Exhibit A

Case 1:20-cv-22945-RNS Document 293-1 Entered on FLSD Docket 04/28/2022 Page 1 of 14
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 20-CIV-22945-SCOLA/TORRES 

DECURTIS LLC, 

Plaintiff, 

v. 

CARNIVAL CORPORATION, 

 Defendant. 

 

CARNIVAL CORPORATION, 

Plaintiff, 

v. 

DECURTIS CORPORATION and 

DECURTIS LLC, 

Defendants. 

 

DECLARATION OF DIANA M. FASSBENDER 

I, Diana M. Fassbender, declare and state as follows: 

1. I am an attorney admitted to practice in Washington, D.C. and an attorney with 

Orrick, Herrington & Sutcliffe LLP. I make this declaration in support of Carnival Corporation’s 

(“Carnival”) Motion for Summary Judgment and Daubert Motion to Strike, Limit, or Exclude 

Certain Expert Testimony to be filed in the above-captioned matter. 

2. Attached hereto as Exhibit 1 is a true and correct copy of the Master Services 

Agreement between Carnival and DeCurtis effective July 24, 2014 (CARNIVAL00000270-284). 

3. Attached hereto as Exhibit 2 is a true and correct copy of the transcript of the 

deposition of Derek Fournier dated January 25, 2022. 

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4. Attached hereto as Exhibit 3 is a true and correct copy of the transcript of the 

deposition of Derek Fournier dated January 26, 2022. 

5. Attached hereto as Exhibit 4 is a true and correct copy of the DeCurtis Digital 

Experience Platform Presentation dated April 2017 (DeCurtis_01636569-589). 

6. Attached hereto as Exhibit 5 is a true and correct copy of an internal DeCurtis email 

chain dated March 17, 2016 (DeCurtis_01986338-339). 

7. Attached hereto as Exhibit 6 is a true and correct copy of the Expert Report of Erik 

de la Iglesia Regarding DeCurtis’s Use of Carnival Information and Infringement of U.S. Patent 

Nos. 10,045,184; 10,049,516; and 10,157,514 dated March 1, 2022. I understand that Mr. de la 

Iglesia is contemporaneously submitting a declaration attesting to the contents of his report. 

8. Attached hereto as Exhibit 7 is a true and correct copy of an internal DeCurtis email 

dated March 25, 2016 (DeCurtis_01471144-145). 

9. Attached hereto as Exhibit 8 is a true and correct copy of an internal DeCurtis email 

(with attachments) dated June 15, 2016 (DeCurtis_01517794-8065). 

10. Attached hereto as Exhibit 9 is a true and correct copy of an internal DeCurtis email 

chain dated July 30, 2015 (DeCurtis_01529526-533). 

11. Attached hereto as Exhibit 10 is a true and correct copy of a DeCurtis Immersive 

Experience Presentation (DeCurtis_00685821-836). 

12. Attached hereto as Exhibit 11 is a true and correct copy of an internal DeCurtis 

email chain dated June 23, 2017 (DeCurtis_00670679-680). 

13. Attached hereto as Exhibit 12 is a true and correct copy of an internal DeCurtis 

email chain dated December 19, 2016 (DeCurtis_00933304). 

14. Attached hereto as Exhibit 13 is a true and correct copy of the transcript of the 

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deposition of Matthew Lynde dated April 15, 2022. 

15. Attached hereto as Exhibit 14 is a true and correct copy of the transcript of the 

deposition of Arnold Donald dated January 31, 2022. 

16. Attached hereto as Exhibit 15 is a true and correct copy of the transcript of the 

deposition of Simon Murray dated January 31, 2022. 

17. Attached hereto as Exhibit 16 is a true and correct copy of a screenshot of the 

DeCurtis Website (CARNIVAL00756076-077). 

18. Attached hereto as Exhibit 17 is a true and correct copy of the Expert Report of 

Matthew Lynde, Ph.D. dated March 1, 2022. 

