Page 1 EXHIBIT A-83Page 2 HO-
Brooks, Brian - Vol.
I.20211213.365944-HQ
12/13/2021 11:21 AM
Full-size Transcript
Prepared by:
HO-Tuesday, June 06, 2023Page 3
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
In the Matter of:
)
)
BINANCE.US
File No. HO-13865-A
)
WITNESS:
Brian Brooks
PAGES:
1 through
PLACE:
Securities and Exchange Commission
100 F Street
Washington, D.C.
DATE:
N.E.
Monday, December 13,
The above-entitled matter came on for hearing,
via WebEx, pursuant to notice, at 11:21 a.m.
Diversified Reporting Services, Inc.
(202)467-
[12/13/2021 11:21 AM] Brooks, Brian - Vol. I.20211213.365944-...Page 4
Trading accounts?
A
Digital asset transfers to BAM Trading
accounts?
Q
The company's trading accounts.
A
I -- I can't recall that happening in the time
that I was there.
Q
Okay.
And was anyone at .com required to give
final signoff for digital asset transfers to third
parties?
A
I -- I'm not even sure I understand the
question.
engine, right, that has buyers and sellers, so third
party buyers and sellers would come and that was the
source of liquidity, so we, you know, we were not
filling orders for customers, we were matching customer
orders, so I don't -- I'm not sure I would even know how
to answer the question.
Q
I mean, BAM Trading operated a matching
So were sometimes BAM Trading paid for
services through digital assets?
A
So with only one caveat, I can't -- I can't
recall that ever happening during my tenure.
The one caveat is there was this group of
employees, basically the Shanghai based technology team,
who I learned right at the very end of my tenure, had
apparently received part of their compensation in BNB
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tokens, which were provided by Binance.com, which was a
source of real concern, you know, for the CFO and me
when we learned about that.
consider them to be third parties, that would be the one
caveat.
happening.
Q
Other than that, I'm not aware of that ever
Do you know who gave signoff to -- giving BNB
to these Shanghai based employees?
But -- and so if you
A
That long predated my arrival.
I have no
idea.
Q
Okay.
A
When did who receive the BNB?
Q
When did the Shanghai based employees receive
When did they receive the BNB?
the BNB?
A
Oh, I -- I don't know.
I mean, it was part of
their compensation.
payment or an annual bonus payment or what that was.
I say, that came to my attention two or three weeks
before I left the company, so I -- I mean, I wasn't even
aware of it until the very end.
Q
I don't know if it was a quarterly
As
Were the Shanghai based employees actual
employees of BAM Trading?
A
Well, they were employees of an entity that
had been set up for the purpose, called Boran.
understanding was that at one time they had been
My
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Binance.com employees and then when the Binance.US
separation happened in 2019, the decision was made to
hive off that group of 50 or so people and they would be
allocated full-time to Binance.US, so the question was
if you had a group of Shanghai based people working for
Binance.US, could they actually legally in China work
for Binance.US or did we have to set up a subsidiary
entity that would be where their employment was tied?
And often in multinational corporations that's the way
it works, is that there's a local corporate entity to
which those employees are assigned, so Boran was an
entirely dedicated to Binance.US workforce, paid for by
Binance.US, but housed within this entity called Boran.
Q
Where was Boran incorporated?
A
I don't know.
I don't know.
But I mean, my
assumption, it was a Chinese legal entity is my
assumption, but I -- I don't know.
Q
Was Boran wholly owned by BAM Trading?
A
I'm not sure.
Q
Okay.
A
I don't.
Q
How did you learn about Boran's structure?
A
Well, as I think I've just indicated, I don't
Do you know who would know?
know very much about Boran's structure, other than to
know, you know, sort of like there's Morgan Stanley,
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Morgan Stanley Asia, Morgan Stanley BD Amsterdam, et
cetera, et cetera, only to understand that its role in
the family of companies was like that; it was an
employee holding company set up for purposes of housing
these Chinese employees.
My focus, as you know from the document that
you have, was to migrate that entire function to an
onshore workforce.
enough to complete that task, but you know, that's
Obviously, I wasn't there long
essentially all I know about Boran.
Q
Did you learn about Boran outside of any
attorney/client communications or potential
attorney/client communications?
A
I mean, Boran was a commonly known thing at
BAM Trading, so I certainly talked about it with non-
lawyers, as well as with lawyers.
CFO was aware that there was an entity called Boran.
was the person who brought to my attention this BNB
arrangement, you know, late in my time there.
terms of whatever I would know about the corporate
structure or its rationale, that would have come from
counsel.
