTREE contests infringement
`
`based on KINGSTREE software that is modified, TI reserves the right to assert any and
`
`all claims against KINGSTREE including without limitation a claim of contempt of court
`
`based on a violation of this Consent Judgment in the event that the Court finds there is no
`
`colorable difference between the modified KINGSTREE software and the software that is
`
`the subject of this Consent Judgment.
`
`10.
`
`This Court shall retain jurisdiction over this case for purposes of enforcing the
`
`Consent Judgment and the Settlement Agreement between the parties pursuant to which
`
`the Consent Judgment is 1iled.
`
`I 1.
`
`Each party shall bear its own costs and attorneys' fees.
`
`/o
`,, ~a.~
`/ }J r(
`
`SOORDERED )
`Dated:
`
`/fJ
`
`. Conlon
`Suzanne
`United States District Court Judge
`
`3
`
`TT0055511
`TTX00055511
`
`Page 10 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`.-
`
`Case 1 :04~cv~06740 Document 4 Filed 10/21/2004 Page 5 of 6
`
`AGREED TO:
`
`Dated:
`
`I o. (:> ~ (~:;) '(
`
`Dated:
`
`Paul H. Berghoff (ID No.
`)
`8
`Leif R. Sigmond, Jr. (ID No. 6204980)
`Matthew J. Sampson (ID No. 6207606)
`McDonnell Boehnen Hulbert
`& BerghoffLLP
`300 South Wacker Drive
`Cldcago,IL 60606
`Tel.: (312) 913,0001
`Fax: (312) 913-0002
`
`Attorneys for Plaintiff
`TRADING TECHNOLOGIES
`INTERNATIONAL, INC.
`
`Attorneys for Defendant
`KINGSTREE TRADING, L.L.C.
`
`4
`
`TT0055512
`TTX00055512
`
`Page 11 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`•.
`
`. -
`...
`
`Case 1 :04-cv-067 40 Document 4 Filed 1 0/21/2004 Page 6 of 6
`
`~
`
`EXHIBIT
`
`I _A_
`
`-·- ------------------------
`
`TT0055513
`TTX00055513
`
`Page 12 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`COPY
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`Trading Technologies International, Inc.,
`
`v.
`
`Ninja Trader, LLC,
`
`Plaintiff,
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`
`)
`)
`)
`)
`
`Civil Action No. 05 C 3953
`
`Judge Der-Y eghiayan
`
`Magistrate Judge Keys
`
`CONSENT JUDGMENT
`
`As a result of settlement of this action by virtue of a confidential settlement
`
`agreement between the parties dated July 7, 2005 which shall become effective upon
`
`entry of this Consent Judgment and upon consent of Plaintiff, Trading Technologies
`
`International, Inc. ("TT") and Defendant, Ninja Trader LLC ("NINJATRADER"),
`
`judgment is hereby entered against NINJATRADER upon TT's Complaint, and it is
`
`hereby ORDERED, ADJUDGED, and DECREED that:
`
`1.
`
`TT commenced this action for patent infringement against NINJA TRADER on
`
`July 7, 2005. This action alleges that NINJATRADER infringes U.S. Patent Nos.
`
`6, 766,304 ("' 304 patent") and 6, 772,132 ("' 132 patent"). NINJA TRADER has received
`
`and reviewed a copy of the Complaint filed by IT in this action.
`
`429754-1
`
`1
`
`TT0050559
`TTX00050559
`
`Page 13 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`2.
`
`This Court has jurisdiction over the parties to this action and over the subject
`
`matter of the Complaint.
`
`3.
`
`TT is the sole and exclusive owner of the '304 patent and the '132 patent, and has
`
`the right to sue upon, and recover damages for past infringement and enjoin future
`
`infringement of the '304 and' 132 patents.
`
`4.
`
`5.
`
`All claims of the '304 and '132 patents are valid and enforceable.
`
`NINJATRADER has infringed the '304 and '132 patents under 35 U.S.C. Section
`
`271 by making, using, selling, offering for sale, importing, and/or otherwise distributing
`
`electronic trading software incorporating the NINJA TRADER SuperDOM screen,
`
`screenshots and documentation of which are included in Exhibit 1.
`
`6.
