Case 2:17-cv-00514-JRG Document 225-10 Filed 02/21/19 Page 1 of 20 PageID #: 19630
`Case 2:17-cv-00514—JRG Document 225-10 Filed 02/21/19 Page 1 of 20 PageID #: 19630
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`EXHIBIT 9
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` UNITED STATES DISTRICT COURT
` SOUTHERN DISTRICT OF FLORIDA
`WEST PALM BEACH DIVISION
`CASE NO. 14-80651-CIV-DMM
`
`
`ADVANCED GROUND INFORMATION
` SYSTEMS, INC.,
`
` Plaintiff, WEST PALM BEACH, FLORIDA
` vs.
` MARCH 9, 2015
`LIFE360, INC.,
` PAGES 1 - 218
` Defendant.
` DAY I
`
`_________________________________/
`
`
`TRANSCRIPT OF JURY TRIAL PROCEEDINGS
`BEFORE THE HONORABLE DONALD M. MIDDLEBROOKS
`UNITED STATES DISTRICT JUDGE
`
`
`
`
`
`
`
`
`
`APPEARANCES:
`
`FOR THE PLAINTIFF: MARK A. HANNEMANN, ESQ.
` GEORGE E. BADENOCH, ESQ.
` THOMAS R. MAKIN, ESQ.
` ROSE CORDERO PREY, ESQ
` Kenyon & Kenyon
` One Broadway
` New York, NY 10004-1007
`
`
` URY FISCHER, ESQ.
` LOTT & FISCHER
` 355 Alhambra Circle
` Suite 1100
` Coral Gables, FL 33134
`
`
`
`
`
`
`
`Monday, March 9, 2015.
`
`

`

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`D A I L Y C O P Y T R A N S C R I P T
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`I-N-D-E-X
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`VOIR DIRE
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`JURY SWORN
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`OPENING STATEMENTS
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` PAGE
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` 11
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` 50
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` By Mr. Hannemann 69
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` By Mr. Baldauf 83
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`MALCOLM K. "CAP" BEYER, JR.
`MALCOLM K. "CAP" BEYER, JR.
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`INDEX OF WITNESSES
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` Direct Examination by Mr. Hannemann 98
`Direct Examination by Mr. Hannemann
`98
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` Cross-Examination by Mr. Baldauf 128
`Cross-Examination by Mr. Baldauf
`128
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`SANDEL BLACKWELL
`SANDEL BLACKWELL
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` Direct Examination by Mr. Hannemann 135
`Direct Examination by Mr. Hannemann
`135
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` Cross-Examination by Ms. Dickson 156
`Cross-Examination by Ms. Dickson
`156
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`ALEXANDER HARO
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` Videotaped Deposition
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` 181
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`AMY RANBARGER
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` Videotaped Deposition
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` 182
`
`
`
`
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`
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`Monday, March 9, 2015.
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`

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`track of agent locations and runners.
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`During -- in Hawaii, it was used by the Hawaiian
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`Police Department. They had 435 phones for -- because
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`President Obama was going to be there and as were 20 heads of
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`state, and prime ministers were also at that conference, and so
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`they used those phones to keep track of them and to keep track
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`of people they thought would disrupt the APEC conference which
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`was taking place.
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`And then, finally, we had some local ones. We had
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`Stuart Fire Department used it for a short time, north of here.
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`Q. If you take a look at line 37 on the table, it says "Stuart
`
`FD." Is that the entry you're referring to?
`
`A. Yes, it is.
`
`Q. Okay. When was your first LifeRing sale?
`Q. Okay. When was your first LifeRing sale?
`
`A. First LifeRing sale was to NCIS -- excuse me, NRL, Naval
`A. First LifeRing sale was to NCIS -- excuse me, NRL, Naval
`
`Research Lab, and it was for their police department, it's,
`Research Lab, and it was for their police department, it's,
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`labeled here "antiterrorism," they have a research lab in
`labeled here "antiterrorism," they have a research lab in
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`Washington D.C., contracted for us to provide phones and
`Washington D.C., contracted for us to provide phones and
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`software, mostly software to their police department.
`software, mostly software to their police department.
`
`Q. Okay. Let's take a look together at Plaintiff's Exhibit
`Q. Okay. Let's take a look together at Plaintiff's Exhibit
`
`190, please.
`190, please.
`
`And as usual, the first question, Cap, is, do you
`And as usual, the first question, Cap, is, do you
`
`recognize this document? If so, what is it?
`recognize this document? If so, what is it?
`
`A. Well, it's our price list. It lists the items we sell,
`A. Well, it's our price list. It lists the items we sell,
`
`software we sell.
`software we sell.
`
`Monday, March 9, 2015.
`
`

