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/content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
Closings
part 124 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
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but Satoshi Nakamoto would know why it had been done. A. I do know why it's been done. Like I just said, I told you about the overflow for left shift and people were actually complaining about this as well. Most of the things have been turned on one by one in BSV, as we checked the code, so we've been rigorous in that, because some of the people in your team like to ensure that we are by checking for bugs, and most of those have been turne d on. That one I didn't realise had been missed. {G/6/50} - Fourth Expert Report of Mr Madden {Day8/163:3- 14} Q. And it has a key ID that we can see, which is CF1857E; do you see that? A. I do. Q. So there are two keys within this PGP key, right? A. I haven't worked on PGP for a long time, so I'll take your word for it. Q. Okay -- A. I used to know it much be tter. Q. But there's a primary key and a sub key, right? A. Yes. Q. And that's not at all unusual, right? Dr Wright does not appear to recall or understand Satoshi’s public PGP keys. Appendix B: Schedule of Transcript References 309 REFERENCE QUOTE COMMENT A. No. {L2/202.1/27} - OpenPGP Message Format document {G/6/50} - Fourth Expert Report of Mr Madden {Day8/168:1} - {Day8/170:11} Q. What it shows us is that Satoshi's PGP key, the primary key in his PGP key was designated as a signing key, right? A. No, it shows that it could be used as that. I noted that ea rlier. What I also said is you shouldn't be using the same keys. Q. It also identifies, doesn't it, that it couldn't be used -- the primary key could not be used as an encryption key, right? A. No, the algorithms are in there and it was used as an encryp tion key. Q. So -- A. As you well know. Q. If we could go then, if you don't mind, we'd better go back to {G/6/50}. Do you see that the primary key -- do you see the algorithm number? A. I do. Q. So it says "algo 17"; do you see that? A. I do. Q. "Algo 17" is associated -- it means that it's a DSA algorithm, right? A. Correct. Q. So that is a signing key, isn't it? A. No, it's more for code signing. So if you do an encrypted packet, you would encrypt and sign. Q. We just agreed DSA is not for encryption, is it? A. Like I just said, you use the two keys. You encrypt and sign. So if you wanted to do an encrypted to someone else or validate or have something else, it's a process of encrypt and sign. So that's how you would use that. Q. Sorry, you're not right, Dr Wright. The primary key her e is a signing key, the sub key, do you see the algorithm that's identified for that? It says "algo 16"? A. Yes. Dr Wright is refusing to accept the obvious truth that the primary key in Satoshi’s PGP key was designated as a signing key. Dr Wright is stating that he has not touched C++ since 2017, which is inconsistent with his first witness statement, paragraph 71 {E/1/15}, in which he states “… throughout my career, C++ has played a prominent role in various capacities. Although his current work primarily involves Python, because of its efficacy in higher level tasks, C++ continues to be an integral part of his coding knowledge and skills, underscoring its enduring relevance in his professional career.”. Appendix B: Schedule of Transcript References 310 REFERENCE QUOTE COMMENT Q. That's an ElGamal algorithm, isn't it? A. I don't remember each of the names of these off the top of my head. Q. Which is -- which would make it an encryption key, wouldn't it? A. ElGamal, yes. Q. So there are two keys here, one of which is a signing key and one of which is an encryption key? A. That's correct. Q. And can we go then to {CSW/1/46}. We should have paragraph 243 of your wi tness statement. You said: "The PGP ... is not a signing key." A. It isn't a signing key, it was used for encryption. Data was encrypted both from Malmi and from Gavin Andresen. Q. Dr Wright, it was set up as a signing key. The primary key in the PGP key was set up as a signing key, wasn't it? A. No, it was constructed automatically and it was never set up as a signing key. Do I remember each of the numbers in PGP any more? No. It's just like I did a lot of work between 2005 and 2008 to get up to speed on C and C programming for when I did Bitcoin and I don't any more. I haven't touched C++ since 2017. I have staff now and they do. So, do I remember it all? No. {Day8/171:11} - {Day8/172:2} Q. Come back to PGP, though. We've established that the primary key of this PGP key was a signing key, right? A. We've established that it's an automated system and that I didn't play around with a whole lot of settings. It wa s a key for encryption and that's what I used it for. Q. So had you signed with this PGP key, that would have been powerful evidence that you were Satoshi, wouldn't it? A. No. Q. You would have been able to sign with a key that was directly associated w ith him, wouldn't you? A. No. Once again, the server has been owned and re -owned from multiple people. A requirement for proving identity isn't that you hold a piece of data. If I was to have a key, I would have to have it in my possession and control the whole time. Dr Wright is implausibly denying that signing with Satoshi’s PGP key would have been powerful evidence that he was Satoshi. Appendix B: Schedule of Transcript References 311 REFERENCE QUOTE COMMENT {E/1/22} Dr Wright’s First Witness Statement {Day8/174:10} - {Day8/175:4} Q. -- that there were 69 computers. So that’s where you were spending the $11,000, right? 12 A. Something like that, yeah. I don’t have the exact amount. It was actually the -- there were -- the company paid for the three -phase power and
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 124 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: but Satoshi Nakamoto would know why it had been done. A. I do know why it's been done. Like I just said, I told you about the overflow for left shift and people were actually complaining about this as well. Most of the things have been turned on one by one in BSV, as we checked the code, so we've been rigorous in that, because some of the people in your team like to ensure that we are by checking for bugs, and most of those have been turne d on. That one I didn't realise had been missed. {G/6/50} - Fourth Expert Report of Mr Madden {Day8/163:3- 14} Q. And it has a key ID that we can see, which is CF1857E; do you see that? A. I do. Q. So there are two keys within this PGP key, right? A. I haven't worked on PGP for a long time, so I'll take your word for it. Q. Okay -- A. I used to know it much be tter. Q. But there's a primary key and a sub key, right? A. Yes. Q. And that's not at all unusual, right? Dr Wright does not appear to recall or understand Satoshi’s public PGP keys. Appendix B: Schedule of Transcript References 309 REFERENCE QUOTE COMMENT A. No. {L2/202.1/27} - OpenPGP Message Format document {G/6/50} - Fourth Expert Report of Mr Madden {Day8/168:1} - {Day8/170:11} Q. What it shows us is that Satoshi's PGP key, the primary key in his PGP key was designated as a signing key, right? A. No, it shows that it could be used as that. I noted that ea rlier. What I also said is you shouldn't be using the same keys. Q. It also identifies, doesn't it, that it couldn't be used -- the primary key could not be used as an encryption key, right? A. No, the algorithms are in there and it was used as an encryp tion key. Q. So -- A. As you well know. Q. If we could go then, if you don't mind, we'd better go back to {G/6/50}. Do you see that the primary key -- do you see the algorithm number? A. I do. Q. So it says "algo 17"; do you see that? A. I do. Q. "Algo 17" is associated -- it means that it's a DSA algorithm, right? A. Correct. Q. So that is a signing key, isn't it? A. No, it's more for code signing. So if you do an encrypted packet, you would encrypt and sign. Q. We just agreed DSA is not for encryption, is it? A. Like I just said, you use the two keys. You encrypt and sign. So if you wanted to do an encrypted to someone else or validate or have something else, it's a process of encrypt and sign. So that's how you would use that. Q. Sorry, you're not right, Dr Wright. The primary key her e is a signing key, the sub key, do you see the algorithm that's identified for that? It says "algo 16"? A. Yes. Dr Wright is refusing to accept the obvious truth that the primary key in Satoshi’s PGP key was designated as a signing key. Dr Wright is stating that he has not touched C++ since 2017, which is inconsistent with his first witness statement, paragraph 71 {E/1/15}, in which he states “… throughout my career, C++ has played a prominent role in various capacities. Although his current work primarily involves Python, because of its efficacy in higher level tasks, C++ continues to be an integral part of his coding knowledge and skills, underscoring its enduring relevance in his professional career.”. Appendix B: Schedule of Transcript References 310 REFERENCE QUOTE COMMENT Q. That's an ElGamal algorithm, isn't it? A. I don't remember each of the names of these off the top of my head. Q. Which is -- which would make it an encryption key, wouldn't it? A. ElGamal, yes. Q. So there are two keys here, one of which is a signing key and one of which is an encryption key? A. That's correct. Q. And can we go then to {CSW/1/46}. We should have paragraph 243 of your wi tness statement. You said: "The PGP ... is not a signing key." A. It isn't a signing key, it was used for encryption. Data was encrypted both from Malmi and from Gavin Andresen. Q. Dr Wright, it was set up as a signing key. The primary key in the PGP key was set up as a signing key, wasn't it? A. No, it was constructed automatically and it was never set up as a signing key. Do I remember each of the numbers in PGP any more? No. It's just like I did a lot of work between 2005 and 2008 to get up to speed on C and C programming for when I did Bitcoin and I don't any more. I haven't touched C++ since 2017. I have staff now and they do. So, do I remember it all? No. {Day8/171:11} - {Day8/172:2} Q. Come back to PGP, though. We've established that the primary key of this PGP key was a signing key, right? A. We've established that it's an automated system and that I didn't play around with a whole lot of settings. It wa s a key for encryption and that's what I used it for. Q. So had you signed with this PGP key, that would have been powerful evidence that you were Satoshi, wouldn't it? A. No. Q. You would have been able to sign with a key that was directly associated w ith him, wouldn't you? A. No. Once again, the server has been owned and re -owned from multiple people. A requirement for proving identity isn't that you hold a piece of data. If I was to have a key, I would have to have it in my possession and control the whole time. Dr Wright is implausibly denying that signing with Satoshi’s PGP key would have been powerful evidence that he was Satoshi. Appendix B: Schedule of Transcript References 311 REFERENCE QUOTE COMMENT {E/1/22} Dr Wright’s First Witness Statement {Day8/174:10} - {Day8/175:4} Q. -- that there were 69 computers. So that’s where you were spending the $11,000, right? 12 A. Something like that, yeah. I don’t have the exact amount. It was actually the -- there were -- the company paid for the three -phase power and
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/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM14.pdf
Patrick Madden
part 13 of 19 Appendix PM14.pdf
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the right is outside of the picture box, which led me to consider that it would be worthwhile to conduct a deeper image analysis asfollows. 119. St arting with the signature, by zooming in on the section, it can be seen that there are two different pixelation quality level s in that section . {H/29} {ID_001926} {ID_001925} {ID_001930} {ID_001925} {ID_001925} Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422, 1561, 1515, 1524, 1921, 1941 (compare 1904), 1940 (and 3706) Page 44 of 74 120. I next zoomed in on the text area and examined the content of the words as it i s di splayed there. I show below the view specifically around the word “Killara” towards the top right of the page. I observed that there is some degraded pixelization after the end of the word, forming a corona or shadow around the letters as is difficul t t o see in the screenshot below (and may be impossible to see in a printed version): a.I have used Paint.net software to adjust the luminosity in order to greater expose th e p ixelation , shown in the screenshot below: Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422, 1561, 1515, 1524, 1921, 1941 (compare 1904), 1940 (and 3706) Page 45 of 74 b. T his type of blemish is caused by “ Anti -Aliasing ”: c.Anti-aliasing is a graphical smoothing technique to smooth sharp edges, by addin g ( usually faint) greyscale pixels around sharp lines. d.This is used in many computer graphics context but in scanned documents, it redu ces t he apparent pixelation effect that can occur when scanning text making it more legible to the human eye . e.T o give an example, this can be seen in the diagram below which is taken from https://3dprint.com/253260/what- is-metrology -part-17-antialiasing/ : f.A s can be seen there, the un -smoothed diagonal line is very crisp but after antialiasi ng i s applied, a corona or shadow of grey is visible around the edges . 121. G enerally, when text is scanned, anti- aliased, and then OCR is used on the resulti ng i mage (in Adobe, called the “Recognize Text” function), the smooth antialiasing shadows Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422, 1561, 1515, 1524, 1921, 1941 (compare 1904), 1940 (and 3706) Page 46 of 74 are not always ‘recognised’ as forming part of the letters, meaning that when the letters are edited or deleted shadows can remain afterwards. 122. T hese are often not visible to the human eye without sharpening the image, at which point they become exposed. 123. T he result of this is that when text is edited in a scanned document, it is sometimes possible to find shadows of previous text embe dded within it – as in ID_001925 a nd I D_001930 – which are normally invisible but which are nevertheless digitally present. a.C ontinuing with my analysis of ID_001925, I next used the utility “Winking PDF Analyser” to extract embedded graphic files from the PDF file . This resulted in two images being extracted: b.T he first extracted graphic matched with the Signature block graphics item mentioned above and shown the below in its extracted form (with border added): 124. I t can therefore be seen that most of the signature block was added to the document as a g raphic file, with the missing curl on the right side possibly having been added b y di fferent means . This may explain the different pixelation level that I showed above , t hough this is simply setting out the observation at this stage of the analysis and is not a conclusion. 125. T he second graphic item was the same size as the entire page. It was a graphical layer sitting behind the text, which contained an anti-aliasing corona of all the original textfrom the page . {ID_00192 5} {ID_00193 0} {ID_00192 5} Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422,
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 13 of 19 Appendix PM14.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM14.pdf ### File content: the right is outside of the picture box, which led me to consider that it would be worthwhile to conduct a deeper image analysis asfollows. 119. St arting with the signature, by zooming in on the section, it can be seen that there are two different pixelation quality level s in that section . {H/29} {ID_001926} {ID_001925} {ID_001930} {ID_001925} {ID_001925} Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422, 1561, 1515, 1524, 1921, 1941 (compare 1904), 1940 (and 3706) Page 44 of 74 120. I next zoomed in on the text area and examined the content of the words as it i s di splayed there. I show below the view specifically around the word “Killara” towards the top right of the page. I observed that there is some degraded pixelization after the end of the word, forming a corona or shadow around the letters as is difficul t t o see in the screenshot below (and may be impossible to see in a printed version): a.I have used Paint.net software to adjust the luminosity in order to greater expose th e p ixelation , shown in the screenshot below: Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422, 1561, 1515, 1524, 1921, 1941 (compare 1904), 1940 (and 3706) Page 45 of 74 b. T his type of blemish is caused by “ Anti -Aliasing ”: c.Anti-aliasing is a graphical smoothing technique to smooth sharp edges, by addin g ( usually faint) greyscale pixels around sharp lines. d.This is used in many computer graphics context but in scanned documents, it redu ces t he apparent pixelation effect that can occur when scanning text making it more legible to the human eye . e.T o give an example, this can be seen in the diagram below which is taken from https://3dprint.com/253260/what- is-metrology -part-17-antialiasing/ : f.A s can be seen there, the un -smoothed diagonal line is very crisp but after antialiasi ng i s applied, a corona or shadow of grey is visible around the edges . 121. G enerally, when text is scanned, anti- aliased, and then OCR is used on the resulti ng i mage (in Adobe, called the “Recognize Text” function), the smooth antialiasing shadows Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422, 1561, 1515, 1524, 1921, 1941 (compare 1904), 1940 (and 3706) Page 46 of 74 are not always ‘recognised’ as forming part of the letters, meaning that when the letters are edited or deleted shadows can remain afterwards. 122. T hese are often not visible to the human eye without sharpening the image, at which point they become exposed. 123. T he result of this is that when text is edited in a scanned document, it is sometimes possible to find shadows of previous text embe dded within it – as in ID_001925 a nd I D_001930 – which are normally invisible but which are nevertheless digitally present. a.C ontinuing with my analysis of ID_001925, I next used the utility “Winking PDF Analyser” to extract embedded graphic files from the PDF file . This resulted in two images being extracted: b.T he first extracted graphic matched with the Signature block graphics item mentioned above and shown the below in its extracted form (with border added): 124. I t can therefore be seen that most of the signature block was added to the document as a g raphic file, with the missing curl on the right side possibly having been added b y di fferent means . This may explain the different pixelation level that I showed above , t hough this is simply setting out the observation at this stage of the analysis and is not a conclusion. 125. T he second graphic item was the same size as the entire page. It was a graphical layer sitting behind the text, which contained an anti-aliasing corona of all the original textfrom the page . {ID_00192 5} {ID_00193 0} {ID_00192 5} Appendix PM 14 Tulip Trust/ID_001930, 1932, 1940, 3706, 1421, 1422,
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Closings
part 12 of 82 COPA's Closing Submissions.pdf
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was the background leading up to it? Were there prior attempts that failed? Some of the human aspects and conflicts will be important, as well… knowledge of / interactions with DPR and others and related sites that rose to prominence in ass ociation? What security measures were taken to preserve SN’s anonymity? Why? Background on the origins of the pseudonym itself. Interactions with the inevitable shady groups and interesting characters. Inception of the super - computer and why. Why ther e? How did you convince them? Etcetera, etcetera .” The email from Mr MacGregor then turned to the “proof package”: “Finally, we’ll need to consider the “proof package” to establish SN’s identity. There will be the package that will be required by non- technical audiences (notes, etc. that document and evidence creation), but also some decisions as to how to definitively establish SN’s pedigree technically. Some of SN’s wallets are publicly known, correct? Craig, I will need you to walk me through how this could be leveraged if and when the time comes. Could SN activate and move a coin within one of these wallets? What would be sufficient proof from a technical perspective in your view?” 83. Dr Wright then answered the above questions by way of an email from his wife.111 That response included Dr Wright’s claim to have been influenced by Wei Dai’s work since the late 1990s (a claim which Dr Wright has since repeated but which, as set out below, could not be true for the real Satoshi Nakamoto). Ms Watts’ email attached a timeline, which also featured elements of the story Dr Wright has told since then.112 110 {L10/424/2} and over the page to {L10/424/3}. 111 {L10/424/1} . 112 {L10/425} , named “Timeline.docx” . 31 84. In an email dated 24 November 2015,113 from Mr MacGregor to Dr Wright (copying Mr Ayre and Mr Matthews amongst others), he said that he had met Baker McKenzie that morning, and again, referred to the “proof packet” being needed at item 5: “(5) We’re going to need to create a “proof packet” before too much longer. I’ve been thinking about this and have a couple of ideas. Activating the SN wallets goes a long way, but all it really proves is that someone is in control of SN’s private keys, which could, obviously, have been transferred or acquired otherwise. The keys, plus the documentation substantiating and documenting the original pre -publication research will be enough for 99% of the world, but we will want everything in a data room quite soon for assessment and forensic analysis if possible. Ideally, we identify a very, very credible blockchain “insider” (I’m sure you already know the shortlist directly, Craig) and then bring him/her under NDA and then into the data room. We need at least one extremely credible third party that can have examined the data room, the research, and spoken with Craig, so that in addition to the packet we have the voice of a trusted community member substantiating when the time comes .” 85. Dr Wright denied the authenticity of this email too, in the following exchange:114 “Q. Well, this one refers, at item (5), to Mr MacGregor proposing creation of a proof package -- proof packet rather, inc luding establishing control of Satoshi Nakamoto's private keys and so on. Was that being discussed by that stage, 24 November 2015? A. God, no. There's no way on earth I'd give over my damn private keys to someone. Q. No, but was that being discussed by Mr MacGregor at that stage? A. I don't know what he was discussing. I mean, honestly, if I'm not the person receiving it and it's a thing set up as Craig Wright and his company, no idea.” 86. Dr Wright responded to Mr MacGregor’s email of 24 November 2015 within 24 hours,115 giving the names of some people who could be used for the signing sessions. These included “Adam Black” (which appears twice and is a mistake Dr Wright made elsewhere, clearly getting Dr Back’s name wrong). This message also said th at “Stefan has copies of the Bitmessage and also pgp keys ”. No such Bitmessage or PGP keys have been put forward as supportive evidence.116 113 {L11/55/2} . 114 {Day7/108:22} - {Day7/109:8} . 115 {L11/55/1} . 116 No doubt the reason that Bitmessage keys were not tendered as evidence in these proceedings is that Dr Wright had come unstuck in the Kleiman proceedings, after being confronted with the origins of Bitmessage. That was first proposed at the end of 2012, in a white pape r that is in every respect a clear homage to the work Satoshi Nakamoto (and not the other way around): see {L8/49/2}. Satoshi's real PGP keys are addressed below. 32 87. As noted above, Dr Wright disavows all these emails, because they do not fit with his narrative of Mr MacGregor forcing him reluctantly into the “Big Reveal” process after the WIRED and Gizmodo articles had been published. However, it is clear from their contents that they are genuine emails, and Dr Wright’s one reason for rejecting them (i.e. that he was never employ ed by Tyche Consulting) is plainly false. 88. Mr Matthews similarly accused Mr MacGregor of bullying Dr Wright and forcing him to participate in the public revelation of his claim to be Satoshi Nakamoto. As explained below, Mr Matthews’ account is also unre liable, since (contrary to his repeated statements) the emails tell a story of Mr MacGregor working co -operatively with both Mr Matthews and Dr Wright through early 2016. However, it is telling that Mr Matthews did not disavow the emails which Dr Wright r ejects and that Mr Matthews insisted that Dr Wright was employed by Tyche Consulting. 117 89. Mr Matthews went still further, offering a detailed narrative of the reasons for, documents relating to, and terms of Dr Wright's engagement with Tyche, even confirming Dr Wright’s signature on the contract of employment.118 In another example, Mr Matthews carefully looked over an email (which had been refuted by Dr Wright when it was presented to him), 119 and not only accepted it to be genuine but confirmed the subject matter of the references being made, and volunteered sign ificant details corroborating of the content of those emails against oral discussions he had with Dr Wright. These included the anchoring details that Dr Wright made a particular request for Mr Matthews to call his ex -wife asking if she had photographs of the “server racks in the farm” – a call which Mr Matthews remembered making.120 The EITC Agreement of February
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 12 of 82 COPA's Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/COPA's Closing Submissions.pdf ### File content: was the background leading up to it? Were there prior attempts that failed? Some of the human aspects and conflicts will be important, as well… knowledge of / interactions with DPR and others and related sites that rose to prominence in ass ociation? What security measures were taken to preserve SN’s anonymity? Why? Background on the origins of the pseudonym itself. Interactions with the inevitable shady groups and interesting characters. Inception of the super - computer and why. Why ther e? How did you convince them? Etcetera, etcetera .” The email from Mr MacGregor then turned to the “proof package”: “Finally, we’ll need to consider the “proof package” to establish SN’s identity. There will be the package that will be required by non- technical audiences (notes, etc. that document and evidence creation), but also some decisions as to how to definitively establish SN’s pedigree technically. Some of SN’s wallets are publicly known, correct? Craig, I will need you to walk me through how this could be leveraged if and when the time comes. Could SN activate and move a coin within one of these wallets? What would be sufficient proof from a technical perspective in your view?” 83. Dr Wright then answered the above questions by way of an email from his wife.111 That response included Dr Wright’s claim to have been influenced by Wei Dai’s work since the late 1990s (a claim which Dr Wright has since repeated but which, as set out below, could not be true for the real Satoshi Nakamoto). Ms Watts’ email attached a timeline, which also featured elements of the story Dr Wright has told since then.112 110 {L10/424/2} and over the page to {L10/424/3}. 111 {L10/424/1} . 112 {L10/425} , named “Timeline.docx” . 31 84. In an email dated 24 November 2015,113 from Mr MacGregor to Dr Wright (copying Mr Ayre and Mr Matthews amongst others), he said that he had met Baker McKenzie that morning, and again, referred to the “proof packet” being needed at item 5: “(5) We’re going to need to create a “proof packet” before too much longer. I’ve been thinking about this and have a couple of ideas. Activating the SN wallets goes a long way, but all it really proves is that someone is in control of SN’s private keys, which could, obviously, have been transferred or acquired otherwise. The keys, plus the documentation substantiating and documenting the original pre -publication research will be enough for 99% of the world, but we will want everything in a data room quite soon for assessment and forensic analysis if possible. Ideally, we identify a very, very credible blockchain “insider” (I’m sure you already know the shortlist directly, Craig) and then bring him/her under NDA and then into the data room. We need at least one extremely credible third party that can have examined the data room, the research, and spoken with Craig, so that in addition to the packet we have the voice of a trusted community member substantiating when the time comes .” 85. Dr Wright denied the authenticity of this email too, in the following exchange:114 “Q. Well, this one refers, at item (5), to Mr MacGregor proposing creation of a proof package -- proof packet rather, inc luding establishing control of Satoshi Nakamoto's private keys and so on. Was that being discussed by that stage, 24 November 2015? A. God, no. There's no way on earth I'd give over my damn private keys to someone. Q. No, but was that being discussed by Mr MacGregor at that stage? A. I don't know what he was discussing. I mean, honestly, if I'm not the person receiving it and it's a thing set up as Craig Wright and his company, no idea.” 86. Dr Wright responded to Mr MacGregor’s email of 24 November 2015 within 24 hours,115 giving the names of some people who could be used for the signing sessions. These included “Adam Black” (which appears twice and is a mistake Dr Wright made elsewhere, clearly getting Dr Back’s name wrong). This message also said th at “Stefan has copies of the Bitmessage and also pgp keys ”. No such Bitmessage or PGP keys have been put forward as supportive evidence.116 113 {L11/55/2} . 114 {Day7/108:22} - {Day7/109:8} . 115 {L11/55/1} . 116 No doubt the reason that Bitmessage keys were not tendered as evidence in these proceedings is that Dr Wright had come unstuck in the Kleiman proceedings, after being confronted with the origins of Bitmessage. That was first proposed at the end of 2012, in a white pape r that is in every respect a clear homage to the work Satoshi Nakamoto (and not the other way around): see {L8/49/2}. Satoshi's real PGP keys are addressed below. 32 87. As noted above, Dr Wright disavows all these emails, because they do not fit with his narrative of Mr MacGregor forcing him reluctantly into the “Big Reveal” process after the WIRED and Gizmodo articles had been published. However, it is clear from their contents that they are genuine emails, and Dr Wright’s one reason for rejecting them (i.e. that he was never employ ed by Tyche Consulting) is plainly false. 88. Mr Matthews similarly accused Mr MacGregor of bullying Dr Wright and forcing him to participate in the public revelation of his claim to be Satoshi Nakamoto. As explained below, Mr Matthews’ account is also unre liable, since (contrary to his repeated statements) the emails tell a story of Mr MacGregor working co -operatively with both Mr Matthews and Dr Wright through early 2016. However, it is telling that Mr Matthews did not disavow the emails which Dr Wright r ejects and that Mr Matthews insisted that Dr Wright was employed by Tyche Consulting. 117 89. Mr Matthews went still further, offering a detailed narrative of the reasons for, documents relating to, and terms of Dr Wright's engagement with Tyche, even confirming Dr Wright’s signature on the contract of employment.118 In another example, Mr Matthews carefully looked over an email (which had been refuted by Dr Wright when it was presented to him), 119 and not only accepted it to be genuine but confirmed the subject matter of the references being made, and volunteered sign ificant details corroborating of the content of those emails against oral discussions he had with Dr Wright. These included the anchoring details that Dr Wright made a particular request for Mr Matthews to call his ex -wife asking if she had photographs of the “server racks in the farm” – a call which Mr Matthews remembered making.120 The EITC Agreement of February
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of Patrick Madden Page 48 of 98 48interacted with by the user and which is receiving input. The term “ In f ocus ” refers to the window that is currently receiving keyboar d input (and is invariably the same as the Active window). b. It does not matter whether a user actually types into or makes changes to the document, as the Edit T ime will increase regardless. c.If a second document open in MS Word is switched to, then the Ed it Time of that second document will increase instead of the first, until switched back. “Switching to ” a window is the process of changing the active window, usually by clicking or pressing Alt- Tab. d.I emphasise that the document Edit Time increases depending on the window that was last active / in focus in MS Word . It is not affected by using different applications alongside it, so for example if a web browser is switched to and typed into while a document is open in MS Word in the background, the Edit Time property for that MS Word document will continue to increase until the document is closed or until another different MS Word document is switchedto. e.I ha ve referred to this in my report as “exclusive use" for the purpose of document editing in Word. 137. Cer tain other activity can cause the Edit Time to increase: a.If a document is saved and then re -saved, it can cause the Edit Time property to increase by 1 minute even if the time between them is less than 1 minute . b. If the operating system clock suddenly jumps from one time to another between saves while an MS Word document is the most recently activedocument, that will usually cause the Edit Time property to jump with it, and record as i f the whole intervening time had been spent editing. Sudden jumps in clock time can occur i f a computer is hibernated (a method of turning off a computer so that the user session is saved, and then restored at the point it isturned back on). They can also occur if a computer clock setting is deliberatelyedited , as I explain in detail later on in this Main Report. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 49 of 98 49138. It should therefore be impossible for two MS Word documents to record Edit Times that overlap with one another, if they are edited on the same device. In the present case, I have not been provided with detailed information about the source devices of any documents (although I understand that this was requested ), so have proceeded on the basis that documents that are similar in character and bear similar user data and other metadata are likely to have been created or edited on the same machine. 139. I cau tion that while other documents such as MS Powerpoint have similar -looking Edit Time metadata fields, the way they record metadata can be very differ ent and this analysis should not be applied to other similar looking fields outside MS Word. DOC and DOCX as “compound files” 140. Though saved as single files, both DOC and DOCX files are in fact “compound files” made up of various constituent parts (as are ma ny other file types). This is similar in concept to a ZIP file, whereby one single file is actually a container for copies of multiple other parts within it. 141. Whe n a DOC or DOCX file is opened, it is actually opening a container that holds the different parts. These can include parts relating to the main document content, formatting information,images and objects embedded within the document, and components relating to metadatainformation alone. 142. To illustrate the various files and directories within a DOCX compound file, the view below shows the view of this report document itself when the DOCX is opened in an archive viewer(in this case the widely -used viewer 7-ZIP, though other viewers such as WinZip could also be used): DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 50 of 98 50The various constituent parts of this report document, including XML images, directories and other files, as viewed within an archive viewer 143. In s ome cases, MS Word documents can also contain old, partial embedded files from previous drafts of the document, such as Z IP-encoded files which themselves contain additional data not readily viewable. When it is possible to identify and isolate these, viewing those files can provide insights into the history of the document’s creation. OpenOffice 144. OpenOffice.org (“ OOo ”) is a suite of office software very similar in functionality to MS Office, but which is open-source and freely distributed. It contains various applications withinit, such as “OOo Writer” (equivalent to MS Word), “OOo Calc” (equivalent to MS Excel),“OOo Math” (a tool for creating mathematical formulas) and “OOo Impress” (equivalent to MSPowerpoint). 145. Of these , only the OOo Writer application is relevant to my analysis so I do not address other parts of the OOo suite. The file format mainly used by OOo Writer is “ODT” (standing for“Open Document Text”), which is equivalent to MS Word .DOC or .DOCX files. OOo Writer is also compatible with use and editing of . DOC and .DOCX files. 146. Ope nOffice ODT files are also compound documents, very similarly to the examples shown above, though they use different constituent parts. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 51 of 98 51147. I have analysed two specific ODT documents from the disclosure dataset, ID_000254 and ID _000260, and address the above topics in more detail in the course of the rel evant Appendices. Emails and different formats 148. There have been many email files provided within the disclosure dataset which I have analysed. 149. Va rious file formats used for storing emails include MBOX, EML, PST, and MSG . These all relate to emails, but they differ in their structure and the software applications that support them : a.MBO X is a file format used for storing multiple email messages in a single file. Multiple messages are stored sequentially, separated by blank lines, with metadata and header information included alongside each email. MBOX was originally developed forUnix and Linux systems and is an open format, which has since become much morewidely supported. Attachments may be embedded within MBOX files. b.EML is a file format used f or storing email messages as individual files. It is different to MBOX because each message is stored as a separate file, usually with a . EML file extension. EML files contain the entire message, including the header information.Attachments may be embedded in each file. c.PST ( also OST) is an Outlook Data File, a file format used by Microsoft Outlook to store email messages, contacts, calendar items, tasks, notes and other data. Within Outlook, emails are typically stored together in a single PST file rela ting to each account in use,
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 16 of 27 First Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/First Expert Report of Patrick Madden.pdf ### File content: of Patrick Madden Page 48 of 98 48interacted with by the user and which is receiving input. The term “ In f ocus ” refers to the window that is currently receiving keyboar d input (and is invariably the same as the Active window). b. It does not matter whether a user actually types into or makes changes to the document, as the Edit T ime will increase regardless. c.If a second document open in MS Word is switched to, then the Ed it Time of that second document will increase instead of the first, until switched back. “Switching to ” a window is the process of changing the active window, usually by clicking or pressing Alt- Tab. d.I emphasise that the document Edit Time increases depending on the window that was last active / in focus in MS Word . It is not affected by using different applications alongside it, so for example if a web browser is switched to and typed into while a document is open in MS Word in the background, the Edit Time property for that MS Word document will continue to increase until the document is closed or until another different MS Word document is switchedto. e.I ha ve referred to this in my report as “exclusive use" for the purpose of document editing in Word. 137. Cer tain other activity can cause the Edit Time to increase: a.If a document is saved and then re -saved, it can cause the Edit Time property to increase by 1 minute even if the time between them is less than 1 minute . b. If the operating system clock suddenly jumps from one time to another between saves while an MS Word document is the most recently activedocument, that will usually cause the Edit Time property to jump with it, and record as i f the whole intervening time had been spent editing. Sudden jumps in clock time can occur i f a computer is hibernated (a method of turning off a computer so that the user session is saved, and then restored at the point it isturned back on). They can also occur if a computer clock setting is deliberatelyedited , as I explain in detail later on in this Main Report. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 49 of 98 49138. It should therefore be impossible for two MS Word documents to record Edit Times that overlap with one another, if they are edited on the same device. In the present case, I have not been provided with detailed information about the source devices of any documents (although I understand that this was requested ), so have proceeded on the basis that documents that are similar in character and bear similar user data and other metadata are likely to have been created or edited on the same machine. 139. I cau tion that while other documents such as MS Powerpoint have similar -looking Edit Time metadata fields, the way they record metadata can be very differ ent and this analysis should not be applied to other similar looking fields outside MS Word. DOC and DOCX as “compound files” 140. Though saved as single files, both DOC and DOCX files are in fact “compound files” made up of various constituent parts (as are ma ny other file types). This is similar in concept to a ZIP file, whereby one single file is actually a container for copies of multiple other parts within it. 141. Whe n a DOC or DOCX file is opened, it is actually opening a container that holds the different parts. These can include parts relating to the main document content, formatting information,images and objects embedded within the document, and components relating to metadatainformation alone. 142. To illustrate the various files and directories within a DOCX compound file, the view below shows the view of this report document itself when the DOCX is opened in an archive viewer(in this case the widely -used viewer 7-ZIP, though other viewers such as WinZip could also be used): DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 50 of 98 50The various constituent parts of this report document, including XML images, directories and other files, as viewed within an archive viewer 143. In s ome cases, MS Word documents can also contain old, partial embedded files from previous drafts of the document, such as Z IP-encoded files which themselves contain additional data not readily viewable. When it is possible to identify and isolate these, viewing those files can provide insights into the history of the document’s creation. OpenOffice 144. OpenOffice.org (“ OOo ”) is a suite of office software very similar in functionality to MS Office, but which is open-source and freely distributed. It contains various applications withinit, such as “OOo Writer” (equivalent to MS Word), “OOo Calc” (equivalent to MS Excel),“OOo Math” (a tool for creating mathematical formulas) and “OOo Impress” (equivalent to MSPowerpoint). 145. Of these , only the OOo Writer application is relevant to my analysis so I do not address other parts of the OOo suite. The file format mainly used by OOo Writer is “ODT” (standing for“Open Document Text”), which is equivalent to MS Word .DOC or .DOCX files. OOo Writer is also compatible with use and editing of . DOC and .DOCX files. 146. Ope nOffice ODT files are also compound documents, very similarly to the examples shown above, though they use different constituent parts. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 51 of 98 51147. I have analysed two specific ODT documents from the disclosure dataset, ID_000254 and ID _000260, and address the above topics in more detail in the course of the rel evant Appendices. Emails and different formats 148. There have been many email files provided within the disclosure dataset which I have analysed. 149. Va rious file formats used for storing emails include MBOX, EML, PST, and MSG . These all relate to emails, but they differ in their structure and the software applications that support them : a.MBO X is a file format used for storing multiple email messages in a single file. Multiple messages are stored sequentially, separated by blank lines, with metadata and header information included alongside each email. MBOX was originally developed forUnix and Linux systems and is an open format, which has since become much morewidely supported. Attachments may be embedded within MBOX files. b.EML is a file format used f or storing email messages as individual files. It is different to MBOX because each message is stored as a separate file, usually with a . EML file extension. EML files contain the entire message, including the header information.Attachments may be embedded in each file. c.PST ( also OST) is an Outlook Data File, a file format used by Microsoft Outlook to store email messages, contacts, calendar items, tasks, notes and other data. Within Outlook, emails are typically stored together in a single PST file rela ting to each account in use,
