`
`BRIGHT DATA, LTD.,
`Plaintiff,
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
` ( CAUSE NO. 2:19-CV-395-JRG
` )
` (
` )
` (
`vs.
` )
` ( NOVEMBER 3, 2021
`TESO, LT UAB, et al
` ) MARSHALL, TEXAS
` ( 8:30 A.M.
`Defendants.
`______________________________________________________________
`
`
`
`VOLUME 3
`
`______________________________________________________________
`TRIAL ON THE MERITS
`BEFORE THE HONORABLE RODNEY GILSTRAP
`UNITED STATES CHIEF DISTRICT JUDGE
`and a jury
`______________________________________________________________
`
`SHAWN M. McROBERTS, RMR, CRR
`100 E. HOUSTON STREET
`MARSHALL, TEXAS 75670
`(903) 237-7464
`shawn_mcroberts@txed.uscourts.gov
`
`Shawn M. McRoberts, RMR, CRR
`Federal Official Court Reporter
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`statement?
`A.
`Yes.
`Q.
`And Tesonet, founders of Oxylabs, please tell the jury
`how you came up with the name Tesonet.
`A.
`So, you know, when I've -- with my business partner, we
`met -- we knew each other when we were little, and we
`came -- we had -- just a company, and we had some very fancy
`name. I don't remember, but it was very, very something about
`group global, something like that.
`And when we came to register it, it was a very rainy day
`in Lithuania. And we stand in the line, and they said this is
`taken, you have to, you know, figure out or go back into the
`line.
`
`So we did, you know, the old-fashioned way, how we can
`call it. We came up with Tomas, Eimantas Sabaliauskas, which
`is his last name, and my last name Okmanas, Teso, and net as
`internet. Tesonet.
`MR. GOVETT: Now, you can take that down, please?
`(BY MR. GOVETT) How did you meet Mr. Sabaliauskas?
`Q.
`So I met him actually online in internet. He was from a
`A.
`small village in Lithuania, and I was from Vilnius. And from
`my early days, I was spending time online and we chatted. I
`think we chatted for the first six years. We met in person
`only after he came to Vilnius to study in Vilnius University
`as well.
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`And did -- what did you do together? Did you eventually
`Q.
`get work together?
`A.
`Yeah. He -- his background is in computer science, so
`his bachelor degree is in computer science. But he is a
`marketing guy.
`And I, over the years in internet service provider,
`taught myself. And I was very passionate about computers.
`And I taught myself about network, about servers, about
`computers in general.
`And we thought our, you know, strengths and weaknesses
`cover each other and his marketing knowledge, even though with
`computer science background, and my technical knowledge with
`business would be a good and powerful combination.
`Q.
`And how many projects did the two of you end up working
`on?
`So we did -- until we found the right one, we calculated
`A.
`that it was 34 projects or products that we did until we found
`the right one.
`Q.
`And in those 30-some-odd products or projects, did you
`have any failures?
`A.
`We don't call it failures. We never call anything a
`failures.
`Q.
`What do you call it?
`A.
`We call it divots, because you fail when you stop, and we
`never stopped.
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`Now, how did Teso start?
`Q.
`So Teso started in my mom's and dad's apartment in
`A.
`Vilnius. And we've been doing those products. But in 2012 or
`early '13, a lot of things changed.
`Q.
`And what is Tesonet today?
`A.
`So currently we -- our -- the biggest tech employer in
`Lithuania. We are a company that has 2,000 people. We are
`one of the biggest taxpayers in the country. We are a big
`technology company.
`Q.
`Who owns Tesonet?
`A.
`From the start until today, the company is owned by a
`Eimantas, myself, and all the employees are shareholders as
`well.
`Is there any other ownership other than Mr. Sabaliauskas,
`Q.
`yourself, and the employees?
`A.
`No. It's just us.
`Q.
`Now, what products does Tesonet have?
`A.
`Currently we have two products. One is in cyber security
`space. Another is Oxylabs.
`Q.
`And what companies does Tesonet have?
`A.
`We have in terms of legal entities or --
`Q.
`Yes, sir.
`A.
`So we have Teso LT, Metacluster, you know, Core Cigna,
`and like Core 200 and many others.
`THE COURT: Be sure to speak up so our reporter can
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`hear you.
`
`THE WITNESS: I'm sorry.
`THE COURT: That's okay.
`(BY MR. GOVETT) How does Oxylabs relate to Teso?
`Q.
`So Oxylabs is just a Tesonet product.
`A.
`How does Metacluster relate to Teso?
`Q.
`Metacluster is Oxylabs' legal entity's name.
`A.
`Has Oxylabs grown in the last few years?
`Q.
`Yes, it did.
`A.
`Tell us what it's like to work at Oxylabs.
`Q.
`You know, people say that to work to do -- at work we're
`A.
`family, but we really mean it, because one of the first
`employees, you know, team members that joined and still is, is
`my wife. She works at HR.
`Eimantas' wife works in marketing. All of my, you know,
`best friends work at the company. My classmates work at the
`company. Mr. Cerniauskas that you saw earlier who is the CEO
`of Oxylabs, his sister works in the legal department of
`Oxylabs, and she is -- actually she got married to the first
`team member that joined, Jytautas.
`So we are family. And we -- you spend so much time at
`work, you have to treat them as family. So I'm not sure --
`you know, we do a lot of things together, but at the company
`we work only four days and a half. Fridays we have off.
`We have extra health insurance. We have extra pension.
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`Not talking about free food or anything else, but we have, you
`know, every three months we gather together, we have corporate
`events or, you know, we call it parties, in a way.
`Once in a year, we go to holidays together. We call it a
`work-cation where we work for four hours and the rest of the
`time we spend time together.
`Q.
`Now, Mr. Okmanas, I want to put up a demonstrative, but
`before I do, please use Mr. or Ms. just for the purposes of
`the record.
`A.
`I'm very sorry.
`Q.
`That's okay.
`MR. GOVETT: Now, if we could look at DDX 4-1,
`
`please.
`Q.
`(BY MR. GOVETT) What do we have here?
`A.
`This is a trip where we're going on the plane with
`all -- with not all, but another plane, there is others, to
`Spain for a week on a holiday for a work-cation.
`Q.
`Is that why everybody's smiling?
`A.
`I hope so.
`Q.
`Okay.
`MR. GOVETT: Now let me show you opening slide 53,
`if we could, please.
`Q.
`(BY MR. GOVETT) Did -- so this slide states, Oxylabs
`believes that the evidence will show independent development,
`five people worked 17 months, Oxylabs did not use, want, or
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`need Bright Data's patents. Is that true?
`A.
`Completely true.
`MR. GOVETT: You can take that down, please.
`(BY MR. GOVETT) Now, in the process of developing your
`Q.
`product, did Oxylabs take a look at what Bright Data and other
`competitors were doing in the marketplace?
`A.
`Yes, of course.
`Q.
`Did you look at public information?
`A.
`Yes.
`Q.
`By the way, before I move off of this, the individuals
`that we saw on that airplane a moment ago, did they all work
`at Oxylabs?
`A.
`Yes.
`Q.
`What's Oxylabs' greatest asset?
`A.
`People.
`Q.
`Why?
`A.
`We don't have trucks or buildings. We just have people.
`The company is built by them. So we need to take care -- we
`take care of them.
`Q.
`Now, let's go back to the independent development. When
`you looked in the marketplace, what did you see?
`A.
`So there were multiple providers in the space. Obviously
`maybe at that time Luminati was one of the bigger ones. I
`didn't do research about this sizing, but in the same time we
`looked at everyone because we wanted to make it better.
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`After you did your public research, what did you do next?
`Q.
`We sat down with the guys and we thought how we can make
`A.
`it better and we started developing it.
`MR. GOVETT: Let me show you Plaintiff's Exhibit
`484, if I could, please, starting at page 1.
`Q.
`(BY MR. GOVETT) What is this?
`A.
`This is our website.
`MR. GOVETT: If we can go to page 5, please.
`(BY MR. GOVETT) It says, how companies use our proxy
`Q.
`service. Do you see that?
`A.
`Yes.
`
`MR. GOVETT: Now let's look at page 7.
`(BY MR. GOVETT) See in the middle, if we could pull that
`Q.
`out, reliable proxy services?
`A.
`Yes.
`Q.
`Tell the jury what this is intending to convey, please.
`A.
`So what our technology does, we always go and collect the
`data. When we do the pricing checks, we cannot have them old
`or, you know, outdated from yesterday. Our customers need it
`on the exact time on the millisecond level. So we always go
`to the website. It can be, you know, American Airlines, and
`we always check it and we always come back and give that to
`the customer.
`So it means that if it would be old one day or two days,
`the customers would just -- wouldn't buy service from us.
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`They need reliable and accurate data.
`Q.
`Did Oxylabs create its own source code?
`A.
`Of course.
`Q.
`Have you ever seen any private Bright Data source code?
`A.
`Never.
`Q.
`Does Bright Data make some of its source code publicly
`available?
`A.
`Yes.
`Q.
`As far as you're aware, has anyone at Oxylabs ever seen
`any Bright Data, Luminati, Hola private source code?
`A.
`They did not.
`MR. GOVETT: Let's look at slide 24 from opening, if
`we could, please. I'm sorry. It should be the timeline from
`the proxy service. There we go. Thank you.
`Q.
`(BY MR. GOVETT) Do you see the timeline at the bottom
`here, sir?
`A.
`Yes.
`Q.
`Was October 2016, is that the date when Oxylabs'
`residential proxy service began development?
`A.
`Correct.
`Q.
`And is February 2018 when Oxylabs' residential proxy
`service launched?
`A.
`Yes.
`
`MR. GOVETT: You can take that down, please.
`(BY MR. GOVETT) So how long is it about from -- from the
`
`Q.
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`buying products from Oxylabs.
`Q.
`Does Oxylabs do business with eBay?
`A.
`Yes.
`Q.
`With Amazon?
`A.
`Yes.
`Q.
`With Target?
`A.
`Yes.
`Q.
`With Walmart?
`A.
`Yes.
`Q.
`With Pepsi?
`A.
`Yes.
`Q.
`Are there other companies that we may not have heard of?
`A.
`We have a lots and lots of customers.
`MR. GOVETT: You can take that down, please.
`(BY MR. GOVETT) And regardless of their size, is price
`Q.
`important to all these customers?
`A.
`It's really, really important.
`Q.
`Let's talk -- when did you first hear of Hola?
`A.
`Yeah, I heard about a long time ago, maybe '12, 2012 or
`so.
`And when the name Luminati came about, is that when you
`Q.
`heard about Luminati?
`A.
`Yes.
`Q.
`Was Hola and Luminati a customer of Oxylabs?
`A.
`Yes.
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`MR. GOVETT: If we look at Defendants' Exhibit 80,
`please. If we can blow up the top?
`Q.
`(BY MR. GOVETT) This is an agreement entered into as of
`December 2nd, 2015, between Hola Networks and UAB Tesonet.
`Tell us about this agreement, please.
`A.
`So, historically, Hola or Luminati were in the
`residential proxy space and we were in data center proxy
`space. And back in the early days, I reached out to Mr.
`Vilenski, and we had chats back and forth, and they became our
`customer. They started buying data center proxies from us.
`Q.
`And we see there Hola has developed, owns, and offers its
`users the Luminati service, the Hola system, partner has also
`developed, owns, and offers its users an alternative solution
`partner system. Is the partner system your system?
`A.
`Yes.
`Q.
`And if we look in paragraph 1, the services, during the
`term of this agreement, Hola shall be entitled at its
`discretion to transfer its user's internet traffic through
`network proxies provided by partner through the partner
`system. Is that what you're referring to?
`A.
`Yes.
`Q.
`You could take some of their extra traffic?
`A.
`Yes. So when they didn't have the capacity on their
`residential pool, they would send the traffic to us.
`Q.
`Did you have any access to their technology?
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`trail further.
`MR. MANN: I understand. I just want to make sure
`what I can say.
`THE COURT: If you have a question, now's the time
`
`to ask me.
`
`MR. MANN: And that's why I'm asking, because I
`don't want to come back here, is that they removed their SDK
`from their product.
`THE COURT: You can say based on --
`MR. MANN: I can say they removed their SDK from
`their product.
`THE COURT: We'll go that far, but no further.
`All right. Let's proceed.
`(The following was had in the presence and hearing
`of the jury.)
`THE COURT: All right. Let's proceed.
`MR. MANN: Thank you, Your Honor.
`(BY MR. MANN) Mr. Okmanas, my question is, you removed
`Q.
`your SDK from your product. Correct?
`A.
`We decided to discontinue SDK from Oxylabs, yes.
`Q.
`Okay. And the SDK, again, is what?
`A.
`It's a software development kit.
`Q.
`All right. Now, at some point in 2015, you knew of a
`company that sold residential proxy services named Hola or
`Luminati. Correct?
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`I knew Luminati, yes.
`A.
`All right. Now named Bright Data.
`Q.
`Yes.
`A.
`Yep. And isn't that company -- let's just talk about
`Q.
`today. Isn't that a company that you knew at that time was a
`leader worldwide in proxy services?
`A.
`Leader is a strong word, but yes.
`Q.
`All right. It is a company that even today you know as a
`leader in proxy services.
`A.
`I wouldn't say that anymore.
`Q.
`Okay. It is a company that you would like to own.
`A.
`Definitely not.
`Q.
`Okay. You've never indicated at any time that you would
`like to own Bright Data?
`A.
`In what way own?
`Q.
`You have never made an inquiry to the company that you
`would like to buy them or own them?
`A.
`I've -- multiple times I've said to Mr. Vilenski and to
`other guys that I've spoke with, Mr. Lenchner, that we could
`do something big together.
`Q.
`Okay. As partners.
`A.
`As -- in whatever form. I was not -- I don't have a form
`in me. Partners, friends, co-owners, whatever. Just open
`discussion.
`Q.
`Okay. But you would like to -- for them to sell to you,
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`time, you got -- had a communication with Mr. Vilenski where
`you wanted to meet with him, and you and he actually met.
`Correct?
`A.
`Correct.
`Q.
`And you worked out a deal where you said you-all could
`kind of work together a little bit maybe, and them use some of
`your data information and you use some of their residential
`information?
`A.
`No.
`Q.
`What did you work out?
`A.
`We had the same contract where Hola was buying services
`from us.
`Q.
`Okay. Now, after you met with Mr. Vilenski, you also
`somehow or another got a Luminati document about collect
`reliable information, Plaintiff's Exhibit 204.
`MR. MANN: If we could put that up. And if we look
`at the second -- let's just flip through it, Mr. Wilson.
`Q.
`(BY MR. MANN) If we flip through it and -- I don't want
`to read it all to you because it can be looked at later, but
`is this information that you had collected on Luminati after
`you had met with Mr. Vilenski?
`A.
`It is public information, yes.
`Q.
`Okay. And so is it true that at that time you had
`become -- or you believed that, for your company to be
`successful, you needed to do what Luminati and Hola were
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`doing?
`A.
`In order to be successful?
`Q.
`Yes, sir. That was my question, yes.
`A.
`Yes.
`Q.
`Okay. Now, at that time, Oxylabs did not have a product
`that used consumer products like phones as proxies in 2015 and
`'16. Isn't that correct?
`A.
`No, we did not.
`Q.
`All right. And if we look at --
`MR. MANN: If I could have 228, Mr. Wilson.
`(BY MR. MANN) This email is dated May 29th, 2017, so
`Q.
`we're skipping forward a couple of years. And it
`concludes -- it has a message to SimilarWeb, which you and Mr.
`Govett talked about earlier. Correct?
`A.
`Correct.
`Q.
`And so you had SimilarWeb collect more intelligence on
`Luminati, or Bright Data. Correct?
`A.
`I just used the service that said they had it collected.
`I didn't ask them to collect any.
`Q.
`Well, you didn't use the service here; you actually
`talked to somebody at SimilarWeb, didn't you?
`A.
`It is the founder and CEO that I emailed him.
`Q.
`Okay. The founder -- I mean, most folks can't just email
`the founder and CEO to get information, can they?
`A.
`They can.
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`could be successful if they used your data center information
`and you used some of their residential information?
`A.
`We shared a very high-level talk both ways.
`Q.
`Okay. All right. And then immediately after that
`meeting, you started to implement a virtual private network
`which you had never had at Oxylabs. Correct?
`A.
`I had NordVPN from 2012.
`MR. MANN: Now, let's pull up Exhibit 221.
`(BY MR. MANN) In this subject line, you say Hola SDK.
`Q.
`Correct?
`A.
`Correct.
`Q.
`In 2016. Who is Sharon Favish?
`A.
`She is office manager at Hola.
`Q.
`Okay. So you were trying to communicate with them to get
`more information, correct, about Hola and SDK?
`A.
`Ofer emailed me, not I did, if you go down.
`Q.
`Okay. And then right after that, November 16th --
`MR. MANN: If you could pull up Exhibit 222.
`(BY MR. MANN) -- within a week Mr. -- is it Cerniauskas?
`Q.
`Correct.
`A.
`Mr. Cerniauskas, who is -- is he a co-owner of the
`Q.
`business, Mr. Cerniauskas?
`A.
`You can say so. He's the CEO, yes.
`Q.
`Of Oxylabs?
`A.
`Yes.
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`Federal Official Court Reporter
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`All right. Mr. Cerniauskas is talking to you and
`Q.
`down -- let's go to the middle where he says, I am Tom from
`Lithuania, and I am looking for a company that could make me
`an extension and promote it. Basically what I am looking for
`is a system that works like hola.org. Correct?
`A.
`Correct.
`Q.
`All right. So you're communicating with another company
`to try to do the same thing that hola.org does. Correct?
`A.
`No.
`Q.
`Let's go down further. I would like you to put either in
`your existing extensions a code that I could use or IP proxies
`I could use and scrape some internet targets. I may need an
`HTTP proxy.
`And then you go on. That's because you wanted to operate
`in private -- in secrecy where somebody could -- where you
`could put your company into an extension in another company.
`Correct?
`A.
`No.
`Q.
`Isn't that what you're asking somebody to do, I would
`like to put either in your existing extensions a code?
`A.
`I can't agree with your phrasing here.
`Q.
`Okay. And then you said, if you cannot add this to your
`existing extensions, I would like you to create some and I
`would promote myself. Correct?
`A.
`It does say that, yes.
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`Federal Official Court Reporter
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