Ceglia v. Zuckerberg et al

Filing 315

DECLARATION signed by Bryan J. Rose re 313 Reply to Response to Motion filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A)(Snyder, Orin)

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EXHIBIT A Attachments: Lawsuit Overview.pdf From: Paul Argentieri [mailto:paul.argentieri@gmail.com] Sent: Friday, December 16, 2011 5:11 PM To: Bryan Rose Subject: Fwd: Lawsuit Overview Bryan [forward from origianl email to Paul Argentieri containing image of contract] Forwarded by Ed Flaitz (12/15/11 at 5:09pm) ---------- Forwarded message ---------From: Jason Holmberg <jason.holmberg@papellets.com> Date: Sun, Mar 6, 2011 at 11:03 PM Subject: Lawsuit Overview To: Paul Ceglia <paulceglia@gmail.com>, Paul Argentieri <paul.argentieri@gmail.com> Paul, Attached is the dossier I put together to present the case to law firms. Let me know if you’d like to change it at all. Many Blessings, Jason Holmberg Mill - (814) 848-9944 Office - (814) 274-3233 Cell - (814) 558-9009 -- 1 Lawsuit Overview PAUL D. CEGLIA Vs. MARK ELLIOT ZUCKERBERG & FACEBOOK, INC. 1 TABLE OF CONTENTS Table of Contents ............................................................................................................. 2 Executive Summary Case Overview .......................................................................................................... 3 Objective..................................................................................................................... 3 Representation History ............................................................................................ 3 Lawsuit Details Current Status ................................................................................................................... 4 Fact Summary ................................................................................................................... 4 Statute of Limitations ...................................................................................................... 4 Prior Cases ...................................................................................................................... 5 Attachments Attachment 1 – June 30th, 2010 Filing Attachment 2 – Proof of Facts Attachment 3 – Oral Arguments 7-20-10 2 EXECUTIVE SUMMARY Case Overview On June 30th, 2010, Paul Ceglia (“Paul”) filed a lawsuit against Mark Zuckerberg (“Zuckerberg”) and Facebook, Inc. in Allegany County, NY (the “Lawsuit”) to enforce the terms of a contract that Paul and Zuckerberg entered into on April 28th, 2003 (the “Contract”). A copy of the court filing is attached as Attachment 1 – June 30th, 2010 Filing. Under the terms of the Contract, Paul purchased an 84% interest in the software, programming language and business interests of the service that was to become Facebook. Paul is Facebook’s first investor and co-owner. Objective Paul is seeking to engage a law firm to represent him in a.) immediate settlement negotiations and b.) the Lawsuit going forward. Paul will be interviewing multiple top tier law firms. The successful firm will demonstrate 1.) a strong desire to represent Paul, 2.) a commitment to developing a close working relationship with Paul, and 3.) a contingency based fee arrangement that is fair for both parties. All firms interviewed have already demonstrated that they have the experience and competency to represent Paul. Representation History Paul originally hired Paul A. Argentieri, Esq. of Hornell, NY to file suit in Allegany County, NY. Mr. Argentieri has and will continue to advise Paul in the case. Paul then engaged Connors & Vilardo, LLP (“C & V”) to represent him when the case was first removed to federal court. C & V is a small but distinguished regional firm of approximately 13 lawyers in Buffalo, NY. Paul and C & V have mutually agreed that because of size, complexity and commitment required of this case, a larger firm is necessary to properly represent Paul’s interests going forward. 3 LAWSUIT DETAILS Current Status The Lawsuit was filed on June 30, 2010 in the Supreme Court of New York, in Allegany County. Shortly thereafter, the case was removed to the Federal Court at the request of the defendants. As of March 1, 2011, the case remains in the US District Court for the Western District of New York where it awaits a decision from Judge Arcara on whether the case will be remanded back to the state court. Paul expects that the Judge will order a hearing on the remand issue and may allow limited discovery to determine domicile of Mark Zuckerberg. Paul does not believe that the choice of venue will have any consequence on the resolution of the case. Fact Summary A detailed Proof of Facts is included as Attachment 2 – Proof of Facts. This gives the background on how the parties met and explains the major facts of the Lawsuit. These include: 1.) An original copy of the contract exists and has been expertly verified. 2.) During oral arguments, defendants’ counsel confirmed “Mr. Zuckerberg did indeed have a contract with Mr. Ceglia” and “Our client entered a contract with Ceglia”. Please see Attachment 4 – Oral Arguments for the full transcript. 3.) There is a witness to the signing of the contract 4.) Paul has a copy of the check that Zuckerberg deposited in his account on the day the contract was signed. 5.) Paul has copies of emails from Paul referencing and negotiating the terms of the contract. 