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`IBG LLC, et al. v. TTI, Inc
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`Charles J Ryan
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` IBG LLC and INTERACTIVE )
` BROKERS LLC, )
` ) Case CBM2016-00054
` Petitioner, ) U.S. Patent No.
` ) 7,693,768 B1
` vs. )
` ) Case CBM2016-00090
` TRADING TECHNOLOGIES ) U.S. Patent No.
` INTERNATIONAL, INC., ) 7,725,382
` )
` Patent Owner. )
` _________________________ )
`
` Deposition of CHARLES J. RYAN, taken
` in the above-captioned cause, at McDonnell,
` Boehnen, Hulbert & Berghoff, 300 South
` Wacker Drive, Chicago, Illinois, before
` Rachel F. Gard, CSR, RPR, CLR, CRR,
` commencing at the hour of 1:02 p.m. on
` Wednesday, April 5, 2017.
`
`------------------------------------------------
` DIGITAL EVIDENCE GROUP
` 1726 M Street, NW
` Suite 1010
` Washington, DC 20036
` 202.232.0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2017
`
`202-232-0646
`
`IBG 1070
`IBG v. TT
`CBM2016-00054
`
`
`
`IBG LLC, et al. v. TTI, Inc
`
`Charles J Ryan
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` IBG LLC and INTERACTIVE )
` BROKERS LLC, )
` ) Case CBM2016-00054
` Petitioner, ) U.S. Patent No.
` ) 7,693,768 B1
` vs. )
` ) Case CBM2016-00090
` TRADING TECHNOLOGIES ) U.S. Patent No.
` INTERNATIONAL, INC., ) 7,725,382
` )
` Patent Owner. )
` _________________________ )
`
` Deposition of CHARLES J. RYAN, taken
` in the above-captioned cause, at McDonnell,
` Boehnen, Hulbert & Berghoff, 300 South
` Wacker Drive, Chicago, Illinois, before
` Rachel F. Gard, CSR, RPR, CLR, CRR,
` commencing at the hour of 1:02 p.m. on
` Wednesday, April 5, 2017.
`
`------------------------------------------------
` DIGITAL EVIDENCE GROUP
` 1726 M Street, NW
` Suite 1010
` Washington, DC 20036
` 202.232.0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2017
`
`202-232-0646
`
`IBG 1070
`IBG v. TT
`CBM2016-00054
`
`
`
`4/5/2017
`
`IBG LLC, et al. v. TTI, Inc
`
`Charles J Ryan
`
`Page 2
`
`APPEARANCES:
`ON BEHALF OF THE PETITIONER:
` STERNE KESSLER GOLDSTEIN & FOX
` BY: MR. ROBERT SOKOHL
` MR. RICHARD M. BEMBEN
` 1100 New York Avenue, NW
` Washington, DC 20005
` 202.371.2600
` rsokohl@skgf.com
` rbemben@skgf.com
`
`ON BEHALF OF THE PATENT OWNER:
` McDONNELL BOEHNEN HULBERT & BERGHOFF, LLP
` BY: MR. MICHAEL D. GANNON
` 300 South Wacker Drive
` Chicago, Illinois 60606
` 312.913.2139
` gannon@mbhb.com
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`IBG LLC, et al. v. TTI, Inc
`
`Charles J Ryan
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`Page 3
`
` I N D E X
`WITNESS PAGE
`CHARLES J. RYAN
` Cross-Examination by Mr. Bemben 4
` Redirect Examination by Mr. Gannon 78
`
` E X H I B I T S
`
`TRADING TECH EXHIBITS PAGE
`
` Exhibit 2223 2004 Declaration 13
`
` Exhibit 2534 2017 Declaration 15
`
`
` (ALL EXHIBITS RETAINED AND NOT ATTACHED)
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`Charles J Ryan
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` (Witness sworn.)
`WHEREUPON:
` CHARLES J. RYAN,
`called as a witness herein, having been first duly
`sworn, was examined and testified as follows:
` CROSS-EXAMINATION
`BY MR. BEMBEN:
` Q. Good afternoon. Please state your full
`name and current address.
` A. Charles J. Ryan. 16 Landmark, Northfield,
`Illinois 60093.
` Q. My name is Richard Bemben. I'm an
`attorney at Sterne Kessler. With me is Robert
`Sokohl, also an attorney at Sterne Kessler. We
`represent petitioners.
