EXHIBIT B

Case 1:20-cv-22945-RNS Document 95-2 Entered on FLSD Docket 11/04/2020 Page 1 of 4
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Onlck, Hrrrlngton t Sutclllfo LLP

Columbia Centar

1152 15th Strool, N.W.

Washington, DC 200091 706

+1 202 339 8400

onlck.com

T. vann Patro February 20,2020

Via Federal Express and E MaII

+1 202 339 8690

+1 202 339 8500

Miriam Holleman

DeCurtis Corporation

3208 East Colonial Drive

suite cl90

Orlando, FL 32803

Re: Camival Corporation exercising its audit rights under the Master Services Agreement

Dear Ms. Holleman:

We represent Carnival Corporation ('Carnival"). On behalf of Carnival, this letter serves as

written notice pursuant to Section 6.5 of the July 24,2014 Master Services Agreement ('MSA')

between Carnival and DeCunis Corporation ("DeCurtis") that Camival is exercising its audit

right under Section 3.4 of the MSA. Camival will inspect all DeCurtis records relevant to

DeCurtis's work for Carnival related to "Project Trident,o'"Camival's Guest Experience and

Innovation Studio," "Carnival Corporation Enterprise Architecture Project," "Experience

prototypes," "Camival Experience Platform," wearable devices, and/or devices and systems

using Bluetooth Low Energy. The scope of the audit includes, but is not limited to, all records

related to the work described in the MSA and the Statements of Work entered into by Carnival

and DeCurtis pursuant to the MSA.

Non-limiting examples ofthe types of documents Carnival expects DeCurtis to make available

for inspection include documentation and / or source code related to the development and

execution of the "Experience Prototype" (e,g.,mobilization experience prototype framework, at

home experience engagement, arrival experience prototypes, imaging experience transformation,

F&B experienc€ prototypes, experience utilities, guest services and guest recovery, and end-toend prototype alignment and harmonization), "Ocean Ready" and "Experience Engagement"

E vpoarec@orrick,com

D

F

Case 1:20-cv-22945-RNS Document 95-2 Entered on FLSD Docket 11/04/2020 Page 2 of 4
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Miriam Holleman

February 20,2020

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development progession, Crew Compass development, Ocean Program creative development,

demonstrations for Board of Directors meetings, Project Trident development, and so on.

A primary purpose of this audit is'to insure compliance by [DeCurtis] with its obligations"

under the MSA, as set forth in Section 3.4, particularly DeCurtis's obligations to protect

Camival's conlidential information under Section 4 of the MSA. Accordingly, among the

records that Camival will inspect are the following:

o Records showing which DeCurtis employees had access to Carnival "Confidential

Information" and "Deliverables" (as defined in the MSA) prepared for Carnival;

r Records showing all measures DeCurtis has taken, if any, to ensure that any such

DeCurtis employees were informed of and agreed to be bound by the MSA's

confidentiality obligations;

o Records showing all measures DeCurtis has taken, if any, to ensure the confidentiality

of Camival Confidential Information and Deliverables;

r Records showing if any Carnival Confrdential Information or Deliverables were shared

with any third parties;

r Records showing if DeCurtis used any Carnival Confidential Information or

Deliverables for DeCurtis's own use (including development of the "DeCurtis

Experience Platform" or the Bluetooth Low Energy products and services advertised by

DeCu*is at, e.g., bttps:l/www.decurtis.com/ble/, or in making presentations to actual or

potential customers) or for the developing products and services for DeCurtis's other

customers (including Norwegian Cruise Lines and Virgin Voyages); and

o Records showing all measures DeCurtis has taken, if any, to ensure that the Camival

Confidential lnformation and Deliverables were not used in any way for DeCurtis's own

use or for the developing products and services for DeCurtis's other customers.

The audit will be conducted by a computer forensics firm working with Carnival's outside legal

counsel at Onick.

Case 1:20-cv-22945-RNS Document 95-2 Entered on FLSD Docket 11/04/2020 Page 3 of 4
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Miriam Holleman

February 20,2020

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Please respond by no later than February 24,2020 providing a date certainn no later than March

2,2020 when Carnival can begin the audit. Your response should identiff the location(s) where

relevant documents are stored and the repositories/custodians holding relevant documents.

Please be advised ttrat DeCurtis has an obligation to not destroy or alter any records or

documents related to this matter within DeCurtis's possession, custody, or control. Any

DeCurtis document destructiorlretention policies should be suspended and all relevant records

should be preserved. Metadata should also be preserved (for example, records of when and by

whom documents were accessed, downloaded, or sent by DeCurtis personnel or third parties).

Very truly yours,

T. Vann Pearce

cc: David DeCurtis

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