EXHIBIT 8

To Motion for Partial Summary Judgment

(Composite of STT and Westphal Responses to 

Interrogatories) 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI-DADE DIVISION 

SCANZ TECHNOLOGIES, INC., fka 

EQUITYFEED CORPORATION, A Canadian 

(Quebec) Corporation, 

 Plaintiff, 

v. 

JEWMON ENTERPRISES, LLC, et al., 

 Defendants. 

Case No. 20-cv-22957 (RNS/EGT) 

DEFENDANT STT’S RESPONSES AND OBJECTIONS TO PLAINTIFF SCANZ’S 

AMENDED AND SUPERSEDED FIRST SET OF INTERROGATORIES TO STT 

In accordance with Fed. R. Civ. P. 33, Defendant StocksToTrade.com, Inc. (“STT”) 

hereby responds to Plaintiff Scanz Technologies, Inc. fka EquityFeed Corporation (“Scanz”) 

Amended and Superseded First Set of Interrogatories (“Interrogatories” or “Requests”) subject to 

the objections set forth below. 

GENERAL STATEMENT 

The following responses are based on information presently known by STT and its 

attorneys. STT reserves the right to amend and/or supplement these responses as more 

information becomes available. 

OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS 

STT incorporates the following general statements and objections into each response: 

1. STT responds to each Request as it understands the Request in light of the issues 

in this lawsuit. If Scanz has a different understanding and disputes STT’s objections or response 

to the Request, STT invites Scanz to meet and confer regarding the Request in an attempt to 

resolve any differences. Upon meeting and conferring with Scanz, STT reserves the right to 

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amend or supplement its response. 

2. STT objects to each Request that seeks information protected by any privilege or 

immunity including, without limitation, the attorney-client privilege, the common interest 

doctrine, the work product doctrine, and privacy laws. STT will not provide any such 

information. 

3. STT objects to each Request to the extent that it calls for information that is 

publicly available or equally available to Scanz, and therefore are of no greater burden for Scanz 

to obtain than for STT to obtain. STT will not provide any such information. 

SPECIFIC RESPONSES AND OBJECTIONS 

Each general statement and objection to definitions and instructions above is incorporated 

into each of the individual responses below, as if written therein. 

Interrogatory No. 1: 

Please describe all aspects concerning any involvement You have ever had with JewMon 

Enterprises, and for each aspect please describe the details concerning each and every one of the 

involvements You identified in Your response. 

Response to Interrogatory No. 1:

STT objects to this request as unclear because the phrases “all aspects concerning any 

involvement” and “details concerning each and every one of the involvements” are 

unintelligible. STT further objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. STT further objects to this 

request because it is not reasonably limited in scope or time as it seeks information regarding 

“all” aspects of “any” involvement “ever had.” STT states that JewMon Enterprises LLC 

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(“Jewmon”) was organized as a Florida limited liability company on or about June 28, 2012 and 

changed its name from Jewmon to Millionaire Publishing LLC (“Millionaire Publishing”) on or 

about October 19, 2017. JewMon entered into an agreement with Scopic Software on or about 

May 7, 2014 under the terms of which Scopic provided software development services to 

JewMon. STT entered into an agreement with Scopic Software on or about May 7, 2016 under 

the terms of which Scopic provided software development services to STT. STT further states 

that, under the May 7, 2014 and May 7, 2016 agreements with Scopic, JewMon and/or STT 

independently developed a stock research, scanning, educational, and trading platform (the STT 

platform). 

Interrogatory No. 2: 

Please describe all aspects concerning any involvement You have ever had with 

Millionaire Media, and for each aspect please describe the details concerning each and every one 

of the involvements You identified in Your response. 

Response to Interrogatory No. 2: 

STT objects to this request as unclear because the phrases “all aspects concerning any 

involvement” and “details concerning each and every one of the involvements” are 

unintelligible. STT further objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. STT further objects to this 

request because it is not reasonably limited in scope or time as it seeks information regarding 

“all” aspects of “any” involvement “ever had.” STT states that Millionaire Media LLC 

(“Millionaire Media”) was organized as a Delaware limited liability company on or about May 

11, 2007.. STT does not have any involvement with Millionaire Media.

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Interrogatory No. 3: 

Please describe all aspects concerning any involvement You have ever had with 

Millionaire Publishing, and for each aspect please describe the details concerning each and every 

one of the involvements You identified in Your response. 

Response to Interrogatory No. 3: 

STT objects to this request as unclear because the phrases “all aspects concerning any 

involvement” and “details concerning each and every one of the involvements” are 

unintelligible. STT further objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. STT further objects to this 

request because it is not reasonably limited in scope or time as it seeks information regarding 

“all” aspects of “any” involvement “ever had.” STT incorporates its Response to Interrogatory 

No. 1. 

Interrogatory No. 4: 

Identify any and all transfers, payments, remittances, movements or deliveries of property 

(hereafter “transfers”) involving You, on the one hand, and any of the Defendants, on the other 

hand, including, without limitation, such transfers by You to any of the Defendants or by any of 

the Defendants to You. For each such transfer, please also describe the dates, amounts and all 

surrounding circumstances and explanations about and involving each such transfer. 

Response to Interrogatory No. 4: 

STT objects to this request as overly broad to the extent it seeks information regarding 

transfers unrelated to Scanz’s allegation of trade secret misappropriation that are not relevant to 

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any parties claim or defense including monetary transactions conducted in the normal course of 

business between STT and companies or individuals of which one or more of such individuals is 

an owner, part-owner, or employee of one or more of such companies. STT further objects to this 

request because it is not reasonably limited in scope or time as it seeks information regarding 

“any and all” transfers.

