Adstra, LLC v. Kinesso, LLC et al
| New York Southern District Court | |
| Judge: | Lewis J Liman |
| Case #: | 1:24-cv-02639 |
| Nature of Suit | 880 Civil Rights - Defend Trade Secrets Act of 2016 (DTSA) |
| Cause | 18:1836(a) Injunction against Misappropriation of Trade Secrets |
| Case Filed: | Apr 08, 2024 |
| Last checked: Saturday Oct 05, 2024 8:49 AM EDT |
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Defendant
Acxiom, LLC
100 West 33rd Street
New York, NY 10001 |
Represented By
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Defendant
Kinesso, LLC
100 West 33rd Street
New York, NY 10001 |
Represented By
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Plaintiff
Adstra, LLC
750 College Road East
Princeton, NJ 08540 |
Represented By
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| Docket last updated: 8 hours ago |
| Monday, December 16, 2024 | ||
| 137 | 137
respm
Declaration in Support of Motion
Mon 12/16 11:12 PM
DECLARATION of Hal S. Shaftel in Support re:128 MOTION for Summary Judgment .. Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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Att: 1
Exhibit 001 Excerpts Holloway Transcript,
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Att: 2
Exhibit 002 Excerpts Erwin Transcript (sealed),
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Att: 3
Exhibit 003 ADSTRA _0009177(Sealed),
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Att: 4
Exhibit 004 ADSTRA_0011799 (Sealed),
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Att: 5
Exhibit 005 Excerpts Xavier Transcript,
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Att: 6
Exhibit 006 ACXIOM001262,
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Att: 7
Exhibit 007 Excerpts Thomas Transcript,
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Att: 8
Exhibit 008 ADSTRA_0009747 (sealed),
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Att: 9
Exhibit 009 Excerpts Johnson (sealed),
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Att: 10
Exhibit 010 Excerpts Mooney Transcript,
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Att: 11
Exhibit 011 ADSTRA_0011965 (sealed),
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Att: 12
Exhibit 012 ADSTRA_001199 (sealed),
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Att: 13
Exhibit 013 ADSTRA_0012266 (sealed),
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Att: 14
Exhibit 014 ADSTRA_0020172 (sealed),
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Att: 15
Exhibit 015 ADSTRA_0012361 (sealed),
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Att: 16
Exhibit 016 ADSTRA_0012374 (sealed),
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Att: 17
Exhibit 017 ADSTRA_0012016 (sealed),
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Att: 18
Exhibit 018 ADSTRA_0000015 (sealed),
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Att: 19
Exhibit 019 Excerpts Donovan Transcript,
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Att: 20
Exhibit 020 ADSTRA_0012153 (sealed),
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Att: 21
Exhibit 021 ADSTRA_0012202 (sealed),
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Att: 22
Exhibit 022 ADSTRA_0010720 (sealed),
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Att: 23
Exhibit 023 ADSTRA_0012953 (sealed),
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Att: 24
Exhibit 024 ADSTRA_0019716 (sealed),
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Att: 25
Exhibit 025 ADSTRA_0002667 (sealed),
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Att: 26
Exhibit 026 ADSTRA_0011663 (sealed),
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Att: 27
Exhibit 027 KINESSO000013 (sealed),
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Att: 28
Exhibit 028 ACXIOM001573 (sealed),
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Att: 29
Exhibit 029 KINESSO000001 (sealed),
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Att: 30
Exhibit 030 Excerpts Becker Transcript,
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Att: 31
Exhibit 031 ACXIOM002844 (sealed),
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Att: 32
Exhibit 032 ACXIOM001712 (sealed),
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Att: 33
Exhibit 033 ACXIOM000358 (sealed),
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Att: 34
Exhibit 034 ACXIOM000240 (sealed),
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Att: 35
Exhibit 035 Excerpts Kelleher Transcript,
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Att: 36
Exhibit 036 Excerpts Bier Transcript,
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Att: 37
Exhibit 037 ACXIOM002685 (sealed),
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Att: 38
Exhibit 038 ADSTRA_0003269 (sealed),
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Att: 39
Exhibit 039 ADSTRA_0003308 (sealed),
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Att: 40
Exhibit 040 ADSTRA_0003824 (sealed),
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Att: 41
Exhibit 041 ADSTRA_0009014 (sealed),
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Att: 42
Exhibit 042 ADSTRA_0009068 (sealed),
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Att: 43
Exhibit 043 ADSTRA_0009011 (sealed),
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Att: 44
Exhibit 044 ADSTRA_0013531(sealed),
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Att: 45
Exhibit 045 ADSTRA_0003379 (sealed),
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Att: 46
Exhibit 046 ACXIOM000619,
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Att: 47
Exhibit 047 ADSTRA_0013882 (sealed),