6.) In an email dated July 22, 2004, which was 7 days prior to the corporate formation of The Facebook, Inc., Zuckerberg offers to repay the $2,000 that Paul had previously paid Zuckerberg. Statute of Limitations Zuckerberg's defense team has not committed to a clear defense strategy for the Lawsuit. The statute of limitations defense is often anticipated as a major hurdle for Paul to clear. The statute of limitations for most breach of contract causes of action is six years from the date the contract is breached. The contract had no term as it is non-durational and required Zuckerberg to a.) maintain and act as the site’s webmaster, b.) to pay for all domain and hosting expenses from the funds received under the contract, and c.) to maintain control of these services at all times. These are promises of future performance within the contract. The Second Circuit of the Southern District of New York has ruled and made clear that promises of future performance within a contract provide for the opportunity to have a series of breaches, each of which reset the statute clock to run anew. 4 Prior Cases There were two prior cases wherein individuals sued Mark Zuckerberg with similar causes of action. Both cases were settled out of court. Eduardo Saverin invested $1,000 on January 7th, 2004, in return for 30% of the ownership of Facebook. This investment occurred after Paul’s investments. Eduardo’s share was diluted without his consent. His lawsuit to resolve the dilution was settled out of court for a reported 5% of Facebook. The Winklevoss twins sued Zuckerberg for their claims he breached an oral agreement by using their idea and code to develop Facebook. They settled for a reported $65 million of shares in Facebook. They had no written agreements. 5 Attachment 1 – June 30th, 2010 Filing 6 O/30/2010 12: 02 60732461ee Case 1:10-cv-00569-RJA SUPREME COURT ZTATE OF NEW YORK Document 6-2 PAUL ARGEN1TIERI Filed 07/09/2010 Page 1 of 16 PAG-E 05 Co (0)F ALLEGANY COUNTY PAUL D. CEGLIA SUMOSALLEGANY COUNTY Plaintf FI LED SUMN vs Index #JUJUN 3 0 2010 MARK ELLIOT ZUCKERBERG, Individually and Face book,inc.CLR RO LERK.CRITA Defendants TO THE ABO0VE NA MED DEFENDA NTS: YOU ARE HEREBY SUMMONED to answer the complaint in this action, and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the PlaIntiff's attorney within 30 days after the service of this summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or within 30 days after completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Trial to be held in the County of Allegany The basis of the venue is Residence of Plaintiff Plaintiff resides in Allegany County Dated:.June 2.9, 20 10-------Paul Argentier Esq. 188 in Street Hornell, NY 14843 607-324-3 232 -o m M flr- PAUL A. ARGENTIER1 - A~TTORNEV AT LAW 6e0MAN STPEET -HOPHELL. N V. 14843-7 TE0OWOM rAn?14 2a2 C- C],ERKY 6073246198 06/30/2010 12:02 Case 1:10-cv-00569-RJA ARGENTIERI Document 6-2PAUL Filed 07/09/2010 Page 2 of 16PAG3E To the above named Defendants: THE NATURE OF THE ACTION IS: Declaratory Judgment The relief sought is: Monetary Damages and 84% Ownership of Facebook,inc. PAUL A. ARGErMIEI - ATrORNEY AT LAW 188 MAIN qTPP"~- HOMNr.LL, N.VY 143 - TELEHCNZ (r807) 324-3232 06 0F6/30/2010 12: 02 6073246188 Case 1:10-cv-00569-RJA Document 6-2 PAUJL ARiENJTIERI Filed 07/09/2010 Page 3 of 16 PAGE 07 ALLEGANY COUNTY CLERYK SUPREME COURTFL ALLEGA4NY COUNTY' PAUL . STATE OF NEW YORK JU CEGIA PAULD. D 3D 0201 R0BEpT,L CHRISTMAN CGLIACLERK Plaintiff VERIFIED COMPLAINT Index ,3 ?/ MARK ELLIOT ZUCKERBERG, Individually, and Facebook, Inc. Defendants The Plaintiff, as and for his verified complaint against the Defendants, alleges as follows: rM) C < I. Plaintiff, Paul D. Ceglia, residing at 2558 Hanover Hill Road, Wellsville, Allegany County, New York, 14895 at all times hereinafter mentioned as either the Purchaser and/or the Buyer. 2. Defendant Mark Elliot Zackerberg, upon information and belief resides at 2 Russell Place, Dobbs Ferry, Westchester County, New York 10522, hereinafter referred to as either the Seller and/or Contractor. 3. Upon in formation and bellef Face book, Inc. is a domestic corporation having Its principal office located in the State of New York having been incorporated in New York on August 6, 2009, hereinafter referred to as Face book, see exhibit A attached hereto and made a part hereof of this complaint, 4. On April 28, 2003, the Seller and the Purchaser entered into a written contract, including but not limited to, the Purchaser acquiring Fifty Percent (50%) interest in the business of the Seller and Facebook, see exhibit B attached hereto and made a part hereof of this complaint, S. Upon information and belief, Mark Elliot Zuckerberg is the principal owner of 'The Face Book" aka "The Page Book" that are the predecessors in interest to Facebook,lnc. PAUL A. ARGFENJRI - ArMrnNEV AT LAW 100 MAIN S"t aT- HORtIELL. N,V 1.043 - TELEPH-,OW! Ca07) 3223 - I 0~2j/0012:02 60732'4618e Case 1:10-cv-00569-RJA ARGDENTIERI Document 6-2PAULFiled 07/09/2010 Page 4 of 16PAGE 6. Under Paragraph 3 of the contract, the Seller and Purchaser agreed that for each day after January 1, 2004, the Purchaser would acquire an additional 1% interest in the business, per day, unril the website was completed. 7. Upon information and belief, the website, the facebook.com', was completed and operational on February 4", 2004, 8- According to the terms of the contract, as of February 411 2004, the Purchaser had acquired an additional 34% interest in the business for a total of eighty four percent (84%). 9. Purchaser paid consideration to the Seller for the contract, upon information and belief, by a check in the amount of One Thousand Dollars (S$7,000.00) to Mark Zuckerberg, on or about November 2 4 11, 2003 among other consideration tendered, see exhibit C attached hereto and made a part hereof of this complaint. 10. Upon information and belief, the Seller simply transferred the originating website business from TheFacebook.com into Face book.com, and ultimately into Face book, Inc. which is a *continuum of the Purchaser's acquisition from the date of the contract until the present time, and also a continuum of the business from pre-incorporation to incorporation of Facebook. I1I Since April 2811', 2003, the Purchaser has complied with the terms and conditions of the contract and the Seller has failed to similarly comply with the terms of the contract to the detriment of the Purchaser, 12. Upon information and belief, Facebook is a closely held corporation of which the Seller is presently the majority stockholder, see exhibit D attached hereto and made a part hereof of this complaint, PAUL A. ARGENT]IERI - A7TPORNFY(AT LAW ISMt SrneET - HOMNF IL. N y 1 A04a - TCLeOHONF MYO)32 3232 08 6073246188 12:02 30/,2 01F GR/ Case 1:10-cv-00569-RJA ARGEHTIERI Document 6-2PAULFiled 07/09/2010 Page 5 of 16PAGE WHEREFORE, the Plaintiff, Paul D. Ceglia, hereby demands by Declaratory judgement against the Defendants, Mark Elliot Zackerberg, Individually, and Facebook, Inc. for an enforcement of the terms and conditions of the April 23r" 2003 con tract wherein Plaintiff would acquire 84% interest of Facebook, Inc. arnd for a Judgment for an Accounting wherein Plaintiff would obtain a further Judgment against the Defendants in the amount of 84%6 of any and all monies realized by the Defendants from April 28J1 2003 to the present time, along with the costs, disbursements, and attorney fees for this action. Paul June 29, 2010 .Arg ntieri, sq. Attorney for Plain iff 188 Main Street Hornell, New York 14843 607-324-3232 PAUL A. ARGEt1nETZ - A77-ORNEY AT LAW 108 MAIN GTRCST - HIORNELL, N.YV 14ASA - ThUe,NONIr <0O, 2-3232 09 ARGENlTIEPI Document 6-2PAUL Filed 07/09/2010 6073246188 Case 1:10-cv-00569-RJA O3eX2010 12:02 P-D STATE OF NEW YORKI COUNTY OF ALLEGANY Page 6 of 16PAGE Cegi ) ss. Paul D, Ceglia, being duly sworn, says that the deponent is the Plain tiff in the within action; that deponent has read the foregoing Verified Comnplaint, and knows the contents thereof ; that the same is true to his own knowledge, except as to matters therein stated to be se ma ers de onent alleged on information and belief and that as t believes it to be true. ---------------------- ---- ----------PD. Ceglia Wme Sworn to before 2tDay thi of June, 20 NOTARY pUICXAT OF NEW YiORK So.0O2AR457 PALIL A. ARG VN'nERI - ATTORNEY AT LAW 10 6073246188 12:02 0/30/221I0 Case 1:10-cv-00569-RJA EXISIT8 6! ARGEHITIERI Document 6-2 PAULFiled 07/09/2010 Page 7 of 16P~AGE 11 06/30/2010 12: e2 Case 1:10-cv-00569-RJA 6073246lee Document 6-2PAULFiled 07/09/2010 ARGENTIERI Page 8 of 16P4GE Entity Information 12 Page I of 2 NYS Department of State Division of Corporations Enfity Information The information contained in' this database is current through June 25, 2010, Selected Entity Name: FACEBOOK, INC. Selected Entity Status Information Current Entity Name:' FACEBOOK, INC. Initial DOS Filing Date: AUGUST 06, 2009 County: NEW YORK Jurisdiction: DELAWARE Entity Type: FOREIGN BUSIN~ESS CORPORATION Current Entity Status: ACTIVE Selected Entity Address Information DOS Process (Address to which DOS will mail process if accepted on behalf of the entity) CORPORATION SERVICE COMPAN~Y 80 STATE STREET ALBANY, NEW YORK, 12207 Registered Agent NONE This office does not record information.regarding the names and addresses of officers, shareholders or directors of nonprofessi ona] corporations except the chief executive officer, if provided, which would be listed above. Professional corp orations.rmust include the name(s) and address(es) of the initial officers, directors, and shareholders in the initial certificate of incorporation, however this information is niot recorded and only available by vievAngthe certificate. "~Stock Information # of Shaires Type of Stock S Value per Share No Information Available *Stock information is aDDlicable tn dr)mp,qtjr )iipc rnrnnra+-,c 06 E30Y/2010 12:02 6073246188 Case 1:10-cv-00569-RJA ARG3EHTIERI Document 6-2PAUL Filed 07/09/2010 Page 9 of 16PAGE * Entity Lnformation 13 Page 2of 2 Name History Filing Date Name Type Entity Name AUG 06, 2009 Actual FACEBOOK, INC. A Fictitious name must be used when the Actual name of a foreign entity is unava ilable for u~se in New York State. The entity must use the fhctitious name when conducting its activities or businet~s in New York State. NOTE: New York State does not issue organizational identification numbers. Search Rpqults Services/Programs IPrivacy Poijc. ljomepaea New Search Accessibility Policy I Disclaimer Contact Us Web Feedback Returnto DOS 6873246188 Case 1:10-cv-00569-RJA * 86/3692616 12:62 ***(<~ ARGENTIEPI Document 6-2 PALLFiled 07/09/2010 PAGE Page 10 of 16 .. N '4>7 14 EXKI~JT A . 'At~ 06/Hg/211 607324618e Case 12:02 1:10-cv-00569-RJA P Document 6-2 Page 11 of 16PAGE PAUL ARGEN~TIERI Filed 07/09/2010 "WORK FOR HERE" CONTRACT SECTION I- GeN&XAL M1OV1IONS u*ac Ir the mers nw&As kor If; opwailofi Thefolowig ei~a apcl~~lselm iadheritPaFr hve~eemeain "Dic P=,o*u" Weir itom to mdiu aid tit udw Amtwe,mmimr PMJCHASER PaWi Cogia adt pay Ib oil damm an d hogfin e9mo tom tI e,Nin& mo6vi under CONTRACTOBJSUE1R - ?Imt Zuckmber& hh Aim, thi oofn n alrM fi he will mawanim cootml of the= 2urvim~ employecsaupplkes, or suonintm Imish;ng nVheluli f rsoe or at an timm CUSTOSIret iiy~1oIg construion or odwe wervioms form 1he Paralme r rvqut,ed ~ ~ f~ aare ~t*ti ~ ~ .,* 6.. 'o~Ado ~ t4wa ~ n~ ~ ttty exu.s~dl~ a Ai M&aio wry odimer md b Mbed.inpek e mde oda mem to Lbeonm ~o ~ulma~pi4eSleimetgodrm ~tw,s Str The omftm, b"wme gm Pumbua wd Seller m-A arhme mWeament and '*ork mak ft h rfe l m wo 90arm 11*11411 VOuu,M, 4097 Ift 6. SdIWUMt of C0C f6t8.m,a , Pat the work to be IM*ieithd &mcitly ft 'be SteedPax Dcabme an kb In t eveart *.M&bipurmw ~ tni of 0galprnent: wtkh b ProgmitnIS ImqmW teo pmVdby Sll= be sia;la" ftm Otis Primn mckfiil i ceof diggiits b&wwn the Scond itis J ftesawg-poX adfxPuete n gm Qrs The Petm ad& efa fbrt6eprqmotSae:r hw rcVuir;hg reterWo or ea~pawl to be fetesb by Ibe, Sellcr, the Seller a1rad irft s dsiedtooffffIhDslWcW of £ffawd uixivansity WMeatDbe boatodwoi&smhev i1hatbarePuweirlbonnelby6me Oa wmto a weshe Aimilir toa Hlincttion1oig yearbook with time work6g rto tePlm om.~lb ~l$1lI1ia adttnimka tMe dnU~ Vwx BW mme theemmft. protj&d A theSA1.olltm tiAe r4ft to PAftaicte in Im eduemat of 3*y d;gpmE t flm utImbt weler 'wil) be asomwe Iti s agreed iedf Porrhner wMl Ahalf Iterest (50%) intthe mfhim own atmb tlgmiimen~bwlz7 Inatd~dedl~rIbexpovbo~ofNo intemt dtall acemeony pwnoW) offiAwkm dw IkeSdIff, whiiah iq that simice boa larger modier-~ withheld or dbL*Me a rmtut of ainy sucdlv" mwxrAa dwe m to V%ctwt OVd e Porter ig ultimrateiy paid h.fttson mWot olt 0*elae1c Sellir 3. P"nxmt Tam, 2. NYm~~~( Teams aball not be dIM1bl if fit 361le Mnlom brmoitl6m of ike PttwA Rod it No losorme or premium dwagmi or picle maiaue wiln be allowed iglwdtrmndta be hm;0a' iumow wvme not i cMiPncne Wment an0worerid by PrortawIn wrating. No latm Inprice Runm wffi h irm ad vpcclitJlalom of t Prime Co*wtmt Pending finel thal steed o tht flie heref ivill be ortaidered thoghit thiediplto of a &Rptft hcrojnthe (M Selker "e OeM an be work undea" diadioftbearda. W-wo*MdIwth*glby fte Pufet a The 49ltesf Op Cast Otsnt Sellf and Mwe tiz Buiyew ltm bvemd Is all kgattz" the fidal ieMoW4 Sanid rev wi&h the 13mi] Spedliacion. mpm1 mt owt Ba)w agrees to pay t id* m ft-m of 1000 apk tbr doe wot gobeperRiftnid Ji orelftid $1,000 Wo wtrk to be dve ptrfinmibr lot PluV Bfoor. Lift fie" ame agreed so b a 5% dedoctimub t gellet7 Pmtdoxt if~~~ t2ne~Iadby 1Weedae ad ar kddMdotat 1% ~~ tieplic Parcher hold scuff r mtm ftr an b&R4n"in sellen, w.ort may dediictinoeac sddy %' otheij" Im dIekytA kWMco Ilig poinL APTMj bopmim *Hir P"rs &wmeaft ftom tlm dJrrxT requm ld by and The pTJlA L2 du %w )j 1r hZworkmde by puier In 6& vm wkmt*l Ir him- Wgementm May 3l,2003.e el" no~ SIar ktvby,~aWme t be ramumble for anf claleng ROOMt tm Tho eedpDromvw&MbIc Pmrhmm of the CadosToeAid lewod iftfi*wwtm fIRM by meorm or umkism fr "The Pace Booe"ffhan beJmapwiy I 2004 imd M:aMidllonml 1%bftrnt int (be pommes or Cusormes pomsiaron.ue or awkof mVy thmebuinma will bo d=e Mle bv),vr AirmT day ftne c8sitis delyedlirm qdoemab1IewdrblmeSlrorbrieiofT psrmtC &Ao date. ofanty work bm,uniler by fie Sefkr 7be Seller mva to defotd at irs Hole AMmal lijbil may be prmidad Jbr eiWwepjedt a a a neeided bm%i3 pm n %aimie**U*t tho it si o wn/rtn'Ctmw OMZOme arid ffic sole dilacrctloi of (be Buyer. boid hams t membtr andi the Cagmuctre DOW nwd floiris all Gomt, airy kInd whioh tke Punhawe or Eha expaedadpmteer. md dtiaof or Cummw mity be oblijmd to "it or iocur by roamm of amy much lmkReo 4. actumal Jehienof a patimat or pebtLa The Promirpew aind the Curnmer A)BYPURCHAME - Parhwer agmm &hat fi;47ewilon shelt Do wwwroncwhaw agisiitrmuti Ycm~Idmhewaqof be iinplrmnrud untO or antem appered by the seller. Thomo irffo ind. m to reor for fte &Rom ofMY iso&sunit revi0ion Thig Indanrftl ann-Dot mmmed to alleRcd or muronal imJY4%mxmAsul multing shall betramaittitilfix wrtbmn TpurvE Do mflleE. ft b Scee wifioeth doPmltnurat&A or Cuitawrimn desivi, b) RY SELLERt - The StUaer apmee dme flarM-Ww hall be no rv sio I itoctiom prmmm, or ftnmah"f prridod, boweme. awstt Same opra imp1miented wntll or aai approved1 by Buyer TIxost be i wpo,Ribole if it 4ini~obntr io asum The line Sellr sbmuld linme been revigiomt Sb&n be taiw lt fer wommte iqpia bo Ite Stee avemm of a pcm%blo alk$Sd or namWe irdnlhgarveint meif* &Qom lho Pox Purchsing Deptartnment Porchanenor Cuaowes degign. ftwienictiome procnim or formulan and f01%b moeJ *e Parde"MI of On&2 l iiy 15 12:82 6673246188 Case 1:10-cv-00569-RJA eG6/3D/2010 Document 6-2 PAUL ARGEHTIERI Filed 07/09/2010 PAGE Page 12 of 16 16 T 9 8, Ansiuorrurntof Subtataneru-mg hiih hsOdrnrU ih,olpig tmnc due hcucnder amassigable m0 WnieraTle (n k'cudiy .Or Ld"nes ar thrio)s I ur Pda e rhasoe?a prior wrenc contsent, And except Asto A) Whenever the SellRu hus knowledge dat amy a=41 mt prtentWa labor dk giputhreabona to delaydthe time4 gor cm or o orer the shal imed ngie notc t % by daig Order %,it)hout the uthacharre'a prior witten tplaoa). Tne Purchterrshnn not be reqiured to =OIertaAgnmrvntOf aushornscr wd~ eaien ~'order taprio nid ridcis Thc buyer acrialI that there will be mwo 6than cubcnoracm warling ontis prceaec thiz wor wil be *aerieLdpmovided a rnomapett: And .wotk rnwld Ir asWeent e no place, for b) The Sell"r ahxll inart seanee of thiA clausc including &it pawagraph (h)in miy subt6vr aipply %gmenin heo=udet i. to which a labor I:R"p "it d&Ay the tisnely p rensof that mcial rinat tch "ach vulatir upply wgene hof provide thariin the emAent imelroy parforrnee is dtixytd or Tbretened bT delry by =iachn) or pmventW et dimputr, the b vubticr Sellearha" irnmediabdyyn.Afy ita tiert ig ia Sler or We Selltats, a the ct: may kc ofiII zdevn mnlon;tion' with.,Hpxc putchancy of -vffutLrieg om KundaIrd cornmirca Artices nm p". die StIlet chAll not tubtomact:e any rta6oIr portion. of rabs work encopaaIIed 9. PM76CM7asyRWo It it colde that this sawork masde forAte, ppmrnent And that a11 lntreetus. propergt n paet Eitam at i of Scloefix.1ne. rK AMl cods inporion or in its comIalrebe (ornremain the property of SreeFalnlfhcnro bcaopplcd hrrundeei'nyeat deiecd ;n gc&mrdanccArit1b qxcifiatiorus ordainx EmniRhed or ationteod by the Purchasser ar ins Customner, sPmb innmx "hal nort be reproduced "sepc with the rMovid of the Yurchmff and, at Applicible, GcaCwo=&'; id ldrvuringp, phtInDraphx, data, softwar, and ot$ei-.teen material Or inf!ortion supplied in contacc6in thanrt sh aaltne. hall emai the propoey of ThevcacrorsCtmnandlac:rhrcd, pmnqdy qspn rc- tRthe complettion, tanrntion ot ccrlAtion of this order. In the evetm that SurrtFat defrulro on ionymoentnyr eights would be granted to selmer 10. Tnnin dondurig 0,TmiainCon ADEFAULTr- Tho llua4vser may trtinate tais oder or any putr rtneof by vhie6fWli*tkx if (he Sellnn a) faInt0 make dcelis or to ormnk# performane of im cKitationa heareunder v;Iin rThe uatcig6d men time * oMrarec ridh thle #&ried schedulct uniml~ mch failure i. &V to o of God, nie othmctavwih meyond te .Selcalr contaol of the Seller. b) ra4 to comply with thA erms ated coodftionas ofthe ctar *order And does mit such kdait not rwithin a period oftean (10) &dedOaftertrines, notice therecf.pirdct to proceehsgsWideramty lw adttir(gtobast"wpy, intol-tncy, or the relief of dcbtwen. Should the Pur-hasaa elect to earm;taw kox 4ciwk tile Pbireb"Cer noay rake p6icivion of a of mry the zortsa to be of Lk~d hereund= whd6 atv; ine Selleres poRmesion wuthoux regard to tag of catniActuan ank cosntrilcto or tusnihe work to a completed On ty aut finya arer f eoet aiasaron~Axty ion ma adiditimnal coa,Es caflmm 6,curred laythe Puadhvcr o,rer and above or themidgin9dpunreepricet firont ie StAl,r pkm fceter RhAll for be the accourvy of sthe Sam .. In all evnkt the Purchaser shal not be or become Uablrc thde Serlme or amy third party dairning through or under the Seiler fat any portion of the prie oa'any itarn thAi PanctAner ciects nor TO accept Foallorving noat of btanintitn for defhu)l.9-l T'he Seller Aetna an deliver the itseni to be supplied lieexnder fore and ti-r or AlD urua, axcaets. andi Cimins acur, or nmelill mn OF and the larEert trayp wiAhol pynmti pending rede;pt of evidence9f( in forra Ind vabsaftnce satisleoiy to itc f the ibneana of suach itrtna, cl,rimo antd Ldorammv 12. Goea Ljtvr 'Mis lhirch9sc Order Arid Arty mtaterial vreaing thateto oWa be govItmed by die lams ofi Tesatem inted whic Th.sraebaa&al offk%mhnt isvu the ordtt iAlocated. if the Sencer srer tamy darrtiTes should AAs meult of antittuet a ,inluiuwn in Any ninner due rowpeie lrag, on rte pae ofianother msnutt,eur of Sacr th el sd=hAl pay ov&r ib thS Peaseas. Any Aa Purelwne huasauffereda= aressul of the ga=i prie fi*ag within a IvaamnalIlirime after- the da"tIxrmaecovered by ,Te Seller. 14. Notieof brirputt% inding tul rdx:I,nM inromaditan vith rexpeetheret. to &Ce postlneer. to Much cliapure. 15, Indannity ~rurinafeContcaeovi/Slik CorartVerWdor tai defend indenity and Wnzs Pa from Street any and all clahYsit, in,Isc, drtapoa, cr rarlanItt, wlaether ca&n Dd or conuibubed Wa the ncgligraumo by &Sea Pax, imdimm.t or wamplaytex or otherwise. on ancount of.iohytiv to or dci1h of arny And alD.Perfo .Is vilort5ioet i"idvMGQAl The CqnraerVor, trubeobctan rroftk*ytaifCnnkwtmfVado; the ftbeooaect. arid, or Sut VLz6.Ha iA aid AD dat,4r to Propetty to .d,mnsoee bllo.E.unhi d by rvend no,or i the aare, euoa or enra f ln$tn ennirigrpia erroo i 2M ,re connetd wItas erbs unssid ef6ntrAc4 or d lar dhis clao rmction,hd e. in'y re" of ordiuLg the poso ace6dapMaxo FUe Ifrfy of waesoefVerdc sub nru4 th~a~e.Or agrntsr upon or in plria,ity in the pC~r of Se& xNqt8fnrigd foregoing, notig heri cct, rsfa bootodaN an ind"rel,fi CiO tile sole tieg)igh of siiWat Pik st 16. PubIlty O bapooaAeojvpvrdean o mnake vpeedchr Aourt or ohecvise ptiblitize the Citrne ot- HcUpIc of tir Prch tOe. or Mel, gmain M t2;1g%;,laour rkil Tilthage Ovrt withouit.firstxitin;I the -6dticortatit ofWEycr. hc procrager or nrutfacrued it iaWil i elafy&oct the Buyer In conteztioan wtthpeformtance of dur dOnh'= rent4 b used by The Buyer for cil pup Iosx: elding th contant and to im de performnce without 6lit7hr tlarrefor to the Scbm 18, Graemal Noon Sellr shal! fatevaer thia puchase order numnber on all doomenn Andilm oaeyesndance related to dhis order 'fI aigmMat below w.ill crocutt: this coreIam Bume - Pan Mr ii ukt L .re 2Y r * /%/%1~ EfJ7324~188 Case 12:~J2 1:10-cv-00569-RJA Document 6-2 PAuL ARGENTIEPI Filed 07/09/2010 Page 13 of 16PAGE 17 -~ 4% I'-, k *5//i012: Case 02 6@73246188 1:10-cv-00569-RJA Document 6-2 PAUL ARGBENTIERI Filed 07/09/2010 VV M r jo. A0c) OMt3 L7 AinOwainvorn rio / 46#~~~ -Abc Jff. Oc Mom"NO dh, 5 V-MN7 - ~FOR.REORDEFlING Qoa.ns* Qc..caa * cOut dal Page 14 of 16PA(3E 6 r& PAY&MENr/ ;c - mrOThS o NEGOTIABLE4v/ 18 6873246188 Case 1:10-cv-00569-RJA e63828812:02 AO PAUL ARGENTIERI Document 6-2 Filed 07/09/2010 PA Page 15 of 16 it I 0/3W/2010 12:02 PAUL APGENTIEPI 60732461198 Case 1:10-cv-00569-RJA Division of Corporations ln,L. wv,, Document 6-2 Filed 07/09/2010 PAGE Page 16 of 16 Offline Ser-vices - Page I of 2 ToAlOW <Iaosm 14!oiraIa .sccrtIy I Cotota'I~ I r)fl ipk Departmoent of Stato; Division of Co'rporationni 2009 Amended Annual Franchise Tax Report You.rSevelan, 10 13 ME3661-S34009 TW fle n rlb e 383ilt once a Station In it sA,rad, oth SpJor1 V ond fIt-num,be, Ag nogdod to sign on io thIn e oln gin, The Golon ID wl b 0vaid~ for hY ooK%,sVOw4nR Set sta ID it 3s,,,d, the ArjalI Report is no] =ontdK*d Mee, The AnrluQl Rupon In ow. ri~,I.~.ub.Tnad pFmm olved.s nonry and lmruu ad riwill be chorpod If comlpqid 0w~t Marh APQufedIC FI@102 PlomaShiolthiyour Annual Rapnthas. alreadyboIo filed far the Tax Year 2001). All latorm,tilon Provided onl tha max% m,r,ni.r,nugf r,poni on his will be rapinowd by fIf You~ mullt" Iir All6%td aogain wen filing Uilmamended haporrl.In ImS dbirroid farmn, chil. Aended "Part, Flia Nubr' 32358015 Corporptlan.Nam,e: FACESOOK INC, F- P reatraI Employer MD: Incrpoation Data: WrA2DD4 Agent Number: 9030014 Agent Wune,l: CORPORATIONJ SERVICE COMPANY Street Addretui 2711 CENTERVILLE ROAD SUITE 400 Clry: WsLMINGTODN Ellen. DE 23p Codcs 191301 rranc,IhIso Taxi & S100.0t) Ponao)ty;a I.GVq'MWonthly Intorast I ArmnuAl FIling Psen31 Pre,,iou. rXrdlJt/D4IanCw v Prseeld Quartery Poyrn.mvnie 1 Amousnt DUR:11 gag~n Ott. End Data OleIgnaltoni I10 CIA"i 0.C. D013 S,4RO.16 5O00) M2.470.415 CR 0.00 0,00 Par Vwlkvoi sler. No. of She"&t COMMON J.D56C,4 0 O F 115,B00,280 COMMON Taw.s Gro. W12109 COMMON 02&D4G,4Qfl PREFERRED - l Prarn DAt"! D D00215 11,545,686 Fnd DAN W FecalI YGAn. F21f2009 RtcoDfoufof Tax A8.61 D,ts lmmiooryyyy) 113,000.200 '001; Q0 Total 0274=~Da Aunsn, X?11,200,000 .000006 PREFERRED 11120r0005 No. or llr, la~suad .0DCh PPEFERPED OG126=900 DDW5 E)ern (sefl,rrr W I T I o Dnl*,te:NVy r Principal Place of Business U~ I rJ~I 2U I 0~ W UN D STATES; T I Swui, Ago,rv Attachment 2 – Proof of Facts 7 Proof of Facts 1. Throughout the years 2001, 2002 and 2003, Paul Ceglia was developing an online database of street intersection photographs that were eventually either hosted on Streetfax.com or sold. 2. Streetfax was a large online database with photos of the majority of intersections within a specified city. The database was intended to aid insurance adjustors in investigating automobile accidents. 3. Throughout that period, Paul Ceglia would frequently post advertisements on Craigslist, an online forum for qualified contractors, which included, but was not limited to, computer programmers. 4. Specifically, Paul Ceglia advertised for programmers who would be able to develop the search engine feature on the Streetfax website to have two unique aspects: non-specific term searching, and synonymous term linking. 5. Those innovations were state-of-the-art at that time, and to Paul Ceglia's knowledge, were not readily available in any code format at that time. 6. In early 2003, Mark Zuckerberg responded to the Paul Ceglia's advertisement on Craigslist. 7. Prior to the signing of the contracts with Mark Zuckerberg on April 28, 2003, Paul Ceglia and Mark Zuckerberg engaged in multiple telephone and email conversations wherein Paul Ceglia introduced to Mark Zuckerberg the specifications of a database and search engine that could differentiate misspellings, non-specific term searching, and synonymous term linking that Mark Zuckerberg initially refuted could be built or programmed. 8. Paul Ceglia prevailed upon Mark Zuckerberg after several weeks of intensive debate by proposing multiple formulas to Mark Zuckerberg about constructing the non-specific word search engine. Prior to the signing of the contract, Paul Ceglia convinced Mark Zuckerberg that the use of a specific mathematical formula could succeed in searching for non-specific terms. 9. At that moment in time, Mark Zuckerberg accepted the viability of Paul Ceglia's formula, shared his enthusiasm about the coming project and offered to Paul Ceglia joint and equal ownership interest in his business venture and continued development of a suitable website for a project he was intending to initiate to the students of Harvard University and with the working title of either “The Face Book.” or “The Page Book”. In addition, it was further agreed that Paul Ceglia would also own 50% in the software, programming language and business interests derived from the expansion of that service to a larger audience. 10. Mark Zuckerberg offered, and Paul Ceglia agreed, to pay $1,000 for 50% ownership stake in the “The Face Book” and to perform elements connected with the computer programming work for the development of the site. 8 11. In addition, Paul Ceglia offered to hire Mark Zuckerberg and Mark Zuckerberg agreed to perform the programming work for Streetfax in the amount of $1,000. 12. On April 28, 2003, Mark Zuckerberg and Paul Ceglia met in person at the Radisson Hotel in Boston, Massachusetts. 13. At that meeting, Mark Zuckerberg signed a written agreement to be the software programmer for Streetfax and simultaneously agreed that Paul Ceglia would have a 50% ownership stake in “The Face Book”. 14. At that meeting, Paul Ceglia tendered a $3,000 cashier's check, dated April 25, 2003, from the Community Bank NA, to Mark Zuckerberg and Mark Zuckerberg deposited the cashier's check (for consideration that exceeded the written contractual requirements) into his student checking account at Fleet Bank. 15. At that meeting, the parties also signed another contract entitled, “StreetFax Back-End Technical Specification”, that had been previously prepared by Mark Zuckerberg. 16. The Facebook/Streetfax “Work for Hire” contract and the “StreetFax Back-End Technical Specification” contracts were both signed in the lounge of the Radisson Hotel in Boston MA. 17. Paul Ceglia's employee accompanied him on the trip and was an eye witness to the actual signing of both contracts as well as to the handwritten modifications (interlineations) contained therein. 18. Those agreements memorialized their understanding regarding Streetfax and “The Face Book” projects. In pertinent part, that agreement provides the following: The Purchaser/Buyer is Paul Ceglia. The Seller/Contractor is Mark Zuckerberg. 19. “The contract between the Purchaser and Seller as a Purchase agreement and “work made for hire” reflects two separate business ventures, the first being for the work to be performed directly for the Streetfax database and the programming language to be provided by Seller.” (Contract page 1, par. 2) 20. “Second, it is for the continued development of the software, program and for the purchase and design of a suitable website for the project Seller has already initiated that is designed to offer the students of Harvard university access to a website similar to a live functioning yearbook with the working title of “The Face Book”. (Contract page 1, par. 2) 21. “It is agreed that Purchaser will own a half interest (50%) in the software, programming language and business interests derived from the expansion of that service to a larger audience.” (Contract page 1, par. 2) 22. Buyer agrees to pay the seller the Sum of $1,000 a piece for the work to be performed for Streetfax and $1,000 for the work to be performed for “The Page Book” (Contract page 1, par. 3) 23. “The agreed upon project due date for the Streetfax software is May 31, 2003.” (Contract page 1, par. 3) 9 24. “The agreed upon completion for the expanded project with working title “The Face Book” shall be January 1, 2004 and an additional 1% interest in the business will be due the buyer for each day the website is delayed from that date.” (Contract page 1, par. 3) 25. The agreement gave rise to an obligation for Mr. Zuckerberg to continue to develop and program The Face Book. 26. The agreement gave rise to fiduciary obligations between Mr. Ceglia and Mr. Zuckerberg. 27. The agreement obligated Mr. Zuckerberg to deal fairly and honestly with Mr. Ceglia. 28. The agreement obligated Mr. Zuckerberg to act with the utmost loyalty. 29. After the agreement was signed, Mr. Zuckerberg and Mr. Ceglia never met in person again, parted ways, and began their respective contractual obligations. 30. Lisa Simpson, counsel for Facebook Inc. and Mark Zuckerberg, on July 20th, 2010, in Federal District Court in Buffalo, NY, before Judge Richard Arcara, made the following admissions under questioning by Judge Arcara: a. “Mr. Zuckerberg did indeed have a contract with Mr. Ceglia.” b. “... agreed to code for Mr. Ceglia with respect to a project called Street Fax”. c. “Street Fax, F-A-X, which is actually one of the projects mentioned in the document” d. ”... with respect to the contract that we have in front of us, we have some serious questions because there are many inconsistencies and many undefined terms and things that don't make sense if you look at it on its face. Specifically, you'll see that there's a mention in there of Facebook and then there's another mention in there of Pagebook, and those are inconsistent. The consideration in the contract is directed directly to Pagebook. There's no consideration at all in the contract that relates to Facebook.” e. “Our client entered a contract with Ceglia.” 31. In an email dated September 2nd 2003, Mark Zuckerberg writes in part, “... Further, since the plan involves more than one college, the name can't have Harvard in it and remains unresolved. Additionally, both original names facebook.com and pagebook.com are unavailable, so there is no actual domain name either. thefacebook.com and thepagebook.com are both available but are clearly not a premium quality domain as they are much harder to remember.” 32. That agreement gave Paul Ceglia a valid enforceable ownership interest in the Facebook. 33. That interest includes, but is not in any way limited to, Facebook's intellectual property rights, advertising rights, current and future business interests. 10 34. That agreement explicitly gives Paul Ceglia an ownership interest in the software, programming language, and business interests derived from the expansion of Facebook to a larger audience. 35. In addition to the $3,000 cashier's check tendered on April 28, 2003, Paul Ceglia further tendered to Mark Zuckerberg a check in the amount of $5,000 on August 4, 2003, that was deposited in Mark Zuckerberg's Fleet Bank student checking account. 36. On November 16, 2003, Paul Ceglia received an email from Mark Zuckerberg requesting $1,000, in additional funds, for the continued development of The Face Book website as Mark Zuckerberg disclosed that there were two Harvard students (Winklevoss twins) preparing a website to compete with The Face Book. 37. Paul Ceglia complied with the request for additional funds for The Face Book and mailed $1,000 by Fed Ex dated November 27, 2003. The receipt of these additional funds for The Face Book are acknowledged by Mark Zuckerberg in his follow-up email on Jan. 1st, 2004, and were deposited in his Fleet Bank student checking account. 38. Mark Zuckerberg, under oath, at his June 22, 2006 hearing in the ConnectU lawsuit admitted that he commingled his funds from Streetfax and The Face Book into his student checking account at Fleet Bank. 39. The contract provided that Paul Ceglia was entitled to an additional 1% ownership interest in the above mentioned property for each day after January 1, 2004, that the website was not online. 40. On January 1, 2004, Mark Zuckerberg authored an email to Paul Ceglia acknowledging the receipt of the $1,000, requests additional funding for The Face Book site, and for Paul Ceglia to waive the penalty clause in their contract. 41. In an email authored on January 5, 2004 from Paul Ceglia to Mark Zuckerberg, Paul Ceglia asks Mark Zuckerberg about the status of The Face Book site, and how he had spent the additional $1,000. 42. In that same email, Paul Ceglia threatens to call Harvard and/or Mark Zuckerberg's parents. 43. At that time and unbeknownst to Paul Ceglia, Mark Zuckerberg is on probation following his violations of the Harvard privacy regulations when he created a website entitled Facemash by hacking into the Harvard University's server and/or students information without authority. 44. Facemash was a website created to allow Harvard students to vote on the appearance of other students in a derogatory and sarcastic manner. 45. On January 6, 2004, Mark Zuckerberg authored an email to Paul Ceglia demanding that any action by Paul Ceglia to call Harvard or his parents “would be seriously violating our trust by doing so, ...” confirms that there existed a “fiduciary relationship” with Paul Ceglia in their contractual and business relationship. 11 46. Unbeknownst to Paul Ceglia, on January 7, 2004, Mark Zuckerberg accepts $1,000 from Eduardo Saverin for 30% of The Face Book. 47. On January 13, 2004, Paul Ceglia authored an email to Mark Zuckerberg agreeing with him to utilize the database from Streetfax in order to facilitate the construction of The Face Book site. “Mark, I got to thinking, seems like a fantastic idea to use the database we built already, there is really no way you could rebuild something that could work as well.” 48. To illustrate the defect in MySpace and Paul Ceglia's contribution with the superior search engine for The Face Book, Paul Ceglia asks Mark Zuckerberg to attempt to spell twenty names of students he attended high school with on MySpace in order to see for himself the disadvantage of the specific spelling requirements of MySpace that The Face Book would eliminate. 49. With permission, Mark Zuckerberg utilized the database created for StreetFax, which was and is the intellectual property of Paul Ceglia. 50. Mark Zuckerberg in his email to Paul Ceglia on January 16, 2004, states, “I'll check into it and see how easily we could modify the script, I think you are right though and that it could manage people just as well as it manages street intersections.” 51. On January 14, 2004, Mark Zuckerberg purchases the domain name “TheFaceBook.com” from monies received from Paul Ceglia. 52. On February 2, 2004, Mark Zuckerberg authored an email to Paul Ceglia complaining about the penalty clause in the contact stating that, as it was presently constituted at that time, Paul Ceglia would own over 80% of the company (Facebook). Mark Zuckerberg gives Paul Ceglia an ultimatum that he would not launch the site until and unless, “you drop the penalty completely and that we officially return to 50/50 ownership.” 53. On February 3, 2004, Paul Ceglia authored an email to Mark Zuckerberg agreeing to remove the penalty clause and share 50/50 ownership in The Face Book. 54. On February 4, 2004, Mark Zuckerberg authored an email to Paul Ceglia confirming the launch of their website “thefacebook.com.” and states, “I'll let you know how it goes.” 55. Prior to the launch of the Face Book site, Paul Ceglia was the progenitor of the business expansion model for the software of The Face Book as a free site versus Mark Zuckerberg's idea of charging $29.95 per month for Harvard students. 56. In addition, Paul Ceglia promoted that The Face Book site go city to city rather than being limited to Harvard and/or the other Ivy League schools. 57. Mark Zuckerberg refused to give Paul Ceglia access to the website stating that he would have to have a harvard.edu address to get beyond the home page. 58. In his last email authored by Mark Zuckerberg to Paul Ceglia on July 22, 2004, Mark Zuckerberg attempts to induce Paul Ceglia to accept a refund in the amount of $2,000 that Paul Ceglia had previously invested in Facebook by lying when he states, “Another summer is here and I still don't have any time to build our site ...” 12 59. Mark Zuckerberg intentionally lied to Paul Ceglia about his actions and the success of TheFaceBook.com. 60. Mark Zuckerberg's email of July 22, 2004 was an outright fraud, as he, among other things, attempted to use his Harvard email address, rather than his Facebook email, to mislead and conceal the truth that Facebook was exploding within it's confined circles. 61. Also at that time, and unbeknownst to Paul Ceglia, Mark Zuckerberg was in the process of incorporating in the State of Delaware when he intentionally made false representations to conceal his intent to defraud Paul Ceglia out of his 50% ownership in Facebook. 62. On July 29th 2004, Mark Zuckerberg Breaches the contract with Paul Ceglia by denying him his ownership interest in Facebook Inc. 63. For several months, Mr. Zuckerberg failed to deliver to Mr. Ceglia his rightful ownership share. 64. Under testimony given on June 22nd 2006, Mark Zuckerberg admits to having backdated at least one document. 65. On July 29, 2004, Mr. Zuckerberg, Mr. Moskovitz, and Mr. Saverin formed The Facebook, Inc. in the State of Delaware. 66. On January 7, 2005, Mr. Zuckerberg, signs the First Amended and Restated Certificate of Incorporation of the The Facebook Inc. in the State of Delaware. 67. On March 31, 2005, Mr. Zuckerberg, signs the Second Amended and Restated Certificate of Incorporation of The Facebook Inc. in the State of Delaware. 68. At some time after the formation of Facebook, Inc., Mr. Zuckerberg assigned his rights and alleged property in Facebook to The Facebook, Inc. 69. Upon information and belief, that assignment included property that rightfully belonged to Mr. Ceglia. 70. Mr. Zuckerberg made that assignment without notifying Mr. Ceglia. 71. Mr. Zuckerberg knew that the property he was purporting to assign to The Facebook, Inc. rightfully belonged to Mr. Ceglia, as evidenced by the email sent one week before on July 22, 2004, wherein Mr. Zuckerberg offers to repay Mr. Ceglia for his Facebook interest. 72. Mr. Zuckerberg knew he was violating his contract with Mr. Ceglia when he assigned those rights to The Facebook, Inc. 73. Mr. Zuckerberg knew he was violating his fiduciary duties to Paul Ceglia. 74. Since the time of that incorporation, Facebook, Inc. has remained a privately held company, making its ownership interest largely unknown. 13 75. However, upon information and belief, Mr. Zuckerberg breached his agreement with Mr. Ceglia by continuing to give ownership interests to new investors. 76. Since Mr. Zuckerberg's assignment to Facebook, Inc., it has become one of the world's most successful business ventures. 77. Currently, Facebook has more than 500 million users. 78. Moreover, Facebook and the proprietary rights connected to Facebook are valued at billions of dollars. 14 Attachment 3 – Oral Arguments 7-20-10 15

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