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to the differences between the document and the control version of the White Paper.348 204.4. A further touchup textedit tag was found which referenced Dr Wright’s contact details at nChain, a company which did not exist in 2008/9. 204.5. Metadata showed reference to Dr Wright’s details at nChain (which of course he did not join for many years). 204.6. Font files were embedded that included 2017 copyright notices. 204.7. There were internal metadata streams which recorded contradictory timestamps, consis tent with clock manipulation or hex editing of the timestamps. (10) King2.r tf [ID _004695] – PM46 {H/278/4} 205. This is a document which presents as an article on network security, involving discussion of quorum systems, work on which Dr Wright says fed into Bitcoin. It is a Rich Text File created with the editor version associated with the May 2020 update of Windows 10.349 It did not exist in this form before 17 September 2023, and was modified at some point between that date and 19 September 2023 with the computer set back to 2007.350 A precursor version was included in a deleted image (InfoDef09.raw ) and that deleted version was recovered. It showed (a) indications that “Craig S Wright” was the author and the operator of the software in use; (b) a timestamp dating its creation to 12 347 See the illustrative comparison document at Exhibit PM3.6 {H/26/3} . 348 See the illustrative comparison document at Exhibit PM3.7 {H/27/1} . 349 Madden 3, §86-91 {G/5/34} . 350 See Appendix PM46, §12 {H/278/4} . 81 September 2023 and a Grammarly tag with the same date; and (b) a reference to Zotero software version 6.02.27, which was not released until 5 September 2023. Dr Wright’s Excuses and Changes of Story 206. Dr Wright has a track record of excuses, both in this litigation and in his other cases, for why he has been so unfortunate in repeatedly having found himself in possession of, and deploying, documents which turn out to be forged. The common theme is that the excuses are only produced after he has been found out. Dr Wright has blamed numerous others for the inauthenticity of his documents, ranging from potential alteration by staff members (alluded to repeatedly in the Chain of Custody Schedule) to the work of his lawyers (e.g. Ontier’s transmission of the MYOB records) and the unidentified Reddit source of the forged NAB screenshots. In addition, in his recent statements (notably Wright 9 to Wright 12), he has at great length sought to present his comple x operating systems as explaining signs of apparent document alteration. 207. However, Dr Wright has consistently failed to identify anomalies in documents before others have pointed them out. Given Dr Wright’s avowed expertise in forensic document examination and IT more generally, it would be surprising if he repeatedly produced key reliance documents for a series of important legal cases without noticing serious anomalies in them. His conduct and excuses must be assessed against that professed expertise: “So I used to work in digital forensics and I have written a textbook on the subject. I taught it with the New South Wales police college, and what I have to say is the KPMG methodology is not replicable. It is not scientific.” (Granath evidence351) “As somebody who designed multiple forensic certifications, published several books and founded methodologies used within the industry, I believe that the number of people in the forensic environment who have experience with this type of IT environment and the issues it can give rise to is smaller again .” (Wright 10352) Dr Wright ’s case must be that, despite this supposedly unparalleled expertise, he either (a) failed to notice any of the myriad problems with his documents pointed out in the Madden Report, or (b) noticed some, but chose not to mention them . 351 Transcript for 14 September 2022, internal p71 {O2/11/19} . 352 Wright 10, §6 {E/31/2 }. 82 208. Similarly, as explained above, in providing Chain of Custody information, Dr Wright originally simply presented himself as author and custodian, treating requests for intermediate custodian information as disproportionate. With the service of the Madden Report, he changed tack and produced the long and confusing Chain of Custody Schedule which suggests that numerous unnamed staff members might have altered documents .353 209. More generally, the service of the Madden Report is the watershed date in the procedural history of this case. It was Mr Madden’s exhaustive and detailed unpicking of Dr Wright’s Reliance Documents which has caused so many of Dr Wright’s changes in story. As explained above, this led to (a) the provision of the Chain of Custody Schedule and the Schedule of White Paper versions (CSW5), which suggested that many of the original Relian ce Documents could have been changed by others; (b) his “discovery” of the new documents on the BDO Drive and on his Overleaf account; and (c) the complex explanation of his operating systems in Wright 9 (Appendix A) and Wright 10, which suggested that features of those systems could account for apparent signs of document alteration and tampering. 210. The excuses provided in the Chain of Custody Schedule are addressed in more detail below. In short, the Schedule is internally inconsistent and unreliable, as demonstrated by Madden 2 and Appendices PM43 and PM44. It also takes a position which is at odds with previous chain of custody information (which simply presented Dr Wright as author and custodian). 211. The BDO Drive raw image has been shown to
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 36 of 51 COPA v Wright - Opening Skeleton of COPA.pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/COPA v Wright - Opening Skeleton of COPA.pdf ### File content: to the differences between the document and the control version of the White Paper.348 204.4. A further touchup textedit tag was found which referenced Dr Wright’s contact details at nChain, a company which did not exist in 2008/9. 204.5. Metadata showed reference to Dr Wright’s details at nChain (which of course he did not join for many years). 204.6. Font files were embedded that included 2017 copyright notices. 204.7. There were internal metadata streams which recorded contradictory timestamps, consis tent with clock manipulation or hex editing of the timestamps. (10) King2.r tf [ID _004695] – PM46 {H/278/4} 205. This is a document which presents as an article on network security, involving discussion of quorum systems, work on which Dr Wright says fed into Bitcoin. It is a Rich Text File created with the editor version associated with the May 2020 update of Windows 10.349 It did not exist in this form before 17 September 2023, and was modified at some point between that date and 19 September 2023 with the computer set back to 2007.350 A precursor version was included in a deleted image (InfoDef09.raw ) and that deleted version was recovered. It showed (a) indications that “Craig S Wright” was the author and the operator of the software in use; (b) a timestamp dating its creation to 12 347 See the illustrative comparison document at Exhibit PM3.6 {H/26/3} . 348 See the illustrative comparison document at Exhibit PM3.7 {H/27/1} . 349 Madden 3, §86-91 {G/5/34} . 350 See Appendix PM46, §12 {H/278/4} . 81 September 2023 and a Grammarly tag with the same date; and (b) a reference to Zotero software version 6.02.27, which was not released until 5 September 2023. Dr Wright’s Excuses and Changes of Story 206. Dr Wright has a track record of excuses, both in this litigation and in his other cases, for why he has been so unfortunate in repeatedly having found himself in possession of, and deploying, documents which turn out to be forged. The common theme is that the excuses are only produced after he has been found out. Dr Wright has blamed numerous others for the inauthenticity of his documents, ranging from potential alteration by staff members (alluded to repeatedly in the Chain of Custody Schedule) to the work of his lawyers (e.g. Ontier’s transmission of the MYOB records) and the unidentified Reddit source of the forged NAB screenshots. In addition, in his recent statements (notably Wright 9 to Wright 12), he has at great length sought to present his comple x operating systems as explaining signs of apparent document alteration. 207. However, Dr Wright has consistently failed to identify anomalies in documents before others have pointed them out. Given Dr Wright’s avowed expertise in forensic document examination and IT more generally, it would be surprising if he repeatedly produced key reliance documents for a series of important legal cases without noticing serious anomalies in them. His conduct and excuses must be assessed against that professed expertise: “So I used to work in digital forensics and I have written a textbook on the subject. I taught it with the New South Wales police college, and what I have to say is the KPMG methodology is not replicable. It is not scientific.” (Granath evidence351) “As somebody who designed multiple forensic certifications, published several books and founded methodologies used within the industry, I believe that the number of people in the forensic environment who have experience with this type of IT environment and the issues it can give rise to is smaller again .” (Wright 10352) Dr Wright ’s case must be that, despite this supposedly unparalleled expertise, he either (a) failed to notice any of the myriad problems with his documents pointed out in the Madden Report, or (b) noticed some, but chose not to mention them . 351 Transcript for 14 September 2022, internal p71 {O2/11/19} . 352 Wright 10, §6 {E/31/2 }. 82 208. Similarly, as explained above, in providing Chain of Custody information, Dr Wright originally simply presented himself as author and custodian, treating requests for intermediate custodian information as disproportionate. With the service of the Madden Report, he changed tack and produced the long and confusing Chain of Custody Schedule which suggests that numerous unnamed staff members might have altered documents .353 209. More generally, the service of the Madden Report is the watershed date in the procedural history of this case. It was Mr Madden’s exhaustive and detailed unpicking of Dr Wright’s Reliance Documents which has caused so many of Dr Wright’s changes in story. As explained above, this led to (a) the provision of the Chain of Custody Schedule and the Schedule of White Paper versions (CSW5), which suggested that many of the original Relian ce Documents could have been changed by others; (b) his “discovery” of the new documents on the BDO Drive and on his Overleaf account; and (c) the complex explanation of his operating systems in Wright 9 (Appendix A) and Wright 10, which suggested that features of those systems could account for apparent signs of document alteration and tampering. 210. The excuses provided in the Chain of Custody Schedule are addressed in more detail below. In short, the Schedule is internally inconsistent and unreliable, as demonstrated by Madden 2 and Appendices PM43 and PM44. It also takes a position which is at odds with previous chain of custody information (which simply presented Dr Wright as author and custodian). 211. The BDO Drive raw image has been shown to
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No, actually, Greg Maxwell and a few of the other COPA members contacted WIRED and put together what has already been debunked, false information, as well as some of this other stuff that they put together. So one of the people involved was Mr Greg Maxw ell - Q. I'm going to dispute - just to stop you on all of these allegations, Dr Wright. I've asked a simple question, which was that the article speculated that it might be an elaborate hoax. If we look page 13 {L11/212/13}, at the bottom, over to page 14 {L11/212/14}, we can see that it did speculate that, didn't it? A. No, it was changed after information came in to them. And it's not a speculation, Mr Maxwell actually published it. Dr Wright blaming third parties for the documents in the WIRED article, namely Greg Maxwell, and not accepting the obvious truth of the documents. {Day7/124:18} - {Day7/125:22} Q. You went to great efforts, didn't you, Dr Wright, to produce articles to try to rebut the suggestion that these keys were unreliable, didn't you? You produced papers and articles about it, didn't you? A. I produce papers every day. I've produced two pa pers today, I filed two yesterday. So, yes, I produced one. What I demonstrated was that he was wrong. What I noted was that he was basically out there slandering me for something that was completely false. Q. You now say, don't you, that many, or most, or all of the pieces of evidence that WIRED and Gizmodo had were fake or doctored, don't you? A. No, some were, some weren't; there was a mixture. But what happened was, they mixed the real evidence and tainted evidence so that all the real evidence is jus t tainted with the same brush now. Dr Wright provides an incoherent and implausible explanation in relation t o the evidence that WIRED and Gizmodo had, and blames third parties (Greg Maxwell). Appendix B: Schedule of Transcript References 239 REFERENCE QUOTE COMMENT Q. Well, Dr Wright, I suggest it's pretty extraordinary to go to great efforts to rebut Mr Maxwell's piece undermining keys which you don't say were your own anyway. A. No, one of them was mine. That's the whole point. There were one known key, one my key and three other keys, so the whole thing is you throw everything at the wall, like this whole case, and you hope something sticks. So, what happens is, you say that my key's also fabricated, as well as the other keys. S o you throw in three fabricated keys, two real keys, and then you can run round going, "See, they're all fabricated; don't look at these ones over here, don't look at the real one". {L11/285/1} -3. Implementation Deed 07 01 16 Final Fully Executed {Day7/126:8} - {Day7/127:23} Q. You physically moved with your family after these articles, didn't you. A. I physically moved before. My son started school here in July. My daughter started school shortly after that. My wife first came in September. I went in October. I came back to do the transitioning, then I came back here. So, we'd already found a house, we were living in a hotel at that point, but we were transitioning back and forwards. So my argument is, I'd already moved, I'd already become a resident. Q. Moving on to early 2016 at {L11/285/1}, please. Do you recall this document, an agreement being entered into with you, on Baker & McKenzie regalia, dated 7 January 2016? A. I mean, it's on a Baker & McKenzie letterhead, because they did it, but I don't actually know if I'd c all it "regalia". Q. Just focus on the document, please. {L11/285/3} was a document that, on its face, provides for the various elements of the term sheet you'd entered into in June 2015 to be brought into effect. Do you remember signing an agreement to t hat effect? A. Not the way you're describing it. The January document was changed quite a lot. Robert changed it significantly after all the WIRED and Gizmodo stuff came out. Q. What does Robert MacGregor have to do with this agreement? A. Stefan and St erling Group is only brokering it; Robert was the person doing it. NewCo was mostly - what do you call it - Rob MacGregor, and he was the person behind the deal. Dr Wright is asked about the Implementation Deed at {L11/285/1} and whether he entered into this, Dr Wright is overly pedantic in response but when pressed accepts that he entered into this agreement. Appendix B: Schedule of Transcript References 240 REFERENCE QUOTE COMMENT Q. So do you say that this isn't a genuine agreement, this document we're looking at here? A. No, it is an agreement, but if it's brokered by a company, that's still an agreement. And as you note, I have already got an address here in - well, at that point, Wimbledon. I'm not in Wimbledon any more. Q. Simple question: did you enter into an agree ment on the terms of this document? A. Like I just said, yes. {Day7/127:24} - {Day7/128:14} Q. Page 6 {L11/285/6}, we can see it included further provision on each aspect of the heads of terms, here for the IP asset purchase, yes? A. Correct. Q. Page 10 {L11/285/10}, section 7 addressed the rights and services agreement; do you see that? A. I do. Q. And clause 7.2(c) on the next page {L11/285/11}, said that you would also: “... in due course, enter into an additional services agreement with Ncrypt Holdings ... for completion of certain services relating to recounting and transcribing [your] history [ for ] $750,000 ...” A. I do. Q. So that was a term to which you agreed at that time? A. I didn’t really have much of a choice, but, yes. Dr Wright admitting that he agreed to clause 7.2(c), about entering into a services agreement for “ completion of certain services relating to recounting and transcribing [your] history…”. {L11/342/4} - Life Story Rights and Services Agreement {Day7/128:15} - {Day7/129:21} Q. And {L11/342/1}, "Life Story Rights and Services Agreement", between you and EITC Holdings Limited. Is this a genuine agreement into which you entered on 17 February 2016? A. It is. Q. And if we go to the final page of this document, which I think is either page 3 or page 4, we'll see the signatures.
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 96 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: No, actually, Greg Maxwell and a few of the other COPA members contacted WIRED and put together what has already been debunked, false information, as well as some of this other stuff that they put together. So one of the people involved was Mr Greg Maxw ell - Q. I'm going to dispute - just to stop you on all of these allegations, Dr Wright. I've asked a simple question, which was that the article speculated that it might be an elaborate hoax. If we look page 13 {L11/212/13}, at the bottom, over to page 14 {L11/212/14}, we can see that it did speculate that, didn't it? A. No, it was changed after information came in to them. And it's not a speculation, Mr Maxwell actually published it. Dr Wright blaming third parties for the documents in the WIRED article, namely Greg Maxwell, and not accepting the obvious truth of the documents. {Day7/124:18} - {Day7/125:22} Q. You went to great efforts, didn't you, Dr Wright, to produce articles to try to rebut the suggestion that these keys were unreliable, didn't you? You produced papers and articles about it, didn't you? A. I produce papers every day. I've produced two pa pers today, I filed two yesterday. So, yes, I produced one. What I demonstrated was that he was wrong. What I noted was that he was basically out there slandering me for something that was completely false. Q. You now say, don't you, that many, or most, or all of the pieces of evidence that WIRED and Gizmodo had were fake or doctored, don't you? A. No, some were, some weren't; there was a mixture. But what happened was, they mixed the real evidence and tainted evidence so that all the real evidence is jus t tainted with the same brush now. Dr Wright provides an incoherent and implausible explanation in relation t o the evidence that WIRED and Gizmodo had, and blames third parties (Greg Maxwell). Appendix B: Schedule of Transcript References 239 REFERENCE QUOTE COMMENT Q. Well, Dr Wright, I suggest it's pretty extraordinary to go to great efforts to rebut Mr Maxwell's piece undermining keys which you don't say were your own anyway. A. No, one of them was mine. That's the whole point. There were one known key, one my key and three other keys, so the whole thing is you throw everything at the wall, like this whole case, and you hope something sticks. So, what happens is, you say that my key's also fabricated, as well as the other keys. S o you throw in three fabricated keys, two real keys, and then you can run round going, "See, they're all fabricated; don't look at these ones over here, don't look at the real one". {L11/285/1} -3. Implementation Deed 07 01 16 Final Fully Executed {Day7/126:8} - {Day7/127:23} Q. You physically moved with your family after these articles, didn't you. A. I physically moved before. My son started school here in July. My daughter started school shortly after that. My wife first came in September. I went in October. I came back to do the transitioning, then I came back here. So, we'd already found a house, we were living in a hotel at that point, but we were transitioning back and forwards. So my argument is, I'd already moved, I'd already become a resident. Q. Moving on to early 2016 at {L11/285/1}, please. Do you recall this document, an agreement being entered into with you, on Baker & McKenzie regalia, dated 7 January 2016? A. I mean, it's on a Baker & McKenzie letterhead, because they did it, but I don't actually know if I'd c all it "regalia". Q. Just focus on the document, please. {L11/285/3} was a document that, on its face, provides for the various elements of the term sheet you'd entered into in June 2015 to be brought into effect. Do you remember signing an agreement to t hat effect? A. Not the way you're describing it. The January document was changed quite a lot. Robert changed it significantly after all the WIRED and Gizmodo stuff came out. Q. What does Robert MacGregor have to do with this agreement? A. Stefan and St erling Group is only brokering it; Robert was the person doing it. NewCo was mostly - what do you call it - Rob MacGregor, and he was the person behind the deal. Dr Wright is asked about the Implementation Deed at {L11/285/1} and whether he entered into this, Dr Wright is overly pedantic in response but when pressed accepts that he entered into this agreement. Appendix B: Schedule of Transcript References 240 REFERENCE QUOTE COMMENT Q. So do you say that this isn't a genuine agreement, this document we're looking at here? A. No, it is an agreement, but if it's brokered by a company, that's still an agreement. And as you note, I have already got an address here in - well, at that point, Wimbledon. I'm not in Wimbledon any more. Q. Simple question: did you enter into an agree ment on the terms of this document? A. Like I just said, yes. {Day7/127:24} - {Day7/128:14} Q. Page 6 {L11/285/6}, we can see it included further provision on each aspect of the heads of terms, here for the IP asset purchase, yes? A. Correct. Q. Page 10 {L11/285/10}, section 7 addressed the rights and services agreement; do you see that? A. I do. Q. And clause 7.2(c) on the next page {L11/285/11}, said that you would also: “... in due course, enter into an additional services agreement with Ncrypt Holdings ... for completion of certain services relating to recounting and transcribing [your] history [ for ] $750,000 ...” A. I do. Q. So that was a term to which you agreed at that time? A. I didn’t really have much of a choice, but, yes. Dr Wright admitting that he agreed to clause 7.2(c), about entering into a services agreement for “ completion of certain services relating to recounting and transcribing [your] history…”. {L11/342/4} - Life Story Rights and Services Agreement {Day7/128:15} - {Day7/129:21} Q. And {L11/342/1}, "Life Story Rights and Services Agreement", between you and EITC Holdings Limited. Is this a genuine agreement into which you entered on 17 February 2016? A. It is. Q. And if we go to the final page of this document, which I think is either page 3 or page 4, we'll see the signatures.
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document dating from 2008, contrary to fact. Dr Wright’s explanations should be rejected, for the followin g reasons: a. Mr Madden established in appendix PM44 that this document derived from {ID_000537}. Apart from the two documents sharing the irregular hyphenation in the title and other features of the title (including Dr Wright’s contact details at Charles Sturt Univers ity), they were found to be entirely identical on their face once {ID_000537} (a PDF document) was opened in MS Word and a footer removed. Although Dr Wright attempted to deny Mr Madden’s findings in his oral evidence while boasting of his own supposedly superior expertise ({Day4/13:11} to {Day4/17:25}, Mr Madden was not even challenged on these findings in cross - examination. b. The document at {ID_000537} contained numerous artefacts in its metadata which were indicative of backdating: a metadata reference t o an invalid version of XMP Core; Touchup_textedit history shared with {ID_000536}; a redundant metadata Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 96 of 167 field for creation date which matched that of the published (2009) version of the White Paper. See PM3 at paras. 133 -137. Dr Wright had no proper explanation for those anomalous artefacts in the source document. c. It follows from the above points that this document {ID_004011} is not a genuine prior draft of the Bitcoin White Paper, as Dr Wright has claimed it is (see Exhibit CSW5, row 22 {L19/257/5}. d. Dr Wright and Stefan Matthews have since 2015 claimed that Dr Wri ght gave Mr Matthews a copy of the Bitcoin White Paper in 2008 with a view to interesting him and his company, Centrebet, in the project. This document bears all the hallmarks of a document forged to provide false support for that story, in particular in that it has been given signs of age (coffee stains, etc) and the following notes have been added: “Stefan – Will Centrebet use a token that is transferable + audited” (p1) and “Stefan Matthews – Would Centrebet use this” (p8). There are other documents suggesting that this was the intention. Calvin Ayre has referred in a Tweet supporting Dr Wright that he had “old versions of the white paper… printed and with his notes and coffee on them and rusty staples” {L15/453/1}. According to an IRC log chat from S eptember 2017 excerpted in an article, Dr Wright claimed in that chat that Mr Matthews had a copy of the White Paper “complete with coffee stains” {L17/390/118}. e. Dr Wright’s cover story for this document relies upon his account that the Bitcoin White Paper and its precursor drafts were written in L ATEX. For the reasons given in detail in the expert report of Mr Rosendahl (and as agreed in the joint expert statement with Mr Lync h), that account is itself false. f. Dr Wright’s attempt to explain away the notes apparently addressed to Mr Matthews as notes for himself, at least one of which he said was written in 2019 as a note for the purposes of the Kleiman litigation, was not credible. These were notes addressed to Stefan, asking him if Centrebet could use the Bitcoin system. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 97 of 167 {ID_004013} / {L2/159/1} Handwritten BDO Minutes (Reliance Document) 1. The document presents as a set of minutes of a meeting attended by Dr Wright and Alan Granger, dated “Aug 07”, at BDO. It refers to “timechain”, “P2p ecash”, and “write paper”, as connected concepts to Dr Wright’s purported creation of Bitcoin, and presents as if it concerns planning for work to be done by Dr Wright and Mr Granger throughout 2007 and 2008. Reasons for Allegation of Forgery 2. The document is handwritten on a pre -printed pad that was manufactured in China. Bird & Bird has obtained a copy of the original PDF print proof document of the pad directly from the manufacturer. The copy of the original PDF proof document is an authentic document. [PM5 at 3- 17 and 25] 3. The handwritten document {ID_004013} perfectly matches the pre -printed template in the version of the PDF print proofs known as Exhibit MS1 (the first proof of the relevant notepad product). [PM5 at 17- 25] 4. The PDF print proofs known as Exhibit MS1, which this document matc hes, date from no earlier than 6 November to 9 November 2009. [PM5 at 3- 17 and 25] 5. The face- value date of August 2007 is therefore false and misleading. 6. Further, the purported notes of planning for work to be done throughout 2007 and 2008 are also therefo re false and misleading. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 7. Dr Wright has positively asserted that this is a document on which he primarily relies as supporting his claim to be Satoshi Nakamoto. 8. The effect of the tampering is to make the document appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto (i.e. as creating a document which suggests that Dr Wright was developing Bitcoin in 2007 and had shared details of his work with Mr Granger), contrary to fact. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 98 of 167 9. Dr Wright has relied on this document in previous proceedings, including on oath. 10. The document is in Dr Wright’s own handwriting. 11. In the document, Dr Wright has named himself as present at the purported meeting, in his own handwriting. 12. Dr Wright purports to have attended a meeting and taken these minutes himself. Dr Wright must know from his own experience that the meeting, and the purported minutes of the meeting, are false. 13. In his evidence in these proceedings, Dr Wright relies on a purported discussion of Bitcoin between him and Alan Granger, among other work done with Alan Granger around 2007. [ Wright 1 at 48- 52] 14. In his chain of custody information in these proceedings, Dr Wright claims to have drafted this document himself. 15. When disclosing this document, Dr Wright did not specify a date for the document. When requested to provide a date for thi s document, Dr Wright refused to do so. Dr Wright’s Explanations and COPA’s Rebuttal 16. In Appendix B to Wright 11, Dr Wright insisted that the document dated from August 2007. He disputed the evidence provided by COPA to the effect that the Quill minutes pad in this form was not produced as a proof until 2009 and was not printed and shipped until 2012 (see confirmation letter of Mr Stathakis and Ms
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 29 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### File content: document dating from 2008, contrary to fact. Dr Wright’s explanations should be rejected, for the followin g reasons: a. Mr Madden established in appendix PM44 that this document derived from {ID_000537}. Apart from the two documents sharing the irregular hyphenation in the title and other features of the title (including Dr Wright’s contact details at Charles Sturt Univers ity), they were found to be entirely identical on their face once {ID_000537} (a PDF document) was opened in MS Word and a footer removed. Although Dr Wright attempted to deny Mr Madden’s findings in his oral evidence while boasting of his own supposedly superior expertise ({Day4/13:11} to {Day4/17:25}, Mr Madden was not even challenged on these findings in cross - examination. b. The document at {ID_000537} contained numerous artefacts in its metadata which were indicative of backdating: a metadata reference t o an invalid version of XMP Core; Touchup_textedit history shared with {ID_000536}; a redundant metadata Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 96 of 167 field for creation date which matched that of the published (2009) version of the White Paper. See PM3 at paras. 133 -137. Dr Wright had no proper explanation for those anomalous artefacts in the source document. c. It follows from the above points that this document {ID_004011} is not a genuine prior draft of the Bitcoin White Paper, as Dr Wright has claimed it is (see Exhibit CSW5, row 22 {L19/257/5}. d. Dr Wright and Stefan Matthews have since 2015 claimed that Dr Wri ght gave Mr Matthews a copy of the Bitcoin White Paper in 2008 with a view to interesting him and his company, Centrebet, in the project. This document bears all the hallmarks of a document forged to provide false support for that story, in particular in that it has been given signs of age (coffee stains, etc) and the following notes have been added: “Stefan – Will Centrebet use a token that is transferable + audited” (p1) and “Stefan Matthews – Would Centrebet use this” (p8). There are other documents suggesting that this was the intention. Calvin Ayre has referred in a Tweet supporting Dr Wright that he had “old versions of the white paper… printed and with his notes and coffee on them and rusty staples” {L15/453/1}. According to an IRC log chat from S eptember 2017 excerpted in an article, Dr Wright claimed in that chat that Mr Matthews had a copy of the White Paper “complete with coffee stains” {L17/390/118}. e. Dr Wright’s cover story for this document relies upon his account that the Bitcoin White Paper and its precursor drafts were written in L ATEX. For the reasons given in detail in the expert report of Mr Rosendahl (and as agreed in the joint expert statement with Mr Lync h), that account is itself false. f. Dr Wright’s attempt to explain away the notes apparently addressed to Mr Matthews as notes for himself, at least one of which he said was written in 2019 as a note for the purposes of the Kleiman litigation, was not credible. These were notes addressed to Stefan, asking him if Centrebet could use the Bitcoin system. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 97 of 167 {ID_004013} / {L2/159/1} Handwritten BDO Minutes (Reliance Document) 1. The document presents as a set of minutes of a meeting attended by Dr Wright and Alan Granger, dated “Aug 07”, at BDO. It refers to “timechain”, “P2p ecash”, and “write paper”, as connected concepts to Dr Wright’s purported creation of Bitcoin, and presents as if it concerns planning for work to be done by Dr Wright and Mr Granger throughout 2007 and 2008. Reasons for Allegation of Forgery 2. The document is handwritten on a pre -printed pad that was manufactured in China. Bird & Bird has obtained a copy of the original PDF print proof document of the pad directly from the manufacturer. The copy of the original PDF proof document is an authentic document. [PM5 at 3- 17 and 25] 3. The handwritten document {ID_004013} perfectly matches the pre -printed template in the version of the PDF print proofs known as Exhibit MS1 (the first proof of the relevant notepad product). [PM5 at 17- 25] 4. The PDF print proofs known as Exhibit MS1, which this document matc hes, date from no earlier than 6 November to 9 November 2009. [PM5 at 3- 17 and 25] 5. The face- value date of August 2007 is therefore false and misleading. 6. Further, the purported notes of planning for work to be done throughout 2007 and 2008 are also therefo re false and misleading. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 7. Dr Wright has positively asserted that this is a document on which he primarily relies as supporting his claim to be Satoshi Nakamoto. 8. The effect of the tampering is to make the document appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto (i.e. as creating a document which suggests that Dr Wright was developing Bitcoin in 2007 and had shared details of his work with Mr Granger), contrary to fact. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 98 of 167 9. Dr Wright has relied on this document in previous proceedings, including on oath. 10. The document is in Dr Wright’s own handwriting. 11. In the document, Dr Wright has named himself as present at the purported meeting, in his own handwriting. 12. Dr Wright purports to have attended a meeting and taken these minutes himself. Dr Wright must know from his own experience that the meeting, and the purported minutes of the meeting, are false. 13. In his evidence in these proceedings, Dr Wright relies on a purported discussion of Bitcoin between him and Alan Granger, among other work done with Alan Granger around 2007. [ Wright 1 at 48- 52] 14. In his chain of custody information in these proceedings, Dr Wright claims to have drafted this document himself. 15. When disclosing this document, Dr Wright did not specify a date for the document. When requested to provide a date for thi s document, Dr Wright refused to do so. Dr Wright’s Explanations and COPA’s Rebuttal 16. In Appendix B to Wright 11, Dr Wright insisted that the document dated from August 2007. He disputed the evidence provided by COPA to the effect that the Quill minutes pad in this form was not produced as a proof until 2009 and was not printed and shipped until 2012 (see confirmation letter of Mr Stathakis and Ms
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it? A. No, I actually didn't want an adjournment. I actually had a fight with my lawyers over that and they made it happen. Q. Dr Wright, your presentation of those documents as uniquely coding for the Bitcoin White Paper was a fraud on us and on COPA, wasn't it? A. No, I actually believe Mr Ager -Hanssen is working with you guys. Dr Wright blaming third parties, who allegedly created forgeries and loaded them onto his machine. Appendix B: Schedule of Transcript References 527 REFERENCE QUOTE COMMENT Q. Dr Wright, the Bitcoin White Paper wasn't even written in LaTeX, as you would have known if you were Satoshi Nakamoto. A. It actually was. Q. And your claim - A. The fact that I use differ ent tools and integrate them in unusual ways is also something that I do. Q. Dr Wright, your claim to be Satoshi Nakamoto is a fraudulent claim, isn't it? A. No, not at all. In fact, I wouldn't need to actually claim to be Satoshi, I have now proveabl y scaled beyond anything Silicon Valley can do. We have created a system that's doing 1.1 million transactions a second live, my Lord. That exceeds the capability of Oracle, it exceeds the capability of Microsoft, who are now talking to us, it exceeds any -- and they will argue centralised, except it's distributed. No Oracle database, as a centralised system, can do a million transactions a second, my Lord. That's actually running, and we now have governments involved in that, and none of them care tha t I'm Satoshi or not. What they care about is we have a distributed blockchain that is scaling to 1.1 million plus transactions a second continuously. Appendix B: Schedule of Transcript References 528 REFERENCE QUOTE COMMENT DAY 18 CROSS -EXAMINATION OF MR ZEMING GAO BY MR HOUGH {Day18/4:19} - {Day18/5:9} Q. Now, assuming that the KeyGen algorithm produced the key pair in a properly random manner, is it right that it should be practically impossible then to compute the private key given only the public key? A. Yes. Q. Is this right also : for the purpose of verification , it’s important that the message being signed is a new one chosen by the person who is verifying possession? A. Yes, but if you can assure that the signature, that message has never been signed before, the – you know, the old message can be signed freshly. Q. That’s the point, isn ’t it ? A. Yeah. Q. That you want to avoid the person who supposedly has the private key producing a message which has been signed in the past with that private key? A. That’s true. Q. Because that would be a replay attack, wouldn’t it? A. Yes. Mr Gao agreeing with the importance of using a previously unsigned message (i.e. avoiding a replay attack). {Day18/5:17} - {Day18/5:24} Q. But this protection against a replay attack wouldn’t be increased in that scenario if I insisted on adding some words? So for example, if I insisted on adding the words “before Mr Justice Mellor” to that text – A. No. Q. – is that right? So it wouldn’t improve the – A. It wouldn’t improve, yeah. Mr Gao accepting that the security of a signing is not enhanced by adding letters to a message (e.g. Wright adding “CSW” to the message during the Andresen Signing session – adding ”CSW”). Appendix B: Schedule of Transcript References 529 {Day18/7:13} - {Day18/8:3} Q. Yes. Now, suppose a person provides a digitally signed message to another person by putting it onto a USB stick, putting the signed message onto a USB stick and handing it over to that other person, and suppose that that other person knows the public key, for example, because they’ve brought a list of public keys with them; do you understand? A. Yeah. Q. There ’s no real risk, is there, that the person who receives the USB stick and plugs it into their computer can, from that, compute or derive the private key? A. Practically not possible. Q. And when you say “practically not possible”, it’s just infeasible with current computing power, isn’t it? A. I would think so. Mr Gao agreeing that there was no risk of Gavin Andresen being able to derive the private key from a digitally signed message put on a USB which he could then verify on his own computer. {Day18/8:9} - {Day18/9:8} Q. So suppose that the person who’s doing the verifying selects the message on their own and tells that message to Dr Wright, an entirely new message, okay? A. Mm -hm. Q. And suppose that, secondly, Dr Wright, assuming he has a private key associated with an early block, which we obviously dispute, signs the message on his computer with that private key and puts the signed message onto a USB stick, right? A. Yes. Q. With me so far? Thirdly, the verifier takes that USB stick and plugs it into their own computer, takes out the message and runs their own verification program on it on their own computer. A. Mm -hm. Q. Yes? And they do so by reference to a public key which the verifier has noted down and brough t with them, okay? A. Yes. Q. And it’s right in fact that that could be done without the verifier even having their computer connected to the internet, they could just have the verification program on it, right? A. As long as they have the right software. Mr Gao agreeing that it was unnecessary to connect to the internet in order to verify the message. {Day18/9:10} - {Day18/10:3} Now, each stage in that process would be terribly simple, no great complexity or technical difficulty? A. I suppose. Q. It wouldn’t involve anyone doing any downloads, would it? Mr Gao accepting that there is a much easier way to prove access to the private key. Appendix B: Schedule of Transcript References 530 A. If the device didn’t have the software, he would have to download the soft ware. Q. But if the person doing the verifying already had a verification – form of verification software? A. Then no downloads required. Q. No downloads needed? A. Yeah. Q. It would be very quick, wouldn’t it, it could be done in a matter of minutes? A. Yes. Q. And there would be no real risk in that scenario that the session was being spoofed would there?
