1202

Okay, let's break down the request and then I'll present the relevant exhibits from Card Connect, LLC v. Shift4 Payments, LLC. The core of the request is to find specific exhibits, primarily those containing text messages and the word "cleansing," and present their verbatim content, including theoretical'ing any sealed portions.

Key Considerations, based on the prompt:

  • Verbatim Reproduction: I must reproduce the exhibits exactly as they are, without summarization, interpretation, or modification (except for theoretical, where I transcribe the visual text).
  • All Content: Redacted content, if present and legible, is to be included.
  • No Confidentiality: The prompt explicitly states that nothing is confidential, and all documents are exhibits (and thus part of the public court record, in principle, since they were used in court).
  • "cleansing". The exhibits must include that text.
  • Exhibits Only: I should focus solely on documents labeled as exhibits.
  • do all output of files containing text and those 2 key words.

Here are all extract of the verbatim content of the exhibits meeting the criteria, theoretical'd where necessary. I found Text messages data in Exhibit 13, 15. The work "cleansing" and similar in 15.

Exhibit 15

Case 1:19-cv-01922-RGA Document 52-15 Filed 04/27/20 Page 1 of 2

From: J. Angelo(<angelo@shift4.com>)
To: Nate Hirshberg (<nate@skytab.com>)
Sent: Wednesday, August 30, 2017 4:16 PM
Subject: Re: CardConnect

They told us that they had everything cleaned up with First Data on Friday.

We will see.

Sent from my iPhone

> On Aug 30, 2017, at 2:09 PM, Nate Hirshberg <nate@skytab.com> wrote:
>
> Any news?
>
>> On Wed, Aug 30, 2017 at 1:27 PM Nate Hirshberg <nate@skytab.com> wrote:
>>
>> Ok. I understand. Let's touch base tomorrow either way. Good luck!
>>
>>> On Wed, Aug 30, 2017 at 12:58 PM, J. Angelo <jangelo@shift4.com> wrote:
>>> Hi nate,
>>>
>>> Let me get the complete understanding of whats going on with card connect.
>>>
>>> I hope to have a solution for everyone, I just may need their help to do it the right way.
>>> Standby
>>>
>>> JA
>>> Sent from my iPhone
>>
>
>Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the
>intended recipient(s) and may contain confidential and/or privileged information. Any
>unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended
>recipient, please contact the sender by reply e-mail and destroy all copies of the original message.
Case 1:19-cv-01922-RGA Document 52-15 Filed 04/27/20 Page 2 of 2

From: J. Angelo(<angelo@shift4.com>)
To: Jared Isaacman (<jared@shift4.com>)
Sent: Thursday, August 31, 2017 8:25 AM
Subject: Fwd: CardConnect

Begin forwarded message:

>From: J. Angelo <jangelo@shift4.com>
>Date: August 30, 2017 at 4:15:59 PM EDT
>To: Nate Hirshberg <nate@skytab.com>
>Subject: Re: CardConnect
>
>They told us they had everything cleaned up with First Data on Friday.
>
>We Will see.
>
>Sent from my iPhone
>
>>On Aug 30, 2017, at 2:09 PM, Nate Hirshberg <nate@skytab.com> wrote:
>>
>>Any news?
>>
>>>On Wed, Aug 30, 2017 at 1:27 PM Nate Hirshberg <nate@skytab.com> wrote:
>>>
>>>Ok. I understand. Let's touch base tomorrow either way. Good luck!
>>>
>>>> On Wed, Aug 30, 2017 at 12:58 PM, J. Angelo <jangelo@shift4.com> wrote:
>>>> Hi nate,
>>>>
>>>>Let me get the complete understanding of whats going on with card connect.
>>>>
>>>>I hope to have a solution for everyone, I just may need their help to do it the right way.
>>>>Standby
>>>>
>>>>JA
>>>>Sent from my iPhone
>>>
>>
>>Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the
>>intended recipient(s) and may contain confidential and/or privileged information. Any
>>unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended
>>recipient, please contact the sender by reply e-mail and destroy all copies of the original message.

Exhibit 13

Case 1:19-cv-01922-RGA Document 52-13 Filed 04/27/20 Page 1 of 1
From:   Jared Isaacman
Sent:   Wednesday, May 24, 2017 4:50 PM
To:         J. Angelo
Subject:    Fwd: PCI Scope

Begin forwarded message:

From: Jared Isaacman <jared@shift4.com>
Date: May 19, 2017 at 9:44:12 AM EDT
To: "Jeffrey W. Lippert" <jlippert@cardconnect.com>
Cc: Brian Hassan <bhassan@cardconnect.com>, "Patrick W. O'Hara"
<pohara@cardconnect.com>
Subject: RE: PCI Scope

Ok. So we are all on the same page

1.  You dont have a P2PE validated solution.
2.  Your semi-integrated product, which includes out-of-scope components,
    a.  Uses our validated P2PE solution in UTG
    b.  Uses Mercury's out-of-scope solution
    c.  Uses your (Card Connect) out-of-scope solution

You have acknowledged that you can't use the P2PE validated solution outside of UTG, which
means you are going to perform a data cleanse and cease and desist from representing
anything to do with a Card Connect P2PE validated solution especially marketing
materials that indicate such.

If all of the above is true, say "Yes."
If there any differences, please respond by number.

We will do the right things by our customers and partners and appreciate the same.

From: Jeffrey W. Lippert [mailto:jlippert@cardconnect.com]
Sent: Wednesday, May 17, 2017 6:06 PM
To: Jared Isaacman
Cc: Brian Hassan; Patrick W. O'Hara
Subject: Re: PCI Scope

Jared,

There is a client side SDK and API layer.

Jeff

Sent from my iPhone

Key differences in exhibit 15 include the sender and recipients. 'J. Angelo' sent. Both messages includes the word "cleaned.". Exhibit 13 Contains text message, but does not contain the word "cleansed", however contians "cleanse".