I mean, certainly the
Q
Okay.
A
Fifty or 60, something like that.
Q
Okay.
He
But in
How many people work for Boran?
We're going to go back to my original
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MR. HOLSCHER:
learned that from counsel --
THE WITNESS:
MR. HOLSCHER:
I'll counsel you, if you
Yeah, I understand.
-- I don't want you to impinge
upon any corporate attorney/client privilege.
THE WITNESS:
Right.
Yeah.
My knowledge of
it really doesn't have anything to do with that, it just
has to do with the way that the company got
bootstrapped.
So you know, the way companies typically
get started is somebody has to pay for it, so you know,
Hewlett & Packard used their personal checking account
in their mother's garage.
is CZ gave the company its first $10 million to get
launched, and that was done in the form of a note.
What happened with Binance.US
MS. HITCHENS:
BY MS. HITCHENS:
Q
Okay.
So I'm going to ask you about sort of making
distinctions.
distinction when reporting to Changpeng Zhao in their
capacity as a board director, as opposed -- his capacity
as a board director, as opposed to reporting to him in
other roles and capacities?
make a distinction?
A
Did you ever personality make any
Did you ever personally
I mean, I was 100 percent clear in my own mind
that -- I mean, until I quit, obviously, but I was
[12/13/2021 11:21 AM] Brooks, Brian - Vol. I.20211213.365944-...Page 9
percent clear in my own mind that I worked for a board
of directors.
strongly held the conviction that I did not work for
Binance.com, that nobody at Binance.com was my boss, and
that my role was to complete and highlight the corporate
separateness.
myself to be talking to him in his role as board chair
BAM Trading.
working at Fannie Mae I spoke to our board chair all the
I personally, you know, very, very, very
So when I talked to CZ, I considered
The same way that when I was, you know,
time and I considered myself to be talking to the board
chair, not to somebody else but the board chair.
Q
Now, sitting here today and looking back on
your time at the company, do you look back and think,
oh, maybe there were distinctions when I was talking to
him?
A
Possibly not the distinction that you're
thinking about.
certain point was CZ was the CEO of BAM Trading, not me.
What -- what became clear to me at a
That's what became clear at a certain point.
That
wasn't because Binance.com somehow controlled us, but
again, he owns the vast majority of Binance.com so I put
that aside.
It was more of an issue of if I'm Steve
Ballmer and he's Bill Gates, who's really running this
company, right?
So it was not that oh, gee, CZ's acting
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in a different capacity, it is more of do I have the
delegation and autonomy to carry out the mission of a
CEO as outlined in the mission document that you've
seen, right?
did not.
Q
And at a certain point I concluded that I
Can you just elaborate more why you're saying
now sitting here today you look back and think of him as
the CEO of BAM Trading?
A
Yeah.
I mean, look, he's obviously not
formally the CEO of BAM Trading, but in -- in my
judgment, right, there's a distinction between
management and governance.
governance.
means day-to-day execution of a board approved strategy.
The role of the board is
The role of the CEO is management, which
The time that the switch flipped in my mind
was, right, so I had joined the company with knowledge
of issues at the company and a belief that if those
issues could be fixed the company could be very
successful.
so working on those fixes, to the exclusion of almost
everything else.
core foundational things realigned.
And I spent the first, you know, 80 days or
The idea was we're going to get these
That was all fine.
And then at a certain day
I was -- a certain day late in that tenure, I was
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overruled on all of them.
previously agreed and had worked on for 80 days were
suddenly repudiated with no further discussion, and on
that day, I realized, huh, I'm not actually the one
running this company, and the mission that I believe I
signed up for isn't the mission.
realized that, I left.
All of the things that we had
And as soon as I
Q
Well, can you tell me a little bit about that
A
Sure.
day?
I would say -- you know, when I say it
was a day, it was really the space of about eight to
days.
know, which I described previously.
were going through the standard agenda items, how's the
fundraise going?
It began with our regular weekly meeting, you
And you know, we
Who are the board members going to be?
What about the tech migration?
And in this particular
call, the issue was why are doing a tech migration?
And
what I remember about that call is that it was late in
the evening, and I said -- I said the tech migration is
one of the most important risks in this company.
the reason the people believe that, you know, that in
fact the company's not an independent company, that in
fact it's controlled by, you know, somebody sitting in
China.
through all the reasons why we had agreed, and I
It's
This is a foundational strategy, and I went
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thing whose cost has already been fully amortized,
that's going to be a lot cheaper than if you have to
bear the cost of the initial startup expense yourself.
