Joint Appendix One

Cas_
l
2
3
4
5
6
7
8
9
l0
II
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2:10-cv-07678-JFW-DTB Document 65-21 Filed 10/07/11 Page 4 of 7 Page ID
#: 1369
environment. Testing was also necessary to determine whether the prototype
printers would function for their intended purpose of printing coupons using
coupon data sent to the printers t¥om a promotional controller and printing vouchers
based on data received from the machine controller. Testing was also necessary to
determine whether the printer would jam ifa customer tried to put his finger over
the bezel or insert an object into the bezel. Testing was required to determine
whether the prototype printer was sturdy enough to withstand customer abuse, such
as attempts to manipulate or interfere with the printer. Testing was further
necessary to determine how and whether the printer would function in wet or rainy
conditions to which an outdoor vending machine would be exposed.
1 l. FutureLogic provided the prototype printers and technical information
regarding those printers to Coca-Cola subject to an understanding that Coca-Cola
would keep the printers and related technical information confidential. To my
understanding, Coca-Cola abided by that confidentiality understanding and never
disclosed any technical information concerning FutureLogic's prototype printers tO
any third parties.
12. FLO001781 is a true and correct copy of the first page of a draft
specification that I prepared tbr the communication protocol used in the prototype
printers. Consistent with my recollection regarding confidentiality, this document
expressly states that it contains "PROPRIETARY and CONFIDENTIAL
information of FutureLogic, Inc." This document was provided to Coca-Cola.
13. Before the field triads, Simmy Ahluwalia, a Coca-Cola representative,
proposed certain procedures for testing the FutureLogic prototype printers to
determine whether they worked tbr their intended purpose. FL0003543 is a true
and correct copy of an email I received on December 19, 1999, from Scott
Shimmin, FutureLogic's project manager for the Coca-Cola coupon printer project.
FL0003544 is a true and correct copy of the preliminary test plan aRached to
Mr. Shimmin's email. FL0019004 is a true and correct copy of an email Mr.
-A0478-
- 4 - DECLARATION OF ERIC
MEYERHOFER 2:10-CV-07678-JFW-DTB
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
!
I
I