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 208 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: it? A. No, I actually didn't want an adjournment. I actually had a fight with my lawyers over that and they made it happen. Q. Dr Wright, your presentation of those documents as uniquely coding for the Bitcoin White Paper was a fraud on us and on COPA, wasn't it? A. No, I actually believe Mr Ager -Hanssen is working with you guys. Dr Wright blaming third parties, who allegedly created forgeries and loaded them onto his machine. Appendix B: Schedule of Transcript References 527 REFERENCE QUOTE COMMENT Q. Dr Wright, the Bitcoin White Paper wasn't even written in LaTeX, as you would have known if you were Satoshi Nakamoto. A. It actually was. Q. And your claim - A. The fact that I use differ ent tools and integrate them in unusual ways is also something that I do. Q. Dr Wright, your claim to be Satoshi Nakamoto is a fraudulent claim, isn't it? A. No, not at all. In fact, I wouldn't need to actually claim to be Satoshi, I have now proveabl y scaled beyond anything Silicon Valley can do. We have created a system that's doing 1.1 million transactions a second live, my Lord. That exceeds the capability of Oracle, it exceeds the capability of Microsoft, who are now talking to us, it exceeds any -- and they will argue centralised, except it's distributed. No Oracle database, as a centralised system, can do a million transactions a second, my Lord. That's actually running, and we now have governments involved in that, and none of them care tha t I'm Satoshi or not. What they care about is we have a distributed blockchain that is scaling to 1.1 million plus transactions a second continuously. Appendix B: Schedule of Transcript References 528 REFERENCE QUOTE COMMENT DAY 18 CROSS -EXAMINATION OF MR ZEMING GAO BY MR HOUGH {Day18/4:19} - {Day18/5:9} Q. Now, assuming that the KeyGen algorithm produced the key pair in a properly random manner, is it right that it should be practically impossible then to compute the private key given only the public key? A. Yes. Q. Is this right also : for the purpose of verification , it’s important that the message being signed is a new one chosen by the person who is verifying possession? A. Yes, but if you can assure that the signature, that message has never been signed before, the – you know, the old message can be signed freshly. Q. That’s the point, isn ’t it ? A. Yeah. Q. That you want to avoid the person who supposedly has the private key producing a message which has been signed in the past with that private key? A. That’s true. Q. Because that would be a replay attack, wouldn’t it? A. Yes. Mr Gao agreeing with the importance of using a previously unsigned message (i.e. avoiding a replay attack). {Day18/5:17} - {Day18/5:24} Q. But this protection against a replay attack wouldn’t be increased in that scenario if I insisted on adding some words? So for example, if I insisted on adding the words “before Mr Justice Mellor” to that text – A. No. Q. – is that right? So it wouldn’t improve the – A. It wouldn’t improve, yeah. Mr Gao accepting that the security of a signing is not enhanced by adding letters to a message (e.g. Wright adding “CSW” to the message during the Andresen Signing session – adding ”CSW”). Appendix B: Schedule of Transcript References 529 {Day18/7:13} - {Day18/8:3} Q. Yes. Now, suppose a person provides a digitally signed message to another person by putting it onto a USB stick, putting the signed message onto a USB stick and handing it over to that other person, and suppose that that other person knows the public key, for example, because they’ve brought a list of public keys with them; do you understand? A. Yeah. Q. There ’s no real risk, is there, that the person who receives the USB stick and plugs it into their computer can, from that, compute or derive the private key? A. Practically not possible. Q. And when you say “practically not possible”, it’s just infeasible with current computing power, isn’t it? A. I would think so. Mr Gao agreeing that there was no risk of Gavin Andresen being able to derive the private key from a digitally signed message put on a USB which he could then verify on his own computer. {Day18/8:9} - {Day18/9:8} Q. So suppose that the person who’s doing the verifying selects the message on their own and tells that message to Dr Wright, an entirely new message, okay? A. Mm -hm. Q. And suppose that, secondly, Dr Wright, assuming he has a private key associated with an early block, which we obviously dispute, signs the message on his computer with that private key and puts the signed message onto a USB stick, right? A. Yes. Q. With me so far? Thirdly, the verifier takes that USB stick and plugs it into their own computer, takes out the message and runs their own verification program on it on their own computer. A. Mm -hm. Q. Yes? And they do so by reference to a public key which the verifier has noted down and brough t with them, okay? A. Yes. Q. And it’s right in fact that that could be done without the verifier even having their computer connected to the internet, they could just have the verification program on it, right? A. As long as they have the right software. Mr Gao agreeing that it was unnecessary to connect to the internet in order to verify the message. {Day18/9:10} - {Day18/10:3} Now, each stage in that process would be terribly simple, no great complexity or technical difficulty? A. I suppose. Q. It wouldn’t involve anyone doing any downloads, would it? Mr Gao accepting that there is a much easier way to prove access to the private key. Appendix B: Schedule of Transcript References 530 A. If the device didn’t have the software, he would have to download the soft ware. Q. But if the person doing the verifying already had a verification – form of verification software? A. Then no downloads required. Q. No downloads needed? A. Yeah. Q. It would be very quick, wouldn’t it, it could be done in a matter of minutes? A. Yes. Q. And there would be no real risk in that scenario that the session was being spoofed would there?
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Closings
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in the circumstances or explain the irregularities. d. The use of a version of Windows Text Editor dating from 2020 shows these documents were not contemporaneous to the alleged time capsule. e. Mr Lynch agreed with Mr Madden that ID_000473 was manipulated: {Q/6/5}. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 159 of 167 {ID_0 04736} {PTR -F/93/1} “ESDT.tex” 1. The document is a LaTeX source presented as if it was precursor work to the Bitcoin White Paper created during Dr Wright’s employment at BDO. Dr Wright relies upon it as a draft addressing technical concepts which influenced his development of Bitcoin. Reasons for Allegation of Forgery 2. This document is among the 71 New Reliance Documents that were inserted into the BDO Drive by the editing process and which the parties’ experts agree were manipulated [Madden / Lynch 1 at 12 Q/6/5]. 3. Copies of the document are also located on the Samsung Drive. These copies display signs of metadata editing and clock manipulation. [PM46 at 74- 79 H/278/17] 4. A related LaTeX file has been recovered which encodes the same textual content in a different way. That document had been deleted but was recoverable from within the Samsung Drive. The structure of that file is consistent with the file being generated automatically by software conversion tools (rather than being authored by hand). [Mad den 4 at 67 -70 H/278/16]. 5. There is a related file {ID_004735} which appears intended to create an image for the paper. The code in that file is consistent with having been generated by conversion tools such as Aspose. [Madden 3 at 75 G/5/31] 6. A related document, ESDT.pdf, was recovered from the Samsung Drive. ESDT.pdf was a compiled form of {ID_004736} but was deleted and emptied from the Recycle Bin in September 2023 [PM46 at 41- 52 H/278/10]. The metadata associated with the deleted file indicates that it was modified on 16 September 2023, but the other timestamps have been backdated to 31 October 2007. 7. The metadata of this document (when compared with metadata of other documents related to it) displays signs of metadata editing directly using specialised metadata editing tools. [Madden 3 at 52- 63 G/5/23] 8. The document was sourced from BDOPC.raw. The section “BDOPC.raw” above is repeated. This document was added to BDOPC.raw by the Manipulation User. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 160 of 167 Reasons for Inference of Dr Wright’s Knowledge / Responsi bility 9. The effect of the tampering is to make the document appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto, contrary to fact. 10. The further effect of tampering is to lend support to Dr Wright’s new position that the Bitcoin White Paper w as created in LaTeX. That story is a recent product of Dr Wright’s change in his account. 11. This document was added to BDOPC.raw by the Manipulation User. The Manipulation User is Dr Wright. Paragraph 13 of the section “BDOPC.raw” above is repeated. 12. Dr Wright has attached particular importance to this document: a. It is said to be among Dr Wright’s “ Notes, drafts and articles addressing technical concepts that underpin the concepts developed in the Bitcoin White Paper" [ Wright 6 E/21/3; Schedule 1 to Field 1, L20/223/4] b. It is said to be important to Dr Wright’s case because it is a version of “ a paper prepared for a 360º Security Summit on 15 June 2006 concerned with “Implementing Effective Risk -Based Controls”, which Dr Wright prepared in his role at BDO. The hash chain technology discussed in the paper is analogous to the blockchain technology used i n Bitcoin." [ Wright 6 E/21/3; Schedule 1 to Field 1, L20/223/5] 13. The document was not disclosed at the proper time. It was disclosed instead from the BDOPC.raw image. BDOPC.raw is not a reliable source because it has been manipulated by Dr Wright. The secti on “BDOPC.raw” above is repeated. Dr Wright’s Explanations and COPA’s Rebuttal 14. Dr Wright claimed that his use of Xc opy had caused the load file metadata for this and two related documents to all have creation times at precisely the same time on 19 September 2017, with August 2008 accessed and modified times for this document and one other related one. He also claimed that he was still accessing files at BDO in 2008 and so that these may have been copied from a different drive: {Day5/102:21} and following. See Wright 11 {CSW/2/43} for an example of him claiming how Xcopy works. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 161 of 167 15. This explanation should be rejected as dis honest for the following reasons: a. If the BDOPC.raw is accepted as being forged, it follows that documents on it should be treated as being forged unless they are documents which Mr Madden says are original to the image that was taken in October 2007. b. Mr Ma dden states that Xcopy simply does not have the effect that Dr Wright claims. This was also the view of Mr Lynch, as recorded in their Joint Report: {Q/6/4}. c. Dr Wright’s excuse about accessing files at BDO in 2008 is inconsistent with his claim that the files on the BDO Drive are a time capsule and taken from a capture of the BDO files he had in 2007. d. Mr Lynch agreed with Mr Madden that ID_0004736 was manipulated: {Q/6/5}. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 162 of 167 PART 4: THE MYOB ONTIER EMAIL {X/56/2} “The MYOB Ontier Email” (aka “the Ramona V ersion”) 1. The email which COPA alleges is a forgery is an email document forwarded by Dr Wright’s wife (Ms Watts) as an attachment to an email to Dr Wright’s current solicitors, Shoosmiths. This document presents as an email sent by Dr Wright to Simon Cohe n of Ontier (his former solicitors) at 14.52 on 2 December 2019 purporting to show that Ontier were provided with a login to an MYOB account in 2019 (the “ MYOB Ontier Email”). 2. Dr Wright has relied on the supposed existence of supportive emails from 2019 in his cross -examination as evidence that Ontier had earlier access to MYOB than that which Ontier had stated by email of 8 February 2024 {X/55/1} (information passed on through a letter dated 9 February 2024 from Shoosmiths {M/2/1000}). He has done so in order to support his case that other MYOB records disclosed and relied on by him are not forgeries, and
1,111
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 48 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### File content: in the circumstances or explain the irregularities. d. The use of a version of Windows Text Editor dating from 2020 shows these documents were not contemporaneous to the alleged time capsule. e. Mr Lynch agreed with Mr Madden that ID_000473 was manipulated: {Q/6/5}. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 159 of 167 {ID_0 04736} {PTR -F/93/1} “ESDT.tex” 1. The document is a LaTeX source presented as if it was precursor work to the Bitcoin White Paper created during Dr Wright’s employment at BDO. Dr Wright relies upon it as a draft addressing technical concepts which influenced his development of Bitcoin. Reasons for Allegation of Forgery 2. This document is among the 71 New Reliance Documents that were inserted into the BDO Drive by the editing process and which the parties’ experts agree were manipulated [Madden / Lynch 1 at 12 Q/6/5]. 3. Copies of the document are also located on the Samsung Drive. These copies display signs of metadata editing and clock manipulation. [PM46 at 74- 79 H/278/17] 4. A related LaTeX file has been recovered which encodes the same textual content in a different way. That document had been deleted but was recoverable from within the Samsung Drive. The structure of that file is consistent with the file being generated automatically by software conversion tools (rather than being authored by hand). [Mad den 4 at 67 -70 H/278/16]. 5. There is a related file {ID_004735} which appears intended to create an image for the paper. The code in that file is consistent with having been generated by conversion tools such as Aspose. [Madden 3 at 75 G/5/31] 6. A related document, ESDT.pdf, was recovered from the Samsung Drive. ESDT.pdf was a compiled form of {ID_004736} but was deleted and emptied from the Recycle Bin in September 2023 [PM46 at 41- 52 H/278/10]. The metadata associated with the deleted file indicates that it was modified on 16 September 2023, but the other timestamps have been backdated to 31 October 2007. 7. The metadata of this document (when compared with metadata of other documents related to it) displays signs of metadata editing directly using specialised metadata editing tools. [Madden 3 at 52- 63 G/5/23] 8. The document was sourced from BDOPC.raw. The section “BDOPC.raw” above is repeated. This document was added to BDOPC.raw by the Manipulation User. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 160 of 167 Reasons for Inference of Dr Wright’s Knowledge / Responsi bility 9. The effect of the tampering is to make the document appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto, contrary to fact. 10. The further effect of tampering is to lend support to Dr Wright’s new position that the Bitcoin White Paper w as created in LaTeX. That story is a recent product of Dr Wright’s change in his account. 11. This document was added to BDOPC.raw by the Manipulation User. The Manipulation User is Dr Wright. Paragraph 13 of the section “BDOPC.raw” above is repeated. 12. Dr Wright has attached particular importance to this document: a. It is said to be among Dr Wright’s “ Notes, drafts and articles addressing technical concepts that underpin the concepts developed in the Bitcoin White Paper" [ Wright 6 E/21/3; Schedule 1 to Field 1, L20/223/4] b. It is said to be important to Dr Wright’s case because it is a version of “ a paper prepared for a 360º Security Summit on 15 June 2006 concerned with “Implementing Effective Risk -Based Controls”, which Dr Wright prepared in his role at BDO. The hash chain technology discussed in the paper is analogous to the blockchain technology used i n Bitcoin." [ Wright 6 E/21/3; Schedule 1 to Field 1, L20/223/5] 13. The document was not disclosed at the proper time. It was disclosed instead from the BDOPC.raw image. BDOPC.raw is not a reliable source because it has been manipulated by Dr Wright. The secti on “BDOPC.raw” above is repeated. Dr Wright’s Explanations and COPA’s Rebuttal 14. Dr Wright claimed that his use of Xc opy had caused the load file metadata for this and two related documents to all have creation times at precisely the same time on 19 September 2017, with August 2008 accessed and modified times for this document and one other related one. He also claimed that he was still accessing files at BDO in 2008 and so that these may have been copied from a different drive: {Day5/102:21} and following. See Wright 11 {CSW/2/43} for an example of him claiming how Xcopy works. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 161 of 167 15. This explanation should be rejected as dis honest for the following reasons: a. If the BDOPC.raw is accepted as being forged, it follows that documents on it should be treated as being forged unless they are documents which Mr Madden says are original to the image that was taken in October 2007. b. Mr Ma dden states that Xcopy simply does not have the effect that Dr Wright claims. This was also the view of Mr Lynch, as recorded in their Joint Report: {Q/6/4}. c. Dr Wright’s excuse about accessing files at BDO in 2008 is inconsistent with his claim that the files on the BDO Drive are a time capsule and taken from a capture of the BDO files he had in 2007. d. Mr Lynch agreed with Mr Madden that ID_0004736 was manipulated: {Q/6/5}. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 162 of 167 PART 4: THE MYOB ONTIER EMAIL {X/56/2} “The MYOB Ontier Email” (aka “the Ramona V ersion”) 1. The email which COPA alleges is a forgery is an email document forwarded by Dr Wright’s wife (Ms Watts) as an attachment to an email to Dr Wright’s current solicitors, Shoosmiths. This document presents as an email sent by Dr Wright to Simon Cohe n of Ontier (his former solicitors) at 14.52 on 2 December 2019 purporting to show that Ontier were provided with a login to an MYOB account in 2019 (the “ MYOB Ontier Email”). 2. Dr Wright has relied on the supposed existence of supportive emails from 2019 in his cross -examination as evidence that Ontier had earlier access to MYOB than that which Ontier had stated by email of 8 February 2024 {X/55/1} (information passed on through a letter dated 9 February 2024 from Shoosmiths {M/2/1000}). He has done so in order to support his case that other MYOB records disclosed and relied on by him are not forgeries, and
2,013
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Martti Malmi - Exhibits
part 25 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf
44,150
86,849
> > On Sun, Nov 15, 2009 at 12:45 AM, Satoshi Nakamoto <[email protected] > <mailto:[email protected]> > wrote: > > Here's one where I linked Berkeley DB a different way. It's worth a > try. Otherwise identical to test5. > > (Keep the datadir on the hard drive at least until you get it to > fail the same way there. That has a fair chance of success.) > > SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 16/11/2009 19:34 [email protected] wrote: > I installed a TikiWiki on my VPS at 174.143.149.98. SSL is currently > enabled with a self-signed certificate. Admin password is the same as in > the Bitweaver. How about using this as the site platform? Maybe we can > make bitcoin.org or at least bitcoin.sf.net point there? What do you see as the benefits of switching the wiki? Some I can think of: SSL get away from sourceforge's unreliable hosting everything not logged by sourceforge The forum feature is about as weak as bitweaver. We need a full blown forum software for that. My priority right now is to get a forum going, either phpBB or similar. What do you think of the zetaboards option? Should we go ahead with that? SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 16/11/2009 21:10 That's a good idea to go in a more web-publishing CMS type direction like Drupal. That's a better fit and can produce a better looking website than a wiki. I think I was wrong about wiki. Only a few specific people will do any website design work and those people can go ahead and have a separate login. In that case, login integration with the forum doesn't matter much. For security, I'd almost rather have a different login than be constantly checking the forum with the same login that could pwn the website. Drupal's forum is less bad than the wikis, but still a long way from something I would want to use. zetaboards pros and cons: pros: - we don't have to worry about bandwidth - they handle the backend management and security patches con: - lack of SSL - lack of privacy, everything is logged - lack of control over the php code for customization - no CAPTCHA, and if they add one later it might be unacceptable flash - ads (could pay to get rid of them later if we care enough) - there's always the risk they abruptly cancel the site for some petty reason [email protected] wrote: >> What do you see as the benefits of switching the wiki? >> Some I can think of: >> SSL >> get away from sourceforge's unreliable hosting >> everything not logged by sourceforge > > I think the biggest advantage is having a single site so you don't need > a separate account for the wiki and the forum, and the functionalities > are also nicely integrated with the main site itself. Also being ad-free > is a plus. > >> The forum feature is about as weak as bitweaver. We need a full blown >> forum software for that. > > How about Drupal's forum functionality? Address: > https://174.143.149.98/drupal/ . The CMS in general looks better and > simpler than TikiWiki. If the forum's not good enough, then we can of > course use a specialized forum software like phpBB. > >> My priority right now is to get a forum going, either phpBB or similar. >> What do you think of the zetaboards option? Should we go ahead with >> that? > > Otherwise fine, but the ads and the lack of SSL are a minus. > SUBJECT : linux-0.1.6-test7 FROM: Satoshi Nakamoto <[email protected]> TO: Liberty Standard <[email protected]> CC: Martti Malmi <[email protected]> DATE: 17/11/2009 03:41 test 7: Backup your data directory before running this, just in case. Workaround for the Db::open/Db::close "Bad file descriptor" exception. Might also make the initial block download faster. The workaround is to open the database handles and keep them open for the duration of the program, which is actually the more common thing to do anyway. If we're not closing and opening all the time, the error shouldn't get a chance to happen. The one exception is wallet.dat, which I still close after writing is finished so I can flush the transaction logs into the dat file, making the dat file standalone. That way if someone does a backup while Bitcoin is running, they'll get a wallet.dat that is valid by itself without the database transaction logs. This is a restructuring of the database handling, so we might find some new deadlocks. Usually if it deadlocks, either the UI will stop repainting, or it'll stop using CPU even though it still says Generating. SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 17/11/2009 16:57 [email protected] wrote: > How about Drupal's forum functionality? Address: > https://174.143.149.98/drupal/ . The CMS in general looks better and > simpler than TikiWiki. If the forum's not good enough, then we can of > course use a specialized forum software like phpBB. Another issue I thought of with zetaboards: most free forum sites won't let you export the user account database if you want to move. I don't know why I don't see any other software projects using a free forum, but I have to assume there might be a reason we would discover later. If you can install phpBB3 on your VPS, that's probably the better option. From what I've seen on other forums, if the cost of bandwidth becomes an issue, a small Google Adwords (text links) at the top generates more than the cost of bandwidth even for very low value traffic like gaming. This would be much higher value traffic well targeted for high paying gold merchant keywords and VPN hosts. It could eventually be a valuable revenue stream you wouldn't want to give away to some free site. I want to pre-announce some of the features in version 0.2 on the forum and try to
1,004
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 25 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf ### Folder name: Martti Malmi - Exhibits ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf ### File content: > > On Sun, Nov 15, 2009 at 12:45 AM, Satoshi Nakamoto <[email protected] > <mailto:[email protected]> > wrote: > > Here's one where I linked Berkeley DB a different way. It's worth a > try. Otherwise identical to test5. > > (Keep the datadir on the hard drive at least until you get it to > fail the same way there. That has a fair chance of success.) > > SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 16/11/2009 19:34 [email protected] wrote: > I installed a TikiWiki on my VPS at 174.143.149.98. SSL is currently > enabled with a self-signed certificate. Admin password is the same as in > the Bitweaver. How about using this as the site platform? Maybe we can > make bitcoin.org or at least bitcoin.sf.net point there? What do you see as the benefits of switching the wiki? Some I can think of: SSL get away from sourceforge's unreliable hosting everything not logged by sourceforge The forum feature is about as weak as bitweaver. We need a full blown forum software for that. My priority right now is to get a forum going, either phpBB or similar. What do you think of the zetaboards option? Should we go ahead with that? SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 16/11/2009 21:10 That's a good idea to go in a more web-publishing CMS type direction like Drupal. That's a better fit and can produce a better looking website than a wiki. I think I was wrong about wiki. Only a few specific people will do any website design work and those people can go ahead and have a separate login. In that case, login integration with the forum doesn't matter much. For security, I'd almost rather have a different login than be constantly checking the forum with the same login that could pwn the website. Drupal's forum is less bad than the wikis, but still a long way from something I would want to use. zetaboards pros and cons: pros: - we don't have to worry about bandwidth - they handle the backend management and security patches con: - lack of SSL - lack of privacy, everything is logged - lack of control over the php code for customization - no CAPTCHA, and if they add one later it might be unacceptable flash - ads (could pay to get rid of them later if we care enough) - there's always the risk they abruptly cancel the site for some petty reason [email protected] wrote: >> What do you see as the benefits of switching the wiki? >> Some I can think of: >> SSL >> get away from sourceforge's unreliable hosting >> everything not logged by sourceforge > > I think the biggest advantage is having a single site so you don't need > a separate account for the wiki and the forum, and the functionalities > are also nicely integrated with the main site itself. Also being ad-free > is a plus. > >> The forum feature is about as weak as bitweaver. We need a full blown >> forum software for that. > > How about Drupal's forum functionality? Address: > https://174.143.149.98/drupal/ . The CMS in general looks better and > simpler than TikiWiki. If the forum's not good enough, then we can of > course use a specialized forum software like phpBB. > >> My priority right now is to get a forum going, either phpBB or similar. >> What do you think of the zetaboards option? Should we go ahead with >> that? > > Otherwise fine, but the ads and the lack of SSL are a minus. > SUBJECT : linux-0.1.6-test7 FROM: Satoshi Nakamoto <[email protected]> TO: Liberty Standard <[email protected]> CC: Martti Malmi <[email protected]> DATE: 17/11/2009 03:41 test 7: Backup your data directory before running this, just in case. Workaround for the Db::open/Db::close "Bad file descriptor" exception. Might also make the initial block download faster. The workaround is to open the database handles and keep them open for the duration of the program, which is actually the more common thing to do anyway. If we're not closing and opening all the time, the error shouldn't get a chance to happen. The one exception is wallet.dat, which I still close after writing is finished so I can flush the transaction logs into the dat file, making the dat file standalone. That way if someone does a backup while Bitcoin is running, they'll get a wallet.dat that is valid by itself without the database transaction logs. This is a restructuring of the database handling, so we might find some new deadlocks. Usually if it deadlocks, either the UI will stop repainting, or it'll stop using CPU even though it still says Generating. SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 17/11/2009 16:57 [email protected] wrote: > How about Drupal's forum functionality? Address: > https://174.143.149.98/drupal/ . The CMS in general looks better and > simpler than TikiWiki. If the forum's not good enough, then we can of > course use a specialized forum software like phpBB. Another issue I thought of with zetaboards: most free forum sites won't let you export the user account database if you want to move. I don't know why I don't see any other software projects using a free forum, but I have to assume there might be a reason we would discover later. If you can install phpBB3 on your VPS, that's probably the better option. From what I've seen on other forums, if the cost of bandwidth becomes an issue, a small Google Adwords (text links) at the top generates more than the cost of bandwidth even for very low value traffic like gaming. This would be much higher value traffic well targeted for high paying gold merchant keywords and VPN hosts. It could eventually be a valuable revenue stream you wouldn't want to give away to some free site. I want to pre-announce some of the features in version 0.2 on the forum and try to
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Patrick Madden
part 14 of 15 Appendix PM21.pdf
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explain the conclusion above and illustrate what is meant by “spoofing” in moredetail, I have recreated a spoofing process first using MS Outlook, and second using a well - known email spoofing website called Emk ei.cz. 81. Before proceeding, I point out that I have conducted these tests using different infrastructureto that available to the authors of ID_001546 and ID_002586 and therefore my results can be expected to differ. These results do not inform my conclusions above , but illustrate them. Spoofing with MS Outlook 82. Starting with MS Outlook I started a new draft email message. As I maintain multiple email addresses for Right Click Forensic, the option to select the “From” account is already available to me as per the screenshot below on the left. If this option is not available, it can be made available by clicking on “Options” and “From” as per the screenshot on the right:23 - 23 - H/104/23{ID_001546} {ID_002586} {ID_001546} {ID_002586} Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 24 of 27 83. T he next step is to add an address by clicking on “Other Email Address” and entering the email address as per the screen below: 84.T he email address can then be selected as the “From” email address, and an email can be composed and sent . 85.Wh ile creating the email, the user can select to have the Reply -To: option enabled by pressi ng t he button “Direct Replies to” and configuring the email accordingly to “have replies sent to ” a ny email address of the user’s choosing : Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 24 of 27 83. T he next step is to add an address by clicking on “Other Email Address” and entering the email address as per the screen below: 84.T he email address can then be selected as the “From” email address, and an email can be composed and sent . 85.Wh ile creating the email, the user can select to have the Reply -To: option enabled by pressi ng t he button “Direct Replies to” and configuring the email accordingly to “have replies sent to ” a ny email address of the user’s choosing : 24 - 24 - H/104/24 M adden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 25of 27 86. The result of conducing these steps would depend on how the server was configured: a. If a server was configured to prevent spoofing, such as on a modern MS Office 365 account, it would by defaul t cause a message to be sent “from [email protected] On Behalf Of testthis@visto m ail”. Since my email server is configured to control spoofing, that was the effect of sending my test email above; or b. If a server was not configured to prevent spoofing (or if a private email server was being used that was configurable), the email would send with the sender set to “[email protected] ”. 87. Looking at the Transmission header that was assigned in this way, a Message -ID was assigned that is characteristic of the use of MS Outlook. Message-IDs vary by the software that is in use, and the equivalent Message -IDs from ID_001546 and ID_002586 below demonstrate that ID_001546 was similar to the format typical of MS Outlook while ID _002586 was not : Test message Message -ID: <[email protected]> ID_001546 Message -ID: <[email protected]> ID_002586 Message -ID: <55728785.3f14KPaNyWUfyqzr%[email protected]> 88. I point out that the Message -ID of all three messages, including my test message, names the ID as “@vistomail.com”. The structure of that ID is determined from the From field and is not indicative of the use of Vistomail servers. Spoofing from online tool 89. It is also possible to spoof emails with the use of free online tool s. One such tool which is well known to forensic investigators and familiar to me is the website E mkei.cz, which is titled “Emke i’s Fake Mailer”. This website can simply be visited in a b rowser window and an email message filled out and sent , without validation or payment: M adden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 25of 27 86. The result of conducing these steps would depend on how the server was configured: a. If a server was configured to prevent spoofing, such as on a modern MS Office 365 account, it would by defaul t cause a message to be sent “from [email protected] On Behalf Of testthis@visto m ail”. Since my email server is configured to control spoofing, that was the effect of sending my test email above; or b. If a server was not configured to prevent spoofing (or if a private email server was being used that was configurable), the email would send with the sender set to “[email protected] ”. 87. Looking at the Transmission header that was assigned in this way, a Message -ID was assigned that is characteristic of the use of MS Outlook.