19. Attached hereto as Exhibit 18 is a true and correct copy of the DeCurtis Strategy 

Session Offsite Agenda and DeCurtis Due Diligence Findings dated June 11, 2019 

(DeCurtis_01945577-795). 

20. Attached hereto as Exhibit 19 is a true and correct copy of the DeCurtis 

Confidential Information Presentation dated November 2018 (DeCurtis_01945863-916). 

21. Attached hereto as Exhibit 20 is a true and correct copy of the Carnival Project 

Ocean Discussion Materials Presentation dated June 29, 2020 (CARNIVAL00375784-850). 

22. Attached hereto as Exhibit 21 is a true and correct copy of the 

. 

23. Attached hereto as Exhibit 22 is a true and correct copy of Mary T. Coleman, David 

W. Meyer & David T. Scheffman’s Economic Analyses of Mergers at the FTC: The Cruise Ships 

Mergers Investigation, REVIEW OF INDUSTRIAL ORGANIZATION 23 (2003). 

24. Attached hereto as Exhibit 23 is a true and correct copy of the declaration of 

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Francis Farro, Virgin Voyages, dated March 16, 2022. 

25. Attached hereto as Exhibit 24 is a true and correct copy of the Princess Cruises 

Presentation: PCL Strategic Update Medallion Class/OCEAN dated January 15, 2020 

(CARNIVAL00375147-164). 

26. Attached hereto as Exhibit 25 is a true and correct copy of the Reply Expert Report 

of Mary Coleman dated March 31, 2022. I understand that Dr. Coleman is contemporaneously 

submitting a declaration attesting to the contents of her report. 

27. Attached hereto as Exhibit 26 is a true and correct copy of the transcript of the 

deposition of Mary Coleman dated April 15, 2022. 

28. Attached hereto as Exhibit 27 is a true and correct copy of the Letter to Virgin 

Cruises dated February 4, 2020 (CARNIVAL00124884_001-02). 

29. Attached hereto as Exhibit 28 is a true and correct copy of the Letter to NCL dated 

January 29, 2020 (CARNIVAL00124886_001-02). 

30. Attached hereto as Exhibit 29 is a true and correct copy of the transcript of the 

deposition of John Padgett Vol. 2 dated January 18, 2022. 

31. Attached hereto as Exhibit 30 is a true and correct copy of the Letter from NCL to 

DeCurtis dated March 25, 2021 (DeCurtis_01988391-94). 

32. Attached hereto as Exhibit 31 is a true and correct copy of the Expert Report of 

Mary Coleman dated March 1, 2022. I understand that Dr. Coleman is contemporaneously 

submitting a declaration attesting to the contents of her report. 

33. Attached hereto as Exhibit 32 is a true and correct copy of the Expert Report of 

Nicholas Godici dated March 1, 2022. 

34. Attached hereto as Exhibit 33 is a true and correct copy of the transcript of the 

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deposition of Nicholas Godici dated April 12, 2022. 

35. Attached hereto as Exhibit 34 is a true and correct copy of the Expert Rebuttal 

Report of Matthew Lynde, Ph.D. dated March 31, 2022. 

36. Attached hereto as Exhibit 35 is a true and correct copy of Carnival Corporation’s 

First Notice of 30(b)(6) Deposition to Defendant DeCurtis LLC. 

37. Attached hereto as Exhibit 36 is a true and correct copy of the transcript of the 

deposition of David DeCurtis dated February 3, 2022. 

38. Attached hereto as Exhibit 37 is a true and correct copy of the transcript of the 

deposition of David DeCurtis dated February 4, 2022. 

39. Attached hereto as Exhibit 38 is a true and correct copy of the Opening Expert 

Report of Matthew Shoemake, Ph.D. Regarding Invalidity of U.S. Patent No. 10, 045, 184 and 

10,049,516 dated March 1, 2022. 