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Att: 48
Exhibit 048 ADSTRA_0020411 (sealed),
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Att: 49
Exhibit 049 ACXIOM000743,
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Att: 50
Exhibit 050 2024.12.05 Letter from A. Aguilar,
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Att: 51
Exhibit 051 Excerpts Qorbani Transcript,
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Att: 52
Exhibit 052 Excerpts Laykin Transcript,
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Att: 53
Exhibit 053 KINESSO000004,
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Att: 54
Exhibit 054 ACXIOM002273,
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Att: 55
Exhibit 055 ACXIOM003234 (sealed),
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Att: 56
Exhibit 056 ACXIOM003243,
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Att: 57
Exhibit 057 ACXIOM002615,
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Att: 58
Exhibit 058 ACXIOM002587,
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Att: 59
Exhibit 059 ACXIOM003176 (sealed),
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Att: 60
Exhibit 060 ACXIOM003252 (sealed),
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Att: 61
Exhibit 061 ACXIOM003257 (sealed),
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Att: 62
Exhibit 062 ACXIOM003175 (sealed),
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Att: 63
Exhibit 063 ACXIOM003240 (sealed),
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Att: 64
Exhibit 064 ACXIOM003237 (sealed),
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Att: 65
Exhibit 065 Article
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| 136 | 136
30+
pgs
respm
Memorandum of Law in Support of Motion
Mon 12/16 9:40 PM
MEMORANDUM OF LAW in Support re:133 MOTION to Preclude Expert Reports and Testimony of Defendants' Experts Ron Schnell and Bala Dharan, Ph.D. . . Document filed by Adstra, LLC..(Burton Walsh, Anne) |
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| 135 | 135
respm
Declaration in Support of Motion
Mon 12/16 9:37 PM
DECLARATION of Anne Burton-Walsh in Support re:133 MOTION to Preclude Expert Reports and Testimony of Defendants' Experts Ron Schnell and Bala Dharan, Ph.D. .. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
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Att: 1
Exhibit Under Seal - November 6, 2024 Expert Report of Ron Schnell, Acxioms technical rebuttal expert,
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Att: 2
Exhibit Under Seal - November 6, 2024 Expert Report of Bala G. Dharan, Acxioms damages rebuttal expert,
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Att: 3
Exhibit Under Seal - October 22, 2024 Expert Report of Erik Laykin, Adstras technical expert,
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Att: 4
Exhibit MDSA with Schedules A and B,
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Att: 5
Exhibit Transcript of June 7, 2024 30(b)(6) Deposition of Kyle Hollaway (Excerpted),
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Att: 6
Exhibit Under Seal - Transcript of September 12, 2024 Deposition of Todd Thomas (Excerpted),
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Att: 7
Exhibit Under Seal - Appendix A to Ron Schnells November 6, 2024 Expert Report,
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Att: 8
Exhibit Under Seal - Transcript of the November 14, 2024 Deposition of Ron Schnell (Excerpted),
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Att: 9
Exhibit Under Seal - October 22, 2024 Expert Report of Christopher W. Young, Ph.D, Adstras damages expert,
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Att: 10
Exhibit Under Seal - Transcript of the November 15, 2024 Deposition of Bala G. Dharan (Excerpted),
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Att: 11
Exhibit Under Seal - Transcript of the November 26, 2024 Deposition of Christopher W. Young, Ph.D. (Excerpted),
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Att: 12
Exhibit Under Seal - KINESSO000125, Confidential Kii Identity Spine Presentation dated January 19, 2023,
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Att: 13
Exhibit April 26, 2024 Declaration of Todd Thomas,
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Att: 14
Exhibit Under Seal - ACXIOM002911, November 16, 2023 internal Acxiom messages between Bryan Donovan and Eugene Becker,
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Att: 15
Exhibit Under Seal - ACXIOM000357 and ACXIOM000358, Email from Veena Xavier dated April 30, 2024 with attachment TTID & MAIDs Identity Crosswalk Generation Workflow Graph,
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Att: 16
Exhibit Under Seal - ACXIOM000285, Email exchange between Kyle Hollaway, et al. dated December 2023 January 2024 re Acxiom/Adstra Follow Up on IP to HH Data,
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Att: 17
Exhibit Under Seal - ACXIOM001798, Acxiom RealID Cross-Referential Identity Graph Presentation dated October 1, 2023,
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Att: 18
Exhibit Under Seal - ACXIOM000715, Email from Veena Xavier to Bryan Donovan and Jennifer Nicholson dated September 16, 2023 re Discussing Adstra Testing,
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Att: 19
Exhibit Under Seal - ACXIOM002655, April 9, 2024 internal Acxiom messages between Alan Rainey and Veena Xavier,
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Att: 20
Exhibit Under Seal - ACXIOM001088, Kinesso/Console/KAS Presentation dated November 2023,