`

`Case 2:17-cv-00514-JRG Document 225-10 Filed 02/21/19 Page 5 of 20 PageID #: 19634
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`MR. HANNEMANN: And, Stan, maybe we could enlarge the
`MR. HANNEMANN: And, Stan, maybe we could enlarge the
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`first one, two, three, four, five, five lines in the table
`first one, two, three, four, five, five lines in the table
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`there. Try and get it as big as we can. Yeah, up one. Up
`there. Try and get it as big as we can. Yeah, up one. Up
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`one.
`one.
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`Yeah, perfect.
`Yeah, perfect.
`
`BY MR. HANNEMANN
`BY MR. HANNEMANN
`
`Q. So let's start with the first line, LifeRing server
`Q. So let's start with the first line, LifeRing server
`
`license. What does that refer to?
`license. What does that refer to?
`
`A. Well, that refers to our server. Now, we provide our
`A. Well, that refers to our server. Now, we provide our
`
`software, you can buy the software for the phone, not buy it
`software, you can buy the software for the phone, not buy it
`
`for the server, you purchase the license for the software. And
`for the server, you purchase the license for the software. And
`
`the first line refers to the server software, and people buy
`the first line refers to the server software, and people buy
`
`the server software, because in the military they don't want us
`the server software, because in the military they don't want us
`
`to know where they are.
`to know where they are.
`
`First responders fall under a thing called HIPAA,
`First responders fall under a thing called HIPAA,
`
`which is a rule to protect the privacy of individuals that have
`which is a rule to protect the privacy of individuals that have
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`a medical problem or something. First responders, police and
`a medical problem or something. First responders, police and
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`fire, therefore, buy the server, as well as some companies
`fire, therefore, buy the server, as well as some companies
`
`have, and it's $30,000. And for that you own the server
`have, and it's $30,000. And for that you own the server
`
`software, and we guarantee it for the first year, and provide
`software, and we guarantee it for the first year, and provide
`
`you updates for the first year as part of that purchase.
`you updates for the first year as part of that purchase.
`
`Q. Okay. And the third line there, LifeRing PDA license, to
`Q. Okay. And the third line there, LifeRing PDA license, to
`
`what does that refer?
`what does that refer?
`
`A. That's the cost for the software if you're buying it,
`A. That's the cost for the software if you're buying it,
`
`again, you own it, for your phone.
`again, you own it, for your phone.
`
`Monday, March 9, 2015.
`
`

`

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`Q. Okay. And the next two lines?
`Q. Okay. And the next two lines?
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`A. The next two lines, you add push-to-talk capability, I
`A. The next two lines, you add push-to-talk capability, I
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`don't know if you would remember the Nextel, where you pushed
`don't know if you would remember the Nextel, where you pushed
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`to talk, that adds that capability to a normal phone. So if
`to talk, that adds that capability to a normal phone. So if
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`you have a smartphone, you'll see a soft switch appear on your
`you have a smartphone, you'll see a soft switch appear on your
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`phone, and you hold down that soft switch and you can say
`phone, and you hold down that soft switch and you can say
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`something, and everybody that's on your network will hear what
`something, and everybody that's on your network will hear what
`
`you said.
`you said.
`
`Q. Okay. Now, these -- the table talks about licenses. And
`Q. Okay. Now, these -- the table talks about licenses. And
`
`the jury's going to hear some evidence later about royalties
`the jury's going to hear some evidence later about royalties
`
`and patent licenses. Just to be clear, are these patent
`and patent licenses. Just to be clear, are these patent
`
`licenses?
`licenses?
`
`A. No, they're not. They're licenses to use the product.
`A. No, they're not. They're licenses to use the product.
`
`Q. Okay. Cap, if you could just look at the tab marked 390
`
`through 401 in your book. And I'd just like to ask you, for
`
`the record, are these copies of AGIS's financial records?
`
`A. I need to find it first.
`
`Q. Yeah, it should be thick.
`
`A. Yes.
`
`Q. Thank you.
`
`Has AGIS ever had a year when it was profitable?
`
`A. We came close one year. Unfortunately, no.
`
`Q. When were you close and how did that happen?
`
`A. 2006, we were working on a classified program that didn't
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`have anything to do with AGIS, actually.
`
`Monday, March 9, 2015.
`
`

`

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`terms of the different pieces and what you meant by maturity?
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`A. Well, the technology. So an example would be, I hadn't
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`seen a mapping system that I thought would be sufficient for
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`that and in factoring an investigation, I found there wasn't a
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`mapping system that was sufficient for that. The
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`communications, I was concerned that it wouldn't be able to
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`keep up with the data rates or those type of things.
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`Q. Okay. Now, when you were working on your prototype, did
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`the PDA or cell phone that you were working with have a GPS
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`built in?
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`A. It didn't. At the time, that GPSs weren't available, so we
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`had to -- to be able to get positional information, I had to
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`use a secondary device, plug into the 232 cord and be able to
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`read that data, to parse and reload and read that data into the
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`system.
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`Q. So the one you were working with did not have internal GPS,
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`but is it correct that there were, maybe, some out there that
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`did?
`
`A. I don't know. The one that we used, the one we picked
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`was -- it could have been there were some out there that did,
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`they weren't Microsoft. Again, you had to be able -- it didn't
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`matter if it had GPS, we couldn't develop against it.
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`Q. Let's take a look at Exhibit 375, if we could.
`Q. Let's take a look at Exhibit 375, if we could.
`
`A. Okay.
`A. Okay.
`
`Q. So what does this document describe?
`Q. So what does this document describe?
`
`Monday, March 9, 2015.
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`

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`A. This is a marketing select sheet that describes the
`A. This is a marketing select sheet that describes the
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`features of LifeRing.
`features of LifeRing.
`
`Q. Okay. And what platforms or hardware does LifeRing run on?
`Q. Okay. And what platforms or hardware does LifeRing run on?
`
`A. LifeRing runs on a PC desktop, tablets, whatever, that runs
`A. LifeRing runs on a PC desktop, tablets, whatever, that runs
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`on Android's either handhelds or heads-up device, or heads-up
`on Android's either handhelds or heads-up device, or heads-up
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`display. You know, something that's using an Android platform.
`display. You know, something that's using an Android platform.
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`There's a scaled-down version that runs on Apple, and there's a
`There's a scaled-down version that runs on Apple, and there's a
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`version that runs on the Blackberry.
`version that runs on the Blackberry.
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`MR. HANNEMANN: Stan, would you mind zooming in on
`MR. HANNEMANN: Stan, would you mind zooming in on
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`the text under the word "features," and then those two
`the text under the word "features," and then those two
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`pictures.
`pictures.
`
`Terrific.
`Terrific.
`
`BY MR. HANNEMANN
`BY MR. HANNEMANN
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`Q. Is -- are the -- is the description in this section of the
`Q. Is -- are the -- is the description in this section of the
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`document accurate as to the features of LifeRing today?
`document accurate as to the features of LifeRing today?
`
`A. It is.
`A. It is.
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`Q. Can you give me an example of how the military might use
`Q. Can you give me an example of how the military might use
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`LifeRing?
`LifeRing?
`
`A. Sure. For military -- that you've got six guys in a Humvee
`A. Sure. For military -- that you've got six guys in a Humvee
`
`that pull up into a town, all six of them get off, they go out
`that pull up into a town, all six of them get off, they go out
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`on patrol, they can see each other, where they're at, where
`on patrol, they can see each other, where they're at, where
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`their resources are, they have communications back if they
`their resources are, they have communications back if they
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`needed support or help. One of the newer features is that they
`needed support or help. One of the newer features is that they
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`can now link directly with artillery and cruise missiles to be
`can now link directly with artillery and cruise missiles to be
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`able to bring in that type of fire, based on what they're
`able to bring in that type of fire, based on what they're
`
`Monday, March 9, 2015.
`
`

`

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`seeing, if they needed support.
`seeing, if they needed support.
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`Q. Okay. How about for First Responders? Can you give me a
`Q. Okay. How about for First Responders? Can you give me a
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`example of how First Responders would use LifeRing?
`example of how First Responders would use LifeRing?
`
`A. First Responders, so you got fire truck pulls up, all the
`A. First Responders, so you got fire truck pulls up, all the
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`fire guys get out, they -- especially if it was a
`fire guys get out, they -- especially if it was a
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`multi-structure event, you could keep track of where all the
`multi-structure event, you could keep track of where all the
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`firemen were, which buildings they went into.
`firemen were, which buildings they went into.
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`If there was something because somebody found that
`If there was something because somebody found that
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`one of the buildings could possibly explode, they could issue
`one of the buildings could possibly explode, they could issue
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`commands of, Hey, there's something about to explode in that
`commands of, Hey, there's something about to explode in that
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`building, everybody get out. And the key piece of that is it
`building, everybody get out. And the key piece of that is it
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`tracks all the people so you know they have to positively
`tracks all the people so you know they have to positively
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`respond and go, Yes, I got that, and so, as opposed to a radio
`respond and go, Yes, I got that, and so, as opposed to a radio
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`call where they just hope they heard it. You know, that they
`call where they just hope they heard it. You know, that they
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`actually have to respond that they positively got it and
`actually have to respond that they positively got it and
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`they're going to respond to it.
`they're going to respond to it.
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`Q. How do users communicate through LifeRing?
`Q. How do users communicate through LifeRing?
`
`A. Well, you can communicate multiple -- different ways, that
`A. Well, you can communicate multiple -- different ways, that
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`visually you can, based on what you see, of what other user --
`visually you can, based on what you see, of what other user --
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`where they're at or where you're at, on the map.
`where they're at or where you're at, on the map.
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`Users can put down indicators or markers of --
`Users can put down indicators or markers of --
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`that -- of things they see. That, you know, police, they see a
`that -- of things they see. That, you know, police, they see a
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`suspicious person and so they could, you know, attach a photo
`suspicious person and so they could, you know, attach a photo
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`to it so they could see that.
`to it so they could see that.
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`They can text, they can chat, that they can
`They can text, they can chat, that they can
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`Monday, March 9, 2015.
`
`

`

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`whiteboard, they can draw on their handset, you know, a map or
`whiteboard, they can draw on their handset, you know, a map or
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`circle something. They can push to talk, to talk to somebody
`circle something. They can push to talk, to talk to somebody
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`directly or talk to a group of people. They can produce video
`directly or talk to a group of people. They can produce video
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`so a person, once they start producing video on their cell
`so a person, once they start producing video on their cell
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`phone, on the LifeRing display, all the other users see, well,
`phone, on the LifeRing display, all the other users see, well,
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`that person's producing a video and they click on that person
`that person's producing a video and they click on that person
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`and they click the video button and, poof, they see the video
`and they click the video button and, poof, they see the video
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`that person is showing.
`that person is showing.
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`So if I broke it down, that it's either
`So if I broke it down, that it's either
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`communications, they can touch and call the person, just they
`communications, they can touch and call the person, just they
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`touch the person and it calls them automatically. So if I
`touch the person and it calls them automatically. So if I
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`broke it down, they can do it by voice, they can do it by text,
`broke it down, they can do it by voice, they can do it by text,
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`they can do it by pictures, and they can do it by video.
`they can do it by pictures, and they can do it by video.
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`Q. And the picture that we see here, it says LifeRing PDA in
`Q. And the picture that we see here, it says LifeRing PDA in
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`case, and just to be clear, LifeRing runs on smartphones as
`case, and just to be clear, LifeRing runs on smartphones as
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`well?
`well?
`
`A. It does.
`A. It does.
`
`Q. So are you familiar with how the LifeRing software and the
`Q. So are you familiar with how the LifeRing software and the
`
`LifeRing product are distributed?
`LifeRing product are distributed?
`
`A. I am.
`A. I am.
`
`Q. How do you provide the software to your customers?
`Q. How do you provide the software to your customers?
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`A. There's three different ways it can get provided that it
`A. There's three different ways it can get provided that it
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`can occur because it's a licensed product so that typically the
`can occur because it's a licensed product so that typically the
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`point of contact or the technical point of contact would get
`point of contact or the technical point of contact would get
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`the software and they would get the license keys. And then
`the software and they would get the license keys. And then
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`Monday, March 9, 2015.
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`they would turn around and either distribute that down to
`they would turn around and either distribute that down to
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`people, if they're using their own devices or if they're using
`people, if they're using their own devices or if they're using
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`devices of that organization, the administrator often will just
`devices of that organization, the administrator often will just
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`put it directly on a phone and hand it out to them for the
`put it directly on a phone and hand it out to them for the
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`specific mission they're going on. Additionally, that it can
`specific mission they're going on. Additionally, that it can
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`go out as an e-mail from marketing, that they -- people will
`go out as an e-mail from marketing, that they -- people will
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`send us request to try out the software and so we'll send them
`send us request to try out the software and so we'll send them
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`an e-mail that has a link in it. And then additionally,
`an e-mail that has a link in it. And then additionally,
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`there's a link on the -- on a website that they can download
`there's a link on the -- on a website that they can download
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`that off of.
`that off of.
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`Q. All right. Do you provide the software for free ever?
`Q. All right. Do you provide the software for free ever?
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`A. We do for a temporary basis. That's what marketing,
`A. We do for a temporary basis. That's what marketing,
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`technically, a demo license for a couple months so people can
`technically, a demo license for a couple months so people can
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`try it out, or they can try an exercise or something like that
`try it out, or they can try an exercise or something like that
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`before they purchase it.
`before they purchase it.
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`Q. Is AGIS continuing to develop the LifeRing product?
`Q. Is AGIS continuing to develop the LifeRing product?
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`A. We are.
`A. We are.
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`Q. All right. Has -- have any of LifeRing's --
`Q. All right. Has -- have any of LifeRing's --
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`A. We're hiring.
`A. We're hiring.
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`Q. Go ahead. I should let you complete your answer. I did
`Q. Go ahead. I should let you complete your answer. I did
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`not mean to interrupt, sir.
`not mean to interrupt, sir.
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`A. No, it was an afterthought. We're hiring.
`A. No, it was an afterthought. We're hiring.
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`Q. In Kansas or in Florida?
`Q. In Kansas or in Florida?
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`A. Kansas.
`A. Kansas.
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`Q. All right. Now, have your customers ever praised the
`Q. All right. Now, have your customers ever praised the
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`Monday, March 9, 2015.
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`

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`product?
`product?
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`A. Yes, that we've gotten numbers of positive feedbacks from
`A. Yes, that we've gotten numbers of positive feedbacks from
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`customers.
`customers.
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`Q. Okay. I don't want to go through all of them, but if we
`Q. Okay. I don't want to go through all of them, but if we
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`could look at Plaintiff's Exhibit 191 and you can tell me what
`could look at Plaintiff's Exhibit 191 and you can tell me what
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`that document is.
`that document is.
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`A. This was a letter from the chief of police for the Honolulu
`A. This was a letter from the chief of police for the Honolulu
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`Police Department. As was said earlier, LifeRing was used for
`Police Department. As was said earlier, LifeRing was used for
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`APEC, which is the Asia-Pacific Economic Conference, that
`APEC, which is the Asia-Pacific Economic Conference, that
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`President Obama and 21 other world leaders were there. HPD was
`President Obama and 21 other world leaders were there. HPD was
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`providing security for riots, VIPs, just all of the pieces of
`providing security for riots, VIPs, just all of the pieces of
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`security, so they used our software for coordination of that.
`security, so they used our software for coordination of that.
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`Q. Okay. How about Plaintiff's Exhibit 101? And let's look
`Q. Okay. How about Plaintiff's Exhibit 101? And let's look
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`at the second page of that.
`at the second page of that.
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`A. There was an exercise we were doing, NIE, that we were at
`A. There was an exercise we were doing, NIE, that we were at
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`three different locations -- San Diego, Fort Huachuca, and Fort
`three different locations -- San Diego, Fort Huachuca, and Fort
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`Bliss -- that the Joint Tactical Networking Center had some
`Bliss -- that the Joint Tactical Networking Center had some
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`satellite things they were trying out and that they were really
`satellite things they were trying out and that they were really
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`happy how LifeRing worked because it handled both the slow
`happy how LifeRing worked because it handled both the slow
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`bandwidth over satellite, high bandwidth over cellular
`bandwidth over satellite, high bandwidth over cellular
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`seamlessly for the users, and it let them validate what they
`seamlessly for the users, and it let them validate what they
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`were working on. And they used our software for that.
`were working on. And they used our software for that.
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`Q. Okay, thank you.
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`Cap Beyer said something about Hound Dog. Are you
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`working on that project?
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`Monday, March 9, 2015.
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`

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`A. We are.
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`Q. Is a consumer product -- is a consumer product a new idea
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`for you guys at AGIS?
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`A. No. That -- no.
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`Q. All right. When do you remember first talking about a
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`market outside of the military and First Responders?
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`A. In 2005.
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`Q. Okay. Let's take a look at Exhibit 579. Can you tell me
`Q. Okay. Let's take a look at Exhibit 579. Can you tell me
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`if it -- should have it in your book, and we'll see it on the
`if it -- should have it in your book, and we'll see it on the
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`screen -- can you tell me what that document is?
`screen -- can you tell me what that document is?
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`A. Sure. I had tasked Russ Rice to -- to come back and tell
`A. Sure. I had tasked Russ Rice to -- to come back and tell
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`me what were all the hurdles if we were going to release a
`me what were all the hurdles if we were going to release a
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`commercial version of the system, what his recommendations and
`commercial version of the system, what his recommendations and
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`what he felt, you know, because remember he was playing in the
`what he felt, you know, because remember he was playing in the
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`CTO world, so what his evaluation of technology was and what we
`CTO world, so what his evaluation of technology was and what we
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`would need to be doing differently to be able to release to a
`would need to be doing differently to be able to release to a
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`consumer market or public market.
`consumer market or public market.
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`Q. When was this document prepared?
`Q. When was this document prepared?
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`A. November of 2005.
`A. November of 2005.
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`Q. If we could turn to page ending 292, which I believe is the
`Q. If we could turn to page ending 292, which I believe is the
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`third page of the document, and if you could take a look under
`third page of the document, and if you could take a look under
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`the heading, 2.1, Sandel, "target audience."
`the heading, 2.1, Sandel, "target audience."
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`Can you tell me what were -- what your company was
`Can you tell me what were -- what your company was
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`describing and in that section of the document?
`describing and in that section of the document?
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`A. It's what the title is which is, it's the target audience
`A. It's what the title is which is, it's the target audience
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`Monday, March 9, 2015.
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`

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`so who it was intended for, and so the -- it was to be as broad
`so who it was intended for, and so the -- it was to be as broad
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`as possible in what they're offering as opposed to LifeRing,
`as possible in what they're offering as opposed to LifeRing,
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`which had features that were pretty specific for the military.
`which had features that were pretty specific for the military.
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`This offering was to be as broad as possible.
`This offering was to be as broad as possible.
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`Q. Did you go ahead and make this particular version of the
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`product back in 2005?
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`A. We didn't. That -- that -- there were some features that
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`needed to be added to the system. There were some other
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`military contracts we were doing at the time; and so during the
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`2006 period, that we laid in some of the infrastructure to
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`support these types of things; and then in 2007, that we tried
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`a venture to put out a public or consumer app.
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`Q. What venture was that in 2007?
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`A. It was a dating app. And so, you know, from the military
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`perspective, a guy looks at his phone, and it's, Where's the
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`closest ammo, or where's the closest gasoline or whatever. And
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`that you can extrapolate to a dating app of, Okay, where's the
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`closet blond, 35, that plays tennis. And so there were key
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`pieces of that that would -- we thought would work for a dating
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`app. We put together a system for that.
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`I engaged one of the local colleges and I met with a
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`fraternity and sorority, all of the heads of those. I pitched
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`that to them. We even offered to give them cell phones for a
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`couple months and so they could try that, and I just didn't get
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`much of a response.
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`Monday, March 9, 2015.
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`

`

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`see if there was interest?
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`A. Right. Worlds of Fun did not have anything like this, and
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`so that's why that we though this would be a good application
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`for it.
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`Q. Okay. Is it fair to say that there's never been a sale of
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`any AGIS app or product to an amusement park, to use in a way
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`that's proposed in this letter?
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`A. That is correct.
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`Q. Okay. Mr. Blackwell, have you ever used the Life360 app?
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`A. I have not.
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`Q. You understand that Life360 is a commercial app?
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`A. I do.
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`Q. AGIS markets LifeRing, right now, to the military and First
`Q. AGIS markets LifeRing, right now, to the military and First
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`Responder segments, correct?
`Responder segments, correct?
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`A. And others -- other people we market that to, so I would
`A. And others -- other people we market that to, so I would
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`say -- I would also include other foreign governments that use
`say -- I would also include other foreign governments that use
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`our stuff, and governmental agencies.
`our stuff, and governmental agencies.
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`Q. Okay. Would it be fair to say that right now, as we sit
`Q. Okay. Would it be fair to say that right now, as we sit
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`here today, as you sit here and I stand here, there is a --
`here today, as you sit here and I stand here, there is a --
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`AGIS does not have any customer in the nonmilitary,
`AGIS does not have any customer in the nonmilitary,
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`nongovernment, non-First Responder, general public marketplace?
`nongovernment, non-First Responder, general public marketplace?
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`A. I would agree.
`A. I would agree.
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`Q. Okay.
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`Now, you've been talking a bit about an app called
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`Hound Dog that you were developing.
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`Monday, March 9, 2015.
`
`

`

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