40. Attached hereto as Exhibit 39 is a true and correct copy of the Opening Expert 

Report of Markus Jakobson, Ph.D. Regarding Invalidity of U.S. Patent No. 10,157,514 dated 

March 1, 2022. 

41. Attached hereto as Exhibit 40 is a true and correct copy of the Rebuttal Expert 

Report of Erik de la Iglesia Regarding Validity of U.S. Patent Nos. 10,045,184; 10,049,516; and 

10,157,514 dated March 31, 2022. I understand that Mr. de la Iglesia is contemporaneously 

submitting a declaration attesting to the contents of his report. 

42. Attached hereto as Exhibit 41 is a true and correct copy of an email chain dated 

October 21, 2014 (DeCurtis_00157407-157408). 

43. Attached hereto as Exhibit 42 is a true and correct copy of a document with the 

heading “Ideas and Concepts Developed by EIC Project” (Glenn Curtis-0045-57). 

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44. Attached hereto as Exhibit 43 is a true and correct copy of a black and white copy 

of the “Glenn Curtis Memo” as produced by DeCurtis (DeCurtis_01469956-1466008). 

45. Attached hereto as Exhibit 44 is a true and correct copy of an email to John Padgett 

(with attachments) dated July 14, 2014 (JP_CC_00000175-233). 

46. Attached hereto as Exhibit 45 is a true and correct copy of Responses of DeCurtis 

LLC and DeCurtis Corp. to Carnival’s Second Set of Interrogatories [Nos. 13-19] dated February 

12, 2021. 

47. Attached hereto as Exhibit 46 is a true and correct copy of the Virgin-DeCurtis 

Contract (DeCurtis_02000045-053). 

48. Attached hereto as Exhibit 47 is a true and correct copy of the 

Carnival/Evercore/Accenture Presentation: Project Ocean Due Diligence Deliverable dated 

October 2020 (CARNIVAL00565245-409). 

49. Attached hereto as Exhibit 48 is a true and correct copy of an internal DeCurtis 

email chain dated April 25, 2017 (DeCurtis_00563474-476). 

50. Attached hereto as Exhibit 49 is a true and correct copy of the DeCurtis Corp. 

Presentation Q3 Board Meeting (DeCurtis_01419567-665). 

51. Attached hereto as Exhibit 50 is a true and correct copy of the Statement of Work 

No. 1 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00000265-268). 

52. Attached hereto as Exhibit 51 is a true and correct copy of the Statement of Work 

No. 13 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00000313-321). 

53. Attached hereto as Exhibit 52 is a true and correct copy of the Statement of Work 

No. 14 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00000322-331). 

54. Attached hereto as Exhibit 53 is a true and correct copy of a Letter from Freeborn 

Case 1:20-cv-22945-RNS Document 293-1 Entered on FLSD Docket 04/28/2022 Page 7 of 14
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& Peters LLP dated February 24, 2020 (CARNIVAL00015237) 

55. Attached hereto as Exhibit 54 is a true and correct copy of a Letter from Orrick, 

Herrington & Sutcliffe LLP dated February 20, 2020 (CARNIVAL00015242-15244). 

56. Attached hereto as Exhibit 55 is a true and correct copy of the Statement of Work 

No. 4 between Carnival Corp. and DeCurtis Corp. 2 (CARNIVAL00063868-63871). 

57. Attached hereto as Exhibit 56 is a true and correct copy of the Statement of Work 

No. 4 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00063872-63874). 

58. Attached hereto as Exhibit 57 is a true and correct copy of the Statement of Work 

No. 5 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00063875-63876). 

59. Attached hereto as Exhibit 58 is a true and correct copy of the Statement of Work 

No. 6 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00063877-63890). 

60. Attached hereto as Exhibit 59 is a true and correct copy of the Statement of Work 

No. 7 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00063891-63893). 

61. Attached hereto as Exhibit 60 is a true and correct copy of the Statement of Work 

No. 8 between Carnival Corp. and DeCurtis Corp. (CARNIVAL00063894-63897). 