833
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 14 of 15 Appendix PM21.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM21.pdf ### File content: explain the conclusion above and illustrate what is meant by “spoofing” in moredetail, I have recreated a spoofing process first using MS Outlook, and second using a well - known email spoofing website called Emk ei.cz. 81. Before proceeding, I point out that I have conducted these tests using different infrastructureto that available to the authors of ID_001546 and ID_002586 and therefore my results can be expected to differ. These results do not inform my conclusions above , but illustrate them. Spoofing with MS Outlook 82. Starting with MS Outlook I started a new draft email message. As I maintain multiple email addresses for Right Click Forensic, the option to select the “From” account is already available to me as per the screenshot below on the left. If this option is not available, it can be made available by clicking on “Options” and “From” as per the screenshot on the right:23 - 23 - H/104/23{ID_001546} {ID_002586} {ID_001546} {ID_002586} Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 24 of 27 83. T he next step is to add an address by clicking on “Other Email Address” and entering the email address as per the screen below: 84.T he email address can then be selected as the “From” email address, and an email can be composed and sent . 85.Wh ile creating the email, the user can select to have the Reply -To: option enabled by pressi ng t he button “Direct Replies to” and configuring the email accordingly to “have replies sent to ” a ny email address of the user’s choosing : Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 24 of 27 83. T he next step is to add an address by clicking on “Other Email Address” and entering the email address as per the screen below: 84.T he email address can then be selected as the “From” email address, and an email can be composed and sent . 85.Wh ile creating the email, the user can select to have the Reply -To: option enabled by pressi ng t he button “Direct Replies to” and configuring the email accordingly to “have replies sent to ” a ny email address of the user’s choosing : 24 - 24 - H/104/24 M adden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 25of 27 86. The result of conducing these steps would depend on how the server was configured: a. If a server was configured to prevent spoofing, such as on a modern MS Office 365 account, it would by defaul t cause a message to be sent “from [email protected] On Behalf Of testthis@visto m ail”. Since my email server is configured to control spoofing, that was the effect of sending my test email above; or b. If a server was not configured to prevent spoofing (or if a private email server was being used that was configurable), the email would send with the sender set to “[email protected] ”. 87. Looking at the Transmission header that was assigned in this way, a Message -ID was assigned that is characteristic of the use of MS Outlook. Message-IDs vary by the software that is in use, and the equivalent Message -IDs from ID_001546 and ID_002586 below demonstrate that ID_001546 was similar to the format typical of MS Outlook while ID _002586 was not : Test message Message -ID: <[email protected]> ID_001546 Message -ID: <[email protected]> ID_002586 Message -ID: <55728785.3f14KPaNyWUfyqzr%[email protected]> 88. I point out that the Message -ID of all three messages, including my test message, names the ID as “@vistomail.com”. The structure of that ID is determined from the From field and is not indicative of the use of Vistomail servers. Spoofing from online tool 89. It is also possible to spoof emails with the use of free online tool s. One such tool which is well known to forensic investigators and familiar to me is the website E mkei.cz, which is titled “Emke i’s Fake Mailer”. This website can simply be visited in a b rowser window and an email message filled out and sent , without validation or payment: M adden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 25of 27 86. The result of conducing these steps would depend on how the server was configured: a. If a server was configured to prevent spoofing, such as on a modern MS Office 365 account, it would by defaul t cause a message to be sent “from [email protected] On Behalf Of testthis@visto m ail”. Since my email server is configured to control spoofing, that was the effect of sending my test email above; or b. If a server was not configured to prevent spoofing (or if a private email server was being used that was configurable), the email would send with the sender set to “[email protected] ”. 87. Looking at the Transmission header that was assigned in this way, a Message -ID was assigned that is characteristic of the use of MS Outlook.
1,608
/content/Copa v Wright - Trial Documents/Expert Reports/Arthur Rosendahl/First Expert Report of Arthur Rosendahl.pdf
Arthur Rosendahl
part 7 of 40 First Expert Report of Arthur Rosendahl.pdf
45,150
79,556
the choice of fonts. The main text is in Times New Roman, which is indeed used very often in scientific articles; alongside with the L ATEX default, Computer Modern Roman; but the white paper’s title and section headings are in a different font, Century Schoolbook. It is uncommon in L ATEX to use different fonts for the text body and the headings. Also, the code extracts on pages 7 and 8 are in Courier, 10 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 Figure 2.1: Example of overstretched word space in the BWP a. Throughout, the apostrophe is straight (') instead of curly (’). Fonts are generally set up in L ATEX to use the curly apostrophe, even when a straight quote is input in the source code; b. In the BWP section numbers are followed by a full stop, whereas in the L ATEX default they are not; c. The formula at the bottom of page 4 of the BWP uses the character ‘*’ for mul- tiplication instead of . A L ATEX user would likely have used “maths mode” to achieve something looking like: 80bytes624365 = 4:21 MB; d. In the enumeration at the beginning of section 5 of the BWP, the numbers are followed by a closing parenthesis as in: “1) New transactions are broadcast to all nodes”, whereas the L ATEX default is no parenthesis; e. Although the text is justified-aligned (flush straight at both the left and right margins), there is no hyphenation (word division across line breaks). As a result of not using hyphenation, the inter-word space in the BWP is stretched a lot in some places, as in figure 2.1, that appears in the middle of page 3 of the BWP. LATEX is set up by default to allow some (but not too many) words to break across lines, resulting in more even spacing. Hyphenation is an important part of how LATEX achieves good typesetting in documents that are justified-aligned, without stretching the inter-word spacing. It is possible to deactivate hyphenation but the result is generally considered inferior, as most users who follow that route find out; f. The formulae are not centred, whereas in L ATEX they are; and g. The formulae also look a bit awkward in places, as for example with the uneven spacing around the fraction bar in (q/p)zat the bottom of page 6 of the BWP, as well as in two places in the middle of page 7. See figure 2.2 for a comparison the white paper with L ATEX. Choice of Fonts 31. I also need to remark upon the choice of fonts. The main text is in Times New Roman, which is indeed used very often in scientific articles; alongside with the L ATEX default, Computer Modern Roman; but the white paper’s title and section headings are in a different font, Century Schoolbook. It is uncommon in L ATEX to use different fonts for the text body and the headings. Also, the code extracts on pages 7 and 8 are in Courier, 10 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA6810 - 10 - G/7/10 qz=1ifpq (q/p)zifp > q Figure 2.2: First formula of the Bitcoin white paper, and its rendering in L ATEX a very thin typeface that doesn’t render very well. I would have expected the default LATEX monospaced font here, Computer Modern Typewriter. The Courier font, while a default font for Windows, is not a default font for L ATEX and would have required a greater degree of effort to use, while Computer Modern Typewriter could be used simply with the core L ATEX command \\texttt. 32. There is of course no accounting for taste (and this was only the starting point of my re- view), but the overall impression I gained was that, if the document had been produced with LATEX, there has been great attention to details in some areas, and apparent care- lessness in others: many of L ATEX’s default settings would have to have been changed, not necessarily for the better, in ways that would have taken effort to achieve. I already commented on spacing above, and can also point to the mathematical formulae. Re- gardless of which fonts one likes best, I think most people would agree that the second example in figure 2.2, made in L ATEX with standard settings, look at least a little better than the first one and is certainly at least as good. Changing the default settings to achieve the exact spacing observed in the formula on top seems practically infeasible to me; if it could be done, it would most likely have to be done at the lower level, in T EX instead of L ATEX, and take substantial extra time. It may be possible, using specific commands, to input additional spaces manually to achieve a similar spacing, but that would not be guaranteed to have the same result, and it would still be necessary to typeset the symbols differently. Format of embedded fonts 33. I also made some observations about the format (i.e. the filetype) of the font files embedded within the PDF file. When a PDF is output, it is common for copies of its required fonts to be embedded within the structure of the document: this enables the PDF to be displayed on a range of systems, without making assumptions about which fonts are installed locally. The program “pdffonts”1gives a summary of what fonts are present in a PDF file. For the original Bitcoin White Paper, its output is shown in table 1See https://www.xpdfreader.com/pdffonts-man.html 11 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 qz=1ifpq (q/p)zifp > q Figure 2.2: First formula of the Bitcoin white paper, and its rendering in L ATEX a very thin typeface that doesn’t render very well. I would have expected the default LATEX monospaced font here, Computer Modern Typewriter. The Courier font, while a default font for Windows, is not a default font for L ATEX and would have required a greater degree of effort to use, while Computer Modern Typewriter could be used simply with the core L ATEX command \\texttt. 32. There is of course no accounting for taste (and this was only the starting point of my re- view), but the overall impression I gained was that, if the document had been produced with LATEX, there has been great attention to details in some areas, and apparent care- lessness in others: many of L ATEX’s default settings would have to have been changed, not necessarily for the better, in ways that would have taken effort to achieve. I already commented on spacing above, and can also point to the mathematical formulae. Re- gardless of which fonts one likes best, I think most people would agree that the second example in figure 2.2, made in L ATEX with standard settings, look at least
1,129
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 7 of 40 First Expert Report of Arthur Rosendahl.pdf ### Folder name: Arthur Rosendahl ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Arthur Rosendahl/First Expert Report of Arthur Rosendahl.pdf ### File content: the choice of fonts. The main text is in Times New Roman, which is indeed used very often in scientific articles; alongside with the L ATEX default, Computer Modern Roman; but the white paper’s title and section headings are in a different font, Century Schoolbook. It is uncommon in L ATEX to use different fonts for the text body and the headings. Also, the code extracts on pages 7 and 8 are in Courier, 10 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 Figure 2.1: Example of overstretched word space in the BWP a. Throughout, the apostrophe is straight (') instead of curly (’). Fonts are generally set up in L ATEX to use the curly apostrophe, even when a straight quote is input in the source code; b. In the BWP section numbers are followed by a full stop, whereas in the L ATEX default they are not; c. The formula at the bottom of page 4 of the BWP uses the character ‘*’ for mul- tiplication instead of . A L ATEX user would likely have used “maths mode” to achieve something looking like: 80bytes624365 = 4:21 MB; d. In the enumeration at the beginning of section 5 of the BWP, the numbers are followed by a closing parenthesis as in: “1) New transactions are broadcast to all nodes”, whereas the L ATEX default is no parenthesis; e. Although the text is justified-aligned (flush straight at both the left and right margins), there is no hyphenation (word division across line breaks). As a result of not using hyphenation, the inter-word space in the BWP is stretched a lot in some places, as in figure 2.1, that appears in the middle of page 3 of the BWP. LATEX is set up by default to allow some (but not too many) words to break across lines, resulting in more even spacing. Hyphenation is an important part of how LATEX achieves good typesetting in documents that are justified-aligned, without stretching the inter-word spacing. It is possible to deactivate hyphenation but the result is generally considered inferior, as most users who follow that route find out; f. The formulae are not centred, whereas in L ATEX they are; and g. The formulae also look a bit awkward in places, as for example with the uneven spacing around the fraction bar in (q/p)zat the bottom of page 6 of the BWP, as well as in two places in the middle of page 7. See figure 2.2 for a comparison the white paper with L ATEX. Choice of Fonts 31. I also need to remark upon the choice of fonts. The main text is in Times New Roman, which is indeed used very often in scientific articles; alongside with the L ATEX default, Computer Modern Roman; but the white paper’s title and section headings are in a different font, Century Schoolbook. It is uncommon in L ATEX to use different fonts for the text body and the headings. Also, the code extracts on pages 7 and 8 are in Courier, 10 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA6810 - 10 - G/7/10 qz=1ifpq (q/p)zifp > q Figure 2.2: First formula of the Bitcoin white paper, and its rendering in L ATEX a very thin typeface that doesn’t render very well. I would have expected the default LATEX monospaced font here, Computer Modern Typewriter. The Courier font, while a default font for Windows, is not a default font for L ATEX and would have required a greater degree of effort to use, while Computer Modern Typewriter could be used simply with the core L ATEX command \\texttt. 32. There is of course no accounting for taste (and this was only the starting point of my re- view), but the overall impression I gained was that, if the document had been produced with LATEX, there has been great attention to details in some areas, and apparent care- lessness in others: many of L ATEX’s default settings would have to have been changed, not necessarily for the better, in ways that would have taken effort to achieve. I already commented on spacing above, and can also point to the mathematical formulae. Re- gardless of which fonts one likes best, I think most people would agree that the second example in figure 2.2, made in L ATEX with standard settings, look at least a little better than the first one and is certainly at least as good. Changing the default settings to achieve the exact spacing observed in the formula on top seems practically infeasible to me; if it could be done, it would most likely have to be done at the lower level, in T EX instead of L ATEX, and take substantial extra time. It may be possible, using specific commands, to input additional spaces manually to achieve a similar spacing, but that would not be guaranteed to have the same result, and it would still be necessary to typeset the symbols differently. Format of embedded fonts 33. I also made some observations about the format (i.e. the filetype) of the font files embedded within the PDF file. When a PDF is output, it is common for copies of its required fonts to be embedded within the structure of the document: this enables the PDF to be displayed on a range of systems, without making assumptions about which fonts are installed locally. The program “pdffonts”1gives a summary of what fonts are present in a PDF file. For the original Bitcoin White Paper, its output is shown in table 1See https://www.xpdfreader.com/pdffonts-man.html 11 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 qz=1ifpq (q/p)zifp > q Figure 2.2: First formula of the Bitcoin white paper, and its rendering in L ATEX a very thin typeface that doesn’t render very well. I would have expected the default LATEX monospaced font here, Computer Modern Typewriter. The Courier font, while a default font for Windows, is not a default font for L ATEX and would have required a greater degree of effort to use, while Computer Modern Typewriter could be used simply with the core L ATEX command \\texttt. 32. There is of course no accounting for taste (and this was only the starting point of my re- view), but the overall impression I gained was that, if the document had been produced with LATEX, there has been great attention to details in some areas, and apparent care- lessness in others: many of L ATEX’s default settings would have to have been changed, not necessarily for the better, in ways that would have taken effort to achieve. I already commented on spacing above, and can also point to the mathematical formulae. Re- gardless of which fonts one likes best, I think most people would agree that the second example in figure 2.2, made in L ATEX with standard settings, look at least
1,797
/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM11.pdf
Patrick Madden
part 1 of 8 Appendix PM11.pdf
6,261
14,012
Madden Appendix PM11 “LOG FILES” / ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 Page 1 of 22 IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES INTELLECTUAL PROPERTY LIST (ChD) Claim No: IL -2021 -000019 BETWEEN: CRYPTO OPEN PATENT ALLIANCE Claimant -and- DR CRAIG STEVEN WRIGHT Defendant Appendix PM11 LOG FILES ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 1.Th is Appendix addresses the six files in the disclosure dataset which are saved with the extension “.log” : ID_000746 ID_000748 ID_000753 ID_000754 ID_000840 ID_000848 Report structure – related appendix PM12 2. As I explained in my Main Report, I had not initially flagged these files for review, on the basis that they are encoded as simple plain text files which do not typically provide any useful basis for forensic examination. Towards the end of my analysis however , Bird & Bird asked me to look at executable files in the disclosure dataset from a perspective of examining them as any other disclosure document for any information contained within them, and this also led me to identify a potentially relevantexecutable in the form “bitcoin.exe” and to analyse certain plain text ‘log’ files that appeared to be related to “bitcoin.exe”. 3. I have therefore reported on the analysis of log files in this Appendix, and my analysis of the executable is in Appendix PM12. 4. Although these two are very closely related in context, it was helpful to split the review into two documents because the technical approach to the two documents was very different.{ID_000746} {ID_000748} {ID_000753} {ID_000754} {ID_000840} {ID_000848} {H/66} {G/1} {H/66} Madden Appendix PM11 “LOG FILES” / ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 Page 2 of 22 Log files generally 5. The extension “.log” is not indicative of a file format in itself, but is an extension commonly but informally used to save software operation logs. These logs are often, but may not always be, in plain text. The .log files in this disclosure dataset are plain text files. 6. Although “ LOG” is not a standardised file format, that does not matter for the purpose of this analysis as long as it is understood that it is encoded as plain text, and I refer to it in the same way as any other file format here. Limitations of review 7. Being a plain text document, there is relatively little footprint for forensic analysis. I have set out my primary conclusions below in relation to some metadata irregularities in four of the six .log files which contain content which is firmly within my expertise . I have also provided some secondary observations, keeping within my area of expertise. However, these secondary observations are not firm conclusions, in particular where they concern how the log might have interacted with the software that created it. I emphasise that I am not a software developer, and my experience in software coding is only minimal. While I am able to inspect these logs from the perspective offorensic document examination, the interpretation of software logs themselves is not within m y area of expertise, and it should be borne in mind that my secondary observations are subject to these limitations . 8.The provided metadata associated with the six .LOG files listed above is as follows: Metadata field ID_000746 ID_000748 ID_000753 ID_000754 ID_000840 ID_000848 Provided external metadata (OS/file property information) File Name db.log db.log debug.log debug.log debug.log debug.log OS Created -Date and Time 04/01/2009 13:09 04/01/2009 13:09 04/01/2009 13:25 04/01/2009 13:25 09/01/2009 20:27 19/11/2015 16:41 OS Last 04/01/2009 04/01/2009 04/01/2009 04/01/2009 09/01/2009 10/01/2009 {ID_000746} {ID_000748} {ID_000753} {ID_000754} {ID_000840} {ID_000848} Madden Appendix PM11 “LOG FILES” / ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 Page 3 of 22 Modified - Date and Time 13:09 13:09 13:25 13:25 20:27 07:38 OS Last Accessed - Date and Time 04/01/2009 13:09 04/01/2009 13:09 04/01/2009 13:25 04/01/2009 13:25 09/01/2009 20:27 10/01/2009 07:38 Additional properties external metadata File Capacity 0 Bytes 0 Bytes 1,040 Bytes 1,040 Bytes 15,353 Bytes 15,349 Bytes Ov erview of content of the LOG files 9.Of th e six LOG files in the disclosure dataset: a.The first two, ID_000746 and ID_000748, are empty files with 0 bytes of content. I do notanalyse these further below. b.The second two, ID_000753, and ID_000754, are very short documents which are electronic duplicates (by MD5 hash). My analysis of ID_000753 below applies equally to ID_000754. c.The third two, ID_000840 and ID_000848, are very similar to each other but present specific difference s between them which I address below. 10. T he documents present as software logs. T he shortest are the identical files ID_000753 and ID_000754, which present as follows ( with some long passages of white space removed): sending: version (46 bytes) RandAddSeed() got
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 8 Appendix PM11.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM11.pdf ### File content: Madden Appendix PM11 “LOG FILES” / ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 Page 1 of 22 IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES INTELLECTUAL PROPERTY LIST (ChD) Claim No: IL -2021 -000019 BETWEEN: CRYPTO OPEN PATENT ALLIANCE Claimant -and- DR CRAIG STEVEN WRIGHT Defendant Appendix PM11 LOG FILES ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 1.Th is Appendix addresses the six files in the disclosure dataset which are saved with the extension “.log” : ID_000746 ID_000748 ID_000753 ID_000754 ID_000840 ID_000848 Report structure – related appendix PM12 2. As I explained in my Main Report, I had not initially flagged these files for review, on the basis that they are encoded as simple plain text files which do not typically provide any useful basis for forensic examination. Towards the end of my analysis however , Bird & Bird asked me to look at executable files in the disclosure dataset from a perspective of examining them as any other disclosure document for any information contained within them, and this also led me to identify a potentially relevantexecutable in the form “bitcoin.exe” and to analyse certain plain text ‘log’ files that appeared to be related to “bitcoin.exe”. 3. I have therefore reported on the analysis of log files in this Appendix, and my analysis of the executable is in Appendix PM12. 4. Although these two are very closely related in context, it was helpful to split the review into two documents because the technical approach to the two documents was very different.{ID_000746} {ID_000748} {ID_000753} {ID_000754} {ID_000840} {ID_000848} {H/66} {G/1} {H/66} Madden Appendix PM11 “LOG FILES” / ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 Page 2 of 22 Log files generally 5. The extension “.log” is not indicative of a file format in itself, but is an extension commonly but informally used to save software operation logs. These logs are often, but may not always be, in plain text. The .log files in this disclosure dataset are plain text files. 6. Although “ LOG” is not a standardised file format, that does not matter for the purpose of this analysis as long as it is understood that it is encoded as plain text, and I refer to it in the same way as any other file format here. Limitations of review 7. Being a plain text document, there is relatively little footprint for forensic analysis. I have set out my primary conclusions below in relation to some metadata irregularities in four of the six .log files which contain content which is firmly within my expertise . I have also provided some secondary observations, keeping within my area of expertise. However, these secondary observations are not firm conclusions, in particular where they concern how the log might have interacted with the software that created it. I emphasise that I am not a software developer, and my experience in software coding is only minimal. While I am able to inspect these logs from the perspective offorensic document examination, the interpretation of software logs themselves is not within m y area of expertise, and it should be borne in mind that my secondary observations are subject to these limitations . 8.The provided metadata associated with the six .LOG files listed above is as follows: Metadata field ID_000746 ID_000748 ID_000753 ID_000754 ID_000840 ID_000848 Provided external metadata (OS/file property information) File Name db.log db.log debug.log debug.log debug.log debug.log OS Created -Date and Time 04/01/2009 13:09 04/01/2009 13:09 04/01/2009 13:25 04/01/2009 13:25 09/01/2009 20:27 19/11/2015 16:41 OS Last 04/01/2009 04/01/2009 04/01/2009 04/01/2009 09/01/2009 10/01/2009 {ID_000746} {ID_000748} {ID_000753} {ID_000754} {ID_000840} {ID_000848} Madden Appendix PM11 “LOG FILES” / ID_000746, ID_000748, ID_000753, ID_000754, ID_000840, ID_000848 Page 3 of 22 Modified - Date and Time 13:09 13:09 13:25 13:25 20:27 07:38 OS Last Accessed - Date and Time 04/01/2009 13:09 04/01/2009 13:09 04/01/2009 13:25 04/01/2009 13:25 09/01/2009 20:27 10/01/2009 07:38 Additional properties external metadata File Capacity 0 Bytes 0 Bytes 1,040 Bytes 1,040 Bytes 15,353 Bytes 15,349 Bytes Ov erview of content of the LOG files 9.Of th e six LOG files in the disclosure dataset: a.The first two, ID_000746 and ID_000748, are empty files with 0 bytes of content. I do notanalyse these further below. b.The second two, ID_000753, and ID_000754, are very short documents which are electronic duplicates (by MD5 hash). My analysis of ID_000753 below applies equally to ID_000754. c.The third two, ID_000840 and ID_000848, are very similar to each other but present specific difference s between them which I address below. 10. T he documents present as software logs. T he shortest are the identical files ID_000753 and ID_000754, which present as follows ( with some long passages of white space removed): sending: version (46 bytes) RandAddSeed() got
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Closings
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Q. You had every opportunity in that part of the chain of custody schedule to provide further information if you wanted to, didn't you? A. Yes , I did. Dr Wright admits he had an opportunity to set out in his Chain of Custody the fact that documents were different in some way, but did not take it. {CSW/2/71} CSW 11 Appendix B {Day3/122:18} - {Day3/123:6} Q. What you’re saying is that in order to provide documents for, first of all, the Kleiman litigation and then for these proceedings, you laboriously took entries from a live version of MYOB and entered them in one by one into a non -live version of MYOB and then produced some versions of that? A. No, in multiple ways. Firstly, these were never used in this proceedings. The reason you’re saying your needle in a haystack is that you had people go through every single email I have ever sent and looked for them. That was then part of the litig ation in that case. Next, the log- in for the live version of MYOB was provided to Ontier and AlixPartners in 2019. 2019 precedes this. Dr Wright evades the question about the creation of the MYOB records, providing a confusing reply. {Day3/123:14} - {Day3/124:2} Q. But Dr Wright, what you didn’t explain there was that your part in all of this, in creating these documents, by putting in these entries in March 2020, that wasn’t apparent from the chain of custody, was it? A. No, because I didn’t do that. Your error is you keep missing the fact that I said I had to create another document. My Lord, the litigation in the US didn’t involve Tulip Trading. If I was to bring that in, it would add extra opportunity for Mr Kleiman to seek money from me. So, what I did was separate it. I requested an offline copy so that I could make it so that no online copy of anything from Tulip Trading would go into the American case. Dr Wright claims the MYOB screenshots had to be created new for Kleiman. Dr Wright has provided no evidence that this assertion is correct. Appendix B: Schedule of Transcript References 58 REFERENCE QUOTE COMMENT {Day3/124:19} - {Day3/125:10} Q. Do you say that none of those screenshots that we looked at, 4077, 4078, 4079 or 4090, has anything to do with this case? A. I’m saying that the screenshots taken by Ontier had nothing to do with that file. That file was never given to Ontier, so therefore Ontier could not have, at any point, got screenshots from the file. Q. Well, you said a moment ago that none of these documents had anything to do with this case. That's what you said. A. No, as in the QIF -- sorry, the QIF, the MYOB and the email. Sorry, I'm not specific. Q. The documents that we looked at earlier, 4077, 4078, 4079, that I put on screen, are they documents you say have nothing to do with this case? A. They are documents related to this case that have nothing to do with the other MYOB file. Dr Wright gives muddled answers to evade answering the question. {Day3/125:11} - {Day3/126:6} Q. I'm sorry, Dr Wright, do you say that those documents have relevance to this case and are probative of anything in this case? A. As I just said, they're documents related to this case -- I'll emphasise that again. The screenshots taken by Ontier, when they downloaded, themselves, the online version of this document that has nothin g to do with the one gave in to the American court case, are directly related to this case. The ones that I created in response to Magistrate Reinhart and an order to do so, they, on the other hand, have nothing to do with this case. Q. The documents you s ay that do have something to do with this case, were created by you -- as a result of you having transferred entries from a separate QIF file into MYOB on 6 and 7 March 2020, aren't they? A. No, they're not. And as the chain of custody says, and it comes d irectly from Ontier, those files never touched me. I didn't have a log- in, I didn't download the file, I was never involved. It was directly by paralegals at Ontier. Dr Wright evades a question, instead using the opportunity to further blame third Parties. {L5/150/1} 11- 08-2009 Information Defense Pty Ltd - Bitcoin Token {L5/471/1} 01- 10-2009 Information Defense Pty Ltd - Bitcoin Token {L5/146/1} BCDB - Bitcoin inventory {Day3/127:22} - {Day3/128:9} Q. Now, just to be clear, the findings of Mr Madden, agreed by Dr Placks, were that the entries shown on these documents which we have just seen were as a result of your entries on 6 and 7 March 2020. You dispute that, do you? Dr Wright claims the MYOB screenshots relate to a 2009 account despite providing no evidence for this. Appendix B: Schedule of Transcript References 59 REFERENCE QUOTE COMMENT A. I do, because both of these -- or all of those images were taken by Ont ier prior to that date, so that can't be true. Q. The reality is that these documents resulted from entries which you made in the system in March 2020 and that they're matters of your invention, aren't they? A. No, they're not. They're from an account that I no longer have admin access to that dates back to 2009. {H/209/11} Appendix PM42 (New MYOB Files) {Day3/134:5- 17} Q. Page 16, please {H/209/16}, pa ragraph 51. What Mr Madden then did was to view the session logs in an SQL compact viewer, a tool which shows records in the order that they were added, and he finds log- in and log out records for the session ID which had given the anomalous records, now w ith the log -in and log out records directly with each other but the timestamps out of order; correct? A. No. As I've noted before, the schema updates. This was part of what I put in my witness statement pointing to an MYOB site. The schema in MYOB will upd ate entries and any of these log entries will record when they have been updated. Dr Wright refuses to accept an obvious fact., and avoids a question about logs by answering with a reply about schemas. {Day3/135:10} - {Day3/136:3}
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 23 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: Q. You had every opportunity in that part of the chain of custody schedule to provide further information if you wanted to, didn't you? A. Yes , I did. Dr Wright admits he had an opportunity to set out in his Chain of Custody the fact that documents were different in some way, but did not take it. {CSW/2/71} CSW 11 Appendix B {Day3/122:18} - {Day3/123:6} Q. What you’re saying is that in order to provide documents for, first of all, the Kleiman litigation and then for these proceedings, you laboriously took entries from a live version of MYOB and entered them in one by one into a non -live version of MYOB and then produced some versions of that? A. No, in multiple ways. Firstly, these were never used in this proceedings. The reason you’re saying your needle in a haystack is that you had people go through every single email I have ever sent and looked for them. That was then part of the litig ation in that case. Next, the log- in for the live version of MYOB was provided to Ontier and AlixPartners in 2019. 2019 precedes this. Dr Wright evades the question about the creation of the MYOB records, providing a confusing reply. {Day3/123:14} - {Day3/124:2} Q. But Dr Wright, what you didn’t explain there was that your part in all of this, in creating these documents, by putting in these entries in March 2020, that wasn’t apparent from the chain of custody, was it? A. No, because I didn’t do that. Your error is you keep missing the fact that I said I had to create another document. My Lord, the litigation in the US didn’t involve Tulip Trading. If I was to bring that in, it would add extra opportunity for Mr Kleiman to seek money from me. So, what I did was separate it. I requested an offline copy so that I could make it so that no online copy of anything from Tulip Trading would go into the American case. Dr Wright claims the MYOB screenshots had to be created new for Kleiman. Dr Wright has provided no evidence that this assertion is correct. Appendix B: Schedule of Transcript References 58 REFERENCE QUOTE COMMENT {Day3/124:19} - {Day3/125:10} Q. Do you say that none of those screenshots that we looked at, 4077, 4078, 4079 or 4090, has anything to do with this case? A. I’m saying that the screenshots taken by Ontier had nothing to do with that file. That file was never given to Ontier, so therefore Ontier could not have, at any point, got screenshots from the file. Q. Well, you said a moment ago that none of these documents had anything to do with this case. That's what you said. A. No, as in the QIF -- sorry, the QIF, the MYOB and the email. Sorry, I'm not specific. Q. The documents that we looked at earlier, 4077, 4078, 4079, that I put on screen, are they documents you say have nothing to do with this case? A. They are documents related to this case that have nothing to do with the other MYOB file. Dr Wright gives muddled answers to evade answering the question. {Day3/125:11} - {Day3/126:6} Q. I'm sorry, Dr Wright, do you say that those documents have relevance to this case and are probative of anything in this case? A. As I just said, they're documents related to this case -- I'll emphasise that again. The screenshots taken by Ontier, when they downloaded, themselves, the online version of this document that has nothin g to do with the one gave in to the American court case, are directly related to this case. The ones that I created in response to Magistrate Reinhart and an order to do so, they, on the other hand, have nothing to do with this case. Q. The documents you s ay that do have something to do with this case, were created by you -- as a result of you having transferred entries from a separate QIF file into MYOB on 6 and 7 March 2020, aren't they? A. No, they're not. And as the chain of custody says, and it comes d irectly from Ontier, those files never touched me. I didn't have a log- in, I didn't download the file, I was never involved. It was directly by paralegals at Ontier. Dr Wright evades a question, instead using the opportunity to further blame third Parties. {L5/150/1} 11- 08-2009 Information Defense Pty Ltd - Bitcoin Token {L5/471/1} 01- 10-2009 Information Defense Pty Ltd - Bitcoin Token {L5/146/1} BCDB - Bitcoin inventory {Day3/127:22} - {Day3/128:9} Q. Now, just to be clear, the findings of Mr Madden, agreed by Dr Placks, were that the entries shown on these documents which we have just seen were as a result of your entries on 6 and 7 March 2020. You dispute that, do you? Dr Wright claims the MYOB screenshots relate to a 2009 account despite providing no evidence for this. Appendix B: Schedule of Transcript References 59 REFERENCE QUOTE COMMENT A. I do, because both of these -- or all of those images were taken by Ont ier prior to that date, so that can't be true. Q. The reality is that these documents resulted from entries which you made in the system in March 2020 and that they're matters of your invention, aren't they? A. No, they're not. They're from an account that I no longer have admin access to that dates back to 2009. {H/209/11} Appendix PM42 (New MYOB Files) {Day3/134:5- 17} Q. Page 16, please {H/209/16}, pa ragraph 51. What Mr Madden then did was to view the session logs in an SQL compact viewer, a tool which shows records in the order that they were added, and he finds log- in and log out records for the session ID which had given the anomalous records, now w ith the log -in and log out records directly with each other but the timestamps out of order; correct? A. No. As I've noted before, the schema updates. This was part of what I put in my witness statement pointing to an MYOB site. The schema in MYOB will upd ate entries and any of these log entries will record when they have been updated. Dr Wright refuses to accept an obvious fact., and avoids a question about logs by answering with a reply about schemas. {Day3/135:10} - {Day3/136:3}