`
`Defendant NINJATRADER, its officers, directors, partners, members, affiliates,
`
`subsidiaries, assigns, and successors-in-interest are hereby permanently enjoined (unless
`
`expressly permitted by TT) during the terms of the '304 and '132 patents from infringing
`
`the '304 and '132 patents, including, without limitation, by the making, using, selling,
`
`offering for sale, importing, facilitating connectivity for and otherwise distributing in the
`
`United States the electronic trading software products referred to in paragraph 5 above
`
`(and substantially similar products) including, without limitation, for use in electronically
`
`trading any item (e.g., futures, options, equities, fixed-income products, etc.).
`
`7.
`
`IT waives its rights to damages from NINJATRADER arising from the
`
`manufacture, use, sale or offers to sell, importation and/or other distribution of the
`
`429754-1
`
`2
`
`TT0050560
`TTX00050560
`
`Page 14 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`electronic trading software products referred to in paragraph 5 above prior to entry of this
`
`Judgment.
`
`8.
`
`This Court shall retain jurisdiction over this case for purposes of enforcing the
`
`Consent Judgment and the confidential Settlement Agreement between the parties
`
`pursuant to which the Consent Judgment is filed.
`
`9.
`
`Each party shall bear its O\\TI costs and attorneys' fees.
`
`429754-1
`
`3
`
`TT0050561
`TTX00050561
`
`Page 15 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`SO ORDERED
`Dated: j"vll c.. I 'I, ].PtJ$
`
`AGREED TO:
`
`Dated: 7 /!ts
`
`· - - -1 - - - f , - - - -
`
`Dated:_7..L._/_e+-0_o_~ __ _
`
`Pt/k/
`
`LeifR. Sigmond, Jr. (ID No. 6264980)
`Matthew J. Sampson (ID No. 6207606)
`McDonnell Boehnen Hulbert & Berghoff LLP
`300 South Wacker Drive
`Chicago, IL 60606
`Tel.: (312) 913-0001
`Fax: (312) 913-0002
`
`Attorneys for Plaintiff
`TRADING TECHNOLOGIES
`INTERNATIONAL, INC.
`
`Steven Petersen (ID No. 6196793)
`Leydig, Voit & Mayer
`Two Prudential Plaza- 180 N. Stetson Avenue
`Suite 4900
`Chicago, Illinois 60601-6780
`Tel: (312) 616-5600
`Fax: (312) 616-5700
`
`Attorneys for Defendant
`NINJA TRADER, LLC
`
`429754-1
`
`4
`
`TT0050562
`TTX00050562
`
`Page 16 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`1
`
`TT0050563
`TTX00050563
`
`Page 17 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`1202.25
`1202.00
`1201.75
`1201.50
`1201.25
`1201.00
`1200.75
`1200.50
`1200.25
`1200.00
`1199.75
`1199.5
`1199.25
`1199.00
`1198.75
`1198.50
`1198.25
`1198.00
`1197.75
`1197.50
`1197.25
`1197.00
`1196.75
`
`1613
`3187
`1133
`1420
`8807
`
`1187
`1669
`13QS
`573
`
`100
`
`Instrument Position Strategy
`
`Stop Strategy
`
`iJ
`
`=T=IF=-____, ..... Ac_co_un_t - - - ,
`
`iJ
`
`j3
`
`TT0050564
`TTX00050564
`
`!Es09-{iJ I
`iJl
`Enby I Stop I Quick Buttons I Reverse & Shadow I
`:··Pos Type ----i L~: SE
`:~:~ Target CIT
`r·-Entry-- ....... -·!
`ii'CIT
`!
`1-.
`l
`1 '·. Naked
`,,· Contracts
`Chase limit
`! --"'
`i
`i I' Ck.....e
`I
`'
`j3 ! -·:u __ ..... :_ -· -· _i
`! C Stop Only
`jJ jo
`11
`J !.~~~Stop /1T
`1 () Stop 12T
`I ('Stop /3T J JO
`
`1
`
`1
`
`J Time Stop
`
`Stop loss
`11.5
`T1 Prufrt
`
`Limit Offset
`fO
`
`jjp
`
`:iJ IB iJ 137806
`±J
`
`Page 18 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`SUPERDOM
`
`The SuperDOM window (SW) provides complete functionality for the management of a position strategy in a highly visual and
`efficient manner. The SW is one of two available position strategy management windows (the other being the Basic Entry window
`{BEW)) where you will spend most of your time using Ninja Trader. The SW and BEW share one common trait, the 'Position Strategy
`Parameter Tabs' (bottom third of the SW and BEW) are identical. This provides consistency when defining your strategy positions.