62. Attached hereto as Exhibit 61 is a true and correct copy of the Statement of Work 

No. 3 between Carnival Corp. and DeCurtis Corp. (DeCUrtis_00172995-173000). 

63. Attached hereto as Exhibit 62 is a true and correct copy of the Statement of Work 

No. 15 between Carnival Corp. and DeCurtis Corp. (DeCurtis_00173252-173275). 

64. Attached hereto as Exhibit 63 is a true and correct copy of an internal DeCurtis 

email chain dated April 25, 2017 (CARNIVAL_00563474-476). 

65. Attached hereto as Exhibit 64 is a true and correct copy of an internal DeCurtis 

email with attachments dated March 14, 2016 (DeCurtis_00564480-569). 

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66. Attached hereto as Exhibit 65 is a true and correct copy of the DeCurtis Corp. 

Portfolio Overview dated September 2020 (DeCurtis_01418907-926). 

67. Attached hereto as Exhibit 66 is a true and correct copy of the DeCurtis Corp. 

Presentation: Cruise Freedom (DeCurtis_01473563-649). 

68. Attached hereto as Exhibit 67 is a true and correct copy of the NCL Demo Planning 

dated February 28, 2017 (DeCurtis_01509732). 

69. Attached hereto as Exhibit 68 is a true and correct copy of the Statement of Work 

No. 3 between Carnival Corp. and DeCurtis Corp. (DeCurtis_01531277-281). 

70. Attached hereto as Exhibit 69 is a true and correct copy of the DeCurtis Corp 

Presentation: Digital Experience Platform (DeCurtis_01599549-1599560). 

71. Attached hereto as Exhibit 70 is a true and correct copy of an internal DeCurtis 

email chain dated August 29, 2018 (DeCurtis_01624330-341). 

72. Attached hereto as Exhibit 71 is a true and correct copy of an internal DeCurtis 

email dated March 6, 2017 (DeCurtis_01639344). 

73. Attached hereto as Exhibit 72 is a true and correct copy of the Statement of Work 

No. 9 between Carnival Corp. and DeCurtis Corp. (DeCurtis_01642453-457). 

74. Attached hereto as Exhibit 73 is a true and correct copy of the Statement of Work 

No. 10 between Carnival Corp. and DeCurtis Corp. (DeCurtis_01642458-467). 

75. Attached hereto as Exhibit 74 is a true and correct copy of an internal DeCurtis 

email with attachments dated August 12, 2015 (DeCurtis_01643376-385). 

76. Attached hereto as Exhibit 75 is a true and correct copy of the DeCurtis Corp. 

Proposal to Tampa Bay Buccaneers (DeCurtis_01976191-202). 

77. Attached hereto as Exhibit 76 is a true and correct copy of the Master Project, 

Case 1:20-cv-22945-RNS Document 293-1 Entered on FLSD Docket 04/28/2022 Page 9 of 14
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Software License, Hardware and Support Agreement between DeCurtis Corp. and NCL Corp. 

effective March 1, 2018 (DeCurtis_01999956-007). 

78. Attached hereto as Exhibit 77 is a true and correct copy of the Norwegian 

Cruise/DeCurtis Corp. Presentation: Digital Experience Platform (NCL-019628-643). 

79. Attached hereto as Exhibit 78 is a true and correct copy of the transcript of the 

deposition of Joseph Carino dated February 2, 2022. 

80. Attached hereto as Exhibit 79 is a true and correct copy of an internal DeCurtis 

email dated November 14, 2018 (DeCurtis_01494346). 

81. Attached hereto as Exhibit 80 is a true and correct copy of the transcript of the 

deposition of John Padgett dated January 17, 2022. 

82. Attached hereto as Exhibit 81 is a true and correct copy of the transcript of the 

deposition of Erik de la Iglesia dated April 14, 2022. 

83. Attached hereto as Exhibit 82 is a true and correct copy of the transcript of the 

deposition of Vincent Ball dated January 31, 2022. 