Interrogatory No. 5: 

For all periods from January 1, 2013 through and including the date upon which the 

Complaint in this Matter was filed, describe in detail Your involvement with any and all 

architectures, software applications, user interfaces and Scanning Platforms associated with, 

regarding or concerning the domain situated at www.stockstotrade.com, including but not limited 

to development, research, design, maintenance, compliance, testing, marketing, sales, 

management, leadership and business planning. 

Response to Interrogatory No. 5: 

STT objects to this request as unclear because the phrase “involvement with any and all 

architectures, software applications, user interfaces and Scanning Platforms associated with, 

regarding or concerning the domain situated at www.stockstotrade.com” is unintelligible. STT 

further objects to this request as overly broad because it seeks information unrelated to Scanz’s 

allegation of trade secret misappropriation. STT states that on or about February 15, 2016, STT 

offered a stock research, scanning, educational, and trading platform (the STT platform) on 

www.stockstotrade.com. Since February 15, 2016, STT has operated and continues to operate 

the STT platform on www.stockstotrade.com. JewMon entered into an agreement with Scopic 

Software on or about May 7, 2014 under the terms of which Scopic provided software 

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development services to JewMon. STT entered into an agreement with Scopic Software on or 

about May 7, 2016 under the terms of which Scopic provided software development services to 

STT. STT further states that, under the May 7, 2014 and May 7, 2016 agreements with Scopic, 

JewMon and/or STT independently developed the STT platform. 

Interrogatory No. 6: 

If you have ever seen and formed an impression or understanding concerning the 

truthfulness or accuracy of the 2017 Colwell Letter, please identify and specifically describe for 

each such occasion where you’ve seen the 2017 Colwell Letter any and all beliefs You have ever 

had regarding the 2017 Colwell Letter, including, but not limited to, Your beliefs regarding (a) 

the accuracy or veracity of the 2017 Colwell letter and/or (b) whether or not the 2017 Colwell 

letter was a comprehensive and all-inclusive statement of Your defenses against the allegations 

of wrongdoing that said letter was purporting to address. If you have never seen and formed any 

impression or understanding concerning the truthfulness or accuracy of the 2017 Colwell Letter, 

please say so. 

Response to Interrogatory No. 6: 

STT objects to this request to the extent it seeks information regarding confidential 

communications between STT and its attorneys protected by the attorney-client privilege and the 

work product doctrine. STT further objects to this request as overly broad because it seeks 

information not relevant to any parties claim or defense as the 2017 Colwell letter is unrelated to 

Scanz’s allegation of trade secret misappropriation. STT states that it believes the factual 

statements contained in the 2017 Colwell Letter were true and accurate. 

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Interrogatory No. 7: 

With respect to the provision of the License Agreement embodied in the second sentence 

of Section 15 of the License Agreement (which sentence reads, “After termination of this 

Agreement, while it is acknowledged that JewMon may create and procure a competitive market 

analysis platform to offer to its customers, JewMon shall not utilize any portion of the Software 

and shall not copy the ‘look and feel’ of the Software/Website.”) please describe Your belief, 

impression, interpretation, or understanding by You regarding the meaning of this particular 

provision of the License Agreement at the time You first became involved with architectures, 

software applications, user interfaces and Scanning Platforms other than the white label product 

identified in the License Agreement, including, but not limited to, at the time you first became 

involved with the Scanning Platforms that are now (as of the date of the filing of the Complaint 

in this Matter) associated with both STT and with the domain situated at 

www.stockstotrade.com. If you never formed such a belief, impression, interpretation or 

understanding regarding this particular provision of the License Agreement, please say so. 

Response to Interrogatory No. 7: 

STT objects to this request as unintelligible because it seeks information regarding its 

“belief, impression, interpretation, or understanding” of the meaning of a provision of an 

agreement to which it was not a party. STT further objects to this request as overly broad 

because it seeks information unrelated to Scanz’s allegation of trade secret misappropriation. 

STT further objects to this request to the extent it seeks information regarding confidential 

communications between STT and its attorneys protected by the attorney-client privilege and the 

work product doctrine. STT states that it understands the quoted provision to be part of an 

agreement between EquityFeed and JewMon the terms of which speak for themselves.

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Interrogatory No. 8: 

With respect to Interrogatory No. 7 and the provision of the License Agreement 

embodied in the second sentence of Section 15 of the License Agreement (which sentence reads, 

“After termination of this Agreement, while it is acknowledged that JewMon may create and 

procure a competitive market analysis platform to offer to its customers, JewMon shall not 

utilize any portion of the Software and shall not copy the ‘look and feel’ of the 

Software/Website.”) please describe any and all of Your discussions or communications of any 

kind with any Person (including, but not limited to, with any of the Defendants, with Scopic 

Software and with Jamil Ben Alluch) concerning Your belief, impression, interpretation, or 

understanding regarding the meaning of this particular provision of the License Agreement. If 

you never had any such discussions or communications with any of the Defendants regarding 

this particular provision of the License Agreement, please say so. 

Response to Interrogatory No. 8: 

STT objects to this request as unintelligible because it seeks information regarding its 

“belief, impression, interpretation, or understanding” of the meaning of a provision of an 

agreement to which it was not a party. STT further objects to this request as overly broad 

because it seeks information unrelated to Scanz’s allegation of trade secret misappropriation. 

STT further objects to this request to the extent it seeks information regarding confidential 

communications between STT and its attorneys protected by the attorney-client privilege and the 

work product doctrine. STT states that it understands the quoted provision to be part of an 

agreement between EquityFeed and JewMon the terms of which speak for themselves.