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Att: 21
Exhibit Under Seal - Transcript of the November 27, 2024 Deposition of Reza Qorbani (Excerpted),
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Att: 22
Exhibit Dharan Deposition Exhibit 3, Screenshot of Acxioms Website,
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Att: 23
Exhibit Under Seal - ACXIOM003176, Acxiom- Master Partnership Agreement, ACXIOM003252 [Acxiom Real ID Contract] and ACXIOM003257 [Acxiom Real ID Licensing Agreement],
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Att: 24
Exhibit Under Seal - Transcript of the September 10, 2024 Deposition of Veena Xavier (Excerpted),
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Att: 25
Exhibit Under Seal - Transcript of the September 11, 2024 Deposition of Andy Johnson,
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Att: 26
Exhibit Under Seal - ACXIOM000499, Email exchange between Veena Xavier, et al. dated February 2024 re Update on Adstra Data
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| 134 | 134
respm
Declaration in Support of Motion
Mon 12/16 9:30 PM
***SELECTED PARTIES***DECLARATION of Hal S. Shaftel in Support re:128 MOTION for Summary Judgment .. Document filed by Kinesso, LLC, Acxiom, LLC, Adstra, LLC.Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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Att: 1
Exhibit 1 Excerpts Hollaway Tr,
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Att: 2
Exhibit 2 Excerpts Erwin Tr,
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Att: 3
Exhibit 3 ADSTRA_0009177,
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Att: 4
Exhibit 4 ADSTRA_0011799,
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Att: 5
Exhibit 5 Excerpts Xavier Tr,
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Att: 6
Exhibit 8 ADSTRA_0009747,
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Att: 7
Exhibit 9 Excerpts Johnson Tr,
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Att: 8
Exhibit 11 ADSTRA_0011965,
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Att: 9
Exhibit 12 ADSTRA_0011991,
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Att: 10
Exhibit 13 ADSTRA_0012266,
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Att: 11
Exhibit 14 ADSTRA_0020172,
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Att: 12
Exhibit 15 ADSTRA_0012361,
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Att: 13
Exhibit 16 ADSTRA_0012374,
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Att: 14
Exhibit 17 ADSTRA_0012016,
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Att: 15
Exhibit 18 ADSTRA_0000015,
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Att: 16
Exhibit 19 Excerpts Donovan Tr,
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Att: 17
Exhibit 20 ADSTRA_0012153,
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Att: 18
Exhibit 21 ADSTRA_0012202,
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Att: 19
Exhibit 22 ADSTRA_0010720,
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Att: 20
Exhibit 23 ADSTRA_0012953,
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Att: 21
Exhibit 24 ADSTRA_0019716,
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Att: 22
Exhibit 25 ADSTRA_0002667,
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Att: 23
Exhibit 26 ADSTRA_0011663,
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Att: 24
Exhibit 27 KINESSO000013,
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Att: 25
Exhibit 28 ACXIOM001573,
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Att: 26
Exhibit 29 KINESSO000001,
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Att: 27
Exhibit 30 Excerpts Becker Tr.,
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Att: 28
Exhibit 31 ACXIOM002844,
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Att: 29
Exhibit 33 ACXIOM000358,
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Att: 30
Exhibit 38 ADSTRA_0003269,
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Att: 31
Exhibit 39 ADSTRA_0003308,
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Att: 32
Exhibit 40 ADSTRA_0003824,
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Att: 33
Exhibit 41 ADSTRA_0009014,
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Att: 34
Exhibit 42 ADSTRA_0009068,
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Att: 35
Exhibit 43 ADSTRA_0009011,
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Att: 36
Exhibit 44 ADSTRA_0013531,
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Att: 37
Exhibit 45 ADSTRA_0003379.,
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Att: 38
Exhibit 47 ADSTRA_0013882,
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Att: 39
Exhibit 48 ADSTRA_0020411,
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Att: 40
Exhibit 49 ACXIOM000743,
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Att: 41
Exhibit 51 Excerpts Qorbani Tr,
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Att: 42
Exhibit 52 Excerpts Laykin Tr,
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Att: 43
Exhibit 55 ACXIOM003234,
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Att: 44
Exhibit 56 ACXIOM003243,
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Att: 45
Exhibit 57 ACXIOM002615,
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Att: 46
Exhibit 58 ACXIOM002587,
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Att: 47
Exhibit 59 ACXIOM003176,
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Att: 48
Exhibit 60 ACXIOM003252,
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Att: 49
Exhibit 61 ACXIOM003257,
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Att: 50
Exhibit 62 ACXIOM003175,
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Att: 51
Exhibit 63 ACXIOM003240,
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Att: 52
Exhibit 64 ACXIOM003237
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| 133 | 133
motion
Preclude
Mon 12/16 9:19 PM
MOTION to Preclude Expert Reports and Testimony of Defendants' Experts Ron Schnell and Bala Dharan, Ph.D. . Document filed by Adstra, LLC..(Burton Walsh, Anne) |
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| 132 | 132
misc
Rule 56.1 Statement
Mon 12/16 8:57 PM
RULE 56.1 STATEMENT. Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 131 | 131
misc
Rule 56.1 Statement
Mon 12/16 8:56 PM
***SELECTED PARTIES***RULE 56.1 STATEMENT. Document filed by Kinesso, LLC, Acxiom, LLC. Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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| 130 | 130
30+
pgs
respm
Memorandum of Law in Support of Motion
Mon 12/16 8:55 PM
MEMORANDUM OF LAW in Support re:128 MOTION for Summary Judgment . . Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 129 | 129
respm
Memorandum of Law in Support of Motion
Mon 12/16 8:53 PM
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re:128 MOTION for Summary Judgment . . Document filed by Kinesso, LLC, Acxiom, LLC, Adstra, LLC. Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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| 128 | 128
motion
Summary Judgment
Mon 12/16 8:52 PM
MOTION for Summary Judgment . Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 127 | 127
respm
Memorandum of Law in Support of Motion
Mon 12/16 8:47 PM
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re:114 MOTION to Preclude Expert Reports and Testimony from Defendants' Experts Ron Schnell and Bala Dharan, Ph.D . . Document filed by Adstra, LLC. Motion or Order to File Under Seal:113 .(Burton Walsh, Anne) |
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| 126 | 126
respm
Declaration in Support of Motion
Mon 12/16 8:44 PM
DECLARATION of Hal S. Shaftel in Support re:122 MOTION in Limine to Exclude the Opinions and Testimony of Christopher W. Young .. Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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Att: 1
Exhibit A Young Expert Report (sealed),
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Att: 2
Exhibit B Young Tr(sealed),
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Att: 3
Exhibit C Dharan Expert Report(sealed),
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Att: 4
Exhibit D Adstra's R&O's to ROG(sealed),
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Att: 5
Exhibit E Adstra Customer Contract(sealed),
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Att: 6
Exhibit F Becker Tr_Redacted,
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Att: 7
Exhibit G Mooney Tr_Redacted,
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Att: 8
Exhibit H Graph Revenue Projection(sealed)
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| 125 | 125
respm
Declaration in Support of Motion
Mon 12/16 8:38 PM
***SELECTED PARTIES***DECLARATION of Hal S. Shaftel in Support re:122 MOTION in Limine to Exclude the Opinions and Testimony of Christopher W. Young .. Document filed by Kinesso, LLC, Acxiom, LLC, Adstra, LLC.Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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Att: 1
Exhibit A Young Expert report,
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Att: 2
Exhibit B Young Tr,
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Att: 3
Exhibit C Dharan Expert Report,
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Att: 4
Exhibit D Adstra's R&Os to ROGs.,
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Att: 5
Exhibit E Adstra Customer Contract,
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Att: 6
Exhibit F Becker Tr,
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Att: 7
Exhibit G Mooney Tr,
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Att: 8
Exhibit H Graph Revenue Projection
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| 124 | 124
30+
pgs
respm
Memorandum of Law in Support of Motion
Mon 12/16 8:32 PM
MEMORANDUM OF LAW in Support re:122 MOTION in Limine to Exclude the Opinions and Testimony of Christopher W. Young . . Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 123 | 123
respm
Memorandum of Law in Support of Motion
Mon 12/16 8:31 PM
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re:122 MOTION in Limine to Exclude the Opinions and Testimony of Christopher W. Young . . Document filed by Kinesso, LLC, Acxiom, LLC, Adstra, LLC. Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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| 122 | 122
motion
In Limine
Mon 12/16 8:29 PM
MOTION in Limine to Exclude the Opinions and Testimony of Christopher W. Young . Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 121 | 121
respm
Declaration in Support of Motion
Mon 12/16 8:24 PM
DECLARATION of Daniel Friedman in Support re:117 MOTION in Limine to Exclude the Testimony of Erik Laykin .. Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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Att: 1
Exhibit A Laykin Report (sealed),
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Att: 2
Exhibit B Laykin Depo(sealed),
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Att: 3
Exhibit C Schnell Report(sealed),
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Att: 4
Exhibit D Schnell Excerpts(sealed),
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Att: 5
Exhibit E ACXIOM000357(sealed),
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Att: 6
Exhibit F ACXIOM000715(sealed),
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Att: 7
Exhibit G Xavier Excerpts(sealed)
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| 120 | 120
respm
Declaration in Support of Motion
Mon 12/16 8:09 PM
***SELECTED PARTIES***DECLARATION of Daniel Friedman in Support re:117 MOTION in Limine to Exclude the Testimony of Erik Laykin .. Document filed by Kinesso, LLC, Acxiom, LLC, Adstra, LLC.Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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Att: 1
Exhibit A Laykin Report,
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Att: 2
Exhibit B Laykin Depo,
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Att: 3
Exhibit C Schnell Report,
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Att: 4
Exhibit D Schnell Excerpts,
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Att: 5
Exhibit E ACXIOM000357,
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Att: 6
Exhibit F ACXIOM000715,
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Att: 7
Exhibit G Xavier Excerpts
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| 119 | 119
27
pgs
respm
Memorandum of Law in Support of Motion
Mon 12/16 8:00 PM
MEMORANDUM OF LAW in Support re:117 MOTION in Limine to Exclude the Testimony of Erik Laykin . . Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 118 | 118
respm
Memorandum of Law in Support of Motion
Mon 12/16 7:59 PM
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re:117 MOTION in Limine to Exclude the Testimony of Erik Laykin . . Document filed by Kinesso, LLC, Acxiom, LLC, Adstra, LLC. Motion or Order to File Under Seal:115 .(Shaftel, Harold) |
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| 117 | 117
motion
In Limine
Mon 12/16 7:55 PM
MOTION in Limine to Exclude the Testimony of Erik Laykin . Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
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| 116 | 116
respm
Declaration in Support of Motion
Mon 12/16 7:46 PM
***SELECTED PARTIES***DECLARATION of Anne Burton-Walsh in Support re:114 MOTION to Preclude Expert Reports and Testimony from Defendants' Experts Ron Schnell and Bala Dharan, Ph.D .. Document filed by Adstra, LLC.Motion or Order to File Under Seal:113 .(Burton Walsh, Anne) |
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Att: 1
Exhibit Nov. 6, 2024 Rebuttal Expert Report of Defendants' Technical Expert Ron Schnell,
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Att: 2
Exhibit Nov. 6, 2024 Rebuttal Expert Report of Defendants' Damages Expert Bala G. Dharan, Ph.D.,
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Att: 3
Exhibit Oct. 22, 2024 Expert Report of Plaintiff's Technical Expert Erik Laykin,
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Att: 4
Exhibit Mar. 3, 2020 MDSA,
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Att: 5
Exhibit Transcript of June 7, 2024 30(b)(6) Deposition of Kyle Hollaway (Excerpted),
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Att: 6
Exhibit Transcript of September 12, 2024 Deposition of Todd Thomas (Excerpted),
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Att: 7
Exhibit Appendix A to Ron Schnells November 6, 2024 Expert Report,
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Att: 8
Exhibit Transcript of November 14, 2024 Deposition of Ron Schnell (Excerpted),
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Att: 9
Exhibit October 22, 2024 Expert Report of Christopher W. Young, Ph.D, Adstras damages expert,
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Att: 10
Exhibit Transcript of November 15, 2024 Deposition of Bala G. Dharan (Excerpted),
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Att: 11
Exhibit Transcript of November 26, 2024 Deposition of Christopher W. Young, Ph.D. (Excerpted),
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Att: 12
Exhibit KINESSO000125, Confidential Kii Identity Spine Presentation dated January 19, 2023,
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Att: 13
Exhibit Declaration of Todd Thomas in Opposition to Adstra, LLCs Proposed Order to Show Cause Seeking a Temporary Restraining Order, Expedited Discovery, and a Preliminary Injunction, dated April 26, 2024,
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Att: 14
Exhibit ACXIOM002911, November 16, 2023 internal Acxiom messages between Bryan Donovan and Eugene Becker,
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Att: 15
Exhibit ACXIOM000357 and ACXIOM000358, Email from Veena Xavier dated April 30, 2024 with attachment TTID & MAIDs Identity Crosswalk Generation Workflow Graph,
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Att: 16
Exhibit ACXIOM000285, Email exchange between Kyle Hollaway, et al. dated December 2023 January 2024 re Acxiom/Adstra Follow Up on IP to HH Data,
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Att: 17
Exhibit ACXIOM001798, Acxiom RealID Cross-Referential Identity Graph Presentation dated October 1, 2023,
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Att: 18
Exhibit ACXIOM000715, Email from Veena Xavier to Bryan Donovan and Jennifer Nicholson dated September 16, 2023 re Discussing Adstra Testing,
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Att: 19
Exhibit ACXIOM002655, April 9, 2024 internal Acxiom messages between Alan Rainey and Veena Xavier,
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Att: 20
Exhibit ACXIOM001088, Kinesso/Console/KAS Presentation dated November 2023,
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Att: 21
Exhibit Transcript of November 27, 2024 Deposition of Reza Qorbani (Excerpted),
|
||
|
Att: 22
Exhibit Dharan Deposition Exhibit 3, Screenshot of Acxioms Website.,
|
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|
Att: 23
Exhibit ACXIOM003176, Acxiom-Adobe Master Partnership Agreement, ACXIOM003252 [Acxiom Real ID Contract] and ACXIOM003257 [Acxiom Real ID Licensing Agreement],
|
||
|
Att: 24
Exhibit Transcript of September 10, 2024 Deposition of Veena Xavier (Excerpted),
|
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|
Att: 25
Exhibit Transcript of September 11, 2024 Deposition of Andy Johnson (Excerpted),
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|
Att: 26
Exhibit ACXIOM000499, Email exchange between Veena Xavier, et al. dated February 2024 re Update on Adstra Data
|
||
| 115 | 115
motion
Seal
Mon 12/16 7:28 PM
LETTER MOTION to Seal addressed to Judge Lewis J. Liman from Hal S. Shaftel dated December 16, 2024. Document filed by Kinesso, LLC, Acxiom, LLC..(Shaftel, Harold) |
|
| 114 | 114
motion
Preclude
Mon 12/16 7:14 PM
***SELECTED PARTIES*** MOTION to Preclude Expert Reports and Testimony from Defendants' Experts Ron Schnell and Bala Dharan, Ph.D . Document filed by Adstra, LLC.Motion or Order to File Under Seal:113 .(Burton Walsh, Anne) |
|
| 113 | 113
motion
Seal
Mon 12/16 7:09 PM
LETTER MOTION to Seal addressed to Judge Lewis J. Liman from Anne Burton-Walsh dated December 16, 2024. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
| 112 | 112
misc
Rule 56.1 Statement
Mon 12/16 6:53 PM
RULE 56.1 STATEMENT. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
| 111 | 111
30+
pgs
respm
Memorandum of Law in Support of Motion
Mon 12/16 6:51 PM
MEMORANDUM OF LAW in Support re:107 MOTION for Partial Summary Judgment . . Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
| 110 | 110
respm
Declaration in Support of Motion
Mon 12/16 6:48 PM
DECLARATION of Anne Burton-Walsh in Support re:107 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
|
Att: 1
Exhibit 41 (Under Seal - ACXIOM003176, Acxiom-[Redacted] Master Partnership Agreement),
|
||
|
Att: 2
Exhibit 42 (Under Seal - ADSTRA_0020957, Excel Spreadsheet of Adstra Revenue by Client 2022 2024),
|
||
|
Att: 3
Exhibit 43 (Under Seal - Excerpted Transcript of the November 27, 2024 Deposition of Reza Qorbani),
|
||
|
Att: 4
Exhibit 44 (Under Seal - ADSTRA_0008144, Email exchange between Chandos Quill and Jonathan Kelleher dated October 2022 re Contract Pricing),
|
||
|
Att: 5
Exhibit 45 - ADSTRA_0012358, Email exchange between Todd Thomas and Kevin McKenna dated January February 2020 re Copy of Contract,
|
||
|
Att: 6
Exhibit 46 - ADSTRA_0019970, Email exchange between Kevin McKenna, et al. dated August October 2022 re Adstra Logs,
|
||
|
Att: 7
Exhibit 47 (Under Seal - ACXIOM000207, Email exchange between Todd Thomas and Bryan Donovan dated October 2023 re Adstra Contract Summary),
|
||
|
Att: 8
Exhibit 48 (Under Seal - ACXIOM001088, Kinesso/Console/KAS Presentation dated November 2023),
|
||
|
Att: 9
Exhibit 49 - Interpublic Groups Press Release announcing IPGs Acquisition of Acxiom LLC dated October 1, 2018,
|
||
|
Att: 10
Exhibit 50 - Acxioms Press Release for Real ID Launch dated October 17, 2023,
|
||
|
Att: 11
Exhibit 51 - ADSTRA_0000044; ADSTRA_0000045; ADSTRA_0000052, April 28, 2022 Email from Todd Thomas to Jason Bier and Nathan Chanel dated April 2022 re Adstra/Kinesso/Acxiom IP Address Legal Sync Bi-Weekly with redlined and clean drafts of the MDSA,
|
||
|
Att: 12
Exhibit 52 (Under Seal - ACXIOM000258, Email exchange between Kyle Hollaway, et al. dated April 9, 2024 re Adstra Data Purge),
|
||
|
Att: 13
Exhibit 53 (Under Seal - ACXIOM000414, Email exchange between Drew Mader and Todd Thomas dated February 20, 2024 re Adstra Payments),
|
||
|
Att: 14
Exhibit 54 (Under Seal - ACXIOM000499, Email exchange between Veena Xavier, et al. dated February 2024 re Update on Adstra Data),
|
||
|
Att: 15
Exhibit 55 (Under Seal - ACXIOM002911, November 16, 2023 internal Acxiom messages between Bryan Donovan and Eugene Becker),
|
||
|
Att: 16
Exhibit 56 (Under Seal - ACXIOM002655, April 9, 2024 internal Acxiom messages between Alan Rainey and Veena Xavier),
|
||
|
Att: 17
Exhibit 57 (Under Seal - ADSTRA_0013655, Adstra Competitors Presentation Slides),
|
||
|
Att: 18
Exhibit 58 (Under Seal - ACXIOM002711, April 12, 2024 internal Acxiom messages between Alan Rainey, Kyle Hollaway, and Veena Xavier)
|
||
| 109 | 109
respm
Declaration in Support of Motion
Mon 12/16 6:16 PM
DECLARATION of Anne Burton-Walsh in Support re:107 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
|
Att: 1
Exhibit April 5, 2024 Declaration of Andrew Johnson,
|
||
|
Att: 2
Exhibit (Under Seal - Excerpts of Expert Report of Erik Laykin),
|
||
|
Att: 3
Exhibit (Under Seal - Excerpts of Deposition Transcript of Andrew Johnson),
|
||
|
Att: 4
Exhibit MDSA with Schedules A and B,
|
||
|
Att: 5
Exhibit (Under Seal - Excerpts of Deposition of Plaintiff's Expert Christopher W. Young),
|
||
|
Att: 6
Exhibit (Under Seal - ADSTRA_0009633, ALC Identity & Data Solutions Presentation),
|
||
|
Att: 7
Exhibit (Under Seal - ADSTRA_0009689, Corporate and Capabilities Overview Presentation dated January 2020),
|
||
|
Att: 8
Exhibit (Under Seal - ADSTRA_0014567, ALC Board of Directors Meeting Presentation dated May 21, 2020),
|
||
|
Att: 9
Exhibit (Under Seal - KINESSO000125, Confidential Kii Identity Spine Presentation dated January 19, 2023),
|
||
|
Att: 10
Exhibit (Under Seal - ACXIOM000358, TTID & MAIDs Identity Crosswalk Generation Workflow Graph),
|
||
|
Att: 11
Exhibit 0011287, Signed Data Processor Agreement dated October 11, 2021,
|
||
|
Att: 12
Exhibit (Under Seal - ACXIOM000646, Data Provider Evaluation Agreement dated February 20, 2022),
|
||
|
Att: 13
Exhibit ADSTRA_0021168, Adstras Associate Handbook dated March 2021,
|
||
|
Att: 14
Exhibit ADSTRA_0021151, Adstras Information Technology Privacy & Security Policies and Procedures Handbook,
|
||
|
Att: 15
Exhibit ADSTRA_0021217, Adstras Data Security Brochure,
|
||
|
Att: 16
Exhibit Transcript (Excerpted) of the June 7, 2024 30(b)(6) Deposition of Kyle Hollaway,
|
||
|
Att: 17
Exhibit (Under Seal - Transcript (Excerpted) of the September 26, 2024 Deposition of Eugene Becker),
|
||
|
Att: 18
Exhibit (Under Seal - ADSTRA_0001069, Enterprise Identity Platform Thesis Presentation dated January 14, 2021),
|
||
|
Att: 19
Exhibit (Under Seal - ADSTRA_0012552, Adstra Board of Directors Meeting Presentation),
|
||
|
Att: 20
Exhibit ADSTRA_0011283, Email from Todd Thomas to Jason Bier and Kevin Mckenna dated October 11, 2021 re Acxiom Adstra Processing Agreement for Kinesso
|
||
| 108 | 108
respm
Declaration in Support of Motion
Mon 12/16 5:55 PM
DECLARATION of Andrew Johnson in Support re:107 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
| 107 | 107
motion
Partial Summary Judgment
Mon 12/16 5:52 PM
MOTION for Partial Summary Judgment . Document filed by Adstra, LLC. Responses due by 1/15/2025.(Burton Walsh, Anne) |
|
| 106 | 106
misc
Rule 56.1 Statement
Mon 12/16 5:34 PM
***SELECTED PARTIES***RULE 56.1 STATEMENT. Document filed by Adstra, LLC. Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
| 105 | 105
respm
Memorandum of Law in Support of Motion
Mon 12/16 5:27 PM
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re:100 MOTION for Partial Summary Judgment . . Document filed by Adstra, LLC. Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
| 104 | 104
respm
Declaration in Support of Motion
Mon 12/16 5:02 PM
***SELECTED PARTIES***DECLARATION of Anne Burton-Walsh in Support re:100 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC.Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
|
Att: 1
Exhibit ACXIOM003176, Acxiom-Adobe Master Partnership Agreement,
|
||
|
Att: 2
Exhibit ADSTRA_0020957, Excel Spreadsheet of Adstra Revenue by Client 2022 2024,
|
||
|
Att: 3
Exhibit Transcript (Excerpted) of the November 27, 2024 Deposition of Reza Qorbani,
|
||
|
Att: 4
Exhibit ADSTRA_0008144, Email exchange between Chandos Quill and Jonathan Kelleher dated October 2022 re Contract Pricing,
|
||
|
Att: 5
Exhibit ADSTRA_0012358, Email exchange between Todd Thomas and Kevin McKenna dated January February 2020 re Copy of Contract,
|
||
|
Att: 6
Exhibit ADSTRA_0019970, Email exchange between Kevin McKenna, et al. dated August October 2022 re Adstra Logs,
|
||
|
Att: 7
Exhibit ACXIOM000207, Email exchange between Todd Thomas and Bryan Donovan dated October 2023 re Adstra Contract Summary,
|
||
|
Att: 8
Exhibit ACXIOM001088, Kinesso/Console/KAS Presentation dated November 2023,
|
||
|
Att: 9
Exhibit Interpublic Groups Press Release announcing IPGs Acquisition of Acxiom LLC dated October 1, 2018,
|
||
|
Att: 10
Exhibit Acxioms Press Release for Real ID Launch dated October 17, 2023,
|
||
|
Att: 11
Exhibit ADSTRA_0000044; ADSTRA_0000045; ADSTRA_0000052, April 28, 2022 Email from Todd Thomas to Jason Bier and Nathan Chanel dated April 2022 re Adstra/Kinesso/Acxiom IP Address Legal Sync Bi-Weekly with redlined and clean drafts of the MDSA,
|
||
|
Att: 12
Exhibit ACXIOM000258, Email exchange between Kyle Hollaway, et al. dated April 9, 2024 re Adstra Data Purge,
|
||
|
Att: 13
Exhibit ACXIOM000414, Email exchange between Drew Mader and Todd Thomas dated February 20, 2024 re Adstra Payments,
|
||
|
Att: 14
Exhibit ACXIOM000499, Email exchange between Veena Xavier, et al. dated February 2024 re Update on Adstra Data,
|
||
|
Att: 15
Exhibit ACXIOM002911, November 16, 2023 internal Acxiom messages between Bryan Donovan and Eugene Becker,
|
||
|
Att: 16
Exhibit ACXIOM002655, April 9, 2024 internal Acxiom messages between Alan Rainey and Veena Xavier,
|
||
|
Att: 17
Exhibit ADSTRA_0013655, Adstra Competitors Presentation Slides,
|
||
|
Att: 18
Exhibit ACXIOM002711, April 12, 2024 internal Acxiom messages between Alan Rainey, Kyle Hollaway, and Veena Xavier
|
||
| 103 | 103
respm
Declaration in Support of Motion
Mon 12/16 4:43 PM
***SELECTED PARTIES***DECLARATION of Anne Burton-Walsh in Support re:100 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC.Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
|
Att: 1
Exhibit ADSTRA_0000003, Email from Todd Thomas to Jason Bier dated April 7, 2022 re Adstra/Kinesso/Acxiom IP Address Legal Sync Bi-Weekly,
|
||
|
Att: 2
Exhibit ADSTRA_0000005, Redlined MDSA, attachment to Ex. 21,
|
||
|
Att: 3
Exhibit ADSTRA_0000012, Redlined Adopting Agreement, attachment to Ex. 21,
|
||
|
Att: 4
Exhibit Transcript (Excerpted) of the September 12, 2024 Deposition of Todd Thomas,
|
||
|
Att: 5
Exhibit ADSTRA_0000096, Assignment Agreement between Acxiom and Kinesso dated November 27, 2023,
|
||
|
Att: 6
Exhibit ADSTRA_0003954, Email exchange between Jason Bier, et al. dated February 2024 re Letter to Jonathan Kelleher, CFO at Adstra, dated November 27, 2023,
|
||
|
Att: 7
Exhibit ADSTRA_0009506 and ADSTRA_0009507, Email from Todd Thomas dated November 28, 2024 attaching Termination Letter dated November 27, 2023,
|
||
|
Att: 8
Exhibit ACXIOM000993, Email exchange between Brent Barrow, et al. dated October 2023 February 2024 re Adstra ISR,
|
||
|
Att: 9
Exhibit ACXIOM002172, Email exchange between Todd Thomas and Cindy White dated January 24, 2024 re Kinesso Files,
|
||
|
Att: 10
Exhibit ACXIOM002074, Email exchange between Todd Thomas, et al. dated July 20, 2023 re Adstras Contribution to Kii,
|
||
|
Att: 11
Exhibit ACXIOM000715, Email from Veena Xavier to Bryan Donovan and Jennifer Nicholson dated September 16, 2023 re Discussing Adstra Testing; ACXIOM000719, Adstra Removal Research; and ACXIOM000720, Adstra Occupancies Analysis,
|
||
|
Att: 12
Exhibit Transcript (Excerpted) of the September 10, 2024 Deposition of Veena Xavier,
|
||
|
Att: 13
Exhibit ACXIOM000737, Email to Michael Lukaszevicz and William McCoy dated February 23, 2024 re Adstra Data,
|
||
|
Att: 14
Exhibit ACXIOM000285, Email exchange between Kyle Hollaway, et al. dated December 2023 January 2024 re Acxiom/Adstra Follow Up on IP to HH Data,
|
||
|
Att: 15
Exhibit ACXIOM000530, Email exchange between Veena Xavier, et al. dated December 2023 January 2024 re Acxiom/Adstra Follow Up on IP to HH Data,
|
||
|
Att: 16
Exhibit ACXIOM001798, Acxiom RealID Cross-Referential Identity Graph Presentation dated October 1, 2023,
|
||
|
Att: 17
Exhibit ACXIOM002599, February 22, 2024 internal Acxiom messages between Kyle Hollaway and Veena Xavier,
|
||
|
Att: 18
Exhibit ACXIOM002981, November 13, 2023 internal Acxiom messages between Bryan Donovan and Todd Thomas,
|
||
|
Att: 19
Exhibit ACXIOM002584, January 18, 2024 internal Acxiom messages between Brandi Johansen and Bryan Donovan,
|
||
|
Att: 20
Exhibit ACXIOM002565, February 20, 2024 internal Acxiom messages between Bryan Donovan and Todd Thomas
|
||
| 102 | 102
respm
Declaration in Support of Motion
Mon 12/16 4:16 PM
***SELECTED PARTIES***DECLARATION of Anne Burton-Walsh in Support re:100 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC.Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
|
Att: 1
Exhibit April 5, 2024 Declaration of Andrew Johnson,
|
||
|
Att: 2
Exhibit October 22, 2024 Expert Report of Erik Laykin,
|
||
|
Att: 3
Exhibit September 11, 2024 Deposition Transcript (Excerpted) of Andy Johnson,
|
||
|
Att: 4
Exhibit March 3, 2020 Master Data Supply Agreement (MDSA), with Schedules A and B,
|
||
|
Att: 5
Exhibit October 22, 2024 Expert Report of Christopher W. Young,
|
||
|
Att: 6
Exhibit ADSTRA_0009633, ALC Identity & Data Solutions Presentation,
|
||
|
Att: 7
Exhibit ADSTRA_0009689, Corporate and Capabilities Overview Presentation dated January 2020,
|
||
|
Att: 8
Exhibit ADSTRA_0014567, ALC Board of Directors Meeting Presentation dated May 21, 2020,
|
||
|
Att: 9
Exhibit KINESSO000125, Confidential Kii Identity Spine Presentation dated January 19, 2023,
|
||
|
Att: 10
Exhibit ACXIOM000357-58, TTID & MAIDs Identity Crosswalk Generation Workflow Graph,
|
||
|
Att: 11
Exhibit ADSTRA_0011287, Signed Data Processor Agreement dated October 11, 2021,
|
||
|
Att: 12
Exhibit ACXIOM000646, Data Provider Evaluation Agreement dated February 20, 2022,
|
||
|
Att: 13
Exhibit ADSTRA_0021168, Adstras Associate Handbook dated March 2021,
|
||
|
Att: 14
Exhibit ADSTRA_0021151, Adstras Information Technology Privacy & Security Policies and Procedures Handbook,
|
||
|
Att: 15
Exhibit ADSTRA_0021217, Adstras Data Security Brochure,
|
||
|
Att: 16
Exhibit June 7, 2024 30(b)(6) Deposition Transcript (Excerpts) of Kyle Hollaway,
|
||
|
Att: 17
Exhibit Transcript of the September 26, 2024 Deposition of Eugene Becker,
|
||
|
Att: 18
Exhibit ADSTRA_0001069, Enterprise Identity Platform Thesis Presentation dated January 14, 2021,
|
||
|
Att: 19
Exhibit ADSTRA_0012552, Adstra Board of Directors Meeting Presentation dated August 11, 2020,
|
||
|
Att: 20
Exhibit ADSTRA_0011283, Email from Todd Thomas to Jason Bier and Kevin Mckenna dated October 11, 2021 re Acxiom Adstra Processing Agreement for Kinesso
|
||
| 101 | 101
respm
Declaration in Support of Motion
Mon 12/16 3:56 PM
***SELECTED PARTIES***DECLARATION of Andrew Johnson in Support re:100 MOTION for Partial Summary Judgment .. Document filed by Adstra, LLC. Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
| 100 | 100
motion
Partial Summary Judgment
Mon 12/16 3:51 PM
***SELECTED PARTIES*** MOTION for Partial Summary Judgment . Document filed by Adstra, LLC. Responses due by 1/15/2025Motion or Order to File Under Seal:99 .(Burton Walsh, Anne) |
|
| 99 | 99
motion
Seal
Mon 12/16 3:43 PM
LETTER MOTION to Seal addressed to Judge Lewis J. Liman from Anne Burton-Walsh dated December 16, 2024. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|
| Wednesday, December 11, 2024 | ||
| 98 | 98
respm
Reply Memorandum of Law in Support of Motion
Wed 12/11 6:05 PM
REPLY MEMORANDUM OF LAW in Support re:88 MOTION for Reconsideration re;82 Order on Motion for Discovery,,,,81 Order on Motion to Compel,,,,, .,91 MOTION for Reconsideration re;82 Order on Motion for Discovery,,,,81 Order on Motion to Compel,,,,, . . Document filed by Adstra, LLC..(Aguilar, Anna) |
|
| 97 | 97
order
Stipulation and Order ~Util - Set Deadlines/Hearings
Wed 12/11 11:25 AM
STIPULATION REGARDING BRIEFING DEADLINES FOR SUMMARY JUDGMENT AND DAUBERT MOTIONS: IT IS STIPULATED AND AGREED, by and between the Parties in the above-referenced action that the following briefing schedule shall apply to motions for summary judgment and/or motions to exclude expert reports and testimony: Opening Briefs: December 16, 2024 Opposition Briefs: January 15, 2025 Reply Briefs: January 29, 2025 IT IS FURTHER STIPULATED AND AGREED that the page limit for Opening and Opposition Briefs shall be 30 pages and the limit for Replies shall be 13 pages, not including tables or signature pages. SO ORDERED. ( Motions due by 12/16/2024., Responses due by 1/15/2025, Replies due by 1/29/2025.) (Signed by Judge Lewis J. Liman on 12/10/2024) (rro) |
|
| Tuesday, December 10, 2024 | ||
| 96 | 96
misc
Proposed Stipulation and Order
Tue 12/10 12:11 AM
PROPOSED STIPULATION AND ORDER. Document filed by Adstra, LLC..(Burton Walsh, Anne) |
|