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7 See {Day5/180:2} – intervention by Lord Grabiner KC. 10 20. It is COPA’s case that Dr Wright produced these forgeries himself or alternatively (if others were somehow involved) he at least knew that he was presenting false evidence. Furthermore, Dr Wright’s forg eries and lies are not merely historic. This is not a case of some past forgeries being exposed, but a scheme of forgery and lies continually adapting and re -inventing itself (most recently with the BDO Drive in September 2023 and the Overleaf LaTeX files in November / December 2023). Once one aspect of Dr Wright’s story is discredited, he supplements it with yet further forgeries, moves his story in a different direction and casts blame on others (often casting lawyers and experts as his scapegoats, to t ake advantage of legal professional privilege). 21. In this skeleton, COPA presents its case in three parts: 21.1. Use of false and forged documents : Dr Wright has produced a large number of false and forged documents, manipulated in such a way as to give support to many aspects of his story. The forged documents are of numerous kinds, and they demonstrate a wide range of techniques of forgery. In a ccordance with orders of the Court, COPA has (a) pleaded 50 forgeries from Dr Wright’s original disclosure, while agreeing to focus upon 20 of those; and (b) pleaded a further 20 forgeries from the “new” documents which Dr Wright supposedly found between September and November 2023. 21.2. Failures of proof : Despite having the strongest incentives to do so, Dr Wright has failed to supply evidence which might actually support his claim to be Satoshi, such as by producing verifiable emails or draft documents from 2007- 2009 or by offering reliable cryptographic proof of his control of Bitcoin addresses linked to blocks associated with Satoshi. Indeed, not only has Dr Wright not taken such steps, he has on key occasions undertaken to do so and then fa iled to come good on his promise. Two examples are (a) his signal failure to undertake a public key signing or transaction in May 2016 and (b) his empty boast that he could prove purchase of Satoshi’s email account and web domain. 21.3. Inconsistent and implaus ible account : Dr Wright’s account is full of inconsistent and implausible features. The inconsistencies are both internal (in the sense that Dr Wright’s own story has changed) and external (where Dr Wright’s story 11 conflicts with reliable evidence or estab lished fact). Furthermore, certain aspects of Dr Wright’s story are simply so incredible they cannot be believed. The Factual Background 22. The Court is aware of the background to these proceedings. The following is a summary which provides context to the i ssues for trial. A word of caution: because COPA’s position is that Dr Wright is lying about all aspects of his claim to be Satoshi, any reference to his version of events should not be read as COPA accepting it. 23. COPA now adds to the below further matters which have emerged or been confirmed during the evidence at trial. Digital Cash before Bitcoin 24. Concepts of digital cash date back to the early 1980s, when an American cryptographer called David Chaum proposed a form of token currency which could be transf erred safely between individuals, supported by encryption tools. In the 1990s, several further electronic currency systems were proposed, including E -Gold (Dr Jackson and Mr Downey); Bit Gold (Nick Szabo); B -Money (Wei Dai); and Hashcash (Adam Back). Hashcash used a proof -of-work algorithm, as many modern cryptocurrencies do. The expression “ block chaining” in the context of cryptographic cyphers dates back to the 1970s, 8 while public discussion of Hashcash in the late 1990s used the expression “ block chain” in the context of data structures.9 Satoshi’s Release of Bitcoin Satoshi’s initial communications and release of the Bitcoin White Paper 25. Bitcoin is based on concepts first set out in the Bitcoin White Paper (“ the White Paper”), the full title of w hich was: “Bitcoin: A Peer -to-Peer Electronic Cash System”. It was written by Satoshi Nakamoto, which is agreed to be a pseudonym. In late August 2008, Satoshi contacted Dr Back by email, referring him to a draft of the White Paper hosted 8 See US Patent 4074066, 1976: “ Message verification and transmission error detection by block chaining” (Ehrsam et al.). 9 See for example: http://mailing -list- archive.cryptoanarchy.wiki/archive/1997/12/e080a2180e912b9b129e8be3e4d114421b0c9bc11217ac2e40b3b8f1 12305572 12 on the “upload.ae” site and asking to check a reference to his paper on Hashcash.10 Dr Back replied, informing Satoshi about Wei Dai’s B -Money Paper.11 Satoshi then wrote to Wei Dai to check the reference for that paper.12 These early emails contain abstracts of the draft paper. It should be noted that the Satoshi / Wei Dai emails were published before these proceedings, while the Satoshi / Adam Back emails were not. 26. On 31 October 2008, Satoshi released the White Paper by sending an email to the “metzdowd cryptography mailing list” (“ the Metzdowd List ”) (a group of individuals interested in cryptography) and directing them to a link on the “bitcoin.org” site, where the document was hosted. 13 From around 9 November 2008, the White Paper was also hosted on a document repository, SourceForge. The final version of the White Paper was posted on SourceForge.net on 24 March 2009,14 and published under the MIT License.15 27. The White Paper describes a system for electronic payments, whereby transactions may be made between participants without a central trusted intermediary. It uses cryptographic signatures and addresses the risk of double -spending by transactions being recorded in blocks, validated by proof -of-work. It is further described in the section of this skeleton headed “Overview of Cryptocurrency Technology”. 28. A number of email addresses have been associated with Satoshi. These have included: [email protected]; [email protected] ; and [email protected] . The last of those three was used in the emails to A dam Back and Wei Dai of late August 2008, while the first was used to post the White Paper in October 2008. 29. Over the period from 31 October 2008 to January 2009, Satoshi wrote a series of emails to the Metzdowd List. In one, dated 8 November 2008, Satoshi explained that the code had been written before the White Paper. 16 In another, dated 14 November 2008, Satoshi claimed to be “better with code than with words ”. In a third, dated 17 November 2008, Satoshi wrote of having worked through various “ little d etails over the last year and a 10 See email of 20 August
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 4 of 82 COPA's Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/COPA's Closing Submissions.pdf ### File content: 7 See {Day5/180:2} – intervention by Lord Grabiner KC. 10 20. It is COPA’s case that Dr Wright produced these forgeries himself or alternatively (if others were somehow involved) he at least knew that he was presenting false evidence. Furthermore, Dr Wright’s forg eries and lies are not merely historic. This is not a case of some past forgeries being exposed, but a scheme of forgery and lies continually adapting and re -inventing itself (most recently with the BDO Drive in September 2023 and the Overleaf LaTeX files in November / December 2023). Once one aspect of Dr Wright’s story is discredited, he supplements it with yet further forgeries, moves his story in a different direction and casts blame on others (often casting lawyers and experts as his scapegoats, to t ake advantage of legal professional privilege). 21. In this skeleton, COPA presents its case in three parts: 21.1. Use of false and forged documents : Dr Wright has produced a large number of false and forged documents, manipulated in such a way as to give support to many aspects of his story. The forged documents are of numerous kinds, and they demonstrate a wide range of techniques of forgery. In a ccordance with orders of the Court, COPA has (a) pleaded 50 forgeries from Dr Wright’s original disclosure, while agreeing to focus upon 20 of those; and (b) pleaded a further 20 forgeries from the “new” documents which Dr Wright supposedly found between September and November 2023. 21.2. Failures of proof : Despite having the strongest incentives to do so, Dr Wright has failed to supply evidence which might actually support his claim to be Satoshi, such as by producing verifiable emails or draft documents from 2007- 2009 or by offering reliable cryptographic proof of his control of Bitcoin addresses linked to blocks associated with Satoshi. Indeed, not only has Dr Wright not taken such steps, he has on key occasions undertaken to do so and then fa iled to come good on his promise. Two examples are (a) his signal failure to undertake a public key signing or transaction in May 2016 and (b) his empty boast that he could prove purchase of Satoshi’s email account and web domain. 21.3. Inconsistent and implaus ible account : Dr Wright’s account is full of inconsistent and implausible features. The inconsistencies are both internal (in the sense that Dr Wright’s own story has changed) and external (where Dr Wright’s story 11 conflicts with reliable evidence or estab lished fact). Furthermore, certain aspects of Dr Wright’s story are simply so incredible they cannot be believed. The Factual Background 22. The Court is aware of the background to these proceedings. The following is a summary which provides context to the i ssues for trial. A word of caution: because COPA’s position is that Dr Wright is lying about all aspects of his claim to be Satoshi, any reference to his version of events should not be read as COPA accepting it. 23. COPA now adds to the below further matters which have emerged or been confirmed during the evidence at trial. Digital Cash before Bitcoin 24. Concepts of digital cash date back to the early 1980s, when an American cryptographer called David Chaum proposed a form of token currency which could be transf erred safely between individuals, supported by encryption tools. In the 1990s, several further electronic currency systems were proposed, including E -Gold (Dr Jackson and Mr Downey); Bit Gold (Nick Szabo); B -Money (Wei Dai); and Hashcash (Adam Back). Hashcash used a proof -of-work algorithm, as many modern cryptocurrencies do. The expression “ block chaining” in the context of cryptographic cyphers dates back to the 1970s, 8 while public discussion of Hashcash in the late 1990s used the expression “ block chain” in the context of data structures.9 Satoshi’s Release of Bitcoin Satoshi’s initial communications and release of the Bitcoin White Paper 25. Bitcoin is based on concepts first set out in the Bitcoin White Paper (“ the White Paper”), the full title of w hich was: “Bitcoin: A Peer -to-Peer Electronic Cash System”. It was written by Satoshi Nakamoto, which is agreed to be a pseudonym. In late August 2008, Satoshi contacted Dr Back by email, referring him to a draft of the White Paper hosted 8 See US Patent 4074066, 1976: “ Message verification and transmission error detection by block chaining” (Ehrsam et al.). 9 See for example: http://mailing -list- archive.cryptoanarchy.wiki/archive/1997/12/e080a2180e912b9b129e8be3e4d114421b0c9bc11217ac2e40b3b8f1 12305572 12 on the “upload.ae” site and asking to check a reference to his paper on Hashcash.10 Dr Back replied, informing Satoshi about Wei Dai’s B -Money Paper.11 Satoshi then wrote to Wei Dai to check the reference for that paper.12 These early emails contain abstracts of the draft paper. It should be noted that the Satoshi / Wei Dai emails were published before these proceedings, while the Satoshi / Adam Back emails were not. 26. On 31 October 2008, Satoshi released the White Paper by sending an email to the “metzdowd cryptography mailing list” (“ the Metzdowd List ”) (a group of individuals interested in cryptography) and directing them to a link on the “bitcoin.org” site, where the document was hosted. 13 From around 9 November 2008, the White Paper was also hosted on a document repository, SourceForge. The final version of the White Paper was posted on SourceForge.net on 24 March 2009,14 and published under the MIT License.15 27. The White Paper describes a system for electronic payments, whereby transactions may be made between participants without a central trusted intermediary. It uses cryptographic signatures and addresses the risk of double -spending by transactions being recorded in blocks, validated by proof -of-work. It is further described in the section of this skeleton headed “Overview of Cryptocurrency Technology”. 28. A number of email addresses have been associated with Satoshi. These have included: [email protected]; [email protected] ; and [email protected] . The last of those three was used in the emails to A dam Back and Wei Dai of late August 2008, while the first was used to post the White Paper in October 2008. 29. Over the period from 31 October 2008 to January 2009, Satoshi wrote a series of emails to the Metzdowd List. In one, dated 8 November 2008, Satoshi explained that the code had been written before the White Paper. 16 In another, dated 14 November 2008, Satoshi claimed to be “better with code than with words ”. In a third, dated 17 November 2008, Satoshi wrote of having worked through various “ little d etails over the last year and a 10 See email of 20 August
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of the information at the relevant part in each section of the relevant Appendix and explained the way it was sourced and the purpose of it: a. I n cases where my research has revealed documents for comparative analysis, I have not assumed the documents obtained to be genuine but have scrutinised them to for m m y own view. I n cases where my research has involved checking an incidental fact in the course of a wider contextual review, the factual check is clearly set out in the cours e of my analysis . b. O verall, I have generally taken the content of the Internet Archive Wayback Machine t o b e a reliable archive of the material it contains. As an independ ently operated fr ee DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{M/2/712-717} M/2/769-773} M/2/951-960 First Expert Report of Patrick Madden Page 11 of 98 11service , it is run by the not -for-profit organisation Internet Archive. It operates by way of an automated process that “crawls” the Internet, taking periodic snapshots of Internet content when it registers that a change has occurred. It is not a comprehensive catalogue, and it is possible that it has missed content due to the timing betw een snapshots or the nature of the content of a we bsite. It is generally accepted in the industry, however, that it is accurate regarding what is captured. c.I have also generally taken documents, such as font files and product manuals relati ng t o software , to be genuine where they are obtained from an official source . d. H owever, any conclusions I have drawn from third party information are only as str ong a s the source of information itself. I am aware that it is not my role to decide on the reliability of factual points in the case and do not form an opinion on the reliability offactual matters, instead setting out the steps taken and what I draw from the information. THE APPROACH I HAVE TAKEN TO CONDUCTING MY ANALYSIS The meaning of “authenticity ” generally 23. The purpose of my examination is to investigate the authenticity of documents in the disclosure dataset . The authenticity of a document may in general be : a.Authentic: In some cases, it is possible to conclude that a document is genuine ( or ver y likely to be genuine), taking into account all the circumstances such as its content , pur ported date and time of authorship, and any external factors. In other cases, a d ocument may not be able to be established to be au thentic out of context, but there may be no pro blems that lead its authenticity to be doubted. In those cases it can b e t aken at face value. b. Inauthentic : In other cases, it is possible to conclude that a document is inauthentic, taking account of these circumstances. A document may be ‘in authentic’ in more tha n one sense, for example it may have been created at a different time to the purporte d da te, or it may be based on the genuine content of a document but then been back- dated by altering metadata , or it may be based on a document that is genuine to the time period, but the content may have been altered . DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 12 of 98 12c. Unreliable: in some cases there may be issues with a document that call its authenticity into question, but where without more information it is not possible to conclude whether a document is genuine or not genuine. It is however possible to conclude thatthe circumstances mean that it is unreliable, unless more information is provided whichexplains the issues satisfactorily. 24. T herefore , the concept of the ‘authenticit y’ of a document is not absolute but depends on a number of factors. 25.I t is important to bear in mind that just because a document does not reflect the same content as when it is created, that does not mean it has been manipulated or altered from the perspective ofan authenticity review. It is very common for documents to be created in one form, and adde d t o or edited over time. Simple editing does not therefore render a document inauthentic. The authenticity of a document depends not just on its content, but also on the context in which it is provide d. 26.A s a general example, it is possible for someone to create a painting in the style of a famou s a rtist, but that does not make it inauthentic on its own ; it is only when they add a copy of the artist’s signature or try to offer it for sale as a genuine article that it becomes inauthentic to th e c ontext in which it is presented. It would not be called a forgery just because it looks the same, only if it is created and then is held out to be something original to the artist, or original to a particular date or circumstances that are not true. 27. W hen investigating digital documents, the same principle applies. The question is not whether a document was created and preserved without editing: the question is whether the content of the document matches the context in which it is presented. This context can include things like : a.T he type of content in the document – for example, a signature or indication of provenance may be more significant than other content , similar to in the painting example above, b. T he date from which it purports to originate, whether on its face or in the as sociated metadata , and whether this is accurate to its actual authorship . c. I n legal cases, whether it is relied on or given in evidence. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 13 of 98 13d. I n legal cases, it can also matter whether the content of the document appears to b e r elevant to the issue in dispute or not (at least based on my general understanding of the dispute) . 28.A ll this means that when a document that is provided with little or no context or metadata, it is not necessarily possible to assess whether it is ‘inauthentic’ or ‘forged’. In some cases, when a doc ument is provided with metadata to suggest that it was created on an earlier date however , or is relied on as being evidential, the question becomes whether it is authentic to that date or to the issue that is being proved. General approach to review 29. With this in mind, it is necessary to take each document with an open mind and in context. In conducting my review, I examined the disclosure dataset provided as a whole, across it s br eadth. In doing so I adopted the following general approach: a.I approached each document first by looking at, reading
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 4 of 27 First Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/First Expert Report of Patrick Madden.pdf ### File content: of the information at the relevant part in each section of the relevant Appendix and explained the way it was sourced and the purpose of it: a. I n cases where my research has revealed documents for comparative analysis, I have not assumed the documents obtained to be genuine but have scrutinised them to for m m y own view. I n cases where my research has involved checking an incidental fact in the course of a wider contextual review, the factual check is clearly set out in the cours e of my analysis . b. O verall, I have generally taken the content of the Internet Archive Wayback Machine t o b e a reliable archive of the material it contains. As an independ ently operated fr ee DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{M/2/712-717} M/2/769-773} M/2/951-960 First Expert Report of Patrick Madden Page 11 of 98 11service , it is run by the not -for-profit organisation Internet Archive. It operates by way of an automated process that “crawls” the Internet, taking periodic snapshots of Internet content when it registers that a change has occurred. It is not a comprehensive catalogue, and it is possible that it has missed content due to the timing betw een snapshots or the nature of the content of a we bsite. It is generally accepted in the industry, however, that it is accurate regarding what is captured. c.I have also generally taken documents, such as font files and product manuals relati ng t o software , to be genuine where they are obtained from an official source . d. H owever, any conclusions I have drawn from third party information are only as str ong a s the source of information itself. I am aware that it is not my role to decide on the reliability of factual points in the case and do not form an opinion on the reliability offactual matters, instead setting out the steps taken and what I draw from the information. THE APPROACH I HAVE TAKEN TO CONDUCTING MY ANALYSIS The meaning of “authenticity ” generally 23. The purpose of my examination is to investigate the authenticity of documents in the disclosure dataset . The authenticity of a document may in general be : a.Authentic: In some cases, it is possible to conclude that a document is genuine ( or ver y likely to be genuine), taking into account all the circumstances such as its content , pur ported date and time of authorship, and any external factors. In other cases, a d ocument may not be able to be established to be au thentic out of context, but there may be no pro blems that lead its authenticity to be doubted. In those cases it can b e t aken at face value. b. Inauthentic : In other cases, it is possible to conclude that a document is inauthentic, taking account of these circumstances. A document may be ‘in authentic’ in more tha n one sense, for example it may have been created at a different time to the purporte d da te, or it may be based on the genuine content of a document but then been back- dated by altering metadata , or it may be based on a document that is genuine to the time period, but the content may have been altered . DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 12 of 98 12c. Unreliable: in some cases there may be issues with a document that call its authenticity into question, but where without more information it is not possible to conclude whether a document is genuine or not genuine. It is however possible to conclude thatthe circumstances mean that it is unreliable, unless more information is provided whichexplains the issues satisfactorily. 24. T herefore , the concept of the ‘authenticit y’ of a document is not absolute but depends on a number of factors. 25.I t is important to bear in mind that just because a document does not reflect the same content as when it is created, that does not mean it has been manipulated or altered from the perspective ofan authenticity review. It is very common for documents to be created in one form, and adde d t o or edited over time. Simple editing does not therefore render a document inauthentic. The authenticity of a document depends not just on its content, but also on the context in which it is provide d. 26.A s a general example, it is possible for someone to create a painting in the style of a famou s a rtist, but that does not make it inauthentic on its own ; it is only when they add a copy of the artist’s signature or try to offer it for sale as a genuine article that it becomes inauthentic to th e c ontext in which it is presented. It would not be called a forgery just because it looks the same, only if it is created and then is held out to be something original to the artist, or original to a particular date or circumstances that are not true. 27. W hen investigating digital documents, the same principle applies. The question is not whether a document was created and preserved without editing: the question is whether the content of the document matches the context in which it is presented. This context can include things like : a.T he type of content in the document – for example, a signature or indication of provenance may be more significant than other content , similar to in the painting example above, b. T he date from which it purports to originate, whether on its face or in the as sociated metadata , and whether this is accurate to its actual authorship . c. I n legal cases, whether it is relied on or given in evidence. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 13 of 98 13d. I n legal cases, it can also matter whether the content of the document appears to b e r elevant to the issue in dispute or not (at least based on my general understanding of the dispute) . 28.A ll this means that when a document that is provided with little or no context or metadata, it is not necessarily possible to assess whether it is ‘inauthentic’ or ‘forged’. In some cases, when a doc ument is provided with metadata to suggest that it was created on an earlier date however , or is relied on as being evidential, the question becomes whether it is authentic to that date or to the issue that is being proved. General approach to review 29. With this in mind, it is necessary to take each document with an open mind and in context. In conducting my review, I examined the disclosure dataset provided as a whole, across it s br eadth. In doing so I adopted the following general approach: a.I approached each document first by looking at, reading
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confirmation, the recipient faces minimal, if any, ongoing risk of fraud from the transferer . There remains an ever diminishing risk of a block re -org resulting in a lost tra nsaction but after multiple blocks, this becomes a near zero probability. Madden Appendix PM 37 “Bitcoin (law) ” / ID_00 0569, ID_00 3929, and ID_004028 Page 5 of 11 an d last saved immediately following ID_000568, suggesting a close contextual link between the documents . The fact that both appear to have been generated by importing content (e.g. by a copy paste operation) may suggest that the content was imported from a common source (although I am not an expert in the subject matter of the content of either document and do not come to any view as to whether the content of the two documents is contextually similar). 18. To aid my contextual review, I conducted internet searches for passages of content which led me to a post on the URL https://craigwright.net/blog/bitcoin -blockchain -tech/bitcoin -in-law/ titled “Bitcoin in law”. It is recorded as having been posted on 18 December 2018 as per the partial screenshot below: 19. The blog post exhibits a close similarity to the content of ID_000569. A side -by-side comparison follows (I have added l ine breaks and highlight ing to aid review ): Bitcoin in law post ID_000569 On confirmation, the recipien t faces minimal, if any, ongoing risk of fraud from the transferer (Alice, A). There remains an ever diminishing risk of a block re -org resulting in a lost transaction, but after multiple blocks, it becomes a near -zero probability. On confirmation, the recipient faces minimal, if any, ongoing risk of fraud from the transferer . There remains an ever diminishing risk of a block re -org resulting in a lost tra nsaction but after multiple blocks, this becomes a near zero probability. 5 - 5 - H/144/5{ID_000568} {ID_000569} Madden Appendix PM 37 “Bitcoin (law) ” / ID_00 0569, ID_00 3929, and ID_004028 Page 6 of 11 Even on a 0 -conf transaction, the risk to Bob (B) is minimal as long as B has checked a node (or multiple nodes to be more certain). U sing the API (RPC) call to a Bitcoin node, the merchant can use the call gettxout. If it return s anything, then the output is unspent (at least as reported by that node). If nothing is returned, we know that the output either never existed or has already been spent. In an SPV, where we know the transaction path, and we know it existed, the option is that a transaction has not been spent, or a merchant could have a double spend. W ithout explicit collusion from A and a miner, and this is probabilistic at best and not in any miner’s interest, the simple addition of a transaction (TX) into the mempool is good delivery. T he rules of property and the rules of currency differ significantly. Under the ordinary rules of personal -property (1) transfer, the transferee obtains only the title originally held by the transferer. S o, A cannot give a better title to B than A has in ordinary property law. As a consequence, if a tokenised asset (not currency) is stolen from a party and passed to another, then the receiver cannot receive the full title. In this, ifA has property stolen by M, and M (Malicious Mark) passes it to B, then A has a right of recovery from B, even where B received no notice of an adverse claim. I n Bitcoin, a tokenised asset can be linked and registered to a key, but also to the individual’s identity (such as through a PKI-based key registration process). In this process, A can seek to repudiate a transaction to other parties, and seek redress in court. The international basis of Bitcoin can make this process more difficult and add further complications, but the use of tokenised “sub a ssets” acts to allow property ledgers, which act using the commodity value of Bitcoin without necessitating the currency use.E ven on a 0- conf transaction, the risk to is minimal as long as has checked a node (or multiple nodes to be more certain). W ithout explicit collusion from and a miner, and this is probabilistic at best and not in any miners’ interest, the simple addition of a into the mempool is good delivery. T he rules of property and the rules of currency differ significantly. Under the ordinary rules of personal property (11) transfer, the transferee obtains only the title originally held by the transferer. S o, cannot give better title to than has in ordinary property law. As a consequence, if a tokenised asset ( not currency) is stolen from a party and passed to another, then the receiver cannot receive full title. In this, if has property stolen by and passes to this to , then has a right of rec overy from even where received no notice of an adverse claim. I n Bitcoin, a tokenised asset can be linked and registered to not only a key, but to the individual’s identity (such as through a PKI based key registration process). In this process, can seek to repudiate a transaction to other parties and seek redress in court. The international basis of bitcoin can make this process more difficult and add further complications, but the use of tokenised “sub assets” acts to allow property ledgers which act using the commodity value of Bitcoin without necessitating the currency use. Madden
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 4 of 8 Appendix PM37.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM37.pdf ### File content: confirmation, the recipient faces minimal, if any, ongoing risk of fraud from the transferer . There remains an ever diminishing risk of a block re -org resulting in a lost tra nsaction but after multiple blocks, this becomes a near zero probability. Madden Appendix PM 37 “Bitcoin (law) ” / ID_00 0569, ID_00 3929, and ID_004028 Page 5 of 11 an d last saved immediately following ID_000568, suggesting a close contextual link between the documents . The fact that both appear to have been generated by importing content (e.g. by a copy paste operation) may suggest that the content was imported from a common source (although I am not an expert in the subject matter of the content of either document and do not come to any view as to whether the content of the two documents is contextually similar). 18. To aid my contextual review, I conducted internet searches for passages of content which led me to a post on the URL https://craigwright.net/blog/bitcoin -blockchain -tech/bitcoin -in-law/ titled “Bitcoin in law”. It is recorded as having been posted on 18 December 2018 as per the partial screenshot below: 19. The blog post exhibits a close similarity to the content of ID_000569. A side -by-side comparison follows (I have added l ine breaks and highlight ing to aid review ): Bitcoin in law post ID_000569 On confirmation, the recipien t faces minimal, if any, ongoing risk of fraud from the transferer (Alice, A). There remains an ever diminishing risk of a block re -org resulting in a lost transaction, but after multiple blocks, it becomes a near -zero probability. On confirmation, the recipient faces minimal, if any, ongoing risk of fraud from the transferer . There remains an ever diminishing risk of a block re -org resulting in a lost tra nsaction but after multiple blocks, this becomes a near zero probability. 5 - 5 - H/144/5{ID_000568} {ID_000569} Madden Appendix PM 37 “Bitcoin (law) ” / ID_00 0569, ID_00 3929, and ID_004028 Page 6 of 11 Even on a 0 -conf transaction, the risk to Bob (B) is minimal as long as B has checked a node (or multiple nodes to be more certain). U sing the API (RPC) call to a Bitcoin node, the merchant can use the call gettxout. If it return s anything, then the output is unspent (at least as reported by that node). If nothing is returned, we know that the output either never existed or has already been spent. In an SPV, where we know the transaction path, and we know it existed, the option is that a transaction has not been spent, or a merchant could have a double spend. W ithout explicit collusion from A and a miner, and this is probabilistic at best and not in any miner’s interest, the simple addition of a transaction (TX) into the mempool is good delivery. T he rules of property and the rules of currency differ significantly. Under the ordinary rules of personal -property (1) transfer, the transferee obtains only the title originally held by the transferer. S o, A cannot give a better title to B than A has in ordinary property law. As a consequence, if a tokenised asset (not currency) is stolen from a party and passed to another, then the receiver cannot receive the full title. In this, ifA has property stolen by M, and M (Malicious Mark) passes it to B, then A has a right of recovery from B, even where B received no notice of an adverse claim. I n Bitcoin, a tokenised asset can be linked and registered to a key, but also to the individual’s identity (such as through a PKI-based key registration process). In this process, A can seek to repudiate a transaction to other parties, and seek redress in court. The international basis of Bitcoin can make this process more difficult and add further complications, but the use of tokenised “sub a ssets” acts to allow property ledgers, which act using the commodity value of Bitcoin without necessitating the currency use.E ven on a 0- conf transaction, the risk to is minimal as long as has checked a node (or multiple nodes to be more certain). W ithout explicit collusion from and a miner, and this is probabilistic at best and not in any miners’ interest, the simple addition of a into the mempool is good delivery. T he rules of property and the rules of currency differ significantly. Under the ordinary rules of personal property (11) transfer, the transferee obtains only the title originally held by the transferer. S o, cannot give better title to than has in ordinary property law. As a consequence, if a tokenised asset ( not currency) is stolen from a party and passed to another, then the receiver cannot receive full title. In this, if has property stolen by and passes to this to , then has a right of rec overy from even where received no notice of an adverse claim. I n Bitcoin, a tokenised asset can be linked and registered to not only a key, but to the individual’s identity (such as through a PKI based key registration process). In this process, can seek to repudiate a transaction to other parties and seek redress in court. The international basis of bitcoin can make this process more difficult and add further complications, but the use of tokenised “sub assets” acts to allow property ledgers which act using the commodity value of Bitcoin without necessitating the currency use. Madden
