`FOR THE EASTERN DISTRICT OF TEXAS
`
`MARSHALL DIVISION
`
`BRIGHT DATA, LTD.,
`
`Plaintiff,
`
`(
`)
`(
`
`CAUSE NO. 2:19-CV-395-JRG
`
`vs.
`
`TESO, LT UAB, et al
`
`Defendants,
`
`NOVEMBER 1, 2021
`MARSHALL, TEXAS
`9:00 A.M.
`
`and a jury 16
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`VOLUME 1
`
`TRIAL ON THE MERITS
`
`BEFORE THE HONORABLE RODNEY GILSTRAP
`
`UNITED STATES CHIEF DISTRICT JUDGE
`
`SHAWN M. McROBERTS, RMR, CRR
`100 E. HOUSTON STREET
`MARSHALL, TEXAS
`75670
`(903) 237-7464
`shawn_mcroberts@txed.uscourts.gov
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`PR2022-00139, EX 00
`
`Shawn M. McRoberts TheRMRGonPR¥TechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00136, tO°o
`
`
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`about
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`twice the speed that you would get regularly at home.
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`And that was not good enough for what we were looking for,
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`so
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`we started looking for other ways to use that residential
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`network we had created, and that's it.
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`Q.
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`Okay. Did you find some other ways to utilize that
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`network?
`
`A.
`
`Yeah.
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`It took a little time, but we found out the
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`internet was growing,
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`a lot of information was online, people
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`started using it, and the questions of privacy were starting
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`to rise, and the VPNs started to appear, and we realized that
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`with this residential network we can build a VPN solution that
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`would be a lot more private than anything that was available
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`at the time.
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`Q.
`
`A.
`
`And what is a VPN?
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`A VPN is a virtual private network that,
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`in effect, hides
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`you from the sites you are visiting.
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`They can't know who you
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`are.
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`Q.
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`And how is the Hola VPN any different than any other VPN
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`at the time?
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`A. Well, it was very different, and in order to understand
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`how different it was, you have to realize that when you visit
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`the page on the internet,
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`like an Amazon product page or an
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`article on Fox News,
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`that page is built from hundreds of small
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`pieces. Like a headline,
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`a button, a piece of graphics, an
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`image, it's all small pieces that are put together to build
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, % aoe
`
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138, Om eee
`
`
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`the VPN that you connected to from your VPN provider, and they
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`home addresses.
`
`Q.
`
`Okay. And let me stop you a minute. And is that the
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`IPR2022-00135, No Federal Official Court Reporter
`IPR2022-00138, ms eee
`
`that page. And when you use a regular VPN all those hundreds
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`of small pieces are requested from the same single server of
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`all went together from the same server,
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`same address,
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`through
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`the website. And,
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`indeed, you were hidden from that website,
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`but they could still see that this page was loaded, it came
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`from an address that was not a home user. And they could even
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`figure out which VPN server you were using.
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`So eventually if enough -- given which authorities were
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`involved and -- you could trace back what you were doing
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`because they knew which door to knock on.
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`They knew which VPN
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`provider you were using,
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`so they could eventually trace back
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`that option that was on the table.
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`And when we're using Hola VPN, what happens is that all
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`these hundreds of small pieces,
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`they were being spread out
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`through millions of people, each one from a different person.
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`I mean,
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`that headline was coming from someone from Louisiana;
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`I don't know, another piece from Los Angeles, New York,
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`Boston.
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`It's all coming together from different places. And
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`when that website looked at what just happened,
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`they couldn't
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`figure out what this was.
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`I mean,
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`they can't trace it back.
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`It's all residential IPs.
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`They can't block it.
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`They can't
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`understand even that you use the VPN service because it's all
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`difference that the IPs were all residential IPs as opposed to
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`something else?
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`A.
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`Yeah.
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`It's not a corporate address; it's all residential
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`IPs and you couldn't piece out together where they are coming
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`from and who is using it and why.
`
`Q.
`
`A.
`
`Is that how you distinguished Hola VPN from other VPNs?
`
`Yeah.