` MR. BEMBEN: Counsel, would you introduce
`yourself?
` MR. GANNON: Yeah. My name is Mike Gannon.
`I'm with McDonnell, Boehnen, Hulbert & Berghoff here
`on behalf of the patent owner Trading Technologies
`and Mr. Ryan.
`BY MR. BEMBEN:
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2017
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`202-232-0646
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`Charles J Ryan
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` Q. Mr. Ryan, have you ever been deposed
`before?
` A. I have.
` Q. You have. How many times?
` A. Just once.
` Q. What was the nature of that deposition?
` A. It was a lawsuit brought by a firm that I
`worked for, Trading World, and I was deposed by
`opposing counsel.
` Q. Did you act as an expert in that case?
` A. No.
` Q. Do you recall the names of the parties
`involved in that case?
` A. The lawsuit was against Solomon Brothers.
`I believe the -- there was several firms that
`brought the lawsuit. I think it was a group. I
`don't recall all of them.
` Q. And generally without divulging any
`confidential information, what was the nature of the
`case?
` A. Solomon Brothers -- you can pull this up
`and read about it -- back in 1991 was involved in a
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`Page 6
`treasury note auction that they went through the
`process of bidding for more than they were allowed
`to bid, and they did it on behalf of some of their
`customers. Some of their customers knew about it;
`some of them didn't. We were one of their
`customers. I was a trader for a firm for one of
`their customers. And they were sued for the losses
`that their clients and the investors of their
`clients received.
` Q. Have you ever testified at trial?
` A. No.
` Q. Okay. So you're a little bit familiar
`with depositions, but I'm just going to give you
`some of the ground rules. I'll ask the questions
`today, and you'll answer them. If one of my
`questions is not clear, please ask me to clarify it.
`Is that fair?
` A. Sure.
` Q. But if you answer the question, I'm going
`to assume that you understood it. Okay?
` A. Okay.
` Q. Please provide verbal answers. It's tough
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`Page 7
`for the court reporter to take down head nods and
`shrugs, but yes, no. And for the same reason, let's
`try not to speak over each other. I'll give you an
`opportunity to answer your questions. I just ask
`that you let me ask my questions.
` A. Okay.
` Q. During the deposition, we can take breaks
`whenever you need to. The only thing I ask is that
`you answer any pending question. Is that fair?
` A. Say that again.
` Q. I just ask that you answer any pending
`questions.
` A. Sure.
` Q. We'll try to take breaks every hour or so.
` A. Okay.
` Q. You do understand you're under oath,
`correct?
` A. I do.
` Q. Is there any reason that you cannot
`provide complete and truthful testimony today?
` A. No.
` Q. Mr. Ryan, are you an attorney?
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`Charles J Ryan
`
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` A. Am I an attorney?
` Q. Yes.
` A. No.
` Q. Are you testifying today as an expert?
` MR. GANNON: Object to the form.
`BY MR. BEMBEN:
` Q. You can still answer the question.
` A. I would consider myself a former expert.
` Q. What is your area of expertise?
` A. Trading.
` Q. Okay.
` A. Trading different securities and financial
`futures.
` Q. You are testifying on behalf of the patent
`owner Trading Technologies, correct?
` MR. GANNON: Object to the form.
`BY MR. BEMBEN:
` Q. Are you testifying on behalf of Trading
`Technologies today?
` MR. GANNON: Object to form.
`BY MR. BEMBEN:
` Q. You can still answer his questions -- my
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`questions.
` A. Yes.
` Q. Okay. And if I say TT for Trading
`Technologies, will you understand what I mean?
` A. I will.
` Q. Okay. Did Trading Technologies hire you
`as an expert?
` A. No.
` MR. GANNON: Object to the form.
`BY MR. BEMBEN:
` Q. Do you understand that you're testifying
`in two covered business method reviews that are
`pending at the U.S. Patent and Trademark Office?
` A. I believe so, yes.
` Q. Okay. And you provided a declaration; is
`that correct?
` A. I did.
` Q. When were you first contacted about
`providing the declaration in these covered business
`method reviews?
` A. Well, I provided two of them.
` Q. Yes. When were you first contacted about
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`Page 10
`first providing the declarations in these covered
`business method reviews?
` MR. GANNON: Object to the form
`BY THE WITNESS:
` A. The first time, sometime in 2004.
` Q. And who contacted you sometime in 2004?
` A. My associate at Trading Technologies,
`Michael Burns.
` Q. You say Michael Burns was your associate
`at Trading Technologies. What do you mean by
`"associate"?
` A. He and I used to work together. Well,
`actually, I take that back. We didn't work
`together. We worked out of the same office years
`before that, years before he worked at Trading
`Technologies. And I just called him an associate.
`I guess he was a salesman. He was director. I'm
`not sure what all of his roles were. It was my way
`of saying he's just a friend of mine.
` Q. And what did Mr. Burns ask you when he
`contacted you?
` A. It was a long time. I really don't
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`remember.
` Q. You don't remember any details of that
`conversation?
` A. Not really. Not to give you an accurate
`answer, no.
` Q. Did he ask you if you'd provide a
`declaration?
` A. I can't say for sure.
` Q. Did anyone else contact you about
`providing a declaration?
` MR. GANNON: Object to the form.
`BY MR. BEMBEN:
` Q. In 2004?
` A. I don't recall. Again, it was a long time
`ago.
` Q. Okay. Why did you provide a declaration
`in 2004?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I can't give you a definitive answer again
`because I don't know exactly -- I can't remember
`everything that was in my thought process at that
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`time, 13 years ago.
` Q. So you don't know why you provided a
`declaration in 2004?
` MR. GANNON: Object. Object to the form.
`BY THE WITNESS:
` A. Again, I can't give you a definitive, you
`know, short answer for that so ...
` Q. I don't need a short answer. Any answer,
`any reasons why you provided a declaration in 2004
`would suffice.
` A. Honestly, I can't think of a reason why. I
`just -- I don't remember.
` Q. When Michael Burns contacted you in 2004,
`did you know that Trading Technologies was involved
`in litigation?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I was aware that there was, you know -- I
`was aware there was a dispute, yeah.
` Q. How did you become aware that there was a
`dispute?
` A. I don't know specifically. You know,
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`Page 13
`you're in the industry enough, you're going to hear
`people talk.
` Q. Did Michael Burns tell you that there was
`a dispute?
` A. I don't recall.
` (Trading Tech Exhibit Number 2223
` in CBM2016-00054 marked for
` identification.)
`BY MR. BEMBEN:
` Q. Okay. Mr. Ryan, I'm going to introduce
`what has been marked as trading tech Exhibit 2223 in
`CBM2016-00054. And I'll let you look through that.
`What that is, it's a compilations of different
`declarations that were filed. Your declaration is
`on Pages 62 and 63. There's little numbers on the
`bottom left-hand corner.
` Do you recognize the document on Pages 62
`and 63?
` A. I do.
` Q. And what is it?
` A. It's a declaration that I made in August
`of 2004.
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`Page 14
` Q. And on Page 63, is that your signature?
` A. Yes, it is.
` Q. Okay.
` MR. BEMBEN: Counsel, can we stipulate that
`Exhibit 2223 in 2016-00054 is the same as
`Exhibit 2223 in CBM2016-00090? I have a copy if
`you'd like to see it.
` MR. GANNON: I have no reason to doubt it. BUT
`I guess for completeness ... yeah, they look to be
`the same. But again, I haven't thumbed through each
`page of each exhibit to confirm that.
`BY MR. BEMBEN:
` Q. Okay. Well, let me ask you, Mr. Ryan, did
`you prepare more than one declaration in 2004?
` A. No.
` Q. This was the only one?
` A. (Nodding).
` Q. I'm going to refer to this as the 2004
`declaration or your declaration; is that correct?
` A. Sure.
` Q. When was the last time you reviewed the
`2004 declaration?
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` A. So when was the last time I looked at this?
` Q. Yes.
` A. This morning.
` Q. And before that, when had you reviewed it?
` A. Yesterday.
` Q. Yesterday. How about before that?
` A. January of 2017.
` Q. Is the 2004 declaration complete and
`accurate?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I believe in the accuracy of everything
`that I put on here and signed.
` Q. Did you write the 2004 declaration?
` A. I did.
` Q. You wrote all the words?
` A. (Nodding).
` Q. Did anyone tell you what to write in the
`2004 declaration?
` A. No.
` Q. Did anyone pay you to prepare the 2004
`declaration?
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`Page 16
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` A. No.