`
`Important!
`Before continuing any further through this section of the User's Guide, you should review the section on 'Position Strategies' to gain
`a clear and thorough understanding of the difference between them and a positions.
`
`Topics in this section
`Modifyjpg Entry And Scale Orders
`Modifying Stop Loss And Profit Target Orders
`Managing An Open/Pending Position
`The Info Button (Displaying Running Position Strategies)
`Right Mouse Click Context Menu
`
`The Price Ladder Display
`Position And Position Strategy Disj>lay
`Selecting InstrumentS And Position Strategies
`Placing Entry And Scale Orders
`Placing Breakoutlfade Orders
`
`The Price Ladder Display
`
`G:lwatch Video Tutorial: SuperDOM Layout
`
`Columns
`The price ladder is broken down into three columns. The left column (referred to as the 'BUY' column) is used to place/modify buy
`orders and to display market depth on the BID side. The center column (referred to as the 'PRICE' column) is used to modify stop
`loss/profit target orders, display instrument price levels and the current inside market. The right column (referred to as the 'SELL'
`column) is used to place/modify sell orders and to display market depth on the ASK side.
`
`The Inside Market
`The inside market is displayed as follows:
`
`BID- Default is bold dark blue
`ASK- Default is bold forest green
`LAST- Price box default highlight color is yellow
`BID depth size- Displayed in the corresponding price rows 'BUY' column
`ASK depth size - Displays in the corresponding price rows 'SELL' column
`LAST trade size -A size marker (box) is displayed to the right of the 'SELL' column with a value representing the number of
`contracts traded at that price
`Cumulative Depth- The bottom integer value in the BUY column and the top integer value in the SELL column represent cumulative
`depth sizes
`
`•superDOM colors are completely user definable via the 'Settings Manager'
`'*Depth display is optional and can be toggled via the right click mouse menu. When disabled, only the best BID/ASK size will
`display.
`
`Adjusting The Price Ladder Display
`Move your mouse into the price ladder and use the mouse scroll wheel to scroll up or down. You can also press the 'C' button to
`center the last traded price.
`
`TT0050565
`TTX00050565
`
`Page 19 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`PRICE LADDER DISPLAY
`
`. : :
`
`~
`
`Instrument Position Strategy
`
`Stop Strategy
`
`IYM O!t 3 iYM 2CARS 3 \YM STANDAii]
`j Quick Buttons I Reverse A Shadow I
`Entry j Stop
`Pos Type ·
`; SE
`Target CIT
`· · Entry
`. Naked
`Contracts
`Chase Umit
`·. CIT
`· Stop Onl}' p
`±l
`·Chase
`:±] jn
`Stop/1T
`Time Stop
`TIF
`Account
`• Stop/2T
`!:!
`j3 \DAY ~ lr:-.98:-1-:21--iJ-,
`Stop/3T
`T2 Oty
`Stop Loss
`j10
`:±JJ1
`T1 Profit
`Limit Offset
`T2 Profit
`::B 1m
`:±Jj3o
`~
`
`:±l
`
`TT0050566
`TTX00050566
`
`Page 20 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`Position And Position Strategy Display
`
`Your account position is displayed at the top of the middle column (orange highlighted box) while position strategy information
`(turquoise highlighted box) is displayed below the price ladder. For the most part, the size values (in this example 1 contract is
`shown) will be identical but for advanced users, these numbers could be different because you could have a situation where you
`have two active position strategies. One managing 1 contract, the other managing two which of course would give a total of 3
`contracts in your account and be reflected at the top of the middle column.
`
`Instrument Position Strategy
`
`IEs 12-i] l
`
`RS
`
`Stop Strategy
`
`iJ
`
`.::Jl
`
`Selecting Instruments And Position Strategies
`
`Selecting/changing strategies will update the parameters in the 'Position Strategy Parameter Tabs'.
`
`Instrument- Changes the active SuperDOM instrument. You can select the 'STOCK' instrument if you wish to request data/trade an
`equity instrument. When selected, a prompt will ask you to enter a stock symbol.
`
`Position Strategy- Selecting a position strategy will update the 'Position Strategy Parameter Tabs' with the associated parameters
`of the selected strategy
`
`Stop Strategy- Selecting a stop strategy will update the 'Stop' tab in the 'Position Strategy Parameter Tabs' with the associated
`parameters of the strategy
`
`TT0050567
`TTX00050567
`
`Page 21 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`Placing Entry And Scale Orders
`
`G::lwatch Video Tutorial: Placing Orders In The SuperDOM
`
`Ninja Trader defines orders in several categories. Within the SW, you can place and manage the following order categories:
`
`Entry Orders - Orders that initiate a position strategy once filled
`Scale Orders- Orders that add/subtract contracts/shares from an open position strategy
`Stop Loss/Profit Target Orders
`
`Entry and Scale orders are manually placed while Stop Loss and Profit Target orders {for the most part) are automatically submitted
`by Ninja Trader once an Entry order has been filled.
`
`The following mouse conventions are used:
`
`Left Click- Places LIMIT orders
`Middle Click -Places STOP orders
`Middle Click+ CTRL Key- Places STOP orders
`
`*The SuperDOM has as STOP order type default (either STOP LIMIT or STOP MARKET), this can be toggled via the right mouse
`click context menu. If STOP LIMIT is default, then middle click will place STOP LIMIT order while middle click + CTRL key
`combination will place STOP MARKET order. The inverse is true if the SuperDOM STOP order type default is STOP MARKET.
`.... Middle mouse button usually refers to pressing down on the scroll wheel of your mouse
`
`The SuperDOM allows you to place a maximum of two Entry orders {using the breakout/fade entry mode which must be enabled via
`the right mouse click context menu) and a maximum of two scale orders while a position is open.
`
`To place a LIMIT order, left click in the appropriate 'BUY' or 'SELL' column at the price level you wish the order to be submitted. A
`cyan colored box will appear with the letters 'LMT' along with a size marker to the left of the 'BUY' column. The size marker color will
`change to reflect the current status of the order. The image to the right illustrates a BUY LIMIT order at 1144.50 for 1 contract
`
`To place a STOP LIMIT order (assuming default stop order type is STOP LIMIT), middle click in the appropriate 'BUY' or 'SELL'
`column at the price level you wish the order to be submitted. A violet colored box will appear with the letters 'SLM' along with a size
`marker to the left of the 'BUY' column. The size marker color will change to reflect the current status of the order. The image to the
`left illustrates a BUY STOP LIMIT order at 1145.75 for 1 contract.
`
`TT0050568
`TTX00050568
`
`Page 22 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`To place a STOP MARKET order (assuming default stop order type is STOP LIMIT), middle click while holding the CTRL key down
`at the price level you wish the order to be submitted. A pink colored box will appear with the letters 'STP' along with a size marker to
`the left of the 'BUY' column. The size marker color will change to reflect the current status of the order. The image to the right
`illustrates a BUY STOP MARKET order at 1146.25 for 1 contract.
`
`You can also place orders using the buttons on the 'Quick Buttons' tab of the 'Pos'ition Strategy Parameter Tabs'.
`
`1r:·1· ·~
`
`sw
`
`333
`
`1146.50
`1146.25
`1146.00
`1145.75
`1145.50
`1145.25
`
`558
`
`1
`
`I
`
`Placing Breakout/Fade Orders
`
`~Watch Video Tutorial: Breakout/Orders
`
`Breakout/Fade orders is where you can place two entry orders as an OCA pair. This means that once one order is filled, the other
`order will be automatically cancelled. There are several breakout/fade order combinations available:
`
`Break- Order pair consisting of one BUY STOP order and one SELL STOP order
`Fade- Order pair consisting of one BUY LIMIT order and one SELL LIMIT order
`Break/Fade Buy- Order pair consisting of BUY LIMIT and STOP orders
`Break/Fade Sell- Order pair consisting of SELL LIMIT and STOP orders
`
`You must first enable breakout/fade mode by selecting the 'Breakout/Fade Entry Mode' via the right mouse click context menu as
`per the image to the below
`
`1145.00
`1144.75
`1144.50
`1144.25
`
`717
`22
`
`6
`
`J
`
`327
`1519
`--·-···
`AI
`waysOoTop
`c
`ashPft.
`.,s
`how Depth
`toe enter
`o~Au
`
`·ze Adjust Value
`Si
`.,s topUmit As Default
`r.::e.· ) .. : =-~·d-: ::··u·'"· r~!cde
`··-- ·-·--·--·--·· .....