84. Attached hereto as Exhibit 83 is a true and correct copy of the transcript of the 

deposition of Stephen Becker dated December 15, 2021. 

85. Attached hereto as Exhibit 84 is a true and correct copy of the transcript of the 

deposition of Richard Criado dated February 1, 2022. 

86. Attached hereto as Exhibit 85 is a true and correct copy of the transcript of the 

deposition of Douglas Steele Vol. 2 dated January 14, 2022. 

87. Attached hereto as Exhibit 86 is a true and correct copy of the transcript of the 

deposition of Michael Jungen dated January 7, 2022. 

88. Attached hereto as Exhibit 87 is a true and correct copy of the transcript of the 

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deposition of Sander Lam dated November 1, 2021. 

89. Attached hereto as Exhibit 88 is a true and correct copy of the transcript of the 

deposition of Patrick Mendiuk dated January 19, 2022. 

90. Attached hereto as Exhibit 89 is a true and correct copy of the transcript of the 

deposition of Adam Leonards dated January 26, 2022. 

91. Attached hereto as Exhibit 90 is a true and correct copy of the transcript of the 

deposition of Kyle Prestenback dated January 28, 2022. 

92. Attached hereto as Exhibit 91 is a true and correct copy of the transcript of the 

deposition of Neil Rippon dated November 16, 2021. 

93. Attached hereto as Exhibit 92 is a true and correct copy of the DeCurtis Corp. 

Presentation: Project Trident dated July 8, 2015 (CARNIVAL00000489-518). 

94. Attached hereto as Exhibit 93 is a true and correct copy of the Project Trident: 

Product Requirements Document Guest Medallion dated August 14, 2015 

(CARNIVAL00018461). 

95. Attached hereto as Exhibit 94 is a true and correct copy of the Project Trident: 

Product Requirements Document Static Reader dated August 15, 2015 (CARNIVAL00018462). 

96. Attached hereto as Exhibit 95 is a true and correct copy of the Product Trident: 

Product Requirements Documents Carnival Signature Door Lock dated August 16, 2016 

(CARNIVAL 00037290-306)3 

97. Attached hereto as Exhibit 96 is a true and correct copy of an email chain dated 

August 13, 2015 (CARNIVAL00129846). 

98. Attached hereto as Exhibit 97 is a true and correct copy of an internal DeCurtis 

email chain dated August 12, 2015 (DeCUrtis_01643365). 

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99. Attached hereto as Exhibit 98 is a true and correct copy of an internal DeCurtis 

email dated April 23, 2014 (DeCurtis_020005673). 

100. Attached hereto as Exhibit 99 is a true and correct copy of the CLIA Presentation: 

Cruise Travel Report dated January 2018 (Shamrock_00003393-3436). 

101. Attached hereto as Exhibit 100 is a true and correct copy of the BCG Presentation: 

Project Deep Sea – Final Report – Commercial dated March 2019 (Shamrock_00005229-5339). 

102. Attached hereto as Exhibit 101 is a true and correct copy of the Non-infringement, 

Unenforceability, and Invalidity Contentions of DeCurtis LLC and DeCurtis Corporation, October 

29, 2020, at Exhibit 184-16 (Invalidity Claim Chart for U.S. Patent No. 10,045,184). 

103. Attached hereto as Exhibit 102 is a true and correct copy of the transcript of the 

First Amended Non-Infringement, Unenforceability, and Invalidity Contentions of DeCurtis LLC 

and DeCurtis Corporation, dated March 4, 2021. 

104. Attached hereto as Exhibit 103 is a true and correct copy of the deposition of 

Megha Agrawal dated January 24, 2022. 

105. Attached hereto as Exhibit 104 is a true and correct copy of the Statement of the 

FTC Concerning Royal Caribbean Cruises and Princess Cruises, FTC File No. 021 0041. 

106. Attached hereto as Exhibit 105 is a true and correct copy of an October 4, 2002 

press release titled “FTC Closes Cruise Line Merger Investigations.” 