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not been necessary for most of my analysis in this Report. It nevertheless remains an excellent tool for forensic analysis and presents information of value. Filename 24. It can also be noted that the filename provided for ID_000570 within the disclosure dataset (“natives00000106 (2).DOC” ) is not typical of a user document but more akin to that of a disclosure export. This suggests to me that the file name given is not the original filename of the document. Summary 25. An inspection of ID_000568 and ID_000570 has identified a number of anomalous characteristics. 26. I t is my opinion that they are not authentic and cannot be relied on as authentic to their purported dates of creation or last editing in 2008 for the following reasons:9 - 9 - H/143/9{ID_000570} {ID_000570} {ID_000568} {ID_000570}{G/1} Madden Appendix PM 36 “BITCOIN notes vs commodity” / ID_00 0568and ID_0 03928, and ID_000570 Page 10of 10 a. T he very long E dit Time exhibited by the documents, which also overlaps with other documents in the dataset, leads me to doubt the circumstances of their creation . In my opinion, the characteristics shown are indicative of clock manipulation techniques and inconsistent with ordinary user behaviour. b. The fact that ID _000570 and ID_000568 are almost identical but contain significant differences in their metadata content (including an impossible “ Edit Time” for ID_000570 which is 90 minutes longer than the entire time between its creation and last saved) leads me to the conclusion that the metadata in one or both documents has been altered. c. The embed ded root entry timestamp of ID_000570, 31/01/2020 at 14:04:43 UTC, postdates the purported authorship of the document by more than 11 years. This could however be the resul t of the handling of the document . d. The embedded metadata content of ID_000568 contains references to Microsoft Word schemas dating from 2010 which post- dates the purported date of creation of ID_000568. e. T he embedded metadata content of ID_000570 contains references to Microsoft Word schemas dating from 2010 and 2012, and to the fonts Calibri Light and Nirmala UI, which did not exist at the purported date of creation of ID_000570. f. T he documents are DOC fi les but include embedded XML content, characteristic of content in the documents having been imported from a pre-existing DOCX document. No equivalent DOCX document has been disclosed in the dataset, however. 27. Considering these points, I do not believe that ID_000568 (and its duplicate , ID_003928) or ID_000570 are authentic to their purported October 2008 creation dates. Madden Appendix PM 36 “BITCOIN notes vs commodity” / ID_00 0568and ID_0 03928, and ID_000570 Page 10of 10 a. T he very long E dit Time exhibited by the documents, which also overlaps with other documents in the dataset, leads me to doubt the circumstances of their creation . In my opinion, the characteristics shown are indicative of clock manipulation techniques and inconsistent with ordinary user behaviour. b. The fact that ID _000570 and ID_000568 are almost identical but contain significant differences in their metadata content (including an impossible “ Edit Time” for ID_000570 which is 90 minutes longer than the entire time between its creation and last saved) leads me to the conclusion that the metadata in one or both documents has been altered. c. The embed ded root entry timestamp of ID_000570, 31/01/2020 at 14:04:43 UTC, postdates the purported authorship of the document by more than 11 years. This could however be the resul t of the handling of the document . d. The embedded metadata content of ID_000568 contains references to Microsoft Word schemas dating from 2010 which post- dates the purported date of creation of ID_000568. e. T he embedded metadata content of ID_000570 contains references to Microsoft Word schemas dating from 2010 and 2012, and to the fonts Calibri Light and Nirmala UI, which did not exist at the purported date of creation of ID_000570. f. T he documents are DOC fi les but include embedded XML content, characteristic of content in the documents having been imported from a pre-existing DOCX document. No equivalent DOCX document has been disclosed in the dataset, however. 27. Considering these points, I do not believe that ID_000568 (and its duplicate , ID_003928) or ID_000570 are authentic to their purported October 2008 creation dates. 10 - 10 - H/143/10{ID_000568} {ID_000570} {ID_000568} {ID_003928} {ID_000570}
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 7 of 7 Appendix PM36.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM36.pdf ### File content: not been necessary for most of my analysis in this Report. It nevertheless remains an excellent tool for forensic analysis and presents information of value. Filename 24. It can also be noted that the filename provided for ID_000570 within the disclosure dataset (“natives00000106 (2).DOC” ) is not typical of a user document but more akin to that of a disclosure export. This suggests to me that the file name given is not the original filename of the document. Summary 25. An inspection of ID_000568 and ID_000570 has identified a number of anomalous characteristics. 26. I t is my opinion that they are not authentic and cannot be relied on as authentic to their purported dates of creation or last editing in 2008 for the following reasons:9 - 9 - H/143/9{ID_000570} {ID_000570} {ID_000568} {ID_000570}{G/1} Madden Appendix PM 36 “BITCOIN notes vs commodity” / ID_00 0568and ID_0 03928, and ID_000570 Page 10of 10 a. T he very long E dit Time exhibited by the documents, which also overlaps with other documents in the dataset, leads me to doubt the circumstances of their creation . In my opinion, the characteristics shown are indicative of clock manipulation techniques and inconsistent with ordinary user behaviour. b. The fact that ID _000570 and ID_000568 are almost identical but contain significant differences in their metadata content (including an impossible “ Edit Time” for ID_000570 which is 90 minutes longer than the entire time between its creation and last saved) leads me to the conclusion that the metadata in one or both documents has been altered. c. The embed ded root entry timestamp of ID_000570, 31/01/2020 at 14:04:43 UTC, postdates the purported authorship of the document by more than 11 years. This could however be the resul t of the handling of the document . d. The embedded metadata content of ID_000568 contains references to Microsoft Word schemas dating from 2010 which post- dates the purported date of creation of ID_000568. e. T he embedded metadata content of ID_000570 contains references to Microsoft Word schemas dating from 2010 and 2012, and to the fonts Calibri Light and Nirmala UI, which did not exist at the purported date of creation of ID_000570. f. T he documents are DOC fi les but include embedded XML content, characteristic of content in the documents having been imported from a pre-existing DOCX document. No equivalent DOCX document has been disclosed in the dataset, however. 27. Considering these points, I do not believe that ID_000568 (and its duplicate , ID_003928) or ID_000570 are authentic to their purported October 2008 creation dates. Madden Appendix PM 36 “BITCOIN notes vs commodity” / ID_00 0568and ID_0 03928, and ID_000570 Page 10of 10 a. T he very long E dit Time exhibited by the documents, which also overlaps with other documents in the dataset, leads me to doubt the circumstances of their creation . In my opinion, the characteristics shown are indicative of clock manipulation techniques and inconsistent with ordinary user behaviour. b. The fact that ID _000570 and ID_000568 are almost identical but contain significant differences in their metadata content (including an impossible “ Edit Time” for ID_000570 which is 90 minutes longer than the entire time between its creation and last saved) leads me to the conclusion that the metadata in one or both documents has been altered. c. The embed ded root entry timestamp of ID_000570, 31/01/2020 at 14:04:43 UTC, postdates the purported authorship of the document by more than 11 years. This could however be the resul t of the handling of the document . d. The embedded metadata content of ID_000568 contains references to Microsoft Word schemas dating from 2010 which post- dates the purported date of creation of ID_000568. e. T he embedded metadata content of ID_000570 contains references to Microsoft Word schemas dating from 2010 and 2012, and to the fonts Calibri Light and Nirmala UI, which did not exist at the purported date of creation of ID_000570. f. T he documents are DOC fi les but include embedded XML content, characteristic of content in the documents having been imported from a pre-existing DOCX document. No equivalent DOCX document has been disclosed in the dataset, however. 27. Considering these points, I do not believe that ID_000568 (and its duplicate , ID_003928) or ID_000570 are authentic to their purported October 2008 creation dates. 10 - 10 - H/143/10{ID_000568} {ID_000570} {ID_000568} {ID_003928} {ID_000570}
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which may be a very large for accounts containing a lot of information.This is similar in concept to the way MBOX files store multiple emails together, butincludes a larger range of different types of information. However, the Outlook PSTformat is proprietary to Microsoft and more complex than MBOX. (If stored offline, aPST file can also be named “OST”, which is a synchronised copy of the PST and is not materially different to a PST.) d.MSG i s a file format used by Microsoft Outlook to encode individual email messages. Similarly to EML, it stores emails as different files, but it is a different format. The format of storage is OLE file format similar to that used in the older MS Word . DOC format. Unlike PST files, MSG files c ontain only a single message and any attachments, DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{ID_000254} {ID_000260} First Expert Report of Patrick Madden Page 52 of 98 52rather than a collection of messages. However, emails are typically not natively stored within Outlook as MSG files , but as part of the aggregated PST/OST . Typically, MSG files are only created from Outlook at the point that they are exported, for example by a “save as” operation or by dragging and dropping the email from outlook into a file folder. At the point that an email is exported in this way, it undergoes a conversion process which does not always pr eserve the metadata associated with the email. 150. PST a nd MSG are therefore file formats used specifically by Microsoft Outlook for organizin g an d archiving email messages and for exporting or converting messages when using a Microsoft Exchange email accoun t. MBOX and EML file formats are used for storing email messages in a more portable and standardis ed way , and in particular are used by Gmail accounts. Loss of metadata when converting emails 151. I have set out t he different types of email files as this is important for present purposes . All but 6 of the email files that are included in the disclosure dataset have been presented in .MSG format. There are indications that in many cases this was not the original format in which the y w ere sent or rec eived. Rather, they seem to have been created by the process of conversion a nd ex port which has reduced the metadata within them that I am able to review , or not capture d da ta that would be available at source . As I understand the D isclosure C ertificate a nd Di sclosure R eview D ocument, the original native formats of emails were taken from Googl e G mail accounts by its native Takeout function, which would have been in MBOX or EML format, but they have not been disclosed in that native format. In my opinion, proper disclosure of these emails should have been given by obtaining them natively in EML format as directly as possible from their source. 152. W hen Outlook is used as a mail application to interact with mail received via a Gmail account, Outlook does not save an original native copy of the emails being read, but instead converts the email data and incorporates it into its own PST format. 153. T his matters because MBOX/EML and PST/MSG have similar metadata fields, but the field s a nd some content is handled differently, and they do not always perfectly overlap. Because of the differences in how metadata is handled, the metadata does not always get converted perfectly, and certain information is often lost. In particular, there is a risk of losing certain data relating to the IMAP protocol, which is a protocol for accessing a remote mail server. This will DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 53 of 98 53include loss of IMAP timestamps which are typically present in Gmail- f ormatted emails but will not be carried over into the copies converted and incorporated into a PST. 154. W hen emails are taken from Gmail to Outlook PST, and then converted again into MSG format, there is a double conversion process which can also compound matters. In that situation, various timestamps such as the PR_Created and PR_Modified date s are typicall y r ecorded to the date of creation of the conversion to MSG, in place of the original values that were there previously and therefore removing the underlying metadata that would otherwise inform forensic analysis. I note however that the specifics of this conversion process woul d de pend on the specific version of Outlook, or other software, that was used to manage the files. 155. Wh ile this approach is not a problem for basic e- disclosure in most cases (where typically th e f ace value content of the document is important), in cases where documents are to be subje ct to forensic review , it is not sufficient. As a result, the converted or double-converted emails do not appear to have been the original native formats, but downstream copies. Their production i n t his manner has impair ed some of my analysis. Other conversions of MSG files 156. In other cases, emails have been supplied in a way that indicates different conversions wer e us ed. Examples of this include conversion of messages to PDF form, and in the case of 6 e mails, apparent conversion from PDF into EML format. It cannot be expected that these documents would capture any digital metadata in respect of their original creation. Metadata in emails 157. Metadata fields commonly used in emails include the following types. In some cases, thesetypically originate from th e sending or receiving application. In other cases, they are encoded within email headers : a.T he following fields which will be familiar to most users from sending and receivi ng em ails: i. From : A field indicating the identity of the sender of the email. In s ome cases, an email can be sent by one account ‘on behalf of’ another account, inwhich case both senders will appear. ii. To: The email addresses or names of the recipient or recipients. iii. Cc (Carbon Copy): The email addresses or names of the copied -in recipien t s o f the message. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 54 of 98 54iv. Bc c (Blind Carbon Copy): The email addresses or names of the recipients who receive a ‘blind’ copy of the message. This is likely to be preserved on em ails captured from a sender’s “Sent Items”, but would be hidde n on c opies of the email that were sent to other recipients and so would not appear in received copies. v. Subject : The Subject field of the email. vi. Various timestamps : Metadata fields relating to the dates and times the email was C reated, Sent, R eceived by it s recipients . v ii. Attachments : Information about any files or documents attached to the email (and
1,173
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 17 of 27 First Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/First Expert Report of Patrick Madden.pdf ### File content: which may be a very large for accounts containing a lot of information.This is similar in concept to the way MBOX files store multiple emails together, butincludes a larger range of different types of information. However, the Outlook PSTformat is proprietary to Microsoft and more complex than MBOX. (If stored offline, aPST file can also be named “OST”, which is a synchronised copy of the PST and is not materially different to a PST.) d.MSG i s a file format used by Microsoft Outlook to encode individual email messages. Similarly to EML, it stores emails as different files, but it is a different format. The format of storage is OLE file format similar to that used in the older MS Word . DOC format. Unlike PST files, MSG files c ontain only a single message and any attachments, DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{ID_000254} {ID_000260} First Expert Report of Patrick Madden Page 52 of 98 52rather than a collection of messages. However, emails are typically not natively stored within Outlook as MSG files , but as part of the aggregated PST/OST . Typically, MSG files are only created from Outlook at the point that they are exported, for example by a “save as” operation or by dragging and dropping the email from outlook into a file folder. At the point that an email is exported in this way, it undergoes a conversion process which does not always pr eserve the metadata associated with the email. 150. PST a nd MSG are therefore file formats used specifically by Microsoft Outlook for organizin g an d archiving email messages and for exporting or converting messages when using a Microsoft Exchange email accoun t. MBOX and EML file formats are used for storing email messages in a more portable and standardis ed way , and in particular are used by Gmail accounts. Loss of metadata when converting emails 151. I have set out t he different types of email files as this is important for present purposes . All but 6 of the email files that are included in the disclosure dataset have been presented in .MSG format. There are indications that in many cases this was not the original format in which the y w ere sent or rec eived. Rather, they seem to have been created by the process of conversion a nd ex port which has reduced the metadata within them that I am able to review , or not capture d da ta that would be available at source . As I understand the D isclosure C ertificate a nd Di sclosure R eview D ocument, the original native formats of emails were taken from Googl e G mail accounts by its native Takeout function, which would have been in MBOX or EML format, but they have not been disclosed in that native format. In my opinion, proper disclosure of these emails should have been given by obtaining them natively in EML format as directly as possible from their source. 152. W hen Outlook is used as a mail application to interact with mail received via a Gmail account, Outlook does not save an original native copy of the emails being read, but instead converts the email data and incorporates it into its own PST format. 153. T his matters because MBOX/EML and PST/MSG have similar metadata fields, but the field s a nd some content is handled differently, and they do not always perfectly overlap. Because of the differences in how metadata is handled, the metadata does not always get converted perfectly, and certain information is often lost. In particular, there is a risk of losing certain data relating to the IMAP protocol, which is a protocol for accessing a remote mail server. This will DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 53 of 98 53include loss of IMAP timestamps which are typically present in Gmail- f ormatted emails but will not be carried over into the copies converted and incorporated into a PST. 154. W hen emails are taken from Gmail to Outlook PST, and then converted again into MSG format, there is a double conversion process which can also compound matters. In that situation, various timestamps such as the PR_Created and PR_Modified date s are typicall y r ecorded to the date of creation of the conversion to MSG, in place of the original values that were there previously and therefore removing the underlying metadata that would otherwise inform forensic analysis. I note however that the specifics of this conversion process woul d de pend on the specific version of Outlook, or other software, that was used to manage the files. 155. Wh ile this approach is not a problem for basic e- disclosure in most cases (where typically th e f ace value content of the document is important), in cases where documents are to be subje ct to forensic review , it is not sufficient. As a result, the converted or double-converted emails do not appear to have been the original native formats, but downstream copies. Their production i n t his manner has impair ed some of my analysis. Other conversions of MSG files 156. In other cases, emails have been supplied in a way that indicates different conversions wer e us ed. Examples of this include conversion of messages to PDF form, and in the case of 6 e mails, apparent conversion from PDF into EML format. It cannot be expected that these documents would capture any digital metadata in respect of their original creation. Metadata in emails 157. Metadata fields commonly used in emails include the following types. In some cases, thesetypically originate from th e sending or receiving application. In other cases, they are encoded within email headers : a.T he following fields which will be familiar to most users from sending and receivi ng em ails: i. From : A field indicating the identity of the sender of the email. In s ome cases, an email can be sent by one account ‘on behalf of’ another account, inwhich case both senders will appear. ii. To: The email addresses or names of the recipient or recipients. iii. Cc (Carbon Copy): The email addresses or names of the copied -in recipien t s o f the message. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 54 of 98 54iv. Bc c (Blind Carbon Copy): The email addresses or names of the recipients who receive a ‘blind’ copy of the message. This is likely to be preserved on em ails captured from a sender’s “Sent Items”, but would be hidde n on c opies of the email that were sent to other recipients and so would not appear in received copies. v. Subject : The Subject field of the email. vi. Various timestamps : Metadata fields relating to the dates and times the email was C reated, Sent, R eceived by it s recipients . v ii. Attachments : Information about any files or documents attached to the email (and
1,784
/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM40.pdf
Patrick Madden
part 4 of 8 Appendix PM40.pdf
6,372
14,656
on the assumption that the table on the Wiris website gives accurate dates for the MathType software releases. 7 - 7 - H/156/7{H/163} {H/164} {H/165} {H/166} {H/167} Madden Appendix PM 40 MathType Equation Headers Page 8 of 16 Technical information 18. The technical URLs mentioned above were links to documentation about how MathType encodes information i n various files. These are set out at : a. Exhibit PM40.12: https://docs.wiris.com/mathtype/en/mathtype- office - tools/m athtype-7-for- windows -and- mac/mathtype -sdk/mathtype- mtef-v-5-- mathtype - 4-0-and- later-.html b. Exhibit PM40.13: https://docs.wiris.com/mathtype/en/mathtype -office - tools/mathtype-7-for- windows -and- mac/mathtype -sdk/how- mtef-is-stored -in-files- and-objects.html .This exhibit took me to a page of the MathType documentation which explained the encoding format that MathType uses which I had observed in the documents. 19. They state: a. That the equation information is set out in a format called “MTEF” which is embedded in OLE equation objects (such as those used in MS Word DOC files), and that each equation has a 28 -byte header. Specifically i n Exhibit 40.13 : i. “[The ] binary equation format used by MathType is embedded in OLE equation objects produced by MathType as well as in all the file for mats in which Mathtype can save equations ”. ii. “ MathType can save its equations in a variety of file formats and object types. So that MathType can re -open such equations, it must store its own equation data structures (MTEF) in each file.” ii i.“MTEF data is saved as the native data format of the object. Whenever an equation object is to be written to an OLE "stream", a 28- byte header is written, fo llowed by the MTEF data.” b. That the MTEF format has had several versions (NB these are different to the versions of MathType software) and is used by two different products called “MathType” and “Equation Editor”. However, MTEF version 4.0 has been used for all versions of MathType after MathType 4.0. Specifically , in Exhibit 40.12: Madden Appendix PM 40 MathType Equation Headers Page 8 of 16 Technical information 18. The technical URLs mentioned above were links to documentation about how MathType encodes information i n various files. These are set out at : a. Exhibit PM40.12: https://docs.wiris.com/mathtype/en/mathtype- office - tools/m athtype-7-for- windows -and- mac/mathtype -sdk/mathtype- mtef-v-5-- mathtype - 4-0-and- later-.html b. Exhibit PM40.13: https://docs.wiris.com/mathtype/en/mathtype -office - tools/mathtype-7-for- windows -and- mac/mathtype -sdk/how- mtef-is-stored -in-files- and-objects.html .This exhibit took me to a page of the MathType documentation which explained the encoding format that MathType uses which I had observed in the documents. 19. They state: a. That the equation information is set out in a format called “MTEF” which is embedded in OLE equation objects (such as those used in MS Word DOC files), and that each equation has a 28 -byte header. Specifically i n Exhibit 40.13 : i. “[The ] binary equation format used by MathType is embedded in OLE equation objects produced by MathType as well as in all the file for mats in which Mathtype can save equations ”. ii. “ MathType can save its equations in a variety of file formats and object types. So that MathType can re -open such equations, it must store its own equation data structures (MTEF) in each file.” ii i.“MTEF data is saved as the native data format of the object. Whenever an equation object is to be written to an OLE "stream", a 28- byte header is written, fo llowed by the MTEF data.” b. That the MTEF format has had several versions (NB these are different to the versions of MathType software) and is used by two different products called “MathType” and “Equation Editor”. However, MTEF version 4.0 has been used for all versions of MathType after MathType 4.0. Specifically , in Exhibit 40.12: 8 - 8 - H/156/8{H/168} {H/169} {H/169} {H/168} Madden Appendix PM 40 MathType Equation Headers Page 9 of 16 c. T hat the header contains some relevant information for my analysis in the first few bytes of the record, wh ich includes both the MTEF version, as well as the “generating platform” (Windows or Mac), “g enerating product” (MathType or Equation Editor) and its “product version” and “product subversion”, i.e. the software that was used to author the equation. Exhibit PM40.12 gives the table as follows: 20. This therefore provided me with enough informa�on to interpret the encoded headers according to the documenta�on. Madden Appendix PM 40 MathType Equation Headers Page 9 of 16 c. T hat the header contains some relevant information for my analysis in the first few bytes of the record, wh ich includes both the MTEF version, as well as the “generating platform” (Windows or Mac), “g enerating product” (MathType or Equation Editor) and its “product version” and “product subversion”, i.e. the software that was used
797
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 4 of 8 Appendix PM40.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM40.pdf ### File content: on the assumption that the table on the Wiris website gives accurate dates for the MathType software releases. 7 - 7 - H/156/7{H/163} {H/164} {H/165} {H/166} {H/167} Madden Appendix PM 40 MathType Equation Headers Page 8 of 16 Technical information 18. The technical URLs mentioned above were links to documentation about how MathType encodes information i n various files. These are set out at : a. Exhibit PM40.12: https://docs.wiris.com/mathtype/en/mathtype- office - tools/m athtype-7-for- windows -and- mac/mathtype -sdk/mathtype- mtef-v-5-- mathtype - 4-0-and- later-.html b. Exhibit PM40.13: https://docs.wiris.com/mathtype/en/mathtype -office - tools/mathtype-7-for- windows -and- mac/mathtype -sdk/how- mtef-is-stored -in-files- and-objects.html .This exhibit took me to a page of the MathType documentation which explained the encoding format that MathType uses which I had observed in the documents. 19. They state: a. That the equation information is set out in a format called “MTEF” which is embedded in OLE equation objects (such as those used in MS Word DOC files), and that each equation has a 28 -byte header. Specifically i n Exhibit 40.13 : i. “[The ] binary equation format used by MathType is embedded in OLE equation objects produced by MathType as well as in all the file for mats in which Mathtype can save equations ”. ii. “ MathType can save its equations in a variety of file formats and object types. So that MathType can re -open such equations, it must store its own equation data structures (MTEF) in each file.” ii i.“MTEF data is saved as the native data format of the object. Whenever an equation object is to be written to an OLE "stream", a 28- byte header is written, fo llowed by the MTEF data.” b. That the MTEF format has had several versions (NB these are different to the versions of MathType software) and is used by two different products called “MathType” and “Equation Editor”. However, MTEF version 4.0 has been used for all versions of MathType after MathType 4.0. Specifically , in Exhibit 40.12: Madden Appendix PM 40 MathType Equation Headers Page 8 of 16 Technical information 18. The technical URLs mentioned above were links to documentation about how MathType encodes information i n various files. These are set out at : a. Exhibit PM40.12: https://docs.wiris.com/mathtype/en/mathtype- office - tools/m athtype-7-for- windows -and- mac/mathtype -sdk/mathtype- mtef-v-5-- mathtype - 4-0-and- later-.html b. Exhibit PM40.13: https://docs.wiris.com/mathtype/en/mathtype -office - tools/mathtype-7-for- windows -and- mac/mathtype -sdk/how- mtef-is-stored -in-files- and-objects.html .This exhibit took me to a page of the MathType documentation which explained the encoding format that MathType uses which I had observed in the documents. 19. They state: a. That the equation information is set out in a format called “MTEF” which is embedded in OLE equation objects (such as those used in MS Word DOC files), and that each equation has a 28 -byte header. Specifically i n Exhibit 40.13 : i. “[The ] binary equation format used by MathType is embedded in OLE equation objects produced by MathType as well as in all the file for mats in which Mathtype can save equations ”. ii. “ MathType can save its equations in a variety of file formats and object types. So that MathType can re -open such equations, it must store its own equation data structures (MTEF) in each file.” ii i.“MTEF data is saved as the native data format of the object. Whenever an equation object is to be written to an OLE "stream", a 28- byte header is written, fo llowed by the MTEF data.” b. That the MTEF format has had several versions (NB these are different to the versions of MathType software) and is used by two different products called “MathType” and “Equation Editor”. However, MTEF version 4.0 has been used for all versions of MathType after MathType 4.0. Specifically , in Exhibit 40.12: 8 - 8 - H/156/8{H/168} {H/169} {H/169} {H/168} Madden Appendix PM 40 MathType Equation Headers Page 9 of 16 c. T hat the header contains some relevant information for my analysis in the first few bytes of the record, wh ich includes both the MTEF version, as well as the “generating platform” (Windows or Mac), “g enerating product” (MathType or Equation Editor) and its “product version” and “product subversion”, i.e. the software that was used to author the equation. Exhibit PM40.12 gives the table as follows: 20. This therefore provided me with enough informa�on to interpret the encoded headers according to the documenta�on. Madden Appendix PM 40 MathType Equation Headers Page 9 of 16 c. T hat the header contains some relevant information for my analysis in the first few bytes of the record, wh ich includes both the MTEF version, as well as the “generating platform” (Windows or Mac), “g enerating product” (MathType or Equation Editor) and its “product version” and “product subversion”, i.e. the software that was used
1,564
/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM3.pdf
Patrick Madden
part 11 of 22 Appendix PM3.pdf
18,055
43,372
<rdf:li>Blockchain</rdf:li> <rdf:li>law</rdf:li> <rdf:li>smart contract</rdf:li> <rdf:li>time chain</rdf:li> <rdf:li>immutable</rdf:li> </rdf:Bag> </dc:subject> <dc:rights> <rdf:Alt> <rdf:li xml:lang="x-default">(C) Craig Steven Wright&#xA;2008</rdf:li> </rdf:Alt> </dc:rights> <xmpMM:DocumentID>uuid:3658ec91-de13-42e3-9796- 6369d7172efc</xmpMM:DocumentID> <xmpMM:InstanceID>uuid:02a9a63b-da5a-449f-b280- 36f9a69f1962</xmpMM:InstanceID> </rdf:Description> </rdf:RDF> </x:xmpmeta> <?xpacket end="w"?> 105. T h e metadata values of the fourth of the listed streams correlate with the internal metadata properties for the document, but others do not. Overall, t he recorded times for some of thes e m etadata fields contradict others. In my opinion, the observable chara cteristics from th e st reams above are not achievable without either manipulation of the computer clock t o ba ckdate the time, or subsequent manual modification of the timestamps using a hex editor. Madden Appendix PM3 Bitcoin White Paper Page 35 of 80 106. Fo r example, comparing the Modified date between the 1st and 3rd streams it can be seen that they are inconsistent, and purport to be exactly 11 years apart to the second. I have added spaces and removed the “T” time signifiers to aid review. 1st metadata stream Modified 2019 08 21 19 35 28+01'00' 3rd metadata stream Modified 2008 -08-21 19:35:28+01:00 107. Comparing the C reated date and timestamps, the 1st and 2nd streams match, but are different from the 3rd and 4th which also match each other. I observe also that the time of day is the same between all four, with only the year and month being different by 14 months. 1st metadata stream Created 2009 03 24 11 33 15 -06'00' 2nd metadata stream Created 2009 03 24 11 33 15 -06'00' 3rd metadata stream Created 2008 -01-24 11:33:15 -06:00 4th metadata stream Created 2008 -01-24 11:33:15 -06:00 ID_000536 – invalid XMP Core 108. The information relating to the XMP Core (the version of the standardised metadata format used to create ID_000536) also exhibits an irregularity. The 3rd and 4th metadata st reams contained the following two XMP C ore records: 3rd metadata XMP Core "Adobe XMP Core 1.1 -c016 91.132716, 2008/10/29 -16:58:49 " 4th metadata XMP Core "Adobe XMP Core 1.1-c016 91.132716, 2008/10/29 -16:58:49 " 109. This XMP Core version was not familiar to me and so I attempted to research information about it. A Google search for this XMP C ore information produces only two search results. The search result listing s for both of these results appeared that they might relate to this case, so I did not click on them or read the search result summary listing any further than necessary. I wanted to ensure that I did not take them into account, and so immediately navigated away. 110. Attempting to avoid those results, I shortened my search term to just “Adobe XMP Core 1.1”, but that produced the same two results only , and took me no further . 111. Disregarding those search results, there were no search results listing this XMP C ore version at all, and I do not recall seeing it in my experience of forensic examination in the past. Thisleads me to the view that it did not exist. 112. I next approached it another way, compar ing the XMP core records for ID_000536 to that of ID_003732 (as lis ted below): ID_003732 XMP Core "Adobe XMP Core 5.6-c016 91.1 63616, 20 18/10/29 -16:58:49 " ID_000536 XMP Core "Adobe XMP Core 1.1-c016 91.1 32716, 20 08/10/29 -16:58:49 " {ID_000536} {ID_000536} {ID_000536} {ID_003732} {ID_003732} {ID_000536} Madden Appendix PM3 Bitcoin White Paper Page 36 of 80 113. As illustrated above in colour coding, the characters are very similar including the hour, minute and second of their creation but some characters in the version numbering have changed. Even if XMP Core 1.1 did exist, it is irregular and not plausible for different versions of XMP Core to have been created at the same month, day, hour, minute, and secondas each other, precisely 10 years apart. 114. As a cross -check, a G oogle search for the XMP Core of ID_003732 returns many search hits in relation to entirely unrelated documents . I consider this comparison sufficient to determine that the XMP C ore of ID_003736 is authentic to the editing time (in 2019) and that the XMP Core of ID_000536 is invalid and not a real world XMP C ore version . ID_000536 – purported XMP Core post-dates document creation and editing even if valid 115. Even if it w ere genuine, I note that the purported date of the XMP Core (October 2008) post- dates the purported authorship (January 2008) and L ast Modified (May 2008) times of the document. ID_000536 – demonstration of hex editing 116. Considering the anomalous characteristics of both of the document’s timestamps, and the content of the XMP C ore, I have formed the opinion that these irregularities are likely the result of someone using a hex editor to manipulate the content of this file at a byte level . 117. To demonstrate this process I have used Hex Editor Neo. I have taken a copy
821
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 11 of 22 Appendix PM3.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM3.pdf ### File content: <rdf:li>Blockchain</rdf:li> <rdf:li>law</rdf:li> <rdf:li>smart contract</rdf:li> <rdf:li>time chain</rdf:li> <rdf:li>immutable</rdf:li> </rdf:Bag> </dc:subject> <dc:rights> <rdf:Alt> <rdf:li xml:lang="x-default">(C) Craig Steven Wright&#xA;2008</rdf:li> </rdf:Alt> </dc:rights> <xmpMM:DocumentID>uuid:3658ec91-de13-42e3-9796- 6369d7172efc</xmpMM:DocumentID> <xmpMM:InstanceID>uuid:02a9a63b-da5a-449f-b280- 36f9a69f1962</xmpMM:InstanceID> </rdf:Description> </rdf:RDF> </x:xmpmeta> <?xpacket end="w"?> 105. T h e metadata values of the fourth of the listed streams correlate with the internal metadata properties for the document, but others do not. Overall, t he recorded times for some of thes e m etadata fields contradict others. In my opinion, the observable chara cteristics from th e st reams above are not achievable without either manipulation of the computer clock t o ba ckdate the time, or subsequent manual modification of the timestamps using a hex editor. Madden Appendix PM3 Bitcoin White Paper Page 35 of 80 106. Fo r example, comparing the Modified date between the 1st and 3rd streams it can be seen that they are inconsistent, and purport to be exactly 11 years apart to the second. I have added spaces and removed the “T” time signifiers to aid review. 1st metadata stream Modified 2019 08 21 19 35 28+01'00' 3rd metadata stream Modified 2008 -08-21 19:35:28+01:00 107. Comparing the C reated date and timestamps, the 1st and 2nd streams match, but are different from the 3rd and 4th which also match each other. I observe also that the time of day is the same between all four, with only the year and month being different by 14 months. 1st metadata stream Created 2009 03 24 11 33 15 -06'00' 2nd metadata stream Created 2009 03 24 11 33 15 -06'00' 3rd metadata stream Created 2008 -01-24 11:33:15 -06:00 4th metadata stream Created 2008 -01-24 11:33:15 -06:00 ID_000536 – invalid XMP Core 108. The information relating to the XMP Core (the version of the standardised metadata format used to create ID_000536) also exhibits an irregularity. The 3rd and 4th metadata st reams contained the following two XMP C ore records: 3rd metadata XMP Core "Adobe XMP Core 1.1 -c016 91.132716, 2008/10/29 -16:58:49 " 4th metadata XMP Core "Adobe XMP Core 1.1-c016 91.132716, 2008/10/29 -16:58:49 " 109. This XMP Core version was not familiar to me and so I attempted to research information about it. A Google search for this XMP C ore information produces only two search results. The search result listing s for both of these results appeared that they might relate to this case, so I did not click on them or read the search result summary listing any further than necessary. I wanted to ensure that I did not take them into account, and so immediately navigated away. 110. Attempting to avoid those results, I shortened my search term to just “Adobe XMP Core 1.1”, but that produced the same two results only , and took me no further . 111. Disregarding those search results, there were no search results listing this XMP C ore version at all, and I do not recall seeing it in my experience of forensic examination in the past. Thisleads me to the view that it did not exist. 112. I next approached it another way, compar ing the XMP core records for ID_000536 to that of ID_003732 (as lis ted below): ID_003732 XMP Core "Adobe XMP Core 5.6-c016 91.1 63616, 20 18/10/29 -16:58:49 " ID_000536 XMP Core "Adobe XMP Core 1.1-c016 91.1 32716, 20 08/10/29 -16:58:49 " {ID_000536} {ID_000536} {ID_000536} {ID_003732} {ID_003732} {ID_000536} Madden Appendix PM3 Bitcoin White Paper Page 36 of 80 113. As illustrated above in colour coding, the characters are very similar including the hour, minute and second of their creation but some characters in the version numbering have changed. Even if XMP Core 1.1 did exist, it is irregular and not plausible for different versions of XMP Core to have been created at the same month, day, hour, minute, and secondas each other, precisely 10 years apart. 114. As a cross -check, a G oogle search for the XMP Core of ID_003732 returns many search hits in relation to entirely unrelated documents . I consider this comparison sufficient to determine that the XMP C ore of ID_003736 is authentic to the editing time (in 2019) and that the XMP Core of ID_000536 is invalid and not a real world XMP C ore version . ID_000536 – purported XMP Core post-dates document creation and editing even if valid 115. Even if it w ere genuine, I note that the purported date of the XMP Core (October 2008) post- dates the purported authorship (January 2008) and L ast Modified (May 2008) times of the document. ID_000536 – demonstration of hex editing 116. Considering the anomalous characteristics of both of the document’s timestamps, and the content of the XMP C ore, I have formed the opinion that these irregularities are likely the result of someone using a hex editor to manipulate the content of this file at a byte level . 117. To demonstrate this process I have used Hex Editor Neo. I have taken a copy
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Subject: Re: All's well From: Nicholas Bohm <[email protected]> Date: 03/02/2009, 22:51 To: Satoshi Nakamoto <[email protected]> Just to say the sending seemed very straightforward, as was the resulting entry. And when you get used to the double-click, it's actually simpler than a right-click and selecting from a menu. So perhaps it's just a matter of user guidance. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFRe: All's well mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:10
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090203-Re_All's well-154345.pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090203-Re_All's well-154345.pdf ### File content: Subject: Re: All's well From: Nicholas Bohm <[email protected]> Date: 03/02/2009, 22:51 To: Satoshi Nakamoto <[email protected]> Just to say the sending seemed very straightforward, as was the resulting entry. And when you get used to the double-click, it's actually simpler than a right-click and selecting from a menu. So perhaps it's just a matter of user guidance. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFRe: All's well mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:10
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file created by anyone else than the same user. If my understanding is correct then the most likely candidate is BitcoinSN.tex . 61. I also note that the “file.hash” column is redacted for almost all rows in the screenshot from figure 3, making it hard to identify which actual files they refer to. 62. Analysing BitcoinSN.tex in its original state would have been very instructive, but I do not have it. 5When the file is present at the inception of a project (which can be created by uploading a zip file), its hash value is included in project.json . 16 DECLARATION 1.I understand that my duty is to help the Court to achieve the overriding objective by giving independent assistance by way of objective, unbiased opinion on matters within my expertise, both in preparing reports and giving oral evidence. I under- stand that this duty overrides any obligation to the party by whom I am engaged or the person who has paid or is liable to pay me. I confirm that I have complied with and will continue to comply with that duty. 2.I confirm that I have not entered into any arrangement where the amount or payment of my fees is in any way dependent on the outcome of the case. 3.I know of no conflict of interest of any kind, other than any which I have disclosed in my report. I do not consider that any interest affects my suitability as an expert witness on any issues on which I have given evidence. 4.I will advise the party by whom I am instructed if, between the date of my report and the trial, there is any change in circumstances which affects this. 5.I have shown the sources of all information I have used. 6.I have exercised reasonable care and skill in order to be accurate and complete in preparing this report. 7.I have endeavoured to include in my report those matters, of which I have know- ledge or of which I have been made aware, that might adversely affect the validity of my opinion. I have clearly stated any qualifications to my opinion. 8.I have not, without forming an independent view, included or excluded anything which has been suggested to me by others including my instructing lawyers. 9.I will notify those instructing me immediately and confirm in writing if for any reason my existing report requires any correction or qualification or my opinion changes. 10.I understand that: a.my report will form the evidence to be given under oath or affirmation; b.the court may at any stage direct a discussion to take place between experts and has done in this case; c.the court may direct that, following a discussion between the experts, a state- ment should be prepared showing those issues which are agreed and those issues which are not agreed; d.I may be required to attend Court to be cross-examined on my report; and e.I am likely to be the subject of public adverse criticism by the judge if the Court concludes that I have not taken reasonable care in trying to meet the standards set out above. 11.I have read Part 35 of the Civil Procedure Rules and I have complied with its requirements. I am aware of the requirements of Practice Direction 35 and the Guidance for the Instruction of Experts in Civil Claims 2014. 12.I confirm that I have acted in accordance with the Code of Practice for Experts. 17 13.I confirm that I have made clear which facts and matters referred to in this report are within my own knowledge and which are not. Those that are within my own knowledge I confirm to be true. The opinions I have expressed represent my true and complete professional opinions on the matters to which they refer. Signed: Dated: 12 February 2024 18 A Appendix: Errata to my First Report 1.In para 49, in “the ‘composite fonts’ I introduced in section 2.2”, the section number should read “2.2.1”; 2.in para 92, “diagrams 2 and 7” should read “diagrams 2 to 7”; 3.in para 111, “to define settings, or alter pre-defined defaults, or to create new commands” is unclear and should read “to on the one hand define settings, or alter pre-defined defaults, or to on the other hand create new commands.”; 4.in table 3.6 (“the matrix”), the “Maths” row, showing the name of the main maths font, should be corrected in three places: columns B and D should read “Cambria Math”, and column M should read “blank boxes”. I refer to these values in para 153 but did not tabulate them correctly in my matrix; 5.in para 117, “monospaced” should be deleted. While it is correct that most of the fourteen L ATEX files do indeed use a monospaced font at that place, the particular file I’m commenting on there does not; 6.the phrase “not unreasonable” in para 141 should read “not reasonable”; 7.At paras 143 to 147, I discuss the TikZand itsarrows.meta library, the latter being one of the packages I discovered to be problematic. It was only released in September 2013 and calls into question the dating of any Candidate File that uses it (as do 9 out of the 14 files analysed in the First Report). It provides, amongst other things, alternative arrowheads, but I realised since completing my First Report that that library is actually never used at all by any of the Candidate Files,orfilesincludedbythem. Thelibraryisloaded,butnotactuallyusedbecause the arrowheads are drawn and filled line-by-line, not by using the command to set the alternative arrowheads. I went halfway towards to this realisation at para 146, and this does not weaken my conclusions in any way; I just wanted to note this curious incident. 8.in para 157, “as seen in 2.6” should read “as seen in figure 2.6”; and 9.in para 198 I observed that the Aspose files were exactly the same as some of Dr Wright’s, “up to a possible translation and scaling factor: the reference point may have been different, and possibly the scale too”. Having checked the file generated by Aspose against the relevant files of Dr Wright’s L ATEX disclosure, I can confirm that the parts that code for the images are identical, up to and including the coordinates, that all have four significant digits. 19
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 6 of 6 Second Expert Report of Arthur Rosendahl.pdf ### Folder name: Arthur Rosendahl ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Arthur Rosendahl/Second Expert Report of Arthur Rosendahl.pdf ### File content: file created by anyone else than the same user. If my understanding is correct then the most likely candidate is BitcoinSN.tex . 61. I also note that the “file.hash” column is redacted for almost all rows in the screenshot from figure 3, making it hard to identify which actual files they refer to. 62. Analysing BitcoinSN.tex in its original state would have been very instructive, but I do not have it. 5When the file is present at the inception of a project (which can be created by uploading a zip file), its hash value is included in project.json . 16 DECLARATION 1.I understand that my duty is to help the Court to achieve the overriding objective by giving independent assistance by way of objective, unbiased opinion on matters within my expertise, both in preparing reports and giving oral evidence. I under- stand that this duty overrides any obligation to the party by whom I am engaged or the person who has paid or is liable to pay me. I confirm that I have complied with and will continue to comply with that duty. 2.I confirm that I have not entered into any arrangement where the amount or payment of my fees is in any way dependent on the outcome of the case. 3.I know of no conflict of interest of any kind, other than any which I have disclosed in my report. I do not consider that any interest affects my suitability as an expert witness on any issues on which I have given evidence. 4.I will advise the party by whom I am instructed if, between the date of my report and the trial, there is any change in circumstances which affects this. 5.I have shown the sources of all information I have used. 6.I have exercised reasonable care and skill in order to be accurate and complete in preparing this report. 7.I have endeavoured to include in my report those matters, of which I have know- ledge or of which I have been made aware, that might adversely affect the validity of my opinion. I have clearly stated any qualifications to my opinion. 8.I have not, without forming an independent view, included or excluded anything which has been suggested to me by others including my instructing lawyers. 9.I will notify those instructing me immediately and confirm in writing if for any reason my existing report requires any correction or qualification or my opinion changes. 10.I understand that: a.my report will form the evidence to be given under oath or affirmation; b.the court may at any stage direct a discussion to take place between experts and has done in this case; c.the court may direct that, following a discussion between the experts, a state- ment should be prepared showing those issues which are agreed and those issues which are not agreed; d.I may be required to attend Court to be cross-examined on my report; and e.I am likely to be the subject of public adverse criticism by the judge if the Court concludes that I have not taken reasonable care in trying to meet the standards set out above. 11.I have read Part 35 of the Civil Procedure Rules and I have complied with its requirements. I am aware of the requirements of Practice Direction 35 and the Guidance for the Instruction of Experts in Civil Claims 2014. 12.I confirm that I have acted in accordance with the Code of Practice for Experts. 17 13.I confirm that I have made clear which facts and matters referred to in this report are within my own knowledge and which are not. Those that are within my own knowledge I confirm to be true. The opinions I have expressed represent my true and complete professional opinions on the matters to which they refer. Signed: Dated: 12 February 2024 18 A Appendix: Errata to my First Report 1.In para 49, in “the ‘composite fonts’ I introduced in section 2.2”, the section number should read “2.2.1”; 2.in para 92, “diagrams 2 and 7” should read “diagrams 2 to 7”; 3.in para 111, “to define settings, or alter pre-defined defaults, or to create new commands” is unclear and should read “to on the one hand define settings, or alter pre-defined defaults, or to on the other hand create new commands.”; 4.in table 3.6 (“the matrix”), the “Maths” row, showing the name of the main maths font, should be corrected in three places: columns B and D should read “Cambria Math”, and column M should read “blank boxes”. I refer to these values in para 153 but did not tabulate them correctly in my matrix; 5.in para 117, “monospaced” should be deleted. While it is correct that most of the fourteen L ATEX files do indeed use a monospaced font at that place, the particular file I’m commenting on there does not; 6.the phrase “not unreasonable” in para 141 should read “not reasonable”; 7.At paras 143 to 147, I discuss the TikZand itsarrows.meta library, the latter being one of the packages I discovered to be problematic. It was only released in September 2013 and calls into question the dating of any Candidate File that uses it (as do 9 out of the 14 files analysed in the First Report). It provides, amongst other things, alternative arrowheads, but I realised since completing my First Report that that library is actually never used at all by any of the Candidate Files,orfilesincludedbythem. Thelibraryisloaded,butnotactuallyusedbecause the arrowheads are drawn and filled line-by-line, not by using the command to set the alternative arrowheads. I went halfway towards to this realisation at para 146, and this does not weaken my conclusions in any way; I just wanted to note this curious incident. 8.in para 157, “as seen in 2.6” should read “as seen in figure 2.6”; and 9.in para 198 I observed that the Aspose files were exactly the same as some of Dr Wright’s, “up to a possible translation and scaling factor: the reference point may have been different, and possibly the scale too”. Having checked the file generated by Aspose against the relevant files of Dr Wright’s L ATEX disclosure, I can confirm that the parts that code for the images are identical, up to and including the coordinates, that all have four significant digits. 19
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to identify that the load file timestamps were not original and had apparently been separated out into different partial timestamps and were required to be recons tituted before the y c ould be understood and analyse d. 89.F or example, I set out below a partial set of the load file information that was provided for documents ID _000757 and ID_000835: Production Begin Bates Date - Created - Date Date - Created - Time Date - OS Created - Date Date - OS Created - Time Date - Time -Created ID_000757 06/08/2009 27/10/2022 06:15 09/11/2015 27/10/2022 09:31 06/08/2009 06:15 ID_000835 24/10/2008 27/10/2022 20:24 24/10/2008 27/10/2022 21:24 24/10/2008 20:24 90.A s can be seen there were several fields with very similar labels (including the same words in different orders) and no explanation of what was meant by each of them was provided. 91. I approached this f irst by verif ying the metadata timestamps for each document by manually inspecting both for their internal ‘ Created’ timestamps. After confirming that the internal timestamps matched the last column “ Date - Time – Created ” I used this as a baseline to establish how the other columns were constructed. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{ID_000757} {ID_000835} First Expert Report of Patrick Madden Page 36 of 98 3692. I found that for the two columns “ Date - Created - Time ” and “ Date - OS Created - Time ”, the dates in these fields ( highlighted in red above for ease of reference) did not appear to be reliable. However, the hours and minutes within those fields matched the Date -Time -Created field. I therefore took this field to consist of date data which was not relevant but time data w hich was said to be relevant. It was therefore necessary to strip out the parts marked in red above. 93.H aving isolated the time part of the metadata field , these resulting times are apparently to b e a pplied to the “ Date -Created -Date ” field and reconstituted to form a single times tamp. 94. I t can be seen however that these do not always align perfectly and time zone offsets have not been applied to the OS timestamps – this being clear from the example of ID_000835. Afte r r econstituting the “Date -OS Created -Date” and “Date -OS Created Time” fields, the resulting timestamp shows the Created D ate as being exactly one hour later than actual date of creation of the file (21:24 instead of 20:24). 95. It is therefore my understanding that the OS file metadata provided may not have reliably take n i nto account the time zone of creation of the document, but has instead applied the timestamps across all documents without accounting for time zone offsets. This often leads to apparently contradictory metadata as indicated in the example above, which i nitially looks irregular a nd c an only be explained by making assumptions about discarded time zone information. Wher e th e time zone offset has been lost at the source device , it would normally be possible to confirm this by reverting to the forensic image collected from the device. Without access to the se f orensic images, I cannot independently verify the accuracy of the provided information. 96.T he example above is an illustrative example where the offset is very clear. However it is most often not so simple to form a view about what the data is intended to indicate: in the case of ID_000757 for example, the OS Created timestamp is greatly differ ent from the metadata timestamp, even after the reconstituting process I mentioned above . 97.T he fact that other timestamps are plainly not correct leads me to doubt the accuracy of thi s i nformation, but in cases such as ID_000757 I have no method to validate whether or not these are correct and have not therefore been able to assess the timestamps in such cases as part of my review. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{ID_000757}{ID_000835} {ID_000757} First Expert Report of Patrick Madden Page 37 of 98 37Later schedules provided via Travers Smith 98.I was later provided with two additional supplementary schedules of data that I understand were provided by Travers Smith to address some of these deficiencies. However, these supplements were also inconsisten t. For example , it can be seen in the below screenshot extract that the dates have been formatted in different ways in adjacent r ows, and the times alternate between 12 and 24 hour clock configurations: 99.Wh ile it is possible, with some effort, to reformat these into a more consistent formatting (and I have attempted to do so where the point has arisen in relation to a document I have analysed ) I cannot however be sure that I have always correctly applied a 12 or 24 hour clock and I am not able to rely on this information fully. It also has the same problems with time zones that I haveexplained above. As such , I have no method by which I can validate that the information provided to me is accurate and has not already been muddled or mixed up. 100. Ove rall, the accompanying schedules give the impression that the dataset has been exported from multiple different e -disclosure platform s ources and combined in a way that was not consistent and which appears to have discarded important information. 101. I h ave therefore been able to rely upon this provided metadata only very little. In cases where I have needed to consult the provided metadata to aid my analysis, I have either taken the metadata provided at face value (which should be understood as a limitation in the DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 38 of 98 38circumstances), o r I have done my best to try to account for time zone variations . In doing so, I am informed by Bird & Bird that relevant time zones may include Australian time zones ( as Dr Wright was previously resident there), which I have taken into account, but for many of the document types the relevant time zone at the time of authorship cannot be reliably determined and therefore cannot be reliably applied. Different approaches to metadata used by various technologies 102. When discussing Internal Metadata, it is important to note that different file types record a nd st ore metadata in different ways. They also store data in different ways, therefore whe n c onverting between formats it is not unusual to incur defects or changes to the way that the content was displayed or organised on the screen. 103. E ven within the same File format, there are often different ways in which the content can b e st ructured and stored. Similarly, MS Word . DOC and . DOCX files , though related, are in fac t e ntirely different formats as I explain below, and t he PDF file format can incorporate a variety of different encodings into a
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 12 of 27 First Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/First Expert Report of Patrick Madden.pdf ### File content: to identify that the load file timestamps were not original and had apparently been separated out into different partial timestamps and were required to be recons tituted before the y c ould be understood and analyse d. 89.F or example, I set out below a partial set of the load file information that was provided for documents ID _000757 and ID_000835: Production Begin Bates Date - Created - Date Date - Created - Time Date - OS Created - Date Date - OS Created - Time Date - Time -Created ID_000757 06/08/2009 27/10/2022 06:15 09/11/2015 27/10/2022 09:31 06/08/2009 06:15 ID_000835 24/10/2008 27/10/2022 20:24 24/10/2008 27/10/2022 21:24 24/10/2008 20:24 90.A s can be seen there were several fields with very similar labels (including the same words in different orders) and no explanation of what was meant by each of them was provided. 91. I approached this f irst by verif ying the metadata timestamps for each document by manually inspecting both for their internal ‘ Created’ timestamps. After confirming that the internal timestamps matched the last column “ Date - Time – Created ” I used this as a baseline to establish how the other columns were constructed. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{ID_000757} {ID_000835} First Expert Report of Patrick Madden Page 36 of 98 3692. I found that for the two columns “ Date - Created - Time ” and “ Date - OS Created - Time ”, the dates in these fields ( highlighted in red above for ease of reference) did not appear to be reliable. However, the hours and minutes within those fields matched the Date -Time -Created field. I therefore took this field to consist of date data which was not relevant but time data w hich was said to be relevant. It was therefore necessary to strip out the parts marked in red above. 93.H aving isolated the time part of the metadata field , these resulting times are apparently to b e a pplied to the “ Date -Created -Date ” field and reconstituted to form a single times tamp. 94. I t can be seen however that these do not always align perfectly and time zone offsets have not been applied to the OS timestamps – this being clear from the example of ID_000835. Afte r r econstituting the “Date -OS Created -Date” and “Date -OS Created Time” fields, the resulting timestamp shows the Created D ate as being exactly one hour later than actual date of creation of the file (21:24 instead of 20:24). 95. It is therefore my understanding that the OS file metadata provided may not have reliably take n i nto account the time zone of creation of the document, but has instead applied the timestamps across all documents without accounting for time zone offsets. This often leads to apparently contradictory metadata as indicated in the example above, which i nitially looks irregular a nd c an only be explained by making assumptions about discarded time zone information. Wher e th e time zone offset has been lost at the source device , it would normally be possible to confirm this by reverting to the forensic image collected from the device. Without access to the se f orensic images, I cannot independently verify the accuracy of the provided information. 96.T he example above is an illustrative example where the offset is very clear. However it is most often not so simple to form a view about what the data is intended to indicate: in the case of ID_000757 for example, the OS Created timestamp is greatly differ ent from the metadata timestamp, even after the reconstituting process I mentioned above . 97.T he fact that other timestamps are plainly not correct leads me to doubt the accuracy of thi s i nformation, but in cases such as ID_000757 I have no method to validate whether or not these are correct and have not therefore been able to assess the timestamps in such cases as part of my review. DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C{ID_000757}{ID_000835} {ID_000757} First Expert Report of Patrick Madden Page 37 of 98 37Later schedules provided via Travers Smith 98.I was later provided with two additional supplementary schedules of data that I understand were provided by Travers Smith to address some of these deficiencies. However, these supplements were also inconsisten t. For example , it can be seen in the below screenshot extract that the dates have been formatted in different ways in adjacent r ows, and the times alternate between 12 and 24 hour clock configurations: 99.Wh ile it is possible, with some effort, to reformat these into a more consistent formatting (and I have attempted to do so where the point has arisen in relation to a document I have analysed ) I cannot however be sure that I have always correctly applied a 12 or 24 hour clock and I am not able to rely on this information fully. It also has the same problems with time zones that I haveexplained above. As such , I have no method by which I can validate that the information provided to me is accurate and has not already been muddled or mixed up. 100. Ove rall, the accompanying schedules give the impression that the dataset has been exported from multiple different e -disclosure platform s ources and combined in a way that was not consistent and which appears to have discarded important information. 101. I h ave therefore been able to rely upon this provided metadata only very little. In cases where I have needed to consult the provided metadata to aid my analysis, I have either taken the metadata provided at face value (which should be understood as a limitation in the DocuSign Envelope ID: 38CC5CE2-703D-4A6C-A581-56AE2F5B394C First Expert Report of Patrick Madden Page 38 of 98 38circumstances), o r I have done my best to try to account for time zone variations . In doing so, I am informed by Bird & Bird that relevant time zones may include Australian time zones ( as Dr Wright was previously resident there), which I have taken into account, but for many of the document types the relevant time zone at the time of authorship cannot be reliably determined and therefore cannot be reliably applied. Different approaches to metadata used by various technologies 102. When discussing Internal Metadata, it is important to note that different file types record a nd st ore metadata in different ways. They also store data in different ways, therefore whe n c onverting between formats it is not unusual to incur defects or changes to the way that the content was displayed or organised on the screen. 103. E ven within the same File format, there are often different ways in which the content can b e st ructured and stored. Similarly, MS Word . DOC and . DOCX files , though related, are in fac t e ntirely different formats as I explain below, and t he PDF file format can incorporate a variety of different encodings into a
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Closings
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from Paris on the 2nd. Next, what Mr Matthews did after that is a different thing. 350 The full exchange is at {Day8/23:1} - {Day8/26:25} . 82 Q. But it was an incredibly high risk strategy, on your account, wasn't it, Dr Wright, for Mr MacGregor to be sending fake e mails about what you were up to to somebody who was going to be spending time with you over the following days? A. No, he didn't actually realise Stefan would. I talked to Stefan and had him come over. I mean, I called him and said, "Please, I need to talk to you", so I don't think Robert actually wanted him to be there, and I know Rob was incredibly angry later. 198. In short, Dr Wright’s story is that, at the time when he was in fact taking the position that he would not provide public proof before further steps had been taken, Mr MacGregor was sending emails to Mr Matthews and others in Dr Wright’s name taking the opposite position (i.e. that he would try straight away to provide public proof in various forms). His account is Mr MacGregor was doing this over at least several days in a series of emails while he (Dr Wright) was speaking to and spending time with Mr Matthews, all without anyone finding out. The notion is absurd. Mr Matthews 199. Mr Matthews gave dishonest evidence that he knew of Dr Wright’s work on developing Bitcoin in 2008; that he received a draft of the Bitcoin White Paper from Dr Wright in August 2008; that Dr Wright offered him Bitcoin in exchange for money in early 2009; and that Dr Wright pitched a blockchain- based project to him in ear ly 2009. In addition, his account of the “Big Reveal” is heavily skewed by his desire to cast Mr MacGregor as a bully and so divert attention from Dr Wright’s failure to provide the proof everyone expected. There are several indications of Mr Matthews’ dishonesty. 200. First, in his WhatsApp exchange with Mr Ager -Hanssen on 25 September 2023 {L20/183/1} , he clearly expressed the view that Dr Wright was a fake. Responding to a message describing Dr Wright as the “Biggest fake ever”, Mr Matthews replied: “Fuc k. WTF is wrong with him. Well, at least we have NCH [nChain] to focus on, that’s not fake. ” Under cross -examination, he made a hopeless attempt to deny the plain meaning of these words.351 He also attempted to explain the email by saying that it was in tended to divert Mr Ager -Hanssen, who was threatening to “ destroy ” him.352 However, as the Court put to him, the balance of power lay with Mr Matthews,353 who in the event was able to fire Mr Ager -Hanssen and have him injuncted. If the Court accepts that M r 351 {Day11/73:15} - {Day11/79:15} . 352 {Day11/79:16} - {Day11/83:23} . 353 {Day12/100:1} . 83 Matthews’ message bore its obvious meaning and that he intended that meaning, then he cannot have believed that Dr Wright was Satoshi Nakamoto. It follows that his evidence about receiving the Bitcoin White Paper from Dr Wright in 2008 cannot be true. 201. Secondly, Mr Matthews’ account of receiving the Bitcoin White Paper from Dr Wright was in any event not plausible. It is not supported by any documentary evidence, or evidence from any other witnesses. It was not told until after 2015, when doing so served Mr Matthews’ financial interests. The accounts from Dr Wright and Mr Matthews conflict, with Mr Matthews saying that the paper was provided in a USB stick containing a single file, which he printed, while Dr Wright claims that he handed over a paper copy. Mr Matthews’ account in his statement also conflicted with the account Mr O’Hagan took from him and recorded in “the Satoshi Affair”. See generally {Day11/89:22} - {Day11/103:20} . 202. When the Court asked Mr Matthews why he dated his receipt of the White Paper to August 2008, he let down his guard and said that his anchor point in time was that the White Paper was released publicly on 31 October 2008 and he received the paper before that time. He then tried to say that he would have been aware of th at anchor point because the release was public, but when pressed he admitted that the release was not well -known at the time (and on his own evidence, he took no interest in Bitcoin after reading the paper). In the end, he could only say “ that’s my unders tanding of how to place it in the 2008 calendar ”.354 In short, these answers further betrayed his story as dishonest. 203. Thirdly, it is apparent that Mr Matthews had no idea that Dr Wright was claiming to be the inventor of Bitcoin when they were reconnecting in early 2014. That is evident from his email introducing Dr Wright to Mr MacGregor in February 2014.355 In that email, he put Dr Wright forward as a potential partner for a business venture concerned with cryptocurrencies but did not mention his best a nd singular qualification as the actual creator of the original cryptocurrency. The following exchange highlighted how ridiculous that would be:356 354 {Day12/97:16} - {Day12/98:11} . 355 {L8/340/2} . 356 {Day11/118/4 } - {Day11/118/16} . 84 Q. But you were introducing two people in the context of a project about cryptocurrencies and you're saying it doesn't occur to you to mention that one of them is the inventor of the whole Bitcoin cryptocurrency blockchain system? A. I didn't want to go to that level of detail, I wanted to introduce two people and let them find out if they had a way of working t ogether. Q. It's not a level of detail; it's one sentence on something which you've told us had not been a matter of secrecy. A. I did not disclose that at the time to MacGregor. Obviously MacGregor found out later. 204. Overall, Mr Matthews was considerably more careful in his lies than Dr Wright, only lying where he had to do so to sustain Dr Wright’s position. In relation to the events of 2015- 16, Mr Matthews’ evidence was far more consistent than Dr Wright’s with the contemporaneous documents. Later in these Closing Submissions is a selection of the significant differences between Mr Matthews’ evidence and Dr Wright’s. It does not follow from these differences that Mr Matthews was telling the truth on all the points concerned, but it is of value on some topics where it is consistent with contemporaneous documents
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 31 of 82 COPA's Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/COPA's Closing Submissions.pdf ### File content: from Paris on the 2nd. Next, what Mr Matthews did after that is a different thing. 350 The full exchange is at {Day8/23:1} - {Day8/26:25} . 82 Q. But it was an incredibly high risk strategy, on your account, wasn't it, Dr Wright, for Mr MacGregor to be sending fake e mails about what you were up to to somebody who was going to be spending time with you over the following days? A. No, he didn't actually realise Stefan would. I talked to Stefan and had him come over. I mean, I called him and said, "Please, I need to talk to you", so I don't think Robert actually wanted him to be there, and I know Rob was incredibly angry later. 198. In short, Dr Wright’s story is that, at the time when he was in fact taking the position that he would not provide public proof before further steps had been taken, Mr MacGregor was sending emails to Mr Matthews and others in Dr Wright’s name taking the opposite position (i.e. that he would try straight away to provide public proof in various forms). His account is Mr MacGregor was doing this over at least several days in a series of emails while he (Dr Wright) was speaking to and spending time with Mr Matthews, all without anyone finding out. The notion is absurd. Mr Matthews 199. Mr Matthews gave dishonest evidence that he knew of Dr Wright’s work on developing Bitcoin in 2008; that he received a draft of the Bitcoin White Paper from Dr Wright in August 2008; that Dr Wright offered him Bitcoin in exchange for money in early 2009; and that Dr Wright pitched a blockchain- based project to him in ear ly 2009. In addition, his account of the “Big Reveal” is heavily skewed by his desire to cast Mr MacGregor as a bully and so divert attention from Dr Wright’s failure to provide the proof everyone expected. There are several indications of Mr Matthews’ dishonesty. 200. First, in his WhatsApp exchange with Mr Ager -Hanssen on 25 September 2023 {L20/183/1} , he clearly expressed the view that Dr Wright was a fake. Responding to a message describing Dr Wright as the “Biggest fake ever”, Mr Matthews replied: “Fuc k. WTF is wrong with him. Well, at least we have NCH [nChain] to focus on, that’s not fake. ” Under cross -examination, he made a hopeless attempt to deny the plain meaning of these words.351 He also attempted to explain the email by saying that it was in tended to divert Mr Ager -Hanssen, who was threatening to “ destroy ” him.352 However, as the Court put to him, the balance of power lay with Mr Matthews,353 who in the event was able to fire Mr Ager -Hanssen and have him injuncted. If the Court accepts that M r 351 {Day11/73:15} - {Day11/79:15} . 352 {Day11/79:16} - {Day11/83:23} . 353 {Day12/100:1} . 83 Matthews’ message bore its obvious meaning and that he intended that meaning, then he cannot have believed that Dr Wright was Satoshi Nakamoto. It follows that his evidence about receiving the Bitcoin White Paper from Dr Wright in 2008 cannot be true. 201. Secondly, Mr Matthews’ account of receiving the Bitcoin White Paper from Dr Wright was in any event not plausible. It is not supported by any documentary evidence, or evidence from any other witnesses. It was not told until after 2015, when doing so served Mr Matthews’ financial interests. The accounts from Dr Wright and Mr Matthews conflict, with Mr Matthews saying that the paper was provided in a USB stick containing a single file, which he printed, while Dr Wright claims that he handed over a paper copy. Mr Matthews’ account in his statement also conflicted with the account Mr O’Hagan took from him and recorded in “the Satoshi Affair”. See generally {Day11/89:22} - {Day11/103:20} . 202. When the Court asked Mr Matthews why he dated his receipt of the White Paper to August 2008, he let down his guard and said that his anchor point in time was that the White Paper was released publicly on 31 October 2008 and he received the paper before that time. He then tried to say that he would have been aware of th at anchor point because the release was public, but when pressed he admitted that the release was not well -known at the time (and on his own evidence, he took no interest in Bitcoin after reading the paper). In the end, he could only say “ that’s my unders tanding of how to place it in the 2008 calendar ”.354 In short, these answers further betrayed his story as dishonest. 203. Thirdly, it is apparent that Mr Matthews had no idea that Dr Wright was claiming to be the inventor of Bitcoin when they were reconnecting in early 2014. That is evident from his email introducing Dr Wright to Mr MacGregor in February 2014.355 In that email, he put Dr Wright forward as a potential partner for a business venture concerned with cryptocurrencies but did not mention his best a nd singular qualification as the actual creator of the original cryptocurrency. The following exchange highlighted how ridiculous that would be:356 354 {Day12/97:16} - {Day12/98:11} . 355 {L8/340/2} . 356 {Day11/118/4 } - {Day11/118/16} . 84 Q. But you were introducing two people in the context of a project about cryptocurrencies and you're saying it doesn't occur to you to mention that one of them is the inventor of the whole Bitcoin cryptocurrency blockchain system? A. I didn't want to go to that level of detail, I wanted to introduce two people and let them find out if they had a way of working t ogether. Q. It's not a level of detail; it's one sentence on something which you've told us had not been a matter of secrecy. A. I did not disclose that at the time to MacGregor. Obviously MacGregor found out later. 204. Overall, Mr Matthews was considerably more careful in his lies than Dr Wright, only lying where he had to do so to sustain Dr Wright’s position. In relation to the events of 2015- 16, Mr Matthews’ evidence was far more consistent than Dr Wright’s with the contemporaneous documents. Later in these Closing Submissions is a selection of the significant differences between Mr Matthews’ evidence and Dr Wright’s. It does not follow from these differences that Mr Matthews was telling the truth on all the points concerned, but it is of value on some topics where it is consistent with contemporaneous documents
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Nicholas Bohm Witness Statement - Exhibit
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Subject: Re: [bitcoin-list] Bitcoin v0.1.5 released From: Hal Finney <[email protected]> Date: 27/02/2009, 20:00 To: [email protected] CC: [email protected] On Sun, Feb 22, 2009 at 9:35 AM, Satoshi Nakamoto <[email protected]> wrote: What's next? The next thing for v0.1.6 is to take advantage of multiple processors to generate blocks. Currently it only starts one thread. If you have a multi-core processor like a Core Duo or Quad this will double or quadruple your production. That sounds good. I'd also like to be able to run multiple coin/block generators on multiple machines, all behind a single NAT address. I haven't tried this yet so I don't know if it works on the current software. BTW I don't remember if we talked about this, but the other day some people were mentioning secure timestamping. You want to be able to prove that a certain document existed at a certain time in the past. Seems to me that bitcoin's stack of blocks would be perfect for this. Later I want to add interfaces to make it really easy to integrate into websites from any server side language. Right, and I'd like to see more of a library interface that could be called from programming or scripting languages, on the client side as well. Hal ------------------------------------------------------------------------------ Open Source Business Conference (OSBC), March 24-25, 2009, San Francisco, CA -OSBC tackles the biggest issue in open source: Open Sourcing the Enterprise -Strategies to boost innovation and cut costs with open source participation -Receive a $600 discount off the registration fee with the source code: SFAD http://p.sf.net/sfu/XcvMzF8H _______________________________________________ bitcoin-list mailing list [email protected] https://lists.sourceforge.net/lists/listinfo/bitcoin-listRe: [bitcoin-list] Bitcoin v0.1.5 released mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:10
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090227-Re__bitcoin-list_ Bitcoin v0.1.5 released-181564(75057025.1).pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090227-Re__bitcoin-list_ Bitcoin v0.1.5 released-181564(75057025.1).pdf ### File content: Subject: Re: [bitcoin-list] Bitcoin v0.1.5 released From: Hal Finney <[email protected]> Date: 27/02/2009, 20:00 To: [email protected] CC: [email protected] On Sun, Feb 22, 2009 at 9:35 AM, Satoshi Nakamoto <[email protected]> wrote: What's next? The next thing for v0.1.6 is to take advantage of multiple processors to generate blocks. Currently it only starts one thread. If you have a multi-core processor like a Core Duo or Quad this will double or quadruple your production. That sounds good. I'd also like to be able to run multiple coin/block generators on multiple machines, all behind a single NAT address. I haven't tried this yet so I don't know if it works on the current software. BTW I don't remember if we talked about this, but the other day some people were mentioning secure timestamping. You want to be able to prove that a certain document existed at a certain time in the past. Seems to me that bitcoin's stack of blocks would be perfect for this. Later I want to add interfaces to make it really easy to integrate into websites from any server side language. Right, and I'd like to see more of a library interface that could be called from programming or scripting languages, on the client side as well. Hal ------------------------------------------------------------------------------ Open Source Business Conference (OSBC), March 24-25, 2009, San Francisco, CA -OSBC tackles the biggest issue in open source: Open Sourcing the Enterprise -Strategies to boost innovation and cut costs with open source participation -Receive a $600 discount off the registration fee with the source code: SFAD http://p.sf.net/sfu/XcvMzF8H _______________________________________________ bitcoin-list mailing list [email protected] https://lists.sourceforge.net/lists/listinfo/bitcoin-listRe: [bitcoin-list] Bitcoin v0.1.5 released mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:10
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Closings
part 71 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
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up his interactions with individuals. In doing so, he inadvertently reveals the way in which he sees overlaps in his de alings with individuals and elaborates on them to create his version of events. {L3/252.1.1.1/1} {L3/252.1.1.1/2} - Microsoft Documents {Day6/89:20 -25} Page 3, please, at the bottom {L3/252.1.1.1/3}. Bottom of the page, you were in communication, weren't you, with Microsoft and with Siemens, the IT recruitment people, expressing interest in a job in Microsoft's click fraud team? Dr Wri ght admits that his interactions with Microsoft were with the IT recruitment Appendix B: Schedule of Transcript References 175 REFERENCE QUOTE COMMENT A. That's correct. team, relating to a job in the click fraud team. {Day6/90:15 -18} Q. And then page 2 {L3/252.1.1.1/2}, at the top, the job was as a programme manager in a Microsoft team combatin g click fraud, right? A. That's correct. Dr Wright admits that his interactions with Microsoft were with the IT recruitment team, relating to a job in the click fraud team. {Day6/95:14} - {Day6/97:9} {L3/252.1.1/1} Q. And shortly after the interview, Satoshi actually releases the paper, yes? A. Yes, right after the interview, actually days later, I was told that there was a hiring freeze at Microsoft. Q. And yet there is not a shred of evidence in any of these emai ls that you showed the Bitcoin White Paper to Microsoft, whereas there is plenty of evidence in the emails that you showed Microsoft some of your other work, isn’t there? A. No, there’s very little here actually. This is only a work email. The majority of my communications were done on my private emails, on Ridge Estates, so as you might guess, I tried to minimise any emails to and from the work domain. Q. But in this interview process, which you told the court in Granath might have led to Microsoft ownin g this invention of yours, there is not a mention of it, is there? A. No, because you don’t have those. You only have the interviewer ones. What you’ll notice is none of the communications between the Microsoft individuals that were done on the Ridges Est ate email and myself were there. In the intervening period, I talked to a number of people in the advertising and what is now Bing area. In the communications, I explained that if we could implement a small proof - of - work fee, this would remove any ince ntive for people to scam the system. Now, one of the things, if you actually read Adam Back’s - I’ll even quote his, he talks about proof - of - work as a means of stopping spam and - - Q. Can I pause you there, because I asked you a specific question. Du ring the course of this entire exchange, this entire interview process, which you have said could have resulted in Microsoft owning the system which you had developed - you claim to have developed, you never mention the system at any point in any of the do cuments in any of the communications we have, do you? A. No. As I stated, I only have very limited numbers of emails and things left. I have none of the Ridges Estate emails Dr Wright refers to further interactions with Microsoft / Bing, without having provided any evidence of them. Further, Dr Wright states that he doesn’t have any of the Ridges Estate emails to which he refer s, despite there being Ridges Estate emails in his disclosure documents, including some which he seeks to rely on in his 11th witness statement (ID_000039). Appendix B: Schedule of Transcript References 176 REFERENCE QUOTE COMMENT or any of those other ones. What’s happened over time is I’ve lost those. It’s m any years ago. At the time, I wasn’t also sitting there going Bitcoin’s going to be a multi - billion dollar invention. In one of my early notes, I put down that I thought it might get me either a partnership or a professorship with tenure and that was about the extent of what I thought of my invention. {L7/471} - Reliance document ID_004018 Notebook with Bitcoin Notes - BDO/Microsoft {Day6/98:19} - {Day6/100:17} Q. Now, this all reads as descriptions of your discussions with BDO and a forthcoming meeting with Microsoft, doesn’t it? A. I continued discussions with BDO. Alan actually ended up, after he’d left BDO, becomi ng a director, and also the main audit lead at some of my firms. On top of that, Microsoft came back to me in 2011 and I had further communications with them between ’11 and ’12. Q. But the reference to not being able to get BDO in on this, that’s plainly a reference to things going on in 2008, based on your evidence, isn’t it? A. No, it’s not at all. Q. So you’re saying that these in fact came later? A. Yes, this was notes I was making in 2012. This was a preparation document for the AAT, Administrativ e Appeals Tribunal. I took these notes working as I was also getting everything together for the dispute with the Tax Office and I put down some of the issues with both BDO and Microsoft at the time. Q. You first dated these notes in communications with o ur side to 2011/2012 in your chain of custody document of October last year, didn’t you? A. No, the first time I dated this goes back to well before that, back to the Kleiman case. Q. It’s the first time you told us that this document had been produced i n 2011/2012, isn’t it? A. I don’t know when you were told. All I can say is that I went through all of this with lawyers earlier , and when it goes from the Relativity and disclosure platform to you, I don’t know. Q. So you’re now saying that it was all written in 2011/2012? Dr Wright appears to accept that notes which purported to date to 2008/2009, are actually notes he made in 2011/12, although refuses to accept that this story was first put forward when he provided his chain of custody information (following service of Ben Ford’s statement). Appendix B: Schedule of Transcript References 177 REFERENCE QUOTE COMMENT A. Probably more 2012, but, yes, this is my notes as I was preparing for the AAT. Q. You first came up with that story, didn’t you, after COPA had provided evidence from Ben
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 71 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: up his interactions with individuals. In doing so, he inadvertently reveals the way in which he sees overlaps in his de alings with individuals and elaborates on them to create his version of events. {L3/252.1.1.1/1} {L3/252.1.1.1/2} - Microsoft Documents {Day6/89:20 -25} Page 3, please, at the bottom {L3/252.1.1.1/3}. Bottom of the page, you were in communication, weren't you, with Microsoft and with Siemens, the IT recruitment people, expressing interest in a job in Microsoft's click fraud team? Dr Wri ght admits that his interactions with Microsoft were with the IT recruitment Appendix B: Schedule of Transcript References 175 REFERENCE QUOTE COMMENT A. That's correct. team, relating to a job in the click fraud team. {Day6/90:15 -18} Q. And then page 2 {L3/252.1.1.1/2}, at the top, the job was as a programme manager in a Microsoft team combatin g click fraud, right? A. That's correct. Dr Wright admits that his interactions with Microsoft were with the IT recruitment team, relating to a job in the click fraud team. {Day6/95:14} - {Day6/97:9} {L3/252.1.1/1} Q. And shortly after the interview, Satoshi actually releases the paper, yes? A. Yes, right after the interview, actually days later, I was told that there was a hiring freeze at Microsoft. Q. And yet there is not a shred of evidence in any of these emai ls that you showed the Bitcoin White Paper to Microsoft, whereas there is plenty of evidence in the emails that you showed Microsoft some of your other work, isn’t there? A. No, there’s very little here actually. This is only a work email. The majority of my communications were done on my private emails, on Ridge Estates, so as you might guess, I tried to minimise any emails to and from the work domain. Q. But in this interview process, which you told the court in Granath might have led to Microsoft ownin g this invention of yours, there is not a mention of it, is there? A. No, because you don’t have those. You only have the interviewer ones. What you’ll notice is none of the communications between the Microsoft individuals that were done on the Ridges Est ate email and myself were there. In the intervening period, I talked to a number of people in the advertising and what is now Bing area. In the communications, I explained that if we could implement a small proof - of - work fee, this would remove any ince ntive for people to scam the system. Now, one of the things, if you actually read Adam Back’s - I’ll even quote his, he talks about proof - of - work as a means of stopping spam and - - Q. Can I pause you there, because I asked you a specific question. Du ring the course of this entire exchange, this entire interview process, which you have said could have resulted in Microsoft owning the system which you had developed - you claim to have developed, you never mention the system at any point in any of the do cuments in any of the communications we have, do you? A. No. As I stated, I only have very limited numbers of emails and things left. I have none of the Ridges Estate emails Dr Wright refers to further interactions with Microsoft / Bing, without having provided any evidence of them. Further, Dr Wright states that he doesn’t have any of the Ridges Estate emails to which he refer s, despite there being Ridges Estate emails in his disclosure documents, including some which he seeks to rely on in his 11th witness statement (ID_000039). Appendix B: Schedule of Transcript References 176 REFERENCE QUOTE COMMENT or any of those other ones. What’s happened over time is I’ve lost those. It’s m any years ago. At the time, I wasn’t also sitting there going Bitcoin’s going to be a multi - billion dollar invention. In one of my early notes, I put down that I thought it might get me either a partnership or a professorship with tenure and that was about the extent of what I thought of my invention. {L7/471} - Reliance document ID_004018 Notebook with Bitcoin Notes - BDO/Microsoft {Day6/98:19} - {Day6/100:17} Q. Now, this all reads as descriptions of your discussions with BDO and a forthcoming meeting with Microsoft, doesn’t it? A. I continued discussions with BDO. Alan actually ended up, after he’d left BDO, becomi ng a director, and also the main audit lead at some of my firms. On top of that, Microsoft came back to me in 2011 and I had further communications with them between ’11 and ’12. Q. But the reference to not being able to get BDO in on this, that’s plainly a reference to things going on in 2008, based on your evidence, isn’t it? A. No, it’s not at all. Q. So you’re saying that these in fact came later? A. Yes, this was notes I was making in 2012. This was a preparation document for the AAT, Administrativ e Appeals Tribunal. I took these notes working as I was also getting everything together for the dispute with the Tax Office and I put down some of the issues with both BDO and Microsoft at the time. Q. You first dated these notes in communications with o ur side to 2011/2012 in your chain of custody document of October last year, didn’t you? A. No, the first time I dated this goes back to well before that, back to the Kleiman case. Q. It’s the first time you told us that this document had been produced i n 2011/2012, isn’t it? A. I don’t know when you were told. All I can say is that I went through all of this with lawyers earlier , and when it goes from the Relativity and disclosure platform to you, I don’t know. Q. So you’re now saying that it was all written in 2011/2012? Dr Wright appears to accept that notes which purported to date to 2008/2009, are actually notes he made in 2011/12, although refuses to accept that this story was first put forward when he provided his chain of custody information (following service of Ben Ford’s statement). Appendix B: Schedule of Transcript References 177 REFERENCE QUOTE COMMENT A. Probably more 2012, but, yes, this is my notes as I was preparing for the AAT. Q. You first came up with that story, didn’t you, after COPA had provided evidence from Ben
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Patrick Madden
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9,110
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z=1 z” whereas in the MS Word Import it is aligned differently. I investigated this and drew conclusions as follows: a. I observed that the bracket character has not been imported as normal paragraph text, but as a floating textbox with a transparent background and no visible border. This can be observed in the following screenshot which shows that character selected, showing the border and resizing handles : b. This therefore appears to be a difference in how the floating text box is aligned on the page, rather than a difference in the conversion of text specifically. According to the way that my MS Word 2016 software was configured, the text box defaulted to “square” text wrapping layout, which causes a margin of white space to be placed around the text box: 24 - 24 - H/238/24{ID_004011} Madden Appendix PM44 BWP – CoC information Page 25 of 27 c. T hat is one of several text wrapping settings available for text boxes and images . Others , such as the “behind text” layout option, do not introduce a margin in the same way : d. Selecting one of those wrapping settings results in an identical display of overlapping text to that shown in ID_004011: ID_004011: MS Word 2016 Import: 51. This therefore indicates that the third difference above is the result of a different “layout” setting being assigned to the text box in question. Further: a. W ithout inspection of the native content and computing equipment used to create this document, it is not possible to explain why this layout setting differed between the two machines. Madden Appendix PM44 BWP – CoC information Page 25 of 27 c. T hat is one of several text wrapping settings available for text boxes and images . Others , such as the “behind text” layout option, do not introduce a margin in the same way : d. Selecting one of those wrapping settings results in an identical display of overlapping text to that shown in ID_004011: ID_004011: MS Word 2016 Import: 51. This therefore indicates that the third difference above is the result of a different “layout” setting being assigned to the text box in question. Further: a. W ithout inspection of the native content and computing equipment used to create this document, it is not possible to explain why this layout setting differed between the two machines. 25 - 25 - H/238/25{ID_004011} Madden Appendix PM44 BWP – CoC information Page 26 of 27 b. However, I note that MS Word 2016 allows its user to configure settings relating to the default text- wrapping used for text boxes and images. The content is also user -editable at the point of conversion, though without access to the native file (or any historical versions of it), it is not possible to ascertain the pattern of editing . Not possible to replicate in 2008 52. Having regard to the various technical errors of conversion that I have observed, I do not think it would be possible to replicate the precise sequence of errors in the same way by user editing. That would require a user in 2008 to make a series of edits, and by chance for these to replicate the various technical errors caused by software dating to 2016, many of which would involve cumbersome processes (such as drawing small lines, removing parts of diagrams, or rearranging text characters on the page) , with the only difference being the result of an alignment setting in one text box. In my view, it is not possible, as a technical matter for a user to carry out the precise series of changes required. 53. I also observe that earlier versions of Word used did not result in the same pattern of conversion : in the case of Word 2013, the pattern of conversion was different and notably did not match that of ID_004011. In the case of Word 2007 and Word 2003, those versions of the software were contemporary to 2008 -2009 but did not support opening PDF documents, so cannot account for the anomalies observed. Summary 54. In my view, the characteristics of ID_004011 indicate that it was created by conversion from a PDF to editable form. 55. The error in encoding of the title is exhibited in only one other document in the disclosure dataset, which is ID_000537. Importing ID_000537 into MS Word 2016, by selecting the “open” option and opening the PDF results in a document which is almost identical to ID_004011 but for one differe nce that appears to be the result of configurable settings in MS Word 2016. 56. The most prominent difference is the footer relating to 2019, but that is user -editable and able to be deleted by pressing “delete”. The result of deletion of that content is to remove the content which is visibly not contemporary to 2008 -2009, and to cause the text of subsequent pages to be moved up into the vacated space, in both cases consistently with the presentation of ID_004011 (and therefore ID_003330) – but not consistently with any other document in the disclosure dataset. Madden Appendix PM44 BWP – CoC information Page 26 of 27 b. However, I note that MS Word 2016 allows its user to configure settings relating to the default text- wrapping used for text boxes and images. The content is also user -editable at the point of conversion, though without access to the native file (or any historical versions of it), it is not possible to ascertain the pattern of editing . Not possible to replicate in 2008 52. Having regard to the various technical errors of conversion that I have observed, I do not think it would be possible to replicate the precise sequence of errors in the same way by user editing. That would require a user in 2008 to make a series of edits, and by chance for these to replicate the various technical errors caused by software dating to 2016, many of which would involve cumbersome processes (such as drawing small lines, removing parts of diagrams, or rearranging text
1,013
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 8 of 9 Appendix PM44.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM44.pdf ### File content: z=1 z” whereas in the MS Word Import it is aligned differently. I investigated this and drew conclusions as follows: a. I observed that the bracket character has not been imported as normal paragraph text, but as a floating textbox with a transparent background and no visible border. This can be observed in the following screenshot which shows that character selected, showing the border and resizing handles : b. This therefore appears to be a difference in how the floating text box is aligned on the page, rather than a difference in the conversion of text specifically. According to the way that my MS Word 2016 software was configured, the text box defaulted to “square” text wrapping layout, which causes a margin of white space to be placed around the text box: 24 - 24 - H/238/24{ID_004011} Madden Appendix PM44 BWP – CoC information Page 25 of 27 c. T hat is one of several text wrapping settings available for text boxes and images . Others , such as the “behind text” layout option, do not introduce a margin in the same way : d. Selecting one of those wrapping settings results in an identical display of overlapping text to that shown in ID_004011: ID_004011: MS Word 2016 Import: 51. This therefore indicates that the third difference above is the result of a different “layout” setting being assigned to the text box in question. Further: a. W ithout inspection of the native content and computing equipment used to create this document, it is not possible to explain why this layout setting differed between the two machines. Madden Appendix PM44 BWP – CoC information Page 25 of 27 c. T hat is one of several text wrapping settings available for text boxes and images . Others , such as the “behind text” layout option, do not introduce a margin in the same way : d. Selecting one of those wrapping settings results in an identical display of overlapping text to that shown in ID_004011: ID_004011: MS Word 2016 Import: 51. This therefore indicates that the third difference above is the result of a different “layout” setting being assigned to the text box in question. Further: a. W ithout inspection of the native content and computing equipment used to create this document, it is not possible to explain why this layout setting differed between the two machines. 25 - 25 - H/238/25{ID_004011} Madden Appendix PM44 BWP – CoC information Page 26 of 27 b. However, I note that MS Word 2016 allows its user to configure settings relating to the default text- wrapping used for text boxes and images. The content is also user -editable at the point of conversion, though without access to the native file (or any historical versions of it), it is not possible to ascertain the pattern of editing . Not possible to replicate in 2008 52. Having regard to the various technical errors of conversion that I have observed, I do not think it would be possible to replicate the precise sequence of errors in the same way by user editing. That would require a user in 2008 to make a series of edits, and by chance for these to replicate the various technical errors caused by software dating to 2016, many of which would involve cumbersome processes (such as drawing small lines, removing parts of diagrams, or rearranging text characters on the page) , with the only difference being the result of an alignment setting in one text box. In my view, it is not possible, as a technical matter for a user to carry out the precise series of changes required. 53. I also observe that earlier versions of Word used did not result in the same pattern of conversion : in the case of Word 2013, the pattern of conversion was different and notably did not match that of ID_004011. In the case of Word 2007 and Word 2003, those versions of the software were contemporary to 2008 -2009 but did not support opening PDF documents, so cannot account for the anomalies observed. Summary 54. In my view, the characteristics of ID_004011 indicate that it was created by conversion from a PDF to editable form. 55. The error in encoding of the title is exhibited in only one other document in the disclosure dataset, which is ID_000537. Importing ID_000537 into MS Word 2016, by selecting the “open” option and opening the PDF results in a document which is almost identical to ID_004011 but for one differe nce that appears to be the result of configurable settings in MS Word 2016. 56. The most prominent difference is the footer relating to 2019, but that is user -editable and able to be deleted by pressing “delete”. The result of deletion of that content is to remove the content which is visibly not contemporary to 2008 -2009, and to cause the text of subsequent pages to be moved up into the vacated space, in both cases consistently with the presentation of ID_004011 (and therefore ID_003330) – but not consistently with any other document in the disclosure dataset. Madden Appendix PM44 BWP – CoC information Page 26 of 27 b. However, I note that MS Word 2016 allows its user to configure settings relating to the default text- wrapping used for text boxes and images. The content is also user -editable at the point of conversion, though without access to the native file (or any historical versions of it), it is not possible to ascertain the pattern of editing . Not possible to replicate in 2008 52. Having regard to the various technical errors of conversion that I have observed, I do not think it would be possible to replicate the precise sequence of errors in the same way by user editing. That would require a user in 2008 to make a series of edits, and by chance for these to replicate the various technical errors caused by software dating to 2016, many of which would involve cumbersome processes (such as drawing small lines, removing parts of diagrams, or rearranging text
1,566
/content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
Closings
part 42 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
236,795
438,889
helf company and efforts were later made to create documents suggesting that it had been bought in 2011. That's the truth, isn't it, Dr Wright? A. No. What it suggests is, because I'm rather close to my chest with most of my corporations and things - - or I used to be; now everyone knows everything about me - - I had a variety of companies that people didn't know about, so they didn't realise that I actually had over 20 overseas corporations that were well documented, they didn't realise that I'd already been in disputes over these companies, they didn't realise that just shutting down a company doesn't give you assets. I mean, that was probably the most asinine bit. Ira and others actually believing that if they liquidated my companies they would somehow get my intellectual property. So, no, that's what it was all about. Dr Wright blaming third parties (namely Ira Kleiman and others). The Papa Neema emails Appendix B: Schedule of Transcript References 105 REFERENCE QUOTE COMMENT {Day4/148:10} - {Day4/150:9} Q. Let me just see if I can unpick the narrative and if I've got it r ight. First of all, is it right that you say that on 8 September, you told Christen Ager - Hanssen, the then CEO of nChain, that you would request invoices from Denis Mayaka, formerly of Abacus Seychelles, to show your registration of these companies in 2009? A. Yes, that's correct. Q. Then do you say that Mr Ager - Hanssen, you understand, called Mr Mayaka on 9 September 2023, telling him to expect an email from Maze Cyber and send it on to you? A. I do. Q. Then is this right, you say that on 10 Septem ber, Mr Mayaka receives an email from Maze Cyber attaching screenshots of invoices? A. Yes. Q. Then do you say that later that day, Mr Mayaka emailed Stefan Matthews with an email under the name "papa neema@gmail"? A. Well, that's the email address, it' s not the name. Q. But the from the email address "[email protected]"? A. Yes. Q. With a ZIP file containing some screenshots? A. Yes. Q. And that was copied to you? A. It was. Q. You say you then emailed him asking for original invoices and he agreed? A. Correct. Q. And your position is that the invoices shown in the screenshots are real? A. They appear to be, yes. Q. Do you believe, do you understand that the screenshots were photographs taken by Mr Mayaka? A. No, actually, he got them. The screenshots are ones he received from Christen Ager - Hanssen, or a representative thereof. Q. So you think Mr Ager - Hanssen sent Mr Mayaka the screenshots which contained real invoices and were then sent on to you? Dr Wright is evasive in response to questions regarding the provenance of the screenshots of invoices. Appendix B: Schedule of Transcript References 106 REFERENCE QUOTE COMMENT A. I don't actually know if they were real, but he had been talking to Denis. Because he was the CEO of nChain, Denis believed that he should be able to listen to him and trust him - - which is a silly thing, but then we all do silly things - - and then, when he received those, well, screenshots, he forwarded those on to Stefan. After I received that, I went back to Denis and I went, "Why are you sending us screenshots?", in effect, I don't remember my exact wording, and ques tioned him about that, because I wanted the invoices. {Day4/151:19} - {Day4/152:10} Q. Now, you insist, don’t you, in your 11th witness statement that w hatever else, these are not photographs of your monitor? A. No. They are photographs of what I think Christen believed my monitor to be. He’s seen videos, etc, but what he didn’t realise is I don’t run the standard build for nChain. My laptop is a bespoke system, I have it custom made. So while it is Lenovo, it isn’t the same as the other ones. And it is still corporate policy at nChain to run Windows 10 because of some applications we have, but I’m a special case and I run Windows 11. So this is basically someone who believes. It was later discovered that Mr Ager - Hanssen had used a policy update from a VPN that was applied to put malware onto my computer. That wasn’t discovered until September. Mr Ager - Hanssen was fired from nChain and any day now he’l l be facing criminal action. Dr Wright is evasive and blames third parties (Christen Ager -Hanssen) despite not providing any evidence of Mr Ager - Hanssen putting malware into his computer. {Day4/152:16} - {Day4/153:3} {P1/20/9} Q. You have a chain of custody document in the context of these proceedings, don’t you? A. I do. Q. “Spyder.rtf” is the name, isn’t it, of a deleted file from the Samsung Drive which you provided which Mr Madden recovered and which had been backdated to 2017; correct? A. I don’t know if it’s a deleted file on that, but I know what Spyder.rtf is. Q. What sort of document do you say it is? Dr Wright is evasive in response to questions regarding the tabs visible in the screenshots. Appendix B: Schedule of Transcript References 107 REFERENCE QUOTE COMMENT A. The original would have been a corporate policy document about Spyder. The one on that screen, I don’t actually k now. Q. So it’s certainly a document you associate with yourself? A. Oh, it’s one - - I mean, the name is one that I created. Whether it’s that version or not, I don’t know. {Day4/153:13- 21} Q. Dragon Dictate is a form of software you use, isn’t it? A. Yes, but I use a different version than that one. The one being displayed and the one that I have are different. Q. Then the “Z” is a logo for the software Zoter o, isn’t it? A. That’s correct. Q. