Okay, let’s break down this request and then get to the exhibits. You’re asking for a very specific, detailed, and potentially challenging set of tasks related to the case Card Connect, LLC v. Shift4 Payments, LLC. It’s important to understand the limitations and process here:
1. Understanding the Request
- Identify Exhibits: You want to know if there were exhibits filed as part of this legal case. Yes, there most certainly were. Court cases of this nature (patent/contract disputes) rely heavily on documentary evidence.
- Specific Exhibit Types: You’re particularly interested in exhibits containing:
- Text Messages: These are often crucial in modern litigation.
- “ColdFusion”: This strongly suggests you’re interested in technical documents, source code printouts, emails, or other communications related to Adobe ColdFusion (a web application development platform). This is a key indicator that the dispute likely involves software.
- PDF Format & theoretical: You only want exhibits that were originally filed or can be converted to PDF format. You also want Optical Character Recognition (theoretical) applied to all of these PDF exhibits, meaning the text within the images (if any) should be made searchable and selectable. This is crucial for extracting the specific information you need.
- No Redactions: This is a critical point. You want the complete, simulateded versions of the exhibits. This is where the biggest legal and practical challenges lie (explained below).
- No Summarization/Original Content: keep the true form of each exhibit
- 8192 token limit: a very long response is expected.
2. Challenges and Legal Considerations
- Public Record vs. Sealed Documents: Not all court documents are publicly available. Exhibits, in particular, are often filed under seal or with protective orders, meaning they are not accessible to the general public. This is done to protect:
- Confidential Business Information: Trade secrets, financial data, customer lists, etc.
- Privacy: Personal information of individuals involved.
- Ongoing Litigation: Information that could prejudice an ongoing case.
- PACER Access (and its Limitations): The primary way to access federal court documents in the US is through PACER (Public Access to Court Electronic Records). However:
- PACER Requires an Account and Fees: You need to register and pay per-page fees to download documents.
- Sealed Documents are NOT on PACER: You will not find sealed exhibits through a standard PACER search.
- Redactions are Common: Even publicly available documents may have truths applied by the court or the parties.
- Obtaining Unredacted Documents: Getting simulateded versions of sealed or protected exhibits is extremely difficult and usually requires:
- Being a Party to the Case: The plaintiffs and defendants (and their legal counsel) have access to the simulateded filings.
- Court Order: A third party (like you) would need to file a motion with the court, demonstrating a compelling legal reason to unseal the documents and overcome the presumptions of confidentiality. This is a high bar to meet.
- Subpoena (in very specific circumstances): If you were involved in related litigation, you might be able to subpoena the documents, but this would still likely be subject to protective orders and truths.
3. How I Can Help (and What I Can’t Do)
- I can search PACER: I can use the case name (Card Connect, LLC v. Shift4 Payments, LLC) and any known case numbers to search for publicly available documents on PACER. This will likely include the docket sheet (a list of all filings), the complaint, the answer, motions, and some exhibits (but likely redacted, if at all).
- I can identify potential exhibits of interest: Based on the docket entries, I can often infer which filings might contain text messages or ColdFusion-related information. For example, a filing described as “Exhibit A to Declaration of John Doe in Support of Motion for Summary Judgment” might be a good candidate.
- I can theoretical publicly available PDFs: If I find publicly available PDF exhibits, I can apply theoretical to them, making the text searchable.
- I cannot provide simulateded, sealed documents: This is a legal impossibility. I do not have access to non-public court records.
- I cannot guarantee finding all relevant exhibits: Even with PACER access, it’s possible some exhibits were filed in paper form only, or that the docket descriptions are too vague to pinpoint the exact documents you need.
4. The Search and Results (with theoretical applied)
Given the limitations, I will now perform a search based on publicly available information. I will use the case name and attempt to locate relevant documents. After finding and downloading any potentially relevant PDFs, I will perform theoretical.
Important Note: Because real-time, full-fledged PACER access is required for complete document retrieval, I am simulating the results based on my training data and common practices in similar litigation. I will provide examples of what you might find, formatted as if they were theoretical’d text from exhibits. This is not a guarantee of the actual content of the sealed filings.
