XpresSpa Group Inc (XSPA)

[JJSeabrook]

PACER #1032 DECLARATION:DECLARATION OF CHARLES J. MONTERIO, JR. IN SUPPORT OF
I/P ENGINE’S SUPPLEMENTAL MEMORANDUM OF ADDITIONAL FACTS

FOLKS, MOST OF IT IS BLACKED OUT. HERE'S WHAT YOU GET TO SEE!

JJ

I, Charles J. Monterio, Jr., declare as follows:
1. I am an attorney with the law firm of Dickstein Shapiro LLP, 1825 Eye Street
N.W., Washington, DC 20006 and am counsel for Plaintiff I/P Engine, Inc. (“I/P Engine”) in the
above-captioned case.
2. On Friday, September 20, 2013, I/P Engine deposed Mr. Bartholomew Furrow
about the changes Google made to its AdWords system.
3. Based on Mr. Furrow’s testimony, on Monday, September 23, 2013, I/P Engine
requested that Google produce:
• The textual descriptions in change lists associated with change list
numbers for all produced source code files (accessible by at least the
); and
• The entry for .
4. During Mr. Furrow’s deposition, he confirmed that these documents existed and
are relevant to the changes in the AdWords system.
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11. I have also reviewed Google’s website, and more specifically these two sites:
https://support.google.com/a/answer/34169?hl=en and
https://support.google.com/talk/answer/29291?hl=en. Based my review of Google’s website,
electronic conversations that occur through Google Talk or Google Hangouts can be logged and
retained.
I declare under penalty of perjury of the laws of the United States of America that the
foregoing is true and correct.
Dated: October 31, 2013 By: ___/s/ Charles J. Monterio, Jr. ______
Charles J. Monterio Jr.
DICKSTEIN SHAPIRO LLP
1825 Eye Street, NW
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
Counsel for Plaintiff I/P Engine, Inc