Q
So were the ongoing maintenance costs for the
Binance.US platform sort of less than Coinbase would
pay?
A
No idea.
Q
Okay.
A
I don't know.
Q
Okay.
Who would know?
Do you know if the cost would change
after the migration occurred?
A
The cost would likely go up.
Q
Okay.
A
Well, because the cost of operating one
And why is that?
platform is always lower than the cost of operating two
platforms, even if the two platforms are identical,
right.
United States to be the 50 people operating it.
labor costs are far higher than Chinese costs are, as
I'm sure that you know.
on we would be responsible for our own design decisions,
and that would cost money.
Q
So we would have to hire a team of people in the
U.S.
And you know, from that point
Were the service level agreements going to
sort of continue to exist after the migration?
A
Who can say that never happens, so I don't
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know.
Q
exist?
A
Do you know whether they were contemplated to
I mean, we never got close to that, so I don't
think that discussion was ever had.
Q
Okay.
So basically, under the service level
agreements, it sounds like .com was able to sort of run
with the same personnel the Binance.US platform and then
the .com platform; is that correct?
A
No.
So let me just start over for a second.
So first of all, you've now said service level agreement
several times; service level agreements just refer to
timetables and deliverables.
were.
agreement, not a service level agreement.
create common language here.
That's not what these
These were a services agreement and a licensing
Just to
We had 50 employees that were not Binance.com
employees, these were the Boran people we previously
talked about who were responsible for our technology.
One of the things that they would do is when Binance.com
had a new release of the code base for this or that or
the other, whatever the particular update was that they
might be releasing, it was the Boran employees who then
spend time, you know, essentially copying that code,
making such minor adjustments as were needed for that
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code to operate on our U.S., you know, front end
platform, and then would push it out to our customers.
So those were not Binance.com employees doing
that, they were Binance.US employees, Boran employees,
receiving updates from .com and then making those
changes for us.
Q
But those employees, though, did not work on
the matching engine; is that correct?
A
They didn't work on the matching engine,
that's right.
Q
So was .com using the -- you know, has its
matching engine folks, and they were also helping -- not
only helping to support the .com platform, ostensibly,
but those matching engine folks were also supporting the
.US platform?
A
engine.
No.
No, they were supporting the matching
We had a license --
Q
Okay.
A
-- that allowed us to use the matching engine.
Q
Okay.
Thank you for clarifying that.
So during your tenure at BAM Trading, did any
of the following happen: code changes occurred to the
Binance.US platform that were not announced to trading
personnel or to users?
MR. HOLSCHER:
I'm just going to counsel you
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if you understand the technology of the question,
answer.
question.
If you don't, just do your best to answer that
THE WITNESS:
I mean, the answer to that I
have no idea.
But I'm not aware of any code that got pushed that
wasn't disclosed to people.
referencing to something in particular, I'm happy to
hear that, but I -- I don't know what that refers to.
I'm not sure I understand the question.
MS. HITCHENS:
I mean, if you're
These are just general
questions to understand what your experience was with
certain issues that could occur with the platform.
BY MS. HITCHENS:
Q
So would -- did any -- during your tenure, any
systemic issue with the code to the Binance.US cause
trading glitches or sort of larger scale trading issues
for users?
A
You know, I -- so I have a memory of there
being one or two occasions when the platform may have
been inaccessible for an hour here or two hours there
because of code updates and things like that.
remember anything more than that.
systemic, I don't recall anything there.
Q
Okay.
I don't
So when you say
Are you aware from your time there of
any sort of latency issues with the servers being used
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EXHIBIT A-83
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HO-13865
Brooks, Brian - Vol.
I.20211213.365944-HQ
12/13/2021 11:21 AM
Full-size Transcript
Prepared by:
HO-13865
Tuesday, June 06, 2023
PDF Page 4
Case 1:23-cv-01599 Document 20-3 Filed 06/06/23 Page 3 of 15
1
1
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2
3
In the Matter of:
)
4
5
)
BINANCE.US
File No. HO-13865-A
)
6
7
WITNESS:
Brian Brooks
8
PAGES:
1 through 212
9
PLACE:
Securities and Exchange Commission
10
100 F Street
11
Washington, D.C. 20549
12
DATE:
N.E.
Monday, December 13, 2021
13
14
15
The above-entitled matter came on for hearing,
via WebEx, pursuant to notice, at 11:21 a.m.
16
17
18
19
20
21
22
23
24
25
Diversified Reporting Services, Inc.
(202)467-9200
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1
2
3
Trading accounts?
A
Digital asset transfers to BAM Trading
accounts?
4
Q
The company's trading accounts.
5
A
I -- I can't recall that happening in the time
6
7
that I was there.
Q
Okay.
And was anyone at .com required to give
8
final signoff for digital asset transfers to third
9
parties?
10
A
I -- I'm not even sure I understand the
11
question.
12
engine, right, that has buyers and sellers, so third
13
party buyers and sellers would come and that was the
14
source of liquidity, so we, you know, we were not
15
filling orders for customers, we were matching customer
16
orders, so I don't -- I'm not sure I would even know how
17
to answer the question.
18
19
20
21
22
Q
I mean, BAM Trading operated a matching
So were sometimes BAM Trading paid for
services through digital assets?
A
So with only one caveat, I can't -- I can't
recall that ever happening during my tenure.
The one caveat is there was this group of
23
employees, basically the Shanghai based technology team,
24
who I learned right at the very end of my tenure, had
25
apparently received part of their compensation in BNB
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1
tokens, which were provided by Binance.com, which was a
2
source of real concern, you know, for the CFO and me
3
when we learned about that.
4
consider them to be third parties, that would be the one
5
caveat.
6
happening.
7
Q
8
Other than that, I'm not aware of that ever
Do you know who gave signoff to -- giving BNB
to these Shanghai based employees?
9
10
But -- and so if you
A
That long predated my arrival.
I have no
idea.
11
Q
Okay.
12
A
When did who receive the BNB?
13
Q
When did the Shanghai based employees receive
14
15
When did they receive the BNB?
the BNB?
A
Oh, I -- I don't know.
I mean, it was part of
16
their compensation.
17
payment or an annual bonus payment or what that was.
18
I say, that came to my attention two or three weeks
19
before I left the company, so I -- I mean, I wasn't even
20
aware of it until the very end.
21
22
23
Q
I don't know if it was a quarterly
As
Were the Shanghai based employees actual
employees of BAM Trading?
A
Well, they were employees of an entity that
24
had been set up for the purpose, called Boran.
25
understanding was that at one time they had been
My
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1
Binance.com employees and then when the Binance.US
2
separation happened in 2019, the decision was made to
3
hive off that group of 50 or so people and they would be
4
allocated full-time to Binance.US, so the question was
5
if you had a group of Shanghai based people working for
6
Binance.US, could they actually legally in China work
7
for Binance.US or did we have to set up a subsidiary
8
entity that would be where their employment was tied?
9
And often in multinational corporations that's the way
10
it works, is that there's a local corporate entity to
11
which those employees are assigned, so Boran was an
12
entirely dedicated to Binance.US workforce, paid for by
13
Binance.US, but housed within this entity called Boran.
14
Q
Where was Boran incorporated?
15
A
I don't know.
I don't know.
But I mean, my
16
assumption, it was a Chinese legal entity is my
17
assumption, but I -- I don't know.
18
Q
Was Boran wholly owned by BAM Trading?
19
A
I'm not sure.
20
Q
Okay.
21
A
I don't.
22
Q
How did you learn about Boran's structure?
23
A
Well, as I think I've just indicated, I don't
Do you know who would know?
24
know very much about Boran's structure, other than to
25
know, you know, sort of like there's Morgan Stanley,
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1
Morgan Stanley Asia, Morgan Stanley BD Amsterdam, et
2
cetera, et cetera, only to understand that its role in
3
the family of companies was like that; it was an
4
employee holding company set up for purposes of housing
5
these Chinese employees.
6
My focus, as you know from the document that
7
you have, was to migrate that entire function to an
8
onshore workforce.
9
enough to complete that task, but you know, that's
10
11
Obviously, I wasn't there long
essentially all I know about Boran.
Q
Did you learn about Boran outside of any
12
attorney/client communications or potential
13
attorney/client communications?
14
A
I mean, Boran was a commonly known thing at
15
BAM Trading, so I certainly talked about it with non-
16
lawyers, as well as with lawyers.
17
CFO was aware that there was an entity called Boran.
18
was the person who brought to my attention this BNB
19
arrangement, you know, late in my time there.
20
terms of whatever I would know about the corporate
21
structure or its rationale, that would have come from
22
counsel.
I mean, certainly the
23
Q
Okay.