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Interrogatory No. 9: 

For all periods from January 1, 2008 through and including the date upon which the 

Complaint in this Matter was filed, describe the circumstances surrounding or otherwise relating 

to and/or concerning all services rendered to any of the Defendants by Jamil Ben Alluch, 

including (a) the dates upon which said services were performed, (b) the payments made to Jamil 

Ben Alluch involving or concerning such services, including (without limitation) the dates and 

amounts of all such payments and (c) the reasons for all such payments to Jamil Ben Alluch 

including, but not limited to, a detailed description concerning the services provided by Jamil 

Ben Alluch not only with respect to all such payments but also with respect to any other reason 

of any kind whatever concerning said services. 

Response to Interrogatory No. 9: 

STT objects to this request as unclear because the phrases “circumstances surrounding or 

otherwise relating to and/or concerning all services rendered” and “not only with respect to all 

such payments but also with respect to any other reason of any kind whatever concerning said 

services” are unintelligible. STT further objects to this request as overly broad because it seeks 

information unrelated to Scanz’s allegation of trade secret misappropriation. STT states that on 

or about September 2015, Jamil Ben Alluch provided consulting services to STT for which he 

was not compensated. STT further states that on or about February 10, 2016, STT hired Jamil 

Ben Alluch as Chief Technology Officer of STT, a position which Jamil Ben Alluch still holds. 

STT further states that Jamil Ben Alluch on behalf of STT and in collaboration with Scopic 

Software independently developed the STT platform. 

Interrogatory No. 10: 

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For all periods from January 1, 2008 through and including the date upon which the 

Complaint in this Matter was filed, describe the circumstances surrounding or otherwise relating 

to and/or concerning all services rendered to any of the Defendants by Scopic Software, 

including (a) the dates upon which said services were performed, (b) the payments made to 

Scopic Software (by any of the Defendants) involving or concerning such services, including 

(without limitation) the dates and amounts of all such payments and (c) the reasons for all such 

payments to Scopic Software including, but not limited to, a detailed description concerning the 

services provided by Scopic Software not only with respect to all such payments but also with 

respect to any other reason of any kind whatever concerning said services. 

Response to Interrogatory No. 10: 

STT objects to this request as unclear because the phrases “circumstances surrounding or 

otherwise relating to and/or concerning all services rendered” and “not only with respect to all 

such payments but also with respect to any other reason of any kind whatever concerning said 

services” are unintelligible. STT further objects to this request as overly broad because it seeks 

information unrelated to Scanz’s allegation of trade secret misappropriation. STT states that on 

or about February 15, 2016, STT offered a stock research, scanning, educational, and trading 

platform (the STT platform) on www.stockstotrade.com. Since February 15, 2016, STT has 

operated and continues to operate the STT platform on www.stockstotrade.com. JewMon entered 

into an agreement with Scopic Software on or about May 7, 2014 under the terms of which 

Scopic provided software development services to JewMon. STT entered into an agreement with 

Scopic Software on or about May 7, 2016 under the terms of which Scopic provided software 

development services to STT. STT further states that, under the May 7, 2014 and May 7, 2016 

agreements with Scopic, JewMon and/or STT independently developed the STT platform. STT 

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further states that it will identify records pursuant to Fed. R. Civ. P. 33(d) responsive to this 

request. 

Interrogatory No. 11: 

From January 1, 2008 to the present, describe all communications between You and any 

other Person regarding or concerning the development of a Scanning Platform, architecture, 

software application or user interface that was intended at any time to be owned or controlled by 

any of the Defendants (involving a Scanning Platform other than the white label product 

identified in the License Agreement), including, but not limited to, the product and technologies 

currently (as of the date the Complaint in this Matter was filed) located at 

www.stockstotrade.com. 

Response to Interrogatory No. 11: 

STT objects to this request as overly broad because it seeks information unrelated to 

Scanz’s allegation of trade secret misappropriation. STT states that on or about February 15, 

2016, STT offered a stock research, scanning, educational, and trading platform (the STT 

platform) on www.stockstotrade.com. Since February 15, 2016, STT has operated and continues 

to operate the STT platform on www.stockstotrade.com. JewMon entered into an agreement with 

Scopic Software on or about May 7, 2014 under the terms of which Scopic provided software 

development services to JewMon. STT entered into an agreement with Scopic Software on or 

about May 7, 2016 under the terms of which Scopic provided software development services to 

STT. STT further states that, under the May 7, 2014 and May 7, 2016 agreements with Scopic, 

JewMon and/or STT independently developed the STT platform.

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Interrogatory No. 12: 

Do you deny that You are legally responsible (in the manner set forth in the Complaint in 

this Matter) for and with respect to the occurrences and transactions described in the Complaint? 

If indeed you deny such legal responsibility (whether in whole or in part), please identify and 

explain all facts and circumstances regarding or supporting Your position that the Complaint’s 

recitation and description of the bases for Your legal responsibility and liability are in truth and 

in fact inaccurate or otherwise wrong or incorrect. 

Response to Interrogatory No. 12: 

STT objects to this request as confusing and unintelligible. STT denies that it ever 

misappropriated anything, including any purported trade secrets, from Plaintiff at least for the 

reasons stated in STT’s Answer to Plaintiff’s Complaint and in STT’s Motion to Dismiss.

Interrogatory No. 13: 

For each of the calendar years 2015, 2016, 2017, 2018, 2019, 2020 – and for the period of 

time starting January 1, 2021 and concluding March 31, 2021 – what were the amounts of money 

You received from any sources concerning, regarding or related in any manner to the Scanning 

Platform available to the public through the domain www.stockstotrade.com or through any 

other source related to the technology delivered through www.stockstotrade.com. 

Response to Interrogatory No. 13: 

STT objects to this request as overly broad because it seeks information unrelated to 

Scanz’s allegation of trade secret misappropriation. STT states that it will identify financial 

statements pursuant to Fed. R. Civ. P. 33(d) responsive to this request, to the extent such records 

exist.

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Interrogatory No. 14: 

From a chronological perspective, please identify the earliest historical date on the 

Gregorian Calendar when any of the Defendants first communicated with an attorney, law firm 

or lawyer concerning or relating in any manner to a business, architecture software application or 

other technology involving a Scanning Platform other than the white label product identified in 

the License Agreement. 

Response to Interrogatory No. 14: 

STT objects to this request as overly broad because it seeks information unrelated to 

Scanz’s allegation of trade secret misappropriation. STT further objects to this request because it 

seeks information regarding confidential communications between STT and its attorneys 

protected by the attorney-client privilege and the work product doctrine.

 

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Dated: May 22, 2021 

SQUIRE PATTON BOGGS (US) LLP 

/s/ Raúl B. Mañón

Raúl B. Mañón 

Florida Bar No. 18847 

200 South Biscayne Boulevard, Suite 4700 

Miami, FL 33131 

Phone: +1 305-577-7000 

raul.manon@squirepb.com 

Gabriel Colwell (admitted pro hac vice) 

555 South Flower Street, 31st Floor 

Los Angeles, CA 90071 

Phone: +1 213-689-5126 

gabriel.colwell@squirepb.com 

Joseph A. Meckes (admitted pro hac vice) 

275 Battery Street, Suite 2600 

San Francisco, CA 94111 

Phone: +1 415-954-0201 

joseph.meckes@squirepb.com 

David P. Prueter (admitted pro hac vice) 

275 Battery Street, Suite 2600 

San Francisco, CA 94111 

Phone: +1 415-954-0200 

david.prueter@squirepb.com 

Attorneys for Defendants StocksToTrade.com, 

Inc. and Zachary Westphal 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on May 22, 2021, a true and correct copy of the foregoing was 

served by electronic mail on all counsel of record. 

 /s Raúl B. Mañón 

 Raúl B. Mañón

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI-DADE DIVISION 

SCANZ TECHNOLOGIES, INC., fka 

EQUITYFEED CORPORATION, A Canadian 

(Quebec) Corporation, 

 Plaintiff, 

v. 

JEWMON ENTERPRISES, LLC, et al., 

 Defendants. 

Case No. 20-cv-22957 (RNS/EGT) 

DEFENDANT ZACHARY WESTPHAL’S RESPONSES AND OBJECTIONS TO 

PLAINTIFF SCANZ’S AMENDED AND SUPERSEDED FIRST SET OF 

INTERROGATORIES TO ZACHARY WESTPHAL 

In accordance with Fed. R. Civ. P. 33, Defendant Zachary Westphal (“Mr. Westphal”) 

hereby responds to Plaintiff Scanz Technologies, Inc. fka EquityFeed Corporation (“Scanz”) 

Amended and Superseded First Set of Interrogatories (“Interrogatories” or “Requests”) subject to 

the objections set forth below. 

GENERAL STATEMENT 

The following responses are based on information presently known by Mr. Westphal and 

his attorneys. Mr. Westphal reserves the right to amend and/or supplement these responses as 

more information becomes available. 

OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS 

Mr. Westphal incorporates the following general statements and objections into each 

response: 

1. Mr. Westphal responds to each Request as he understands the Request in light of 

the issues in this lawsuit. If Scanz has a different understanding and disputes Mr. Westphal’s 

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objections or response to the Request, Mr. Westphal invites Scanz to meet and confer regarding 

the Request in an attempt to resolve any differences. Upon meeting and conferring with Scanz, 

Mr. Westphal reserves the right to amend or supplement its response. 

2. Mr. Westphal objects to each Request that seeks information protected by any 

privilege or immunity including, without limitation, the attorney-client privilege, the common 

interest doctrine, the work product doctrine, and privacy laws. Mr. Westphal will not provide any 

such information. 

3. Mr. Westphal objects to each Request to the extent that it calls for information 

that is publicly available or equally available to Scanz, and therefore are of no greater burden for 

Scanz to obtain than for Mr. Westphal to obtain. Mr. Westphal will not provide any such 

information. 

SPECIFIC RESPONSES AND OBJECTIONS 

Each general statement and objection to definitions and instructions above is incorporated 

into each of the individual responses below, as if written therein. 

Interrogatory No. 1: 

Please describe all aspects concerning any involvement You have ever had with JewMon 

Enterprises, and for each aspect please describe the details concerning each and every one of the 

aspects you identified in your response. 

Response to Interrogatory No. 1:

Mr. Westphal objects to this request as unclear because the phrases “all aspects 

concerning any involvement” and “details concerning each and every one of the aspects” are 

unintelligible. Mr. Westphal further objects to this request as overly broad because it seeks 

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information unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal 

further objects to this request because it is not reasonably limited in scope or time as it seeks 

information regarding “all” aspects of “any” involvement “ever had.” Mr. Westphal states that 

JewMon Enterprises LLC (“Jewmon”) was organized as a Florida limited liability company on 

or about June 28, 2012 and changed its name from Jewmon to Millionaire Publishing LLC 

(“Millionaire Publishing”) on or about October 19, 2017. Mr. Westphal was an owner of 

Jewmon and is an owner of Millionaire Publishing. 

