Dunstan et al v. comScore, Inc.

Filing 176

DECLARATION of Robyn Bowland regarding memorandum in opposition to motion 175 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Errata J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(Bowland, Robyn)

EXHIBIT C
PARTIALLY FILED
UNDER SEAL

1
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of
a class of similarly situated
individuals,
Plaintiffs,
vs.
COMSCORE, INC., a Delaware
corporation,
Defendant.

)
)
)
)
)
)
) Case No. 1:11-5807
)
)
)
)
)

*** CONFIDENTIAL -- ATTORNEYS' EYES ONLY ***

The 30(b)(6) deposition of COMSCORE, INC.
by MICHAEL BROWN, called for examination, taken
pursuant to the Federal Rules of Civil Procedure of
the United States District Courts pertaining to the
taking of depositions, taken before JENNIFER L.
WIESCH, CSR No. 84-4528, a Notary Public within and
for the County of Will, State of Illinois, and a
Certified Shorthand Reporter of said state, at 350
North LaSalle Street, Suite 1300, Chicago, Illinois,
on the 15th day of August, A.D. 2012, at 9:36 a.m.

Job No: 26674

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

A P P E A R A N C E S:
On behalf of Plaintiffs:
EDELSON McGUIRE, LLC
350 North LaSalle, Suite 1300
Chicago, Illinois 60654
BY: RAFEY S. BALABANIAN, ESQ.
[e-mail]
CHANDLER GIVENS, ESQ.
[e-mail]
BEN THOMASSEN, ESQ.
[e-mail]

4
1
2
3
4
5
6

I N D E X (Continued)
E X H I B I T S (Continued)
Number
Description
Page
Brown Exhibit
Exhibit 9
comScore PermissionResearch
Registration Flow, July 2009,
Bates Nos. CS0016680 through
CS0016692

7

Exhibit 10
8

Changes to avoid false AV
detection, Created: Jul 21, 2011,
3 pages

10
11
12
13
14

Exhibit 11
On behalf of Defendant:
QUINN EMANUEL URQUHART & SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, Illinois 60661
312-705-7400
BY: ANDREW SCHAPIRO, ESQ.
[e-mail]
ROBYN M. BOWLAND, ESQ.
[e-mail]
ALSO PRESENT:
MR. THOMAS S. CUSHING III,
comScore Deputy General Counsel and
Privacy Officer;
MR. AMIR MISSAGHI, Summer Associate.

INDEX
Examination
Page
MICHAEL BROWN
Examination By Mr. Balabanian

5

EXHIBITS
Number
Description
Page
Brown Exhibit
Exhibit 1
comScore, Inc. vs. The Nielsen 14
Company (US), LLC and NetRatings,
LLC, Defendants' Brief in
Opposition to Plaintiff comScore's
Motion for Proposed Claim
Constructions and Partial Summary
Judgment of Infringement, 39 pages
Exhibit 2
Harris & Dunstan vs. comScore, 21
Inc., Plaintiffs' Revised Notice
of Rule 30(b)(6) Deposition of
Defendant comScore, Inc., 6 pages

15

Exhibit 3
16
17
18

comScore Software Distribution 98
Program Software Bundle Guidelines
For New Partner, Bates Nos.
CS0016693 through CS0016705
Exhibit 4
Exhibit A, PremierOpinion Terms of 116
Service, 2 pages

19

Exhibit 5
20
21
22

XML file containing different
127
pieces of the Terms of Service or
URL agreement for multiple brands
in multiple languages, 24 pages
Exhibit 6
Various contents, Bates Nos.
163
CS0015891 through CS0016005

23

Exhibit 7
24
25

231

9
10
11

comScore Ticket No. 271, Bates No. 233
CS0016504
Exhibit 12
comScore Ticket No. 277, Bates No. 236
CS0016515

12

* * *
13
14
15
16
17
18
19
20
21
22
23
24
25

3
1
2
3
4
5
6
7
8
9

227

comScore Ticket No. 22, Bates No. 203
CS0016053
Exhibit 8
comScore Ticket No. 180, Bates No. 212

5
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
(WHEREUPON, the witness was duly
sworn.)
MR. BALABANIAN: This is the deposition and
oral examination of defendant comScore's witness
designated under Federal Rule of Civil Procedure
30(b)(6), pursuant to notice and continued by
agreement of the parties.
MICHAEL BROWN,
called as a witness herein, having been first duly
sworn, was examined and testified as follows:
EXAMINATION
BY MR. BALABANIAN:
Q. I'd like to go over a few ground rules,
Mr. Brown. My name is Rafey Balabanian. I am an
attorney for plaintiffs, Mike Harris and Jeff
Dunstan. I'm joined to my left with Ben Thomassen,
who's also an attorney for plaintiffs, and Chandler
Givens sitting next to Ben, another attorney, and
then my summer associate, Amir Missaghi.
I just want to talk about a couple ground
rules before we get into the questioning and
whatnot. Have you ever been deposed before?
A. I have.
Q. Okay. So I need verbal answers from you.

2 (Pages 2 to 5)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
62
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
Q. So I thought just a second ago that you
said that the software upgrade that superseded
NSCheck came about in 2003. Can you reconcile the
two?
A. Sure.
Q. Please do so.
A. Okay. The functionality of NSCheck was
incorporated into OSSProxy in 2003. Is that more
clear, sir?
Q. Uh-huh. So in 2001, is it correct to say
that panelists were given the option of upgrading to
OSSProxy from NSCheck?
A. No.
Q. Why would that be inaccurate?
A. I believe the question you asked me
was -- the first one was the first version of
OSSProxy, and that was in 2001. We didn't -- it
wasn't installed at that point to panelists in that
year.
Q. Okay. When was the first -- withdrawn.
When did OSSProxy first get installed in
panelists' systems?
A. That was in 2002.
Q. So there was a test phase of OSSProxy

64
1
2
3
4
5
6
8
9
10
11

14
15
16
17
19
20
21
22

63
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

65
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

17 (Pages 62 to 65)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
66
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

68
1
2
3
4
5
6
7
8
9
10
11
12
14
15
16
17
18
19
20
21
22
23

67
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

69
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

18 (Pages 66 to 69)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
82
1

84
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

83
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

85
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

22 (Pages 82 to 85)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
102
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

104
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

103
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

105
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

27 (Pages 102 to 105)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
106
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
Q. -- subsidiaries -- go ahead.
A. The wording you're using is not the same
words I would use. There is registration sites that
execute QA's prescribed process -Q. Okay.
A. -- if things have been completed, as in
the viewing of the terms of service, some of the
privacy disclosures, even for any information that's
captured about like, for example, their name,
address, those all have to happen -- those are
all -- happen, and the disclosure happens first.
After that is completed, then the install the
software is driven through the web page to install
in a machine, similar in the manner of how you would
install the Google toolbar off of its website.
Q. And do you know who -- which websites
allow for direct registration like you just talked
about?
A. If we walk through that list of the ones
you enumerated earlier, I could tell you which ones
are which.
Q. RelevantKnowledge?
A. No.
Q. OpinionSquare?

108
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

107
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

109
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

28 (Pages 106 to 109)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
110
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

112
1
3
4

8
9
1

14
15

25

111
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

113
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

29 (Pages 110 to 113)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
130
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

132
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

131
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

133
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

34 (Pages 130 to 133)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
134
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
program?
MR. SCHAPIRO: Objection, calls for a legal
conclusion.
BY MR. BALABANIAN:
Q. Well, if you -- and I wasn't asking a
question. You testified earlier that it governs
that. Do you know if there's any other terms of
service out there that would somehow govern that
relationship?
A. It would be this that -Q. This is the -A. -- describe -- this is the entirety
from -Q. Okay. So there's no other terms of
service that comScore would say applies or that the
subsidiaries can say applies, these are them?
A. That is correct.
Q. It might be an obvious question -A. I'm just trying to answer your question,
sir.
Q. I want to talk about the -- what
information is collected as set forth in these
terms.
A. Okay.

136
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

135
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

137
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

35 (Pages 134 to 137)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
178
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

180
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

s
.

179
1
3
4
5
6
7
9
10
11
12
14
15
16
17
18
20
21
22
23

181
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

46 (Pages 178 to 181)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
182
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

184
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

183
1
3
4
5

9
10
11

14
15
16

20
21
22

185
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

47 (Pages 182 to 185)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
186
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

188
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
the representation of the date the data was
received.
Q. Okay.
A. Other things you'll see is -- the very
top, you'll see a unique hash of track information.
We take the name of the trunk and information about
it, we run it through an MD5 hash algorithm to
create the unique ID for it.
Q. And do you parse where the track came
from; i.e., the device that it came from?
A. The kind -- if you look at the column of
Kind, the column named Kind indicates the location
of that track.
Q. Okay. So if that -- if that track were
on an iPod, it would identify that location?
A. That is correct.
Q. Okay. Can you flip to Bates No. 15923 in
Brown Exhibit 6.
A. Yes.
Q. You see in the middle of the page where
it says "OSSProxy Rules"?
A. Yes.
Q. Can you just describe for me generally
what is meant by OSSProxy Rules?

187
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
20
21
22
23
24

189
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
A. The software project OSSProxy, also
MacMeter, is designed to reference configuration
information from a remote re -- my tongue is just
losing -- remote locate -- remote resource like a
URL, so the information and -- of the types of
things we want to do or collect can be configured
and adjusted quickly without requiring a new version
of the software to be deployed.
Q. Well, first, the rules, is that another
way of saying instructions, instructions to the
software?
A. I don't think it's really -- like in my
personal opinion from the computer science
definition of things, I think the rules are more
like definitions or lists -Q. Okay.
A. -- versus instructions. There's -instructions to me indicates something that like has
an if-then conditional, and these do not have
embedded in that if-then conditional type of things.
Q. Do you see in the written text under
OSSProxy slash CProxy Rules, there is two paragraphs
right under that subheading? Do you see that?
A. I do.

48 (Pages 186 to 189)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
190
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

192
1
2
3
4
5
6
7
8
9
10
11
12
14
15
16

191
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

193
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

49 (Pages 190 to 193)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
194
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
explain why the rule would be outdated because now
traffic is no longer routed to comScore's proxy
servers?
A. It's outdated because we no longer use
proxy servers, so, therefore, there's no need to
route traffic to proxy servers.
Q. When did comScore stop using proxy
servers?
A. 2005.
Q. Why did it stop?
A. We decided to upgrade the functionality
of our software to no longer require using proxy
servers.
Q. What's a proxy server?
A. Proxy server is a piece of software that
runs on a set of servers that receives requests from
clients; in our case, panelists receive that request
and initiate a new request on behalf of that
requester to a target server; that data is then
returned back to that proxy server, and that data is
then sent from that proxy server to the respective
client.
Q. It's like an intermediary server?
A. Correct. It is acting as an

196
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

195
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
intermediary.
Q. So now is the -- is the data just
directly sent to comScore's servers instead of
routed through a proxy server?
A. In the case of the proxy server, all -all -- give me a second. I'm trying to think of the
best way to explain this. Data would be routed
selectively to our proxy servers, and when we are
operating with proxy servers prior, including and
prior to 2005. With the CProxy running 100 percent
locally, the rules are executed locally on the
panelist's computer, so the information of interest
gets sent to comScore's servers.
Q. From the panelist's computer?
A. From the panelist's computer, correct.
Q. Okay. Can you turn your attention to
kind of halfway down the page where it says XPF.
A. Yes.
Q. Do you know what XPF is?
A. I know what XPF is in relation to this
document, and specifically within this section of
the document.
Q. Okay. Can you explain it to me -A. Sure.

197
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
20
21
22
23
24

50 (Pages 194 to 197)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
210

212
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

211
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
20
21
22
23
24

213
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

54 (Pages 210 to 213)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
214

216
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

1
3
4
5
6
8
9
10
11
12
14
15
16
17
19
20
21
22
23

215
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

217
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

55 (Pages 214 to 217)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
218
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
of information. You have to look for two pieces to
see if that DLL is valid; it has to be present and
registered.
THE WITNESS: If you guys don't mind, I'd like
to take a break when there's an opportune time. I
know you're in the vain here, not urgent, I'd just
like to -MR. BALABANIAN: Yeah, we're just -- I'm
afraid I'm finishing. Let's take one now. How
about five minutes.
(WHEREUPON, a recess was had from
3:59 p.m. to 4:06 p.m.)
BY MR. BALABANIAN:
Q. Why does comScore fuzzify data? Why does
it collect fuzzified data? Why doesn't it just not
collect the data at all?
A. You've got a couple questions in there.
Do you want to break it down into a couple -Q. Yeah.
A. We can take it one by one if you wish.
Q. Yeah. Why does it collect fuzzified
data?
A. We collect fuzzified data because we
don't want to collect data that would be harmful or

220
1
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

219
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

MICHAEL BROWN
identify who that panelist is, you know. The last
thing we want to have is a list of credit card
numbers from panelists. That's an exposure for the
panelist and exposure for us.
Q. It's important to filter the information?
A. In this case, we're not talking about
filtering the information, we're talking about
changing the information. So in this case, with
respect to this, we're changing the information in a
one-way manner that's not reversible; that is the
goal of fuzzification.
Q. Filtering and fuzzifying are two
different things?
A. In my opinion, filtering and fuzzifying
are two different things.
Q. Filtering is just not accepting the data
at all, right?
A. That is one possible -- that is one
possible interpretation of the word filter.
Q. Can you flip to 15930, Mr. Brown?
A. Yes, I am there. Is there a particular
section?
Q. Actually, 15929 is where I'd like you to
start, sorry, in the very bottom. I'm looking at

221
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
18
20
21
22
23
24

56 (Pages 218 to 221)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]

MICHAEL BROWN - CONFIDENTIAL - ATTORNEYS' EYES ONLY
222
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

224
1
2
3
4
5
6
7
8
9
10
11
12
14
15
16
17
18
19
20
21
22
23

223
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

225
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

57 (Pages 222 to 225)
DAVID FELDMAN WORLDWIDE, INC.
450 Seventh Avenue - Ste 500, New York, NY 10123 [phone]