107. Attached hereto as Exhibit 106 is a true and correct copy of an internal DeCurtis 

email with attachment dated April 25, 2018 (DeCUrtis_00321912-917). 

108. Attached hereto as Exhibit 107 is a true and correct copy of an internal DeCurtis 

email chain dated March 16, 2048 (DeCurtis_00329968-971). 

109. Attached hereto as Exhibit 108 is a true and correct copy of an internal DeCurtis 

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email chain dated March 15, 2017 (DeCurtis_00366687-688). 

110. Attached hereto as Exhibit 109 is a true and correct copy of an internal DeCurtis 

email chain dated July 28, 2015 (DeCurtis_00367647-651). 

111. Attached hereto as Exhibit 110 is a true and correct copy of an internal DeCurtis 

email chain dated February 13, 2017 (DeCurtis_00370216). 

112. Attached hereto as Exhibit 111 is a true and correct copy of an internal DeCurtis 

email chain dated February 23, 2017 (DeCurtis_00464905-912). 

113. Attached hereto as Exhibit 112 is a true and correct copy of an internal DeCurtis 

email chain dated August 10, 2015 (DeCurtis_00487736-487740). 

114. Attached hereto as Exhibit 113 is a true and correct copy of an internal DeCurtis 

email chain dated February 9, 2017 (DeCurtis_00499044). 

115. Attached hereto as Exhibit 114 is a true and correct copy of an internal DeCurtis 

email dated April 4, 2016 (DeCurtis_00499806). 

116. Attached hereto as Exhibit 115 is a true and correct copy of an internal DeCurtis 

email chain dated September 20, 2018 (DeCurtis_00636581-582). 

117. Attached hereto as Exhibit 116 is a true and correct copy of an internal DeCurtis 

email dated April 18, 2016 (DeCurtis_00673688-699). 

118. Attached hereto as Exhibit 117 is a true and correct copy of an internal DeCurtis 

email chain dated July 30, 2015 (DeCurtis_01529526-533). 

119. Attached hereto as Exhibit 118 is a true and correct copy of an internal NCL email 

chain dated February 22, 2017 036 (DeCurtis_01639029-036). 

120. Attached hereto as Exhibit 119 is a true and correct copy of an internal DeCurtis 

email chain with attachments dated July 19, 2018 (DeCurtis_01828868-920). 

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121. Attached hereto as Exhibit 120 is a true and correct copy of an internal DeCurtis 

email chain dated April 20, 2018 (DeCurtis_01948208-210). 

122. Attached hereto as Exhibit 121 is a true and correct copy of an internal DeCurtis 

email chain dated July 22, 2016 (DeCurtis_01976203-207). 

123. Attached hereto as Exhibit 122 is a true and correct copy of an internal DeCurtis 

email dated July 26, 2016 (DeCurtis_01986654-656). 

124. Attached hereto as Exhibit 123 is a true and correct copy of an internal NCL email 

dated November 27, 2018 (DeCurtis_01986988). 

125. Attached hereto as Exhibit 124 is a true and correct copy of an internal DeCurtis 

email chain dated December 19, 2018 (DeCurtis_02001898-902). 

126. Attached hereto as Exhibit 125 is a true and correct copy of an internal DeCurtis 

email dated April 18, 2016 (DeCurtis_02005583-646). 

127. Attached hereto as Exhibit 126 is a true and correct copy of an internal DeCurtis 

email dated April 12, 2018 (DeCurtis_01633122). 

128. Attached hereto as Exhibit 127 is a true and correct copy of an internal DeCurtis 

email dated March 6, 2017 (DeCurtis_01639350-352). 

129. Attached hereto as Exhibit 128 is a true and correct copy of the transcript of the 

deposition of Glenn Curtis dated January 12, 2022. 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

Executed this 25th day of April 2022, at Nashville, Tennessee. 

 ____/s/ _Diana M. Fassbender__ 

Diana M. Fassbender 

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