`
`You have to understand that that's a whole
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`different level of privacy, because not only you are hidden
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`from the site, not only you are hidden from the website,
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`they
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`can't even know that you are using a service like a VPN
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`service, and they can't figure out even what you were
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`accessing on the website because all of those small pieces
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`came from different places,
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`they can't even know what you did
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`there.
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`So that's a whole with different level of privacy.
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`Q.
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`Was that successful in that a lot of people wanted to
`
`utilize that service?
`
`A.
`
`Yeah, it was extremely successful.
`
`As soon as it started
`
`to work, a lot of people started to download it.
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`It was very
`
`successful. And without even using any marketing or ads, it
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`just spread out.
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`People were starting to use it and it became
`
`very successful.
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`Q.
`
`A.
`
`And was that a money-making project?
`
`No. Mr. Vilenski and Mr. Shribman decided that we should
`
`not monetize this technology, it should be free, and from that
`
`day up until now Hola VPN is a free service to everyone. And
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, ~ aoe
`
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138, om eee
`
`
`
`we needed to keep looking for something else, another way to
`
`use that technology to make money.
`
`Q.
`
`And did you ultimately find another way to utilize that
`
`technology?
`
`A.
`
`Yeah, we did.
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`Soon after that, we ran into something
`
`issue with being private -- with the privacy on the network,
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`which was a little surprising, but we found out that as the
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`internet grew and all these retailers and services,
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`they all
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`put their products on the network, everything was open. And
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`as they always did, competitors looked at each other's
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`information,
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`the products,
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`the prices, and they were competing
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`and that opened, and free competition is good for all of us
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`because it lowers down the prices.
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`But what started to happen is that these companies,
`
`they
`
`started to see who is going on their website.
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`They said,
`
`Okay,
`
`this is a competitor;
`
`I'm going to block them;
`
`I'm not
`
`going to let them see these prices. And that hurt
`
`competition.
`
`that surprised us. We realized that businesses have a similar
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`And they realized that if they go through our residential
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`network,
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`they can see all of this free competition is back
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`online and they can make the business decisions that would
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`help them compete.
`
`Q.
`
`And is that what Bright Data refers to as a residential
`
`proxy network?
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`IPR2022-00135, en Federal Official Court Reporter
`IPR2022-00138, em. eee
`
`
`
`A.
`
`Yeah.
`
`So when we realized that, we built a proxy
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`interface above this residential network so that businesses
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`can access the network and collect that information, and that
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`became our residential proxy network.
`
`Q.
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`And is that for use by businesses,
`
`though, as opposed to
`
`individuals,
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`for the most part?
`
`A.
`
`Yeah. That was used by businesses, and we -- and it
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`provided the huge value for them, and we realized that this
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`value can be monetized, something -- it's a service that we
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`can charge money for.
`
`Q.
`
`And can you give us an example or two of why a business
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`would want to utilize this residential proxy network of yours?
`
`A.
`
`Yeah.
`
`So as I said, retail competition,
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`that was very
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`obvious. But as we grew, we found a lot more uses for that
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`network, which also surprised us,
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`like social networks that
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`were relying on ads for their revenue. And each ad that was
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`submitted,
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`they validated that it's legal, content is not
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`hurtful for the users, and -- but what happened is that there
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`were bad players in the ad market, and what they did is that
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`they checked if the social network companies were watching
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`their ad,
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`they gave them this valid legal ad, and if home
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`users were watching that ad,
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`they got this illegal content now
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`where phishing sites all these things that were illegal. And
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`that became a real big problem for them, and they realized
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`that if they access those ads through our network they would
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, ener
`
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138, em. eee
`
`
`
`see it as home users and they would be able to block all these
`
`bad players.
`
`Q.
`
`A.
`
`Okay.
`
`Can you give us one more example, briefly?
`
`Sure. Also we had a lot of security companies, big
`
`companies that what
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`they do is hunt these malware sites,
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`phishing sites, all this illegal content that is hurting
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` 272
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`people. And they had a similar problem that these hackers
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`that build these sites,
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`they were detecting that someone from
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`corporate is watching the site,
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`they would give them a content
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`that was legal and good, while people from home that watched
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`the site got that hacking site that could steal your
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`information, and they were unable to track them down.
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`They
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`were hiding from them. And when they accessed those sites
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`through our network,
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`the residential network,
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`they could see
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`the real content and they could bring them down.
`
`Q.
`
`And how long did it take you-all to develop this
`
`residential proxy network on top of the time that you spent
`
`building Hola VPN?
`
`A.
`
`It took almost
`
`two years to get that infrastructure in
`
`place.
`
`Q.
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`And what are the steps a business, at least initially,
`
`would take -- if you can describe to the jury that a business
`
`takes to utilize your system. What do they have to do?
`
`A. Well,
`
`they have to obviously register with our service,
`
`they get a username and password, and they would start sending
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`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, ~ aoe
`
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138, ms eee
`
`
`
`super proxies.
`
`Q.
`
`Okay.
`
`MR. THOMPSON: Mr. Wilson, can we have the next
`
`slide?
`
`their requests for web information to our servers that we call
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`Q.
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`(BY MR. THOMPSON) Mr. Kol, do you recognize this graph
`
`here that's PDX 2.2?
`
`A.
`
`Yeah. That's a diagram of the Bright Data network of
`
`servers and all their connections between them.
`
`Q.
`
`Is this representative of Bright Data's system here as we
`
`sit here today?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Yeah. That's fairly updated.
`
`And who -- do you know who drew this graph here?
`
`I did that.
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`All right. And it has a lot of different parts, arrows.
`
`It seems fairly complicated to me.
`
`Do you consider your
`
`system complex?
`
`A.
`
`Yes, it's a very complex system.
`
`You have to understand
`
`that on this side on the right side was where the residential
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`network exists.
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`It's already the size of tens of millions of
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`devices. And these devices go on and offline every second.
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`They have a good internet connectivity,
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`they have a bad
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`network connectivity, and this changes all the time.
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`It's a
`
`very dynamic network.
`
`And, on the other hand, we have thousands of customers
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`IPR2022-00135, Oo Federal Official Court Reporter
`IPR2022-00138, . eee
`
`
`
`that all they want -- they want access their network so they
`
`don't get blocked, but they want a stable connection, a fast
`
`connection, a reliable and with a high success rate.
`
`So
`
`combining those two things it's a very big technological
`
`challenge that we have eventually resolved.
`
`MR. THOMPSON:
`
`Can we bring up the next slide?
`
`Q.
`
`(BY MR. THOMPSON) And this shows the customers or users
`
`on the left side.
`
`Do you see that?
`
`A.
`
`Q.
`
`Yes.
`
`And who are these customers for the residential proxy
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`network?
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`A.
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`They can be any business,
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`from very small businesses to
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`large corporates, Fortune 500 companies. We even have a few
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`from the very top 10.
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`What do you mean top 10?
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`Top 10 companies of the Fortune 500.
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`Okay. And where are these customers located?
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`All over the world; U.S. and other countries.
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`And how many customers do you have?
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`To date that's over 10,000.
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`Okay. And when a customer makes an initial request, what
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`information is in that request that they provide to Bright
`
`Data?
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`A. Well,
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`they provide the username and password for
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`authentication,
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`the target domain that they want to access,
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, ON oro
`
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138,
`eee
`
`
`
`275
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`and the request itself that we need to send.
`
`Q.
`
`A.
`
`And what is a domain?
`
`A domain is like an address on the internet, similar to
`
`www.amazon.com.
`
`Q.
`
`Okay. And so if they want to make a request to
`
`Amazon.com, what is an example of the information they might
`
`be requesting?
`
`A. Well,
`
`they could be accessing a product page or doing a
`
`search on the site,
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`things like that.
`
`Looking up the price of
`
`a product.
`
`Q.
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`A.
`
`Q.
`
`Okay. And once they make that request, where does it go?
`
`It goes to our super proxy.
`
`All right. And is that what's identified here as the
`
`server, Bright Data server?
`
`A.
`
`Right.
`
`:
`
`.
`
`.
`
`.
`
`So it's a super proxy; a server basically?
`
`Yeah.
`
`It's a pool of servers, yeah.
`
`And what does it do?
`
`It takes the request, it authenticates the customer, and
`
`it sends it -- it chooses a residential consumer device and
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`sends its request onto that site.
`
`Q.
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`And where are these super proxies of Bright Data's
`
`located? 24
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`A.
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`Q.