` Q. Why did you prepare the 2004 declaration,
`then?
` A. When I -- when I understood all that was
`going on, I was asked if I would make this
`declaration, and I said I would.
` Q. Ask by who?
` A. Mike Burns.
` Q. Anyone else?
` A. Not that I can remember.
` Q. And when Mike Burns asked you to make the
`2004 declaration, what exactly did he ask you to do?
` A. I don't remember exactly.
` Q. Did he ask you to write any of these
`specific paragraphs that are in the 2004
`declaration?
` A. I don't recall.
` Q. Did you receive any form of
`compensation --
` A. No.
` Q. -- for preparing the 2004 declaration?
` A. (Shaking head).
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`Page 17
` Q. Did you know that the 2004 declaration was
`going to be used in the litigation that Trading
`Technologies was involved in?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I knew that it was a possibility,
`absolutely.
` Q. Did you review any materials when you
`prepared the 2004 declaration?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. What do you mean by "materials"? What
`would I have reviewed?
` Q. Any materials, whether software code,
`screen shots, user manuals, any materials that are
`relevant to your declaration.
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I don't recall.
` Q. You don't remember if you reviewed any
`material?
` A. You know, no. When I -- in 2004, up until
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`Page 18
`I stopped trading in 2012, I lived and breathed
`this. So I didn't really have to review anything.
`So did I go back and look at a user's manual or
`anything like that, as you mentioned, I don't
`recall.
` Q. In your answer you said you lived and
`breathed this. What do you mean by that?
` A. I traded probably 20 out of 24 hours a day.
` Q. Traded using Trading Technologies
`software?
` A. Trading Technologies, eSpeed, Broker Tech.
`All of the, you know, tools available to me to trade
`U.S. government securities and financial futures.
` Q. When was the first time -- strike that.
` Why don't you go ahead and take a minute
`to look at Exhibit 2223 and the other declarants.
`Do you know any of those other declarants?
` A. I've met Ray Cahnman. Is this a
`declaration?
` Q. That's a fair question. No, but do you
`know Mr. Durkin?
` A. I do. I know Brian Gelber. I know Paul
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`Johnson. And I know Chuck Ryan. That's it.
` Q. How do you know Mr. Cahnman?
` A. Just through mutual -- it was social,
`nothing business-related.
` Q. How do you know Mr. Durkin?
` A. I was a client of Dan Durkin's for a while.
` Q. How do you know Mr. Gelber?
` A. I was a client of his for a little while.
` Q. How do you know Mr. Johnson?
` A. Paul and I worked out of the same offices
`for a while. We were just associates, no business
`relation.
` Q. Did you know that Mr. Cahnman, Mr. Durkin,
`Mr. Gelber, Mr. Johnson were providing declarations
`when you provided declarations in 2004?
` A. No. News to me today.
` (Trading Tech Exhibit Number 2534
` in CBM2016-00054 marked for
` identification.)
`BY MR. BEMBEN:
` Q. Okay. Mr. Ryan, I'm going to introduce
`what has been marked Exhibit 2534 in CBM2016-00054.
`
`www.DigitalEvidenceGroup.com
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`Digital Evidence Group C'rt 2017
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` A. Thank you.
` Q. Mr. Ryan, do you recognize this document?
` A. I sure do.
` Q. What is it?
` A. It's the declaration that I made this past
`January.
` MR. BEMBEN: Counsel, can we stipulate
`Exhibit 2534 in CBM2016-00054 is the same as
`Exhibit 2534 in CBM2016-00090? And I have a copy if
`you'd like to say it.
` MR. GANNON: I'd give the same answer. It
`appears to be the same, but I haven't done a
`word-for-word comparison.
`BY MR. BEMBEN:
` Q. Mr. Ryan, did you provide more than one
`declaration in 2017?
` A. No, this one is it.
` Q. Please turn to Page 5 of your 2017
`declaration. And is it okay if I refer to
`Exhibit 2534 as your 2017 declaration?
` A. Just this time, yes.
` Q. Turn to Page 5 of your 2017 declaration?
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` A. Okay.
` Q. Is that your signature?
` A. It is.
` Q. When was the last time you reviewed your
`2017 declaration?
` A. This morning.
` Q. Is it complete and accurate?
` A. It is.
` Q. When were you first contacted about
`preparing your 2017 declaration?
` A. January of 2017.
` Q. Who contacted you about preparing the 2017
`declaration?
` A. Mike Burns.
` Q. And what did Mike Burns say to you when he
`contacted you?
` A. Asked me if I would generate a new
`declaration, that there were continuing legal issues
`and asked me if I would renew it or write a new one.
` Q. How many times did Mr. Burns contact you
`in relation to the 2017 declaration?
` A. I don't know.
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` Q. Was it more than once?
` A. Asking me to do so? So can you rephrase
`that question?
` Q. How many times did Mr. Burns contact you
`in relation to the 2017 declaration?
` A. I don't know exactly.
` Q. Was it more than once?
` A. It was more than once.
` Q. Was it more than 10 times?
` A. I doubt it.
` Q. Did you write the 2017 declaration?
` A. I did.
` Q. You wrote all of the words?
` A. I did.
` Q. Did Mike Burns tell you what to write in
`the 2017 declaration?
` A. No.
` Q. Did anyone tell you --
` A. No.
` Q. -- what to write in the 2017 declaration?
` Did anyone pay you for preparing the 2017
`declaration?
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` A. No.
` Q. Did you receive any compensation
`whatsoever for preparing the 2017 declaration?
` A. No.
` Q. Did you review any materials when you
`prepared the 2017 declaration?
` A. I reviewed my 2004 declaration.
` Q. Anything else?
` A. Not that I can think of, no.
` Q. And who provided you with your 2004
`declaration?
` A. I had a copy of it.
` Q. Okay. Let's set those aside for a moment.
`I'm just going to ask you some general questions
`because we don't have a whole lot about your
`background in the declaration.
` So, Mr. Ryan, what year were you born?
` A. 1963.
` Q. And did you graduate from high school?
` A. Yes.
` Q. When did you graduate from high school?
` A. 1981.
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` Q. And did you obtain any education after
`high school?
` A. Yes.
` Q. What?
` A. I went through 4 years of college at
`Northern Illinois and DePaul University; and I have
`enough credits to graduate from DePaul, but I'm two
`classes short.
` Q. So you didn't earn a degree?
` A. I did not.
` Q. And are you a professional trader?
` A. No longer, no.
` Q. Were you at one point a professional
`trader?
` A. Yes.
` Q. When did you begin trading professionally?
` A. 1984.
` Q. And before you began in 1984, did you have
`any other professions?
` A. Did I have any other professions?
` Q. Yes.
` A. No. I was a professional student.
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` Q. And did you retire in 2012?
` A. Can you define "retire"?
` Q. Did you retire from professional trading
`in 2012?
` A. I stopped trading professionally in 2012,
`yes.
` Q. And between 1984 when you started and 2012
`when you stopped trading professionally, did you
`have any other professions?
` A. No.
` Q. Did you ever trade in the pits?
` A. No. I was always off the floor.
` Q. What exchanges did you trade on?
` A. Chicago Board of Trade. The LIFFE
`Exchange. I can't remember the name of the German
`electronic exchange and the Italian electronic
`exchange, but I traded on both of those. Those are
`the only exchanges. Some companies are -- yeah,
`those are the only exchanges.
` Q. Did you trade on anything that wasn't
`considered an exchange?
` A. Uh-huh.
`
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`Digital Evidence Group C'rt 2017
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` Q. What?
` A. Well, I traded cash government securities
`with -- they're basically referred to as brokers.
`Cantor Fitzgerald, Broker Tech. Cantor Fitzgerald
`became eSpeed. I can't remember the names of their
`predecessors, but there were several of them.
` Q. Did you trade on any Asian exchanges?
` A. No.
` Q. Did you -- so you traded as an electronic
`trader?
` A. Yeah.
` Q. Throughout your whole period?
` A. Yes. Well, I was -- you know, there
`wasn't -- futures weren't electronically traded in
`1984 up and through most of the 1990s. So it was,
`you know, orders that were passed over the phone and
`signalled into the pit. And in cash government
`securities, my trading with Cantor Fitzgerald and
`other brokers was done over the phone. So
`technically it wasn't electronic early on.
` Q. Now, when you say that there wasn't
`futures trading in -- I'm sorry. Scratch that.
`
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`Page 27
` When you just mentioned that there wasn't
`electronic futures trading in 1984 up through most
`of the 1990s, are you referring to the U.S., in the
`U.S.?
` A. Yes. In the products that I traded, yes.
` Q. Okay. Was there electronic trading
`outside of the U.S. in that time frame?
` A. Yeah, I think they traded electronically in
`Europe before they did here. It caught on a little
`bit quicker there.
` Q. Anywhere else that traded electronically
`before the U.S.?
` A. Asia, probably. My guess.
` Q. Do you know any of the exchanges in Asia
`that electronic trading -- scratch that.
` When you say "Asia," do you know which
`exchanges traded electronically in the time frame
`from 1984 to the 1990s?
` A. No.
` Q. Are you familiar with how trading in the
`pits worked?
` A. Uh-huh.
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`Page 28
` Q. Okay. Did the pits include market makers?
` A. Did the pits include market makers? Yeah,
`yes.
` Q. Did market makers keep an order book?
` MR. GANNON: Object to the form.
`BY MR. BEMBEN:
` Q. Well, let me strike that question.
` Do you know what an order book is?
` A. I do.
` Q. What is it?
` A. A vague term.
` Q. Okay. But you have an understanding of
`what it means?
` A. It's not a tangible thing. It's a concept.
` Q. Okay. Can you describe that content to
`me?
` A. A list of customers that provide orders to
`people to execute for them.
` Q. And did market makers maintain an order
`book?
` A. Did market makers? I was never a market
`maker. I don't know for sure.
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`Page 29
` Q. But you are familiar with market makers,
`correct?
` A. I am.
` Q. But you do not know if they kept an order
`book?
` A. No.
` Q. How did they maintain or keep track of the
`orders that customers gave them?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. Market makers didn't have customers giving
`them orders.
` Q. Okay. How did market makers organize
`the -- scratch that.
` How did market makers organize the orders
`that they received?
` A. You're going to have to ask a market maker
`in the pit.
` Q. So you don't know?
` A. Not definitively, no.
` Q. But you testified earlier you're an expert
`in trading?
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`Page 30
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` A. Sure.
` Q. But you don't know how market makers
`maintain their order books?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I don't know how pit trading market makers
`kept track of their prices. As I said before, I was
`never in the pit. I was off the floor.
` Q. Okay. So how about outside the pit? How
`were order books maintained outside the pit?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. I always worked for private institutions.
`I didn't -- or a fund manager. We didn't have
`specific orders coming from clients.
` Q. So are you aware of any market -- scratch
`that.
` Are you aware of how anyone kept an order
`book?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. Specifically, no.
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`Page 31
` Q. Do you know what an order book looked
`like?
` A. I think I'm going to go back to what I said
`before. I think it was a concept, more. It wasn't
`a tangible thing.
` Q. Do you know whether anyone in the trading
`pits wrote down the orders in a book, in a physical
`book? Scratch that question.
` Do you know whether market makers in the
`pits wrote down orders in a physical book?
` A. In a physical book, market makers, I don't
`know for sure, but I don't think so.
` Q. Do you know what a limit order is?
` A. Uh-huh.
` Q. When you traded, did you ever trade limit
`orders?
` A. If I did, very rarely. I can't say
`definitively no; I can't say definitively yes.
` Q. So you can't say definitively if in your
`entire career as a trader, if you traded a limit
`order?
` A. Yeah, I did.
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`Page 32
` Q. Okay. And so when you would place a limit
`order, do you know what would happen to it after it
`left your desk?
` MR. GANNON: Object to the form.
`BY THE WITNESS:
` A. Would that be a cash limit order or futures
`limit order?
` Q. Let's start with cash limit order. What
`would happen after you placed a cash limit order?
` A. When I placed a cash limit order, it would
`be given to a broker in New York and who would then
`enter the order into their system.
` Q. What do you mean by "their system"?
` A. Even though -- there was -- there was
`actually cash was traded -- prices of the cash
`market were represented electronically, okay. And
`then when orders would be placed, they would be
`entered into an electronic system. And it would
`show up on a screen that I had on my desk.
` Q. And what time frame are you referring to
`when you're talking about this?
` A. 1984 until probably around 2000. Can't say
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`specific.
` Q. And what did -- you mentioned a screen
`that you had on your desk. What did the orders look
`like on the screen that you had on your desk?
` A. Again, for cash or futures?
` Q. Well, I think we started with cash limit
`orders.
` A. Okay. The security that I was trading
`would be listed. And then there would be a bid
`p
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