24
A
Fifty or 60, something like that.
25
Q
Okay.
He
But in
How many people work for Boran?
We're going to go back to my original
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1
2
MR. HOLSCHER:
learned that from counsel --
3
THE WITNESS:
4
MR. HOLSCHER:
5
I'll counsel you, if you
Yeah, I understand.
-- I don't want you to impinge
upon any corporate attorney/client privilege.
6
THE WITNESS:
Right.
Yeah.
My knowledge of
7
it really doesn't have anything to do with that, it just
8
has to do with the way that the company got
9
bootstrapped.
So you know, the way companies typically
10
get started is somebody has to pay for it, so you know,
11
Hewlett & Packard used their personal checking account
12
in their mother's garage.
13
is CZ gave the company its first $10 million to get
14
launched, and that was done in the form of a note.
What happened with Binance.US
15
MS. HITCHENS:
16
BY MS. HITCHENS:
17
Q
Okay.
So I'm going to ask you about sort of making
18
distinctions.
19
distinction when reporting to Changpeng Zhao in their
20
capacity as a board director, as opposed -- his capacity
21
as a board director, as opposed to reporting to him in
22
other roles and capacities?
23
make a distinction?
24
25
A
Did you ever personality make any
Did you ever personally
I mean, I was 100 percent clear in my own mind
that -- I mean, until I quit, obviously, but I was 100
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1
percent clear in my own mind that I worked for a board
2
of directors.
3
strongly held the conviction that I did not work for
4
Binance.com, that nobody at Binance.com was my boss, and
5
that my role was to complete and highlight the corporate
6
separateness.
7
myself to be talking to him in his role as board chair
8
BAM Trading.
9
working at Fannie Mae I spoke to our board chair all the
I personally, you know, very, very, very
So when I talked to CZ, I considered
The same way that when I was, you know,
10
time and I considered myself to be talking to the board
11
chair, not to somebody else but the board chair.
12
Q
Now, sitting here today and looking back on
13
your time at the company, do you look back and think,
14
oh, maybe there were distinctions when I was talking to
15
him?
16
A
Possibly not the distinction that you're
17
thinking about.
18
certain point was CZ was the CEO of BAM Trading, not me.
19
What -- what became clear to me at a
That's what became clear at a certain point.
That
20
wasn't because Binance.com somehow controlled us, but
21
again, he owns the vast majority of Binance.com so I put
22
that aside.
23
It was more of an issue of if I'm Steve
24
Ballmer and he's Bill Gates, who's really running this
25
company, right?
So it was not that oh, gee, CZ's acting
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1
in a different capacity, it is more of do I have the
2
delegation and autonomy to carry out the mission of a
3
CEO as outlined in the mission document that you've
4
seen, right?
5
did not.
6
Q
And at a certain point I concluded that I
Can you just elaborate more why you're saying
7
now sitting here today you look back and think of him as
8
the CEO of BAM Trading?
9
A
Yeah.
I mean, look, he's obviously not
10
formally the CEO of BAM Trading, but in -- in my
11
judgment, right, there's a distinction between
12
management and governance.
13
governance.
14
means day-to-day execution of a board approved strategy.
The role of the board is
The role of the CEO is management, which
15
16
The time that the switch flipped in my mind
17
was, right, so I had joined the company with knowledge
18
of issues at the company and a belief that if those
19
issues could be fixed the company could be very
20
successful.
21
so working on those fixes, to the exclusion of almost
22
everything else.
23
core foundational things realigned.
24
25
And I spent the first, you know, 80 days or
The idea was we're going to get these
That was all fine.
And then at a certain day
I was -- a certain day late in that tenure, I was
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overruled on all of them.
2
previously agreed and had worked on for 80 days were
3
suddenly repudiated with no further discussion, and on
4
that day, I realized, huh, I'm not actually the one
5
running this company, and the mission that I believe I
6
signed up for isn't the mission.
7
realized that, I left.
8
9
All of the things that we had
And as soon as I
Q
Well, can you tell me a little bit about that
A
Sure.
day?
10
I would say -- you know, when I say it
11
was a day, it was really the space of about eight to 10
12
days.
13
know, which I described previously.
14
were going through the standard agenda items, how's the
15
fundraise going?
16
It began with our regular weekly meeting, you
And you know, we
Who are the board members going to be?
What about the tech migration?
And in this particular
17
call, the issue was why are doing a tech migration?
And
18
what I remember about that call is that it was late in
19
the evening, and I said -- I said the tech migration is
20
one of the most important risks in this company.
21
the reason the people believe that, you know, that in
22
fact the company's not an independent company, that in
23
fact it's controlled by, you know, somebody sitting in
24
China.
25
through all the reasons why we had agreed, and I
It's
This is a foundational strategy, and I went
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thing whose cost has already been fully amortized,
2
that's going to be a lot cheaper than if you have to
3
bear the cost of the initial startup expense yourself.
4
Q
So were the ongoing maintenance costs for the
5
Binance.US platform sort of less than Coinbase would
6
pay?
7
A
No idea.
8
Q
Okay.
9
A
I don't know.
10
Q
Okay.
11
Who would know?
Do you know if the cost would change
after the migration occurred?
12
A
The cost would likely go up.
13
Q
Okay.
14
A
Well, because the cost of operating one
And why is that?
15
platform is always lower than the cost of operating two
16
platforms, even if the two platforms are identical,
17
right.
18
United States to be the 50 people operating it.
19
labor costs are far higher than Chinese costs are, as
20
I'm sure that you know.
21
on we would be responsible for our own design decisions,
22
and that would cost money.
23
24
25
Q
So we would have to hire a team of people in the
U.S.
And you know, from that point
Were the service level agreements going to
sort of continue to exist after the migration?
A
Who can say that never happens, so I don't
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know.
2
Q
3
exist?
4
A
5
Do you know whether they were contemplated to
I mean, we never got close to that, so I don't
think that discussion was ever had.
6
Q
Okay.
So basically, under the service level
7
agreements, it sounds like .com was able to sort of run
8
with the same personnel the Binance.US platform and then
9
the .com platform; is that correct?
10
A
No.
So let me just start over for a second.
11
So first of all, you've now said service level agreement
12
several times; service level agreements just refer to
13
timetables and deliverables.
14
were.
15
agreement, not a service level agreement.
16
create common language here.
17
That's not what these
These were a services agreement and a licensing
Just to
We had 50 employees that were not Binance.com
18
employees, these were the Boran people we previously
19
talked about who were responsible for our technology.
20
One of the things that they would do is when Binance.com
21
had a new release of the code base for this or that or
22
the other, whatever the particular update was that they
23
might be releasing, it was the Boran employees who then
24
spend time, you know, essentially copying that code,
25
making such minor adjustments as were needed for that
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code to operate on our U.S., you know, front end
2
platform, and then would push it out to our customers.
3
So those were not Binance.com employees doing
4
that, they were Binance.US employees, Boran employees,
5
receiving updates from .com and then making those
6
changes for us.
7
8
9
10
11
Q
But those employees, though, did not work on
the matching engine; is that correct?
A
They didn't work on the matching engine,
that's right.
Q
So was .com using the -- you know, has its
12
matching engine folks, and they were also helping -- not
13
only helping to support the .com platform, ostensibly,
14
but those matching engine folks were also supporting the
15
.US platform?
16
17
A
engine.
No.
No, they were supporting the matching
We had a license --
18
Q
Okay.
19
A
-- that allowed us to use the matching engine.
20
Q
Okay.
21
Thank you for clarifying that.
So during your tenure at BAM Trading, did any
22
of the following happen: code changes occurred to the
23
Binance.US platform that were not announced to trading
24
personnel or to users?
25
MR. HOLSCHER:
I'm just going to counsel you
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if you understand the technology of the question,
2
answer.
3
question.
If you don't, just do your best to answer that
4
THE WITNESS:
I mean, the answer to that I
5
have no idea.
6
But I'm not aware of any code that got pushed that
7
wasn't disclosed to people.
8
referencing to something in particular, I'm happy to
9
hear that, but I -- I don't know what that refers to.
10
I'm not sure I understand the question.
MS. HITCHENS:
I mean, if you're
These are just general
11
questions to understand what your experience was with
12
certain issues that could occur with the platform.
13
14
BY MS. HITCHENS:
Q
So would -- did any -- during your tenure, any
15
systemic issue with the code to the Binance.US cause
16
trading glitches or sort of larger scale trading issues
17
for users?
18
A
You know, I -- so I have a memory of there
19
being one or two occasions when the platform may have
20
been inaccessible for an hour here or two hours there
21
because of code updates and things like that.
22
remember anything more than that.
23
systemic, I don't recall anything there.
24
25
Q
Okay.
I don't
So when you say
Are you aware from your time there of
any sort of latency issues with the servers being used
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