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`25
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`There are many locations around the world.
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`And how many of them do you have?
`
`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, a aoe
`
`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138, ON ree
`
`
`
`A.
`
`Q.
`
`Over 12,000 servers.
`
`Okay.
`
`So once the server gets the request,
`
`then the next
`
`step --
`
`MR. THOMPSON:
`
`If we can see the next slide.
`
`Q.
`
`(BY MR. THOMPSON)
`
`-- is to send that request to a
`
`residential consumer device.
`
`Is that what you're saying?
`
`A.
`
`Q.
`
`Yes.
`
`And what are examples of residential consumer devices?
`
`A. Well, it can be a mobile phone, it can be a laptop, a
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`desktop computer, even a smart TV.
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`And where are these residential consumer devices located?
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`All over the world.
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`And how many do you have, estimate, as of today?
`
`It's a very dynamic network.
`
`It can be between 40- and
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`70 million devices at a time.
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`Q.
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`And why do you need that many devices?
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`A. Well, now that we have these thousands of customers, over
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`10,000,
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`they create an amount of traffic,
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`a lot of requests
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`for data that are comparable at the peak times they can do in
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`one hour more traffic than Google search worldwide traffic
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`they do in a whole day.
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`So that's a huge amount of traffic,
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`and we need to spread it out over a very big network.
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`Q.
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`And so if you -- you couldn't run your network,
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`I guess,
`
`if you had 10,000 consumer devices as opposed to 40 million.
`
`A.
`
`No, absolutely not.
`
`I mean, eventually on such a network
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`as large as we have,
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`the target is that a single consumer
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`device won't transfer more data than is comparable to a couple
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`of video ads that you see on apps or YouTube in a whole day,
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`so very small amount of data per device.
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`Q.
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`And so how does someone get their consumer device to be a
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`part of your network?
`
`A. Well,
`
`they would have to install our SDK.
`
`Q.
`
`A.
`
`And what is an SDK?
`
`An SDK is a software development kit.
`
`It's likea
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`library that can be imbedded in a different application.
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`Q.
`
`A.
`
`Q.
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`And who develops this SDK?
`
`It's developed at Bright Data.
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`And so how do you get the SDK onto, you know, a phone or
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`a laptop or an iPad or something like that?
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`A.
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`You would have to install an application that includes
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`it.
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`It can be a Bright application or one of our partners.
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`Q.
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`Okay. And so if someone chooses to download one of these
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`apps, are they just automatically part of the network? Or how
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`does that work? Or do they get to choose?
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`A.
`
`No. When -- the first time you run the app you get a
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`consent screen, very clear, it explains who is Bright Data,
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`what do we do, and it gives you the option to opt in or opt
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`out.
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`It's your choice and you can decide.
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`Q.
`
`So no one's going to be a part of your network or have
`
`their device,
`
`their residential consumer device be a part of
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`The Data Company Technologies Inc. v. Bright Data Ltd.
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`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
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`your network without agreeing to it.
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`Is that right?
`
`A.
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`Q.
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`That's right.
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`Okay. And why would they agree to that? Why would they
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`allow their device to be a part of your network?
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`A.
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`We provide a number of benefits in different scenarios.
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`And some applications are costing money, and if you agree to
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`be part of the network you'd get it for free.
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`In other cases
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`there are applications that are monetized by ads, and if you
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`agree to be part of the network you'll get it ad-free. And
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`you can even install one of Bright apps that if you agree to
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`be part of the network you actually can earn real money.
`
`Q.
`
`Okay. And so if someone agrees to have -- they go
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`through,
`
`they consent,
`
`they agree to be a part of your
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`network,
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`is their device being used constantly a hundred
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`percent of the time by your network?
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`A.
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`No. We monitor the device, battery use, memory use, and
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`we make sure that we don't interrupt the user's day-to-day
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`activities.
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`If you are on the phone, if you're streaming a
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`video, we won't be interrupting. We monitor it very
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`carefully. And it's only in use when there are free
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`resources.
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`Q.
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`A.
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`Okay. What do you mean by free resources?
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`I mean that there is enough battery,
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`there is enough free
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`memory, and you're not doing anything with a device right now.
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`Q.
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`And so if I have my phone as part of your network and I'm
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`The Data Company Technologies Inc. v. Bright Data Ltd.
`IPR2022-00135, MS ebop
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`Shawn M. McRoberts TheR&MRGonPRRTechnologiesInc, v. Bright Data Ltd.
`Federal Official Court Reporter
`IPR2022-00138, NS eee
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`using my phone to make a phone call or whatever, would I ever
`
`know that you're actually using my phone also as part of your
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`network?
`
`A. Well, if there are free resources and you're just like
`
`browsing or something, you will not notice ever that it's
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`being used.
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`Q.
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`And if someone agrees to be a part of the network and
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`then decides they don't want to be,
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`they change their mind,
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`can they opt out or get out of it?
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`A.
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`Yeah, you can always opt out.
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`It's in the menus. That
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`option is always available.
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`Q.
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`Is there ever any risk that the personal
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`information on
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`someone's phone or laptop or whatever,
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`that that's at risk of
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`being harvested by someone on your network, or is it secure?
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`A.
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`Absolutely not.
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`It's secure. We're not interested in
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`the device,
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`the information of the users,
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`the private
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`information on the device, we're not interested in it.
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`It is
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`always the case just the pipe.
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`It gets a request, sends it
`
`out, returns the response. We're not interested in anything
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`else.
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`And occasionally we invite security companies that
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`audit this SDK, and they validate that this is exactly what we
`
`do.
`
`Q.
`
`Okay. And so once the consumer device is chosen and it
`
`receives the request, what happens to that request?
`
`A.
`
`Then it is sent to the web server, and the web server
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`The Data Company Technologies Inc. v. Bright Data Ltd.
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`sends its response back, and then it makes all the way in the
`
`proxy, and then all the way back to the customer that sent the
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`original request.
`
`MR. THOMPSON: And so this final slide here, 2.7.
`
`Q.
`
`(BY MR. THOMPSON)
`
`In your opinion,
`
`is this a fair,
`
`high-level depiction of Bright Data's residential proxy
`
`network?
`
`A.
`
`Yes.
`
`It's very, very simplified, but
`
`in high level it
`
`represents fairly the network.
`
`Q.
`
`And when you-all developed this at Bright Data, were you
`
`aware of any other company having any type of residential
`
`proxy network like this?
`
`A.
`
`Q.
`
`No,
`
`I was not aware.
`
`All right.
`
`Thank you, sir.
`
`same path to the residential consumer device back to the super
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`MR. THOMPSON:
`
`I'll pass the witness, Your Honor.
`
`THE COURT: Cross examination by the Defendants?
`
`Go ahead, Mr. Leventhal.
`
`MR. LEVENTHAL:
`
`Thank you, Your Honor.
`
`CROSS EXAMINATION
`
`BY MR. LEVENTHAL:
`
`Q.
`
`You've been working with Hola and now Bright Data for
`
`over a decade. Correct?
`
`A.
`
`Correct.
`
`And during that time you designed several products.
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`the United States. Correct?
`
`A.
`
`Yeah, probably a few thousand even.
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`The Data Company Technologies Inc. v. Bright Data Ltd.
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`Right?
`
`A.
`
`Q.
`
`Right.
`
`Right. And you'd agree with me that when you are
`
`designing a communication product,
`
`there is countless design
`
`choices that you make along the way. Right?
`
`A.
`
`Q.
`
`Obviously, yeah.
`
`First, you've got do decide on the big picture
`
`architecture,
`
`the boxes and how they are arranged with each
`
`other. Right?
`
`A.
`
`Q.
`
`Yeah, could be.
`
`Okay. And then you need to decide where each of those
`
`boxes are going to be physically located. Right?
`
`A.
`
`Q.
`
`I'm not sure what you mean.
`
`You talked earlier about the super proxies and you made a
`
`decision about where Bright Data puts those around the world.
`
`Right?
`
`A.
`
`Q.
`
`Yeah.
`
`And that was a decision, a design decision you made as
`
`you designed your network. Right?
`
`A.
`
`When we built the interface for the proxy residential
`
`network, yeah.
`
`Q.
`
`And,
`
`in fact, Mr. Kol, you have several hundred
`
`thousand -- excuse me, several hundred super proxies within
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`Q.
`
`And that's a design choice you made. Another company
`
`with a different residential proxy network could have had a
`
`different design choice and not put servers within the United
`
`States. Correct?
`
`A.
`
`Q.
`
`Yeah, could be.
`
`If they did so, it's still a residential proxy network
`
`just with a different design. Right?
`
`A.
`
`I would have to look at the entire design to be sure, but
`
`it's a choice.
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`Q.
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`If we could put up your demonstrative PDX 2.8.
`
`Now, having the super proxy at all was a design choice
`
`that you made. Correct?
`
`A.
`
`Yeah, you would need -- the super proxies are the
`
`gateways,
`
`the entry point to the residential network, so they
`
`have to exist in some form.
`
`Q.
`
`A.
`
`Q.
`
`So it's a key part of your architecture. Right?
`
`It's the gateway to enter the residential network.
`
`If the super proxy does not perform its role, Bright Data
`
`couldn't offer its service. Right?
`
`A.
`
`If the super proxy did not exist, customers could not
`
`access the network.
`
`MR. LEVENTHAL: Okay.
`
`So I'd like to now go to
`
`PX 517, please.
`
`Q.
`
`(BY MR. LEVENTHAL)
`
`And this document relates to
`
`something else you discussed with counsel.
`
`You talked about
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`The Data Company Technologies Inc. v. Bright Data Ltd.
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`(The following was had in the presence and hearing
`
`of the jury.)
`
`THE COURT: Ladies and gentlemen of the jury, we're
`
`going to recess for the day at this juncture. There's not
`
`another witness that's ready to be called that won't take at
`
`least a couple of hours,
`
`so we're not going to do that and
`
`start that this afternoon at this point.
`
`Please remember to take your notebooks with you when you
`
`leave the courtroom and go into the jury room.
`
`Please leave
`
`them closed on the table in the jury room so they'll be
`
`available for you tomorrow.
`
`Please remember all the instructions that I've talked
`
`with you about,
`
`including that unless you live alone, when you
`
`get home you're going to be asked what went on today. Don't
`
`even try to answer that question.
`
`Please keep all my
`
`instructions in mind,
`
`including not to communicate in any way
`
`about the case.
`
`Please travel safely to your homes.
`
`I'd like to have you
`
`back in the morning assembled in the jury room before 8:30.
`
`And we'll try to proceed at 8:30, or as close to it as
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`possible.
`
`With that,
`
`ladies and gentlemen, you are excused for the
`
`day.
`
`I'll see you tomorrow morning.
`
`(Whereupon,
`
`the jury left the courtroom.)
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`THE COURT:
`
`Be seated, please.
`
`Counsel, according to my records, we've used 2 hours and
`
`between 30 and 31 minutes today.
`
`I've allocated that an hour
`
`and almost 28 minutes, an hour and 27 minutes and 45 seconds
`
`to the Plaintiff, and the Defendants have used an hour and 2
`
`minutes and 56 seconds, call it an hour and 3 minutes.
`
`Are there issues or questions that either side needs to
`
`take up with the Court before we recess for the evening?
`
`Anything from Plaintiff?
`
`MR. HARKINS: No, Your Honor.
`
`COURT: Anything from Defendants?
`
`MR. SMITH: No, Your Honor.
`
`have us prepared to address those with you in the most
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`THE COURT: Let me remind you of your ongoing
`
`obligation to meet and confer with regard to overnight
`
`disputes. We went
`
`through a lot of demonstrative disputes in
`
`chambers this morning. We had a little more time because of
`
`jury selection. We won't have that much time going forward.
`
`Try to narrow those, if you will, counsel. There's no real
`
`reason that you can't. But assuming that there are disputes
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`that do survive your ongoing overnight efforts to resolve
`
`them, I'll be available in chambers by 7:30 to meet with you
`
`and give you guidance on those.
`
`Follow all my existing procedures and protocols that
`
`we've discussed in pretrial as to how to notify my staff and
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`The Data Company Technologies Inc. v. Bright Data Ltd.
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`efficient way possible.
`
`If there aren't other issues that need to be raised, we
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`stand in recess until tomorrow morning.
`
`(The proceedings were concluded at 5:40 p.m.)
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