Interrogatory No. 2: 

Please describe all aspects concerning any involvement You have ever had with 

Millionaire Media, and for each aspect please describe the details concerning each and every one 

of the involvements you identified in your response. 

Response to Interrogatory No. 2: 

Mr. Westphal objects to this request as unclear because the phrases “all aspects 

concerning any involvement” and “details concerning each and every one of the involvements” 

are unintelligible. Mr. Westphal further objects to this request as overly broad because it seeks 

information unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal 

further objects to this request because it is not reasonably limited in scope or time as it seeks 

information regarding “all” aspects of “any” involvement “ever had.” Mr. Westphal states that he 

understands that Millionaire Media LLC (“Millionaire Media”) was organized as a Delaware 

limited liability company on or about May 11, 2007. As he testified during his deposition, Mr. 

Westphal provided marketing services to Millionaire Media as an independent contractor. 

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Interrogatory No. 3: 

Please describe all aspects concerning any involvement You have ever had with 

Millionaire Publishing, and for each aspect please describe the details concerning each and every 

one of the involvements you identified in your response. 

Response to Interrogatory No. 3: 

Mr. Westphal objects to this request as unclear because the phrases “all aspects 

concerning any involvement” and “details concerning each and every one of the involvements” 

are unintelligible. Mr. Westphal further objects to this request as overly broad because it seeks 

information unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal 

further objects to this request because it is not reasonably limited in scope or time as it seeks 

information regarding “all” aspects of “any” involvement “ever had.” Mr. Westphal incorporates 

his Response to Interrogatory No. 1.

Interrogatory No. 4: 

Please describe all aspects concerning any involvement You have ever had with STT, 

and for each aspect please describe the details concerning each and every one of the 

involvements you identified in your response. 

Response to Interrogatory No. 4: 

Mr. Westphal objects to this request as unclear because the phrases “all aspects 

concerning any involvement” and “details concerning each and every one of the involvements” 

are unintelligible. Mr. Westphal further objects to this request as overly broad because it seeks 

information unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal 

further objects to this request because it is not reasonably limited in scope or time as it seeks 

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information regarding “all” aspects of “any” involvement “ever had.” Mr. Westphal states that 

StocksToTrade.com, Inc. (“STT”) was organized as a Delaware corporation on or about June 11, 

2015. Mr. Westphal is an owner of STT.

Interrogatory No. 5: 

Identify any and all transfers, payments, remittances, movements or deliveries of property 

(hereafter “transfers”) involving You, on the one hand, and any of the Defendants, on the other 

hand, including, without limitation, such transfers by you to any of the Defendants or by any of 

the Defendants to you. For each such transfer, please also describe the dates, amounts and all 

surrounding circumstances and explanations about and involving each such transfer. 

Response to Interrogatory No. 5: 

Mr. Westphal objects to this request as overly broad to the extent it seeks information 

regarding transfers unrelated to Scanz’s allegation of trade secret misappropriation that are not 

relevant to any parties claim or defense including monetary transactions conducted in the normal 

course of business between Mr. Westphal and companies of which he is an owner, part-owner, or 

employee. Mr. Westphal further objects to this request because it is not reasonably limited in 

scope or time as it seeks information regarding “any and all” transfers.

Interrogatory No. 6: 

Describe in detail Your experience and educational background regarding the business of, 

and industries related to, the following: online trading platforms, software applications, 

architecture and Scanning Platforms, including but not limited to business management, coding, 

compliance, information technology, marketing, programming, sales, software development, 

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software engineering, user interface development or evaluation, software languages, and web 

design. 

Response to Interrogatory No. 6: 

Mr. Westphal objects to this request as unclear because the phrase “experience and 

educational background regarding the business of, and industries related to” is unintelligible. Mr. 

Westphal further objects to this request as overly broad because it seeks information unrelated to 

Scanz’s allegation of trade secret misappropriation. Mr. Westphal states that he has a Bachelor’s 

Degree in Business from Utah Valley University and a Master’s Degree in Business 

Administration from the University of Southern California.

Interrogatory No. 7: 

Describe in detail Your involvement with any and all architectures, software applications, 

user interfaces and Scanning Platforms associated with, regarding or concerning STT and/or the 

domain situated at www.stockstotrade.com, including but not limited to development, research, 

design, maintenance, compliance, testing, marketing, sales, management, leadership and business 

planning. 

Response to Interrogatory No. 7: 

Mr. Westphal objects to this request as unclear because the phrase “involvement with any 

and all architectures, software applications, user interfaces and Scanning Platforms associated 

with, regarding or concerning STT and/or the domain situated at www.stockstotrade.com” is 

unintelligible. Mr. Westphal further objects to this request as overly broad because it seeks 

information unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal states 

that on or about February 15, 2016, STT offered a stock research, scanning, educational, and 

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trading platform (the STT platform) on www.stockstotrade.com. Since February 15, 2016, STT 

has operated and continues to operate the STT platform on www.stockstotrade.com. JewMon 

entered into an agreement with Scopic Software on or about May 7, 2014 under the terms of 

which Scopic provided software development services to JewMon. STT entered into an 

agreement with Scopic Software on or about May 7, 2016 under the terms of which Scopic 

provided software development services to STT. Mr. Westphal further states that, under the May 

7, 2014 and May 7, 2016 agreements with Scopic, JewMon and/or STT independently developed 

the STT platform. As he testified during his deposition, Mr. Westphal was not involved in the 

development of the STT platform.

Interrogatory No. 8: 

If you have ever seen and formed an impression or understanding concerning the 

truthfulness or accuracy of the 2017 Colwell Letter, please identify and specifically describe for 

each such occasion where you’ve seen the 2017 Colwell Letter any and all beliefs You have ever 

had regarding the 2017 Colwell Letter, including, but not limited to, Your beliefs regarding (a) 

the accuracy or veracity of the 2017 Colwell letter and/or (b) whether or not the 2017 Colwell 

letter was a comprehensive and all-inclusive statement of Your defenses against the allegations 

of wrongdoing that said letter was purporting to address. If you have never seen and formed any 

impression or understanding concerning the truthfulness or accuracy of the 2017 Colwell Letter, 

please say so. 

Response to Interrogatory No. 8: 

Mr. Westphal objects to this request to the extent it seeks information regarding 

confidential communications between Mr. Westphal and his attorneys protected by the attorneyCase 1:20-cv-22957-RNS Document 110-12 Entered on FLSD Docket 06/07/2021 Page 24 of

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client privilege and the work product doctrine. Mr. Westphal further objects to this request as 

overly broad because it seeks information not relevant to any parties claim or defense as the 2017 

Colwell letter is unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal 

states that he saw the 2017 Colwell Letter on or about April 7, 2017 and that he believed the 

factual statements contained in the Letter were true and accurate.

Interrogatory No. 9: 

With respect to the provision of the License Agreement embodied in the first sentence of 

Section 6 of the License Agreement (which sentence reads, “Each party shall keep confidential 

and not disclose to any third party or use (except as contemplated by this Agreement), any nonpublic information obtained from the other party that is marked or otherwise designated 

confidential (“Confidential Information”) provided, however, that neither party shall be 

prohibited from disclosing or using Confidential Information that: (i) is publicly available or 

becomes publicly available through no act or omission of the receiving party, (ii) is or has been 

disclosed to such party by a third party who is not under an obligation of confidentiality with 

respect thereto, (iii) is or has been independently developed by such party, without use or 

reference to the other party’s confidential information, by persons without access to the same, or 

(iv) must be used or disclosed under court order, request of a governmental agency or applicable 

law, provided such use or disclosure is to the minimum extent required by such court order, 

governmental request or applicable law.”) please describe your belief, impression, interpretation, 

or understanding by You regarding the meaning of this particular provision of the License 

Agreement at all times prior to the time Timothy Sykes signed the License Agreement and at the 

time Timothy Sykes signed the License Agreement. 

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Response to Interrogatory No. 9: 

Mr. Westphal objects to this request as unintelligible because it seeks information 

regarding his “belief, impression, interpretation, or understanding” of the meaning of a provision 

of an agreement to which he was not a party. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

misappropriation. Mr. Westphal further objects to this request to the extent it seeks information 

regarding confidential communications between Mr. Westphal and his attorneys protected by the 

attorney-client privilege and the work product doctrine. Mr. Westphal states that he understands 

the quoted provision to be part of an agreement between EquityFeed and JewMon the terms of 

which speak for themselves. 

Interrogatory No. 10: 

With respect to the provision of the License Agreement embodied in the fourth sentence 

of Section 8 of the License Agreement (which sentence reads, “Upon termination of this 

agreement for any reason, all use of the Software by JewMon shall cease, the provision of 

Services by EquityFeed shall cease, and each party shall return to the other party or destroy any 

Confidential Information obtained from the other party.”) please describe your belief, 

impression, interpretation, or understanding by You regarding the meaning of this particular 

provision of the License Agreement at all times prior to the time Timothy Sykes signed the 

License Agreement and at the time Timothy Sykes signed the License Agreement. 

Response to Interrogatory No. 10: 

Mr. Westphal objects to this request as unintelligible because it seeks information 

regarding his “belief, impression, interpretation, or understanding” of the meaning of a provision 

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of an agreement to which he was not a party. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

misappropriation. Mr. Westphal further objects to this request to the extent it seeks information 

regarding confidential communications between Mr. Westphal and his attorneys protected by the 

attorney-client privilege and the work product doctrine. Mr. Westphal states that he understands 

the quoted provision to be part of an agreement between EquityFeed and JewMon the terms of 

which speak for themselves. 

Interrogatory No. 11: 

With respect to the provision of the License Agreement embodied in the fourth sentence 

of Section 13 of the License Agreement (which sentence reads, “. . . JewMon agrees and 

undertakes not to, except as permitted in this Agreement: (i) use the Software, or any part 

thereof, in an outsourcing agreement in support of any third-party; (ii) sell, lease, sublicense or 

distribute the Software, or part thereof, or otherwise transfer the Software other than as 

expressly permitted herein; (iii) reverse engineer, decompile, disassemble, or otherwise reduce 

to human-perceivable form the Software’s source code, or part thereof; (iv) modify, revise, 

enhance, or alter the Software other than for internal use purposes in accordance with the terms 

set forth herein; or (v) claim any rights to or ownership of the Software.”) please describe your 

belief, impression interpretation, or understanding by You regarding the meaning of this 

particular provision of the License Agreement at all times prior to the time Timothy Sykes 

signed the License Agreement and at the time Timothy Sykes signed the License Agreement. 

Response to Interrogatory No. 11: 

Mr. Westphal objects to this request as unintelligible because it seeks information 

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regarding his “belief, impression, interpretation, or understanding” of the meaning of a provision 

of an agreement to which he was not a party. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

misappropriation. Mr. Westphal further objects to this request to the extent it seeks information 

regarding confidential communications between Mr. Westphal and his attorneys protected by the 

attorney-client privilege and the work product doctrine. Mr. Westphal states that he understands 

the quoted provision to be part of an agreement between EquityFeed and JewMon the terms of 

which speak for themselves. 

Interrogatory No. 12: 

With respect to the provision of the License Agreement embodied in the second sentence 

of Section 15 of the License Agreement (which sentence reads, “After termination of this 

Agreement, while it is acknowledged that JewMon may create and procure a competitive market 

analysis platform to offer to its customers, JewMon shall not utilize any portion of the Software 

and shall not copy the ‘look and feel’ of the Software/Website.”) please describe your belief, 

impression, interpretation, or understanding by You regarding the meaning of this particular 

provision of the License Agreement at all times prior to the time Timothy Sykes signed the 

License Agreement and at the time Timothy Sykes signed the License Agreement. 

Response to Interrogatory No. 12: 

Mr. Westphal objects to this request as unintelligible because it seeks information 

regarding his “belief, impression, interpretation, or understanding” of the meaning of a provision 

of an agreement to which he was not a party. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

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misappropriation. Mr. Westphal further objects to this request to the extent it seeks information 

regarding confidential communications between Mr. Westphal and his attorneys protected by the 

attorney-client privilege and the work product doctrine. Mr. Westphal states that he understands 

the quoted provision to be part of an agreement between EquityFeed and JewMon the terms of 

which speak for themselves. 

Interrogatory No. 13: 

With respect to Interrogatory No. 12 and the provision of the License Agreement 

embodied in the second sentence of Section 15 of the License Agreement (which sentence reads, 

“After termination of this Agreement, while it is acknowledged that JewMon may create and 

procure a competitive market analysis platform to offer to its customers, JewMon shall not 

utilize any portion of the Software and shall not copy the ‘look and feel’ of the 

Software/Website.”) please describe any and all discussions or communications of any kind with 

any Person (including, but not limited to, with any of the Defendants, with Scopic Software and 

with Jamil Ben Alluch) concerning Your belief, impression, interpretation, or understanding 

regarding the meaning of this particular provision of the License Agreement. 

Response to Interrogatory No. 13: 

Mr. Westphal objects to this request as unintelligible because it seeks information 

regarding his “belief, impression, interpretation, or understanding” of the meaning of a provision 

of an agreement to which he was not a party. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

misappropriation. Mr. Westphal further objects to this request to the extent it seeks information 

regarding confidential communications between Mr. Westphal and his attorneys protected by the 

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attorney-client privilege and the work product doctrine. Mr. Westphal states that he understands 

the quoted provision to be part of an agreement between EquityFeed and JewMon the terms of 

which speak for themselves. 

Interrogatory No. 14: 

For all periods from January 1, 2008 through and including the date upon which the 

Complaint in this Matter was filed, describe the circumstances surrounding or otherwise 

relating to and/or concerning all services rendered to any of the Defendants by Jamil Ben 

Alluch, including (a) the dates upon which said services were performed, (b) the payments 

made to Jamil Ben Alluch involving or concerning such services, including (without limitation) 

the dates and amounts of all such payments and (c) the reasons for all such payments to Jamil 

Ben Alluch including, but not limited to, a detailed description concerning the services provided 

by Jamil Ben Alluch not only with respect to all such payments but also with respect to any 

other reason of any kind whatever concerning said services. 

Response to Interrogatory No. 14: 

Mr. Westphal objects to this request as unclear because the phrases “circumstances 

surrounding or otherwise relating to and/or concerning all services rendered” and “not only with 

respect to all such payments but also with respect to any other reason of any kind whatever 

concerning said services” are unintelligible. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

misappropriation. Mr. Westphal states that on or about September 2015, Jamil Ben Alluch 

provided consulting services to STT for which he was not compensated. Mr. Westphal further 

states that on or about February 10, 2016, STT hired Jamil Ben Alluch as Chief Technology 

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Officer of STT, a position which Jamil Ben Alluch still holds. Mr. Westphal further states that 

Jamil Ben Alluch on behalf of STT and in collaboration with Scopic Software independently 

developed the STT platform. 

Interrogatory No. 15: 

For all periods from January 1, 2008 through and including the date upon which the 

Complaint in this Matter was filed, describe the circumstances surrounding or otherwise relating 

to and/or concerning all services rendered to any of the Defendants by Scopic Software, 

including (a) the dates upon which said services were performed, (b) the payments made to 

Scopic Software (by any of the Defendants) involving or concerning such services, including 

(without limitation) the dates and amounts of all such payments and (c) the reasons for all such 

payments to Scopic Software including, but not limited to, a detailed description concerning the 

services provided by Scopic Software not only with respect to all such payments but also with 

respect to any other reason of any kind whatever concerning said services. 

Response to Interrogatory No. 15: 

Mr. Westphal objects to this request as unclear because the phrases “circumstances 

surrounding or otherwise relating to and/or concerning all services rendered” and “not only with 

respect to all such payments but also with respect to any other reason of any kind whatever 

concerning said services” are unintelligible. Mr. Westphal further objects to this request as 

overly broad because it seeks information unrelated to Scanz’s allegation of trade secret 

misappropriation. Mr. Westphal states that on or about February 15, 2016, STT offered a stock 

research, scanning, educational, and trading platform (the STT platform) on 

www.stockstotrade.com. Since February 15, 2016, STT has operated and continues to operate 

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the STT platform on www.stockstotrade.com. JewMon entered into an agreement with Scopic 

Software on or about May 7, 2014 under the terms of which Scopic provided software 

development services to JewMon. STT entered into an agreement with Scopic Software on or 

about May 7, 2016 under the terms of which Scopic provided software development services to 

STT. Mr. Westphal further states that, under the May 7, 2014 and May 7, 2016 agreements with 

Scopic, JewMon and/or STT independently developed the STT platform. Mr. Westphal further 

states that he or STT will identify records pursuant to Fed. R. Civ. P. 33(d) responsive to this 

request. 