`
`..
`
`•
`
`.. ..
`
`- '•'
`
`~-
`
`~-
`
`-·
`
`0
`1<<1
`
`TT0050569
`TTX00050569
`
`Page 23 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`You can then place the breakout/fade order combination. The image on the left illustrates a Fade order pair combination.
`
`Modifying Entry And Scale Orders
`
`To modify an order price, use the same mouse button used to place the original order and click on a new price in the same column
`the order currently resides. You can also modify order contract size by clicking on the size marker.
`
`Left Click - Increments the order size
`Middle Click- Decrements the order size
`
`The order size is modified by the 'Size Adjust Value' which can be toggled via the right mouse click context menu.
`
`Modifying Stop Loss And Profit Target Orders
`
`Once a position has been established, the SW will display your entire position by color coding rows where your stop loss and profit
`target orders exist. The image to the right illustrates a position that has three targets (green shaded rows) and a •stop loss order
`(red colored row). The position's average entry price is highlighted by the brown colored price box. Each stop and target has an
`associated size marker (to the left of the 'BUY' column) displaying the number of contracts for each order.
`
`*From a trader's perspective, there is only one stop loss however. in reality, the stop loss is made up of three separate stop orders
`in this example. Each profit target order is OCA paired with a stop loss order. Although there are three stop orders, Ninja Trader
`combines them into one red row for display purposes.
`
`TT0050570
`TTX00050570
`
`Page 24 of 464
`
`TRADING TECH EXHIBIT 2283
`IBG ET AL. v. TRADING TECH. - CBM2016-00054
`
`

`

`To modifying stop loss and profit target order prices click in the center 'Price' column. Clicking in the price column on the BID or
`above when long will adjust your profit target order prices, below the BID will adjust stop loss order prices. Clicking in the price
`column on the ASK or below when short will adjust your profit target order prices, above the ASK will adjust stop loss order prices.
`
`Left Click - Modify either stop loss order or closest profit target
`Middle Click- Modify second closest profit target order
`Middle Click + CTRL Key- Modify third closest profit target order
`Left Click + CTRL Key- Modify all profit target orders to the price that is clicked on
`
`You can modify profit target order prices so that two or more orders rest at the same price. The SuperDOM wilt combine the order
`display in the same manner as it does for stop loss orders however, all three order remain active. In other words, profit target orders
`do not combine into one order. This allows you to preserve independent order FIFO advantage.
`
`To modify stop loss or profit target order sizes click on the appropriate orders size marker.
`
`Left Click - Increments the order size
`Right Click - Decrements the order size
`
`Since a position strategy has built in intelligence, there will be cases where you can not modify an order's size. For example, if you
`have three profit targets with a total position strategy size of three contracts (one contract per profit target order} you can't modify the
`profit target order sizes since there is no 'excess' contracts to move around. In the same scenario, if you had a total position strategy
`size of four contracts, you could move the fourth contract from one profit target to another.
`
`Add/Remove Targets
`At any time, you can add or remove a target from your position strategy via the right mouse click context menu.
`
`Managing An Open/Pending Position Strategy
`
`~Watch Video Tutorial: Managing Positions
`
`Reverse- Closes the current position strategy and opens a new position strategy in the opposite direction. The new position
`strategy is created based on the current parameters set in the 'Position Strategy Parameter Tabs'.
`
`Cancel -Cancels any pending Entry or Scale orders.
`
`Close- Closes the current open position strategy.
`
`In the image above right we have a LONG position of three contracts. Auto Trail (TR) and Auto Breakeven (BE} are currently
`enabled since they are highlighted in green. The label column are position strategy automation features. By clicking on them, you
`can enable or disable these features. It is important to note that the position size displayed is the size of the position strategy and
`not your total NET position. For most cases, this value will be the same however, there are times where you may have a total NET
`position of 5 contracts but only 3 are managed via a strategy.
`
`TR - Enable/disable auto trail.
`
`BE- Enable/disable auto breakeven.
`
`SS- Enable/disable simulated stop loss and entry. When a position
`strategy is pending it will display 'SE' for simulated entry, when a position
`strategy is open it will display 'SS'.
`
`CIT- Enable/disable auto chase. While a position strategy is pending, clicking this with your middle mouse button will change the
`auto chase type between Chase If Touched {CIT) or Chase (CH).
`
`RT- Enable/disable au

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket