Music Download Lawsuit - John Deep v. RIAA, Boies, et al.

A. Dec. 2000 – I Disclose Confidential Information to My Lawyers

73. On November 15, 2000, David Boies wrote a letter to me on the letterhead of the law firm of Boies-Schiller, signed by David Boies and dated November 15, 2000.

74. The letter refers to the receipt of “Datamine’s 15% equity interest.” The letter concludes, “I look forward to working with you and your team.”

75. On December 13, 2000, David Boies flew to Albany, New York, to attend a meeting with me, at which I provided confidential information and documents to David Boies, Steven Fischer, CEO of LSAG, and Duker acting an agent of Trans World, about the use of my proprietary method for “targeted” marketing of discounted prices, which I had branded as “Aimster.”

76. Between November 2000 and now, I provided confidential documents or information about my proprietary Aimster method to David Boies, and to Boies-Schiller lawyers or staff supervised by David Boies, including George Carpinello, Kathleen Franklin, Michael Endler, Robert Silver, David Barrett, Christopher Boies, Adam Shaw and other staff attorneys.

77. I have also been represented by the firm of Straus Boies, which did not communicate with me but communicated instead directly with my lawyers at Boies Schiller.