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UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

DECURTIS LLC, 

Plaintiff, 

v. 

CARNIVAL CORPORATION, 

Defendant. 

Civil Action No. 1:20-22945-Civ-Scola

CARNIVAL CORPORATION

Plaintiff, 

v. 

DECURTIS CORPORATION and 

DECURTIS LLC, 

Defendant.

DECLARATION OF MARY COLEMAN 

I, Mary Coleman, declare under penalty of perjury as follows: 

1. My name is Mary Coleman. I am an Executive Vice President at Compass Lexecon, which 

is a division of FTI, Inc. I received my Ph.D. in economics from Stanford University and my BA 

in economics from Stonehill College. During 2001-2004, I served as Deputy Director for Antitrust 

in the Bureau of Economics at the Federal Trade Commission (“FTC”). My qualifications are 

explained in more detail in my March 1, 2022 Expert Report in this matter, attached to this 

declaration as Exhibit A. 

Case 1:20-cv-22945-RNS Document 285-130 Entered on FLSD Docket 04/25/2022 Page 1 of

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2. I have been engaged by counsel for Carnival Corporation (“Carnival”) to develop an 

estimate of damages incurred by Carnival if DeCurtis Corporation (“DeCurtis”) is found liable for 

breach of contract and patent infringement. My opinions with respect to these damages are set 

forth in my March 1, 2022 Expert Report. 

3. In addition, I have been asked to respond to the antitrust claims made by DeCurtis – 

specifically the claims that Carnival has monopolized the market for “systems and methods for 

providing guests with seamless engagement with the facilities of cruise ship through the use of 

wireless sensing technologies” as well as well as the alleged market for “cruise ship travel” with 

such guest engagement systems. As part of that analysis, I have responded to the opinions of 

DeCurtis’ economic expert, Dr. Matthew Lynde, on the relevant antitrust markets, monopolization 

issues, and DeCurtis’s estimated damages for its antitrust, tortious interference, and unfair 

competition claims. My opinions with respect to these issues are set forth in my March 31, 2022 

Expert Reply Report, attached to this declaration as Exhibit B. 

4. The opinions that I intend to offer at trial in this matter are set forth in my Expert Report 

dated March 1, 2022 (a true and correct copy of which is attached hereto as Exhibit A), in my 

Reply Expert Report dated March 31, 2022 (a true and correct copy of which is attached hereto as 

Exhibit B), in the Errata to my Reply Expert Report dated April 14, 2022 (a true and correct copy 

of which is attached hereto as Exhibit C), and in my deposition in this matter which was taken on 

April 15, 2022. 

5. All opinions I have rendered in this matter are believed to be true and are to the best of my 

knowledge and belief. I continue to reserve the right to revise my opinions should further 

information and facts supplied in discovery (including upon resolution of any privilege disputes 

between the parties) or through subsequent expert reports render such revisions appropriate. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on: April 25, 2022 

Boston, MA Mary Coleman 

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EXHIBIT A 

FILED UNDER SEAL 

Case 1:20-cv-22945-RNS Document 285-130 Entered on FLSD Docket 04/25/2022 Page 3 of

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EXHIBIT B 

FILED UNDER SEAL 

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