TimesLines, Inc v. Facebook, Inc.

Filing 81

DECLARATION of Brendan J. Hughes regarding motion for summary judgment 79 , memorandum 80 (Attachments: # 1 Exhibit 1 - 13, # 2 Exhibit 14 - 17, # 3 Exhibit 18 - 19, # 4 Exhibit 20 - 31, # 5 Exhibit 32 - 35, # 6 Exhibit 36 - 40, # 7 Exhibit 41 - 43, # 8 Exhibit 44 - 46, # 9 Exhibit 47 - 51, # 10 Exhibit 52 - 57, # 11 Exhibit 58 - 59, # 12 Exhibit 60 - 62, # 13 Exhibit 63.1, # 14 Exhibit 63.2, # 15 Exhibit 64 - 71)(Hughes, Brendan)

Exhibit 1

Key Facts - Facebook Newsroom

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4,331 employees at the end of September 30, 2012.

Safety and Privacy
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Statistics

Fact Check

One billion monthly active users as of October 2012.
Approximately 81% of our monthly active users are outside the U.S. and Canada.
584 million daily active users on average in September 2012.
604 million monthly active users who used Facebook mobile products as of September 30,

Contact Info

2012.

[e-mail]

Search

Board Members
Mark Zuckerberg, Founder, Chairman and CEO, Facebook
Marc Andreessen, Co-founder and General Partner, Andreessen Horowitz
Jim Breyer, Partner, Accel Partners
Donald E. Graham, Chairman and CEO, The Washington Post Company
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Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Page 1
1
2

IN THE UNITED STATES DISTRICT COURT

3

FOR THE NORTHERN DISTRICT OF ILLINOIS

4

EASTERN DIVISION

5
6
7

TIMELINES, INC.,

)
)

8

Plaintiff,

)
)

9

vs.

) No. 11-CV-06867
)

10

FACEBOOK, INC.,

)
) Judge John W. Darrah

11

Defendant.

)

___________________________)
12
13
14

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY

15
16
17

VIDEOTAPED DEPOSITION OF BRIAN HAND

18

Chicago, Illinois

19

Thursday, September 20, 2012

20
21
22
23

Reported by:

24

PAULA CAMPBELL, CSR, RDR, CRR, CCP

25

JOB NO. 53018
TSG Reporting - Worldwide

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1

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

calls for the witness to testify to any

3

conversations with his counsel, and foundation.

4

If you can answer the question based on any

5

knowledge that's outside of anything you have

6

discussed with me, you can answer it.

7

The other objection I would make is that

8

it's a denial within the context of a number of

9

other sentences.

10
11
12
13

So I object to the form.

With all that said you can -A.

I don't have anything further to add to

that.
Q.

So you can't answer the question because

14

any response would reveal attorney-client

15

communications?

16

A.

Is that the position here?

Based on what my counsel has just said, it

17

sounds like there is some ambiguity to the question

18

you have asked.

19

Q.

20

Let me state it another way.
Do you, sitting here today, believe that

21

the sentence, "The noun 'timeline' refers to a

22

chronological organization of events or other

23

information" is false?

24
25

A.

No, I believe that is true.

sentence is true.
TSG Reporting - Worldwide

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That one

Page 52
1

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

purposes in order to have the different points on

3

the page searchable by Google.

4

sure the title of the page, plus the other parts of

5

the page, could insert that word to increase our SEO

6

value.

7

Q.

We wanted to make

And the company didn't intend the term

8

timeline in that context, Al Capone Timeline, to

9

describe anything about the information that's

10

featured under Al Capone Timeline?

11

A.

No, it didn't.

12

Q.

If you look under the heading Al Capone

That's correct.

13

Timeline, you will see there are a series of dates

14

listed on the left, and then text and other

15

information immediately to the right of those dates.

16

Do you see that?

17

A.

Yes.

18

Q.

And that runs all the way through the third

19

page of this document.

20

run from 1894 to 1986; is that correct?

And the dates on the left

21

A.

Correct.

22

Q.

And are those dates in chronological order?

23

A.

Yes, they are on this page.

24

Q.

And the dates and the text to the right of

25

them are all aligned horizontally -- vertically;
TSG Reporting - Worldwide

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1
2

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND
Q.

And I notice on the front page the date is

3

September 11th, 2009.

4

recollection, on that date did you give a

5

presentation to Shawmut?

To the best of your

6

A.

Yes.

7

Q.

And just without going into the details,

8
9

what was the general theme of the pitch to Shawmut?
A.

The same as to newspaper companies, a way

10

to organize your events, events here being

11

construction contracts they have completed, as a way

12

to showcase, this is where showcase term came --

13

showcase what you've done as a company in the past.

14

And our thought was

15

engineering/construction companies tend to be very

16

backwards from a sales and marketing perspective.

17

Their future projects, when they are selling, are

18

heavily based on what they've done in the past.

19

if there was a way to showcase the great things that

20

they have done, there might be a revenue

21

opportunity.

22
23
24
25

So

So we decided to pitch them to see if, you
know, this concept would make sense.
Q.

And so was one element of the pitch an

offer to provide the Timelines Showcase or Timelines
TSG Reporting - Worldwide

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1
2

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND
SE feature?

3

A.

Yes.

4

Q.

And would that be something used to provide

5

content via their website?

6

A.

Yes.

7

Q.

If you will look on the fourth page of this

8

document, it's similar to the pages we have

9

considered with -- in the other presentations.

The

10

rectangular box toward the bottom of the page, it

11

says, (Reading:)

12

video, and text presentation with timelines and

13

maps.

14
15

Platform includes built-in photo,

In that context is the company using
timelines in a generic sense?

16

A.

Yes.

17

Q.

And are there images on the top half of the

18
19

page that reflect timelines, in a generic sense?
A.

We have a placeholder on the timelines SE

20

above the map.

21

that was the placeholder for the -- for the

22

timeline.

23
24
25

Q.

I can't see it on this, but I think

How about the image under LifeSnapz.com,

does that reflect a timeline?
A.

No.

No.
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1

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

AFTERNOON SESSION

3

(Time noted: 12:57 P.M.)

4

VIDEOGRAPHER:

It's the beginning of DVD

5

No. 3 of the testimony of Brian Hand.

6

12:57 P.M.

7
8
9
10
11

B R I A N

We are back on the record.

H A N D,

resumed and testified as follows:
CONTINUED EXAMINATION
BY MR. WILLSEY:
Q.

12
13

It is

Okay.

Back on the record after lunch.

Mr. Hand, is the term timeline used on the
LifeSnapz website?

14

A.

Yes.

15

Q.

Do you know whether it's used generically

16

in some instances?

17

A.

It's used generically, yes.

18

Q.

And LifeSnapz is just part of Timelines,

19

Inc.?

20

A.

Yes.

21

Q.

So is it correct to say that Timelines,

22

Inc. uses the term timelines generically in some

23

instances?

24

A.

Yes.

25

Q.

I'll show you a document that we'll have
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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

provide.

3

newspapers, and it could also support everything we

4

are doing at Timelines.com.

5
6

Q.

So for Timelines.com we've got SEO.

We've

got Bob Armour doing outreach, making calls.

7
8

So we could provide a great service to the

Was Timelines.com promoted at any
conferences that you attended?

9

A.

Not that I recall, no.

10

Q.

Any television ads for Timelines.com?

11

A.

No.

12

Q.

Radio ads?

13

A.

No.

14

Q.

How about keyword search term advertising?

15

A.

I think you asked that of Bob yesterday.

I

16

don't know if we did or didn't.

17

didn't -- we may have done a small amount of keyword

18

buying, but I don't recall doing it.

19

didn't recall it, then I'm sure we probably didn't,

20

because he would have been the one to put that in

21

place.

22

Q.

I suspect we

Bob said he

I'm going to show you a document we should

23

mark as Hand Exhibit No. 20.

24

small type size on this, but this is how it was

25

produced.

I apologize for the

So it might be difficult to read.
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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2
3

A.

It was through Google AdSense.

So it was

the advertisers in their channel.

4

Q.

Did you have any companies contract with

5

you directly to run ads on times.com --

6

Timelines.com?

7

A.

I thought we did.

8

deposition yesterday.

9

been.

I asked Bob after our

I thought there may have

I know we got solicited or asked to put ads

10

up.

11

did do that.

12

Q.

Okay.

13

A.

Done on this?

14

Q.

Yeah, done with that.

15

A.

Okay.

16

Q.

Turning to what's been marked as Hand

17

But from what he was saying, we never actually
So all the revenue came from Google.
Now turning to --

Deposition Exhibit No. 21.

18

A.

I have that, yes.

19

Q.

Okay.

20

A.

Yes.

21

Q.

And what is it?

22

A.

It is the Google AdWords account.

Do you recognize this document?

So this

23

is money we spent on advertising for LifeSnapz.com.

24

Let me see what date this runs through.

25

Yes.

Again, there may have been some money
TSG Reporting - Worldwide

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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

spent on Timelines.com, but it would have been

3

fairly de minimis.

4

vast, vast majority of the dollars here were spent

5

on LifeSnapz.com, and I think Bob said yesterday

6

that was a hundred percent.

7

hundred percent LifeSnapz.com.

8
9
10

Q.

Okay.

I'm very comfortable saying the

So this would be a

So these are -- this reflects money

that was spent based on keywords that you purchased
through the AdWords program?

11

A.

Yes, to drive people to LifeSnapz.com.

12

Q.

And do you recall what the keywords are

13

that were purchased?

14

A.

I don't.

There were -- again, Bob was

15

running this, but I bet there were a thousand,

16

thousands.

17
18

Q.

I mean there was many, many.

Do you know if the company at any point

purchased the term timelines as a keyword?

19

A.

I would say we -- I'm sure we did, yes.

20

Q.

And how about the singular version,

21

timeline?

22

A.

Again, I'm sure we probably did, yes.

23

Q.

And do you recall what the rationale was

24

for purchasing timelines or timeline as keywords

25

was?
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2

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND
A.

Because that for LifeSnapz.com, timeline

3

was one of the features.

4

bought it for all kinds of other concepts.

5

had photos, things related to photos, things related

6

to videos, things related to location, events,

7

family, history, all the words around what we've

8

described as our company vision, and the different

9

things that are LifeSnapz.com.

10
11

So we had -- I think we
So we

We were trying many

different variations of that.
Q.

12

Okay.

That's all I have for that document.

So just to close things out on

13

Timelines.com, I want to make sure we include all

14

the different types of marketing and advertising

15

that you engaged in to promote Timelines.com.

16

So there was SEO.

There was Bob Armour

17

doing outreach.

18

purchases, but that would have been de minimis.

19

conferences.

20
21

There may have been some keyword

No radio.

No

No television.

Is there anything that I'm not covering?
A.

Bob -- I can't remember all the things Bob

22

went into yesterday, but everything he described, I

23

am comfortable, because if there were additional

24

things that he said we did, then -- I can validate

25

that those would be correct.
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2

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND
A.

We received an office action.

3

MR. WILLSEY:

4

Hand Exhibit No. 25.

5

Let me have this marked as

(Hand Exhibit 25 marked for

6

identification.)

7

Q.

8

And for the record, this document has Bates

numbers FB_TL_00002580 through 2643.

9

Do you see those?

10

A.

Yes.

11

Q.

And I'll represent to you this is, as it

12

says on the first page, this is a certified copy of

13

the file history for application serial

14

No. 85,432026.

15

If you'll turn to page 2 of the document --

16

A.

Okay.

17

Q.

-- with 2581 at the bottom?

18

A.

Yes.

19

Q.

Do you see in the main chart the reference

20

to serial number?

21

A.

Yes.

22

Q.

And to the right of that, the number

23

Yes.

85,432026?

24

A.

Yes.

25

Q.

Does it appear that this is -- pertains to
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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

the application that you referenced in that

3

paragraph of the first amended complaint?

4
5

A.

Yes, I think so.

You are talking about

on --

6

Q.

Yes.

7

A.

Whatever that was on.

8
9
10

Yes, it's the same number.
Q.

Okay.

Yes.

And with Exhibit 25, that's this

one; right?

11

A.

This is 25, yeah.

12

Q.

If you'll turn to the third page of that

13

document with the Bates number at the bottom 2582?

14

A.

Yes.

15

Q.

You'll see on the right-hand side of the

16

page, under the heading Goods and/or Services and

17

Basis Information, you'll see the number 42 --

18

A.

Yes.

19

Q.

-- across from class, and then beneath that

20

a long description of services.

21

A.

Yes.

22

Q.

Do you see that?

23

A.

Yes.

24

Q.

Did you prepare that description of

25

services?
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HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

A.

Yes.

3

Q.

And how did go about preparing it?

4

A.

I used our -- the existing Timelines

5

description of services, and then I looked up the

6

Facebook description of services to see if there was

7

overlap with what we were doing but had not

8

described in our identification in the past, and

9

what Facebook was doing and had described in their

10

identification.

11

in this application to make our description and our

12

identification more complete.

13

Q.

And I thought to incorporate that

So portions of this description that you

14

prepared were based upon descriptions of services

15

covered by Facebook trademark filings?

16

A.

Yeah, I used -- I read through the way they

17

described it, which more fully described the

18

services we were providing, and used that to add to

19

our identification.

20
21

Q.

And were the Facebook filings that you

looked at for the mark Facebook?

22

A.

Yes.

23

Q.

And there weren't -- you didn't find any

24
25

Facebook applications for the term timeline?
A.

No.
TSG Reporting - Worldwide

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1

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND

2

new brand that Facebook was rolling out.

3

to me, is a direct infringement of our trademark,

4

100 percent.

5

Q.

And that,

Putting aside the F8 conference, what can

6

you identify in terms of efforts by Facebook to

7

market and advertise its services under the term

8

timeline?

9

A.

All subsequent communication with the

10

press.

There was tons of press that came out after

11

that.

All of it referring to this new service that

12

was going to be launched called Timeline.

13

Q.

Do you know if when a user accesses his or

14

her Facebook page and the first page comes up,

15

whether a user is presented with the term timeline

16

on that page?

17
18
19

A.

I don't know the inner workings of the

Facebook site.
Q.

Are you aware of any television

20

advertisements that Facebook has run featuring the

21

term timeline?

22

A.

I don't know.

23

Q.

So to be very clear, and just put an end to

24

this line of questioning, the only action the

25

company has taken to enforce rights in Timelines as
TSG Reporting - Worldwide

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1
2

HIGHLY CONFIDENTIAL - OUTSIDE COUNSEL ONLY - B. HAND
a trademark is this lawsuit; correct?

3

A.

Yes.

4

Q.

Has the company ever entered into a license

5

with anyone relating to the use of the term timeline

6

as a trademark?

7

A.

8
9

MR. WILLSEY:

Do we have a stapler in the

room?

10
11

No.

MR. ALBRITTON:

Open on the right.

There

you go.

12

THE WITNESS:

You may want to use this on

13

one or two of these that are getting caught up

14

in paper clips.

15

MR. WILLSEY:

Let's mark this document as

16

Hand Deposition Exhibit No. 26.

17

(Hand Exhibit 26 marked for

18

identification.)

19

Q.

This document does not have any Bates

20

numbers.

21

it out today after going to what I believe is

22

your -- the company's page on Facebook.

23

you'll see at the bottom, there is a URL referenced.

24

And the date is September 18.

25

wasn't today.

I'll represent to you that we just printed

My apologies, it

It was earlier this week.
TSG Reporting - Worldwide

And if

877-702-9580

It was

Exhibit 6

Exhibit 7

LifeSnapz - Events

Page 1 of 1

lori mayall

All

Account

Logout

test

test
Latest Updates

Events

Timeline

Map

Photos

Videos

Invite New Member

EXPLORE EVENTS

View All Events

Your Favorites

They Were There

brother

dad

sister

Filter by date range

Blog

Help & FAQs

About Us

Feedback

Visit Timelines.com to record and share history with the rest of the world.

Terms of Use

Privacy Policy

©2012 Timelines, Inc.

http://lifesnapz.com/groups/3289/events/browser?view=timeline

9/18/2012

Exhibit 8

Exhibit 9

Timelines
Searc
for

Search for people, places and things

Timelines

About

Lori Mayall

Highlights

Like

Liked

Basic Info

Discover, record & share history on with Timelines. Visit Timelines.com to get
started.

Launched

April 20, 2009

Mission

Products

Timelines offers four services:
- Timelines.com, for individuals and entities that want to
reach and interact with a broad audience about publicly
shared events

Company Overview
Timelines, Inc. is the leader in providing services that enable people and
entities to discover, record and share history on the web. The company’s
platform is uniquely built to chronicle events (using descriptions, photos, videos,
and locations contributed by multiple users), and then enables people to relate
these events to each other based on time, place or topic.

- Timelines SE, for media businesses that want a custombranded, hosted solution as part of their websites to
showcase past content in an innovative, contextually
relevant manner

The company is based in Chicago and funded by Apex Venture Partners and
Trident Capital.

- LifeSnapz.com, for families and other trusted groups that
want a more controlled, permission-based environment for
recording and sharing their events
Photogram, a free iPhone app that provides special
delivery of your photos via Email, Facebook and Twitter
(launching in June 2011)

Contact Info
Website

About

Create an Ad

Create a Page

Developers

Careers

Privacy

Cookies

Terms

Privacy

Create PageShortcuts

Sponsored

About

Our mission is to enable the Web and mobile devices to be used as a platform
to record history and share events.

Home

http://timelines.com

Sponsored
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Exhibit 10

Exhibit 11

Exhibit 12

Exhibit 13

The Oxford
College Dictionary
SECOND EDITION

I

SPARK

PUBLISHING

New York

I

© 2002, 2007 by Oxford University Press, Inc.
First published 2002 (as the Oxford American College Dictionary)
This second edition published by Spark Publishing, a division of
Barnes & Noble, Inc.~ by arrangement with Oxford University Press, Inc.
Oxford is a registered trademark of Oxford University Press.
All rights reserved. No part of this publication may be reproduced,
stored in a retrieval system, or transmitted, in any form or by any means,
electronic, mechanical, photocopying, recording, or otherwise, without
prior written permission from Oxford University Press.
ISBN-13: 978-1-4114-0500-4
/ lSBN-10: 1-4114-0500-5
Library of Congress Cataloging-in-Publication Data available
This book includes some words that are, or are asserted to be,
proprietary names or trademarks. Their inclusion does not imply that
they have acquired for legal purposes a nonproprietary or general significance,
nor is any other judgment implied concerning their legal status. In cases
where the editor has some evidence that a word is used as a proprietary
name or trademark, this is indicated by the designation trademark,
but no judgment concerning the legal status of such
words is made or implied thereby.
Printed and bound in the United States of America
1

3 5 7 9

10

8 6 4

2

time frame

tinea

time frl!me 1> n. a period of time, esp. a specified period in which some·
thing occurs or is planned to take place.
time·hon•ored 1> adj. [attrib.J (of a custom or tradition) respected or valued because it has existed for a long time.
time•keep•er /'tim,kepar/ 1> n. 1 a person who measures or records the
amount of time taken, esp. in a sports competition. 2 [usu. with adj.J a person regarded as being punctual or not punctual:
were good timekeepers. • a watch or clock regarded as recording time accurately or
inaccurately. • archaic a cloCk.- time·keep•ing n.
time lag 1> n. see v>G' (sense 1).
time-lapse 1> a~J. denoting the photographic technique of taking a
sequence of frames at set intervals to record changes that take place
slowly over time. When the frames are shOwn at normal spe'ed, or in
quick succession, the actiOn seems much faster.
"
·
time•hlss /'t!mlls/ 1> adJ. not affected by the passage of time or changes
in fashion: timeless designs. - time•less•ly adv. time•less•ness n.
time lim·it 1> n. a limit of time within which something must be done.
tlme•line /'tim,lin/ (also time line) 1> n. a graphic representation of the
passage of time as a line.
time lock 1> n. a lock fitted with a device that prevents it from being
unlocked until a set time. • a device built into a computer program to
stop it operating after a certain time. l>v. (time-lock) [trans.j secure (a
door orother locking mechanism) with a time lock. •link (something)
inextricably to a certain period of time.
tlme•ly /'tllnl~/ 1> adj. done or occurring at a favorable or useful time;
opportune: a timely warning. - tlme•ll·ness n.
time ma•chlne 1> n. (in science fiction) a machine capable of transporting a person backward or forward in time.
time off.,. n. time for rest or recreation away from one's usual work or
studies: we're too busy to take time off.
time out ..,. n. 1 time for rest or recreation away from one's usual work
or studies. • (usu. timeout or time-out) a brief break in play in a game
or sport. • (also timeout or time-out) an imposed temporary suspension of activities, esp ..the separation of a misbehaving child from one
or more playmates as a disciplinary measure. 2 (usu. timeout) Comput a
cancellation or cessation that automatically occurs when a predefined
interva1 of time has passed without a certain event occurring.
time•piece /'tlm,pes/ 1> n. an instrument, such as a clock or watch, for
measuring time.
tim•er /'timar/ .... n. 1 an automatic mechanism for activating· a device
at a preset time: a video timer. • a person or device that measures or
records the amount of time taken by a process or activity. 2 !in comb.]
used to indicate how many times someone has done something: we,re
first-timers.
tlma-n~•lease 1> adj. denoting something, esp. a drug preparation, that
· releases an active substance gradually.
times /tlmz/ 1> prep. multiplied by: li times 4 is 44- [see nME sense 5 of
then.]
tlme•sav•ing /'tim,saviNG/ 1> adj. (of a device, method, etc.) reducing the
time spent or required through greater efficiency or a shorter route.
~ tlme•sav•er n.
time se•ries ._. n. Stat. a series of values of a quantity obtained at successive times, often with equal intervals between them.
tima-sarv•er 1> n. 1 a person who changes their views to suit the prevail·
ing circumstances or fashion. 2 a person who makes very'little effort at
work because they are waiting to leave or retire.- time~serv•lng·adJ.
tinie~shan1 j't!m,sae(a)r/ 1> n. the arrangement whereby several joint
owners have the right to use a property as a vacation home under a
time-sharing scheme. • a pfoperty owned in such a way.
tJme-shar•ing • n. 1 the operation of a conlputer system by several
users for different operations at the same time. 2 the use of a property
as a vacation home at specified times by several joint own:ers.
time sheet (also tlme•sheet /'tlm,saet/) 1> n. a piece of paper for record·
ing the number of hours worked.
time-shift 1> v. 1 [intrans.l move from one period in time to another.
2. !trans.) record (a television program) for later viewing. 1> n. (time
shift) a movement from one period in time to another, esp. in a play
or movie.
time sig•na•ture 1> n. Music an indication of rhythm following a clef, generally expressed asa fractiM with the denominator defining the beat
as a division of a whole note and the numerator giving the number of
beats in each bar.
time slic~ ._. n. Com put. a short interval of time during which a computer
or its central processor deals uninterruptedly with one user or program, before switching to another.
times ·ta·ble • n. informal term for MUL.l1PLICAnoN TABLE.
tinie•ta•ble /'tlm,tiibal/ 1> n. a chart showing the departure and arrival
tim~S of trains, bU.se·s. or 'planes. -• a plan of times at which'events are
scheduled to take place, esp. toward a particular end. l>v. ltran.l sched-·
ule (something) to take place at a particular time: weigh~ins are timetabled for Mondays.
time trav•el 1> n. (in science fiction) the action of traveling through
time into the p-ast or the future.- time-traY.el v. time trav ..el•er n.
time tri•al ..,. n. (in various sports} a test of a co111petitor's· individual
speed over a set distance, esp. a cycling race in which competitors· are
separately timed.
time warp 1> n. (esp. in science fiction) an imaginary distortion of space

we

in relation to time whereby people or objects of one period can be
moved to another.
time•worn /'tim, worn/ (also time·worn) 1> adj. damaged or impaired, or
made less striking or attractive, as a result of ag·e Or much use.
time zone 1> n. see ZONE (sense 1).
tlm•id /'timid/ 1>adj. (-id•er, -ld•iest) showing a lack of courage or confidence; easily frightened. -' ti•mld•l•ty /ti'midite/ n. tim·ld•ly adv. tim•
ld•ness n. [16th C.: from L timidus, fromtimere 'to fear.']
tim•ing /'timiNG/ 1> n. the choice, judgment, or control of when something should be done: one of the secrets ofgolfis good timing. • a particular point or period Of time when something happens. • (in an internal
combustion engine)the times when the valves open and close, and the
time of the ignition spark, in relation to the movement of the piston
in the cylinder.
tim•ing belt 1> n: a metal chain or reinforced rubber belt that drives the
camshaft of an internal-combustion engine. Also called timing chain.
Tl•mi•,oa•ra /,temesH'waraJ a city in western Romania; pop. 325,000.
Hungarian name TEMESVAR.
tl•moc•ra•cy jta'makrase/ 1> n. (pl. -des) esp. Philos. 1 a form of government
in which possession of property is required in order to hold office. 2 a
form of government in which rulers are motivated by ambition or love
of honor.- ti•IIIO'cratoic /,tilna'kratik/ adj.[15th C.: from OFr. timocracie, via med. L. from Gk. timokratia, from time•honor, worth'+ ~kratia
'p-ower.' Sense 1 reflects Aristotle's usage, sense 2 Plato'S.}
Tl•mor /'tem6r/ the largest of the Lesser .Sunda Islands, in the southern Malay Archipelago; pop. 3,383,000. - Tl•mo•rese /,tema'rez; -'res/
adj. & n.
tim•or•ous j'timaras/ • adj. showing or suffering· from nervousness,
fear, or a lack of confidence: a timorous voice.- tim·or-ous•ly adV. tim•
or•ous•neu n. [ME (in the sense 'feeling fear'): from OFr. temoreus,
from med. L. timorosus, from L timor'fear,' from timere 'to fear.']
Tl•mor Sea an arm of the Indian Ocean between Timor and northwestern Australia.
"
Tlm•o•thy /'timaTHe/ either of two books of the.New Testament, epistles
of St. Paul addressed to St. Timothy.
,
tim•o•thy j'tima'l'He/ (alsotlm•o•thygrass) 1> n. a Eurasian grass (Phleum
pratense) that is widely grown for grazing and hay, It is naturalize<\ in
North America, where many cultivars !)ave been developed. [18~h C.:
named after Timothy Hanson, the American farmer who introduced it
to Carolina from New York (c.1720):]
Tlm•o•thy, St. (1st century AD), disciple of St. Paul.
tlm•pa•ni j'timpane/ (also tym;pa•nl) 1> plural n. kettledrums, esp. when
played by one musician in an orchestra. - tlm•pa•nlst n. [19th C.:
from !tal., pl. of timpano 'keitledrum,' from L tympanum 'drum' (see
TYMMNUM).J

tin /tin/ 1> n. 1 a silvery-white metal, the chemical ele\'llent of atomic
number so. It is used in various alloys, notably bronze, and for electroplating iron or steel sheets to make tinplate. (Symbol: Sn) • short for
nNPl.An:. 2 a metal container,' in particular: • esp. Brit. an airtight sealed
container for preserving food, made of tinplate or aluminum; a· can. • a
lidded airtight container made of tinplate or aluminum: a cookie.tin.
1> v. (tinned jtind/, tin•ning) [trans. I cover with a thin layer of tin.
- PHRASES have a tin ear be tone-deaf. IOE, of Gmc. origin; rei. to Du.
tin and Ger. Zinn.j
tin•a•mou /'tina,moo/ 1> n. a ground-dwelling tropical American bird
(familyTinamidae) that looks somewhat like a grouse. [18th C: via Fr.
from Ga!ibi tinamu.]
Tin•ber•gen 1 /'tiR,bergan/, jan (1903-94), Dutch economist; brother of
Nikolaas Tinbergen. He pioneered in econometrics. Nobel Prize for
Economics (1969, shared with Ragnar Frisch).
Tln•ber•gen', Nikolaas (1907-88), Dutch zoologist; brother of Jan Tinbergen. He introduced the concept of displacement activity. Nobel
Prize for Physiology or Medicine (1973, shared with Lorentz and Karl
von Frisch).
tin can • n. a tinplate or aluminum container-for preserving food, esp.
an empty one. • Nautical slang a destroyer or.a submarine.
tinct. 1> abbr. tincture.
tlnc•to•ri•al /tiNf3k't6real/ 1> adj. tech. of or reiating to dyeing, coloring,
or staining propertiesc [17th C.: from L. tinctorius (from tinctor 'dyer,'
from tingere 'to dye or color')+ -AJ..]
tinc•tun! /'tiNGkCHar/ 1> n. 1 a medicine .made by dissolving a drug in
alcohol. 2 a slight trace of something: a tincture of bitterness. 3 Heraldry
any of the conventional colors (includin_g the metals and. stah'ls, a:nd
often the furs) used in coats of arms. l>v. (be tinctured) be tinged,
flavored, or imbued with a slight amount .ot IM~ (denoting a dye or
pigment): from L. tinctu~a 'dyeing,' from tingere 'to'dye .or color.' Sense
z (early 17th C.) coriles from the obs. sense 'impait!id quality,' likened
to a tint imparted by a dye.]
··
' '
tin•der /'tlndar/ 1> n. dry, flamr_nable material, such ~s wood. or paper,
used for lighting a fire.- tin•der·y adj. IOE tynder, tyndre, of Gmc. origin; rei. to Du. tonder and Ger. Zunder.)
,
tin-der•box /'tindar,biiks/..,. n. hist. a box containing tinder,.flirit, a steel,
and other items for kindling fires. • fig. a thing that is readily ignited.
11!1 fig. a volatile situation, or a person who is readily aroused, .esp. to
anger.
tine /'tin/ 1> n. a prong or sharp point, such as that on a fork or antler.
-tined adj. [OE tind,.of Gmc. origin; rei. to Ger. Zinne·'.pinnacle.']
tin•e•a /'tinea/ 1> n. technical term for RINGWORM. [ME: from L., 'worm.']