Interrogatory No. 16: 

From January 1, 2008 to the present, describe all of Your interactions and 

communications with Stephan Touizer, including the date of such interactions and a detailed 

description regarding your location during all such communications (including, without 

limitation, all personal and/or in-person meetings) as well as the substance and content of all 

such communications. 

Response to Interrogatory No. 16: 

Mr. Westphal objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal states that he 

communicated by email and phone with Stephan Touizer and that such communications resulted 

in JewMon and EquityFeed signing a white label licensing agreement on or about April 2013. 

Interrogatory No. 17: 

From January 1, 2008 to the present, describe all of Your interactions and 

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communications with any Person regarding or concerning Scopic Software, including the date of 

such interactions and a detailed description regarding the content of all such communications. 

Response to Interrogatory No. 17: 

Mr. Westphal objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal states that on or 

about February 15, 2016, STT offered a stock research, scanning, educational, and trading 

platform (the STT platform) on www.stockstotrade.com. Since February 15, 2016, STT has 

operated and continues to operate the STT platform on www.stockstotrade.com. JewMon entered 

into an agreement with Scopic Software on or about May 7, 2014 under the terms of which 

Scopic provided software development services to JewMon. STT entered into an agreement with 

Scopic Software on or about May 7, 2016 under the terms of which Scopic provided software 

development services to STT. Mr. Westphal further states that, under the May 7, 2014 and May 

7, 2016 agreements with Scopic, JewMon and/or STT independently developed the STT 

platform. As he testified during his deposition, Mr. Westphal was not involved in the 

development of the STT platform. 

Interrogatory No. 18: 

From January 1, 2008 to the present, describe all communications between You and any 

other Person regarding or concerning the development of a Scanning Platform, architecture, 

software application or user interface that was intended at any time to be owned or controlled by 

any of the Defendants (involving a Scanning Platform other than the white label product 

identified in the License Agreement), including, but not limited to, the product and technologies 

located at www.stockstotrade.com. 

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Response to Interrogatory No. 18: 

Mr. Westphal objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal states that on or 

about February 15, 2016, STT offered a stock research, scanning, educational, and trading 

platform (the STT platform) on www.stockstotrade.com. Since February 15, 2016, STT has 

operated and continues to operate the STT platform on www.stockstotrade.com. JewMon entered 

into an agreement with Scopic Software on or about May 7, 2014 under the terms of which 

Scopic provided software development services to JewMon. STT entered into an agreement with 

Scopic Software on or about May 7, 2016 under the terms of which Scopic provided software 

development services to STT. Mr. Westphal further states that, under the May 7, 2014 and May 

7, 2016 agreements with Scopic, JewMon and/or STT independently developed the STT 

platform. As he testified during his deposition, Mr. Westphal was not involved in the 

development of the STT platform.

Interrogatory No. 19: 

For each of the calendar years 2015, 2016, 2017, 2018, 2019, 2020 -- and for the period 

of time starting January 1, 2021 and concluding March 31, 2021 -- what were the amounts of 

money You received from any sources concerning, regarding or related in any manner to the 

Scanning Platform available to the public through the domain www.stockstotrade.com or 

through any other source related to the technology delivered through www.stockstotrade.com. 

Response to Interrogatory No. 19: 

Mr. Westphal objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal states that he or 

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STT will identify financial statements pursuant to Fed. R. Civ. P. 33(d) responsive to this 

request, to the extent such records exist.

Interrogatory No. 20: 

From a chronological perspective, please identify the earliest historical date on the 

Gregorian Calendar when any of the Defendants first communicated with an attorney, law firm 

or lawyer concerning or relating in any manner to a business, architecture, software application 

or other technology involving a Scanning Platform other than the white label product identified 

in the License Agreement. 

Response to Interrogatory No. 20: 

Mr. Westphal objects to this request as overly broad because it seeks information 

unrelated to Scanz’s allegation of trade secret misappropriation. Mr. Westphal further objects to 

this request because it seeks information regarding confidential communications between Mr. 

Westphal and his attorneys protected by the attorney-client privilege and the work product 

doctrine. 

 

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Dated: May 22, 2021 

SQUIRE PATTON BOGGS (US) LLP 

/s/ Raúl B. Mañón

Raúl B. Mañón 

Florida Bar No. 18847 

200 South Biscayne Boulevard, Suite 4700 

Miami, FL 33131 

Phone: +1 305-577-7000 

raul.manon@squirepb.com 

Gabriel Colwell (admitted pro hac vice) 

555 South Flower Street, 31st Floor 

Los Angeles, CA 90071 

Phone: +1 213-689-5126 

gabriel.colwell@squirepb.com 

Joseph A. Meckes (admitted pro hac vice) 

275 Battery Street, Suite 2600 

San Francisco, CA 94111 

Phone: +1 415-954-0201 

joseph.meckes@squirepb.com 

David P. Prueter (admitted pro hac vice) 

275 Battery Street, Suite 2600 

San Francisco, CA 94111 

Phone: +1 415-954-0200 

david.prueter@squirepb.com 

Attorneys for Defendants StocksToTrade.com, 

Inc. and Zachary Westphal 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on May 22, 2021, a true and correct copy of the foregoing was 

served by electronic mail on all counsel of record. 

 /s Raúl B. Mañón 

 Raúl B. Mañón

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