JOHN J. ACTING ATTORNEY GENERAL UF NEW IERSEY Divisien Df Law 124 Halsey Street - Fieer BOX 45029 Newark, New Jersey as an Attemey fer New Jersey Division of Censumer Affairs By: Glenn T. Ciraham Deputy Attorney General 973-643-4346 STATE DF NEW JERSEY DEPARTMENT DF LAW die PUBLIC SAFETY DIVISION CIIF CONSUMER. AFFAIRS In the Mam" Of Administrative Aetien Jeremy Rubin, individually . and dim Tidbit I ttwartaoearearss TD: Jeremy Rubin dfhfa Titibit 229 Cemmenweaith Avenue Eastern, Massachusetts 16 AND 410 Ivlemefiai Drive Cainbridge, Massachusetts 02139 PLEASE TAKE THAT the New Jersey Division of C-ensumer Affairs, Dffiee of Censumer Preteetirm ("Divisien"J, demands answers of Jeremy Rubin, individually and dfbfa Tidhit, tn the fellevving Interrngateries in the ah-eve-entitled investigatirm. pursuant to N.J.S.A. 513:3-3 and 56:3-4 ef the New Jersey Censumer Frauri Aet under eath er eertifieatien and en er befere ED, 2013. Dated: 4, 3' Newark, New Jersey JOHN J. HUFFMAN ACTING GEBTRAL OF NEW M. By: ierm T. Graharn Deputy General PROOF OF SERVICE 1-. Princess Slater, being ef full age, eertify that an December at 10:03 I caused te be served the within Interregateries en Jeremy Regain at 229 Cearaterrweatrh Avenue. Begtnn. Massachusetts agrrn and at fl Memorial Drive, Cambridge. 39, via Certified and Regular mail. I eertify that the foregoing statements made by me are true. I am aware that if any ef the ferege-ing statements made by me are willfully false, I am subjeet te punishment. Dated: n'n ss Slater INSTRUCTIDNS AND DEFINITIDNS A. Instructions: 1. The Interrogatories are directed to Tidbit as well as its owners, officers, directors, founders, agents, employees, representatives, attorneys, corporations, subsidiaries, affiliates, successors, assigns or any ether person acting or purporting to act on its behalf. 2. Unless otherwise specifically indicated, the period of time encompassed by these Interrogatories shall be from January l, 2012 up to and including the date of your answers. 3. Unless specifically indicated, each and every responsive document produced must be Batesvstamped, Bates-labeled or otherwise consecutively numbered and the person making the production shall identify the corresponding lnterrogatory Number to which each document or group of documents responds. 4. Whenever in these lnterrogatories you are asked to "Identify" or to provide an "ldentity", you are requested: a. When referring to a person, "Identify" or "ldentity" means to give, to the extent knovm, the person's fiull name, present or last known address and telephone number, and when referring to a natural person, additionally, the present or last lcnown place of employment. Once a person has been identified in accordance with this snbparagraph, only the name of that person need be listed in response to subsequent discovery requesting the identification of that person. b. When referring to a document, "Identify" or "Identity" means to give, to the extent known, the: type of document; (ii) general subject matter; date of the document; and {iv} author[s], addressce[s] and recipient[s]. 5. If information requested herein are withheld under a claim of privilege or otherwise, identify the Interrogatory as which the objection is made, and set forth with particularity the basis upon and the extent to which the information is being withheld. 6. To the extent you assert any objection to these interrogatories, state with particularity the basis for the objection. ii I I- B. Definitiens: 1. "Tidbit" and "Rubin" mean Jeremy Rubin, individually and dfbia Tidbit, as well as ins evvners, efficers, directers, sharehelders, founders, managers, agents, servants, representatives, atterneys, cerperatiens, subsidiaries, affiliates, successers, assigns er any ether individual er entity acting er purperting te act en his behalf. 2. "Any" includes "all" and vice versa_ 3, "Access" means te instruct, cemmunicate with, stere data in, retrieve data frem, er etherwrse make use ef any reseurees ef a eemputer, cemputer system, er cemputer netwerlc 4. "Eitcein cede" means the seflwarc cede distributed and! er develeped by Tidbit that uses andfer causes users' cemputers te mine fer bitceins. 5. "Breach ef security" means unautherized access te electrenic files, media er data that cempremises the security, cenfidentiality er integrity ef data when access te the data has net been secured by er by any ether methed er technelegy that renders the data unreadable er unusable, Greed faith acquisitien cf data by an empleyec er agent cf Tidbit fer a legitimate business purpese is net a breach ef security, previded that the data is net used fer a purpese unrelated te the business er subject te further unautheriaed disclesure, 6. "Cemputer" shall be defined in aceerdancc with T, "Cencerning" means relating te pertaining te, referring te, describing, evidencing er censtitutingr 3. means any Decumcnt intended te transmit infennatien lncludin letters, memeranda, mail, faxes, "instant messa es," messa es," veice mail messages and netes, 9. "Decument" includes all writings, recerdings, drawings, graphs, charts, phetegraphs, phene recetds, cempact discs, videe cassettes, cernputer files, electrenicfmagnetic files ef any type and any ether data cempilatiens freer which inferrnatien can be ebtaincd and translated, if necessary, by use ef detectien devices inte reasenably usable term. It}. "Include" and "lncluding" shall be eenstrued as breadly as possible and shall mean "witheut limitatien". 1 1. "New Jersey" and *'State" shall refer te the State efbiew Jersey. i2. "Persen[s]" means any natural persen, individual, any business entity {whether partnership, cerperatien, limited liability cernpany er cerperatien, trust, estate, incerperated er unincorporated asscciaticn cr peraticn), any cr cnriiy and any lcgal cr ccnuncrcial cnrity crganized. 13. and "Ycur" rncan Tidbit and Rubin. 14. "Uscr" rncans any who uses a cr rncbilc dcyicc. 15. As uscd hcrcin, "all" and "cach" shall be as all and cach. 16. As uscd hcrcin, ccnjuncticns and "cr" shall be ccnjunctiycly and shall bc disjunctiycly tc c:-rclucic any within cf this Request. tn the singular incluuzlc the plural and tc plural includc singular. iy Identify all person[s] {other than attomeys) with whom the personfs] executing the Certification accompanying these answers consulted in the preparation of such answers. As to each identified person[s], identify the Interrogatory for which person[s] furnished information. State the fiill name of Tidbit (including corporate name and as well as its telephone number, date and state of incorporation (or organization}. Describe Tidbit's corporate structure and state the names of all parents, subsidiaries, divisions, affiliates, branches, joint ventures, franchises, operations under assumed names, websites, and entities over which it exercises supervision or control. For each such entity, describe its function or business purpose, and the nature of its relationship to Tidbit. Identify all officers, directors, principals and owners of Tidbit, and all shareholders with a 5% or more ownership of Tidbit, stating each shareholder's percentage of ownership. Identify your total number of employees and state your total annual revenue. Describe the services and products offered by you. Identify all customers of Tidbit and the services or products they purchased from you. Attach a copy of all contracts and' or agreements. 10. ll. 12. 13. Describe the method, manner and process your customers use the Eitcoin code, including the henefittfs) of the Brtcoin code to customers. Describe the henefit(s) of the Bitcoin code to users. Describe the henefit(s) you receive from having customers andfor websites utilize the Bitooin code, including transaction fees and newly minted hitcoins. Identify the person{s) who developed the Bitcoin code and produce all versions of the code. Provide contact information, including full name, address, e-mail address, and telephone numbers for the following individuals anrlfor handles: Oliver Song; Carolyn Kcking; Rubin', and any other person(s] associated with Tidbit andfor the Bitcoin code. 2 _a.r - la" Wfibfillfis utilised andfor were affected by the Biteoin code'? Identify all '31? URL and provide copies of all contracts and! or agreements with all website providers. 15. identify all persons whose computers were eaused to mine for Biteoins through the Biteoin eode, including: First and last name; Co) IP address; and Contaet information. 16. Identify all Biteoin wallet addresses associated with the Bitooin eode. For each Eiteoin further identify all iriformation, ineluding: first and last name; ttsername, alias or shortlink; fie) e~rnail address; and identifier. Produee all doeurnents in support of your response to this interrogatory. identify all website publishers, adsrertisers, andlor other third-parties with whom you have a oontraetual relationship. Attach a eopy of all eontraots. 13+ Does Tidbit review the privaeyr policies of' websites utilising the Bitooin oode? If so, deseribe the process and produce all documents and eorrespondenee in support of your response to this Interrogatory. 20. 21. 22. 23. 24. 1'5. Does Tidbit conduct qua} Bufitenters sndfor website all reviews and this lnterrogstorgr. a:fl?m utmfilflg the Bitcoin code? 'If so, describe the process for ocurnents and correspondence 111 support of your response to Id'311l1fY 311 instances where Titibit, its employees endfor websites utilizing the Bitcoin code consurner computers without express written authorization or accessed constuner computers beyond what was authorized. For each instance: "Describe the nature and purpose of the access; and Identify the source of the unauthorized access. Set fi:rI'tl1 end ntt:-sch a copy of all your pest and present privacy policies. Set forth attach a cop}; of all your past and present date retention policies. Set forth and 3 copy of all your past and present record destruction policies. Set forth and attach a copy of all your past and present data collection policies. Set forth and attach a copy of your past and present breech of security policies. -.I ll'; -- st-mpliauice sndior other reviews prior to I . What disclosures did Ticlbit provide website publishers sucffor Biteoin code users eoneeruiug Biteoin Identify any state or federal inquiries or Hf Whiflh 31'" aiflialfle} Tidhit. Attach a eopy of all doeuments and in your answer to this Interrogstorj,r. CERTIFICATION I hereby eertify that the statements made by are in the fureguing answers to Iutetrugaturies are true and eurreet tn the best uf my knowledge, and belief. I am aware that if any uf the fureguiug statements made by me are willfully false. I 3111 subjeet tu punishment fur euutempt uf Cnurt. Signature Dated: Name printecl