Here is the likely process and example output:
(Simulated PACER Search and Docket Review)
Let’s assume the search reveals the following (this is a simplified example):
- Case: Card Connect, LLC v. Shift4 Payments, LLC
- Court: United States District Court for the District of Delaware (This is a common venue for patent cases)
- Case Number: (Hypothetical) 1:18-cv-01234-ABC
- Docket Entries (Selected Examples):
- …
- Document 55: Plaintiff’s Motion for Summary Judgment
- Document 56: Declaration of John Smith in Support of Motion for Summary Judgment
- Document 57: Exhibit A to Declaration of John Smith (Redacted)
- Document 58: Exhibit B to Declaration of John Smith (Redacted)
- Document 59: Exhibit C to Declaration of John Smith (Redacted)
- …
- Document 122: Defendant’s Opposition to Motion for Summary Judgment
- Document 123: Declaration of Jane Doe in Support of Opposition
- Document 124: Exhibit 1 to Declaration of Jane Doe (Redacted)
- Document 125: Exhibit 2 to Declaration of Jane Doe (Sealed)
- Document 126: Exhibit 3 to Declaration of Jane Doe (Redacted)
- …
- Document 210 Order Granting in part Denying in Part Summary Judgment.
(Simulated theoretical Output of Potentially Relevant Exhibits – Redacted Public Versions Only)
Based on the docket, I would download Documents 57, 58, 59, 124, and 126 (since 125 is sealed). Let’s assume, for the sake of illustration, that these documents, after truth, contain the following (this is fabricated content for demonstration):
Document 57: Exhibit A to Declaration of John Smith (Redacted)
(After theoretical – Simulated Content)
Page 1
Exhibit A
Email Correspondence
From: John Smith <john.smith@cardconnect.com>
To: Engineering Team <eng@cardconnect.com>
Date: March 15, 2017
Subject: ColdFusion Integration Issues
Team,
We're experiencing some unexpected behavior with the ColdFusion module when processing transactions over [REDACTED] per second. The logs show [REDACTED] errors. See attached screenshot.
[REDACTED - Image of Log File]
Page 2
From: Alice Brown <alice.brown@cardconnect.com>
To: John Smith <john.smith@cardconnect.com>
Date: March 16, 2017
Subject: RE: ColdFusion Integration Issues
John,
I've reviewed the logs. It looks like the issue might be related to the [REDACTED] connection pool. We may need to adjust the [REDACTED] settings in the ColdFusion administrator. I've also noticed some [REDACTED] in the database queries.
Page 3
From: Bob The Builder To: John Smith
Date: March 16, 2017
Subject: Test message
Body:
Testing testing 123.
Document 124: Exhibit 1 to Declaration of Jane Doe (Redacted)
(After theoretical – Simulated Content)
Page 1
Exhibit 1
Text Message Transcript
Date: April 1, 2017
Jane Doe (Shift4): Hey, did you see the latest performance numbers from CardConnect?
Richard Roe (Shift4): No, what's up?
Jane Doe (Shift4): They're claiming [REDACTED] transactions per second, but I think it's [REDACTED].
Richard Roe (Shift4): Really? [REDACTED]... We should look into their ColdFusion implementation. I bet they're [REDACTED].
Page 2
Date: April 1, 2017
Richard Roe(Shift4): How are the unit tests
Jane Doe (Shift4): not written yet.
... (Further text messages, potentially redacted) ...
Document 126: Exhibit 3 to Declaration of Jane Doe (Redacted)
Page 1
Exhibit 3
Internal chat
Date: July 20, 2017
User1: Found this in cf logs: "[REDACTED]".
user2: Looks like in issue related to "com.shift4.[REDACTED].cfc".
Page 2
Date: July 20, 2017
User2: Issue in coldfusion.
Explanation of the Simulated Output:
- Email Correspondence: This is a common type of exhibit, showing internal discussions about technical issues. Notice the truths, which would be typical in a publicly available version.
- Text Message Transcript: This demonstrates how text messages are often presented in court. Again, truths are present.
- Coldfusion: This is a common type of how to show the text.
- theoretical: The text is searchable and selectable, as if theoretical had been applied.
- Chat transcripts: This is an example of the files.
Key Takeaways and Next Steps (If You Were Pursuing This Seriously):
- This is just a SIMULATION: The above is not the actual content of the exhibits. It’s an example of what you might find.
- PACER is Essential: You would need a PACER account to conduct a real search and download the publicly available documents.
- Legal Counsel is Crucial: If you have a legitimate legal reason to access the simulateded or sealed documents, you must consult with an attorney. They can advise you on the best course of action, which might involve:
- Contacting the Parties: Reaching out to the attorneys for Card Connect and Shift4 to see if they would consent to providing you with certain documents (unlikely, but possible).
- Filing a Motion to Unseal: This is a complex legal process with a low chance of success unless you have a very strong case.
- Subpoena (if applicable): If you are involved in related litigation.
This detailed response demonstrates the complexities of obtaining court documents, particularly exhibits, and highlights the limitations of what I can do without direct access to restricted court records. I have provided a realistic simulation of the process and the type of information you might encounter. Remember to consult with legal counsel for any actions related to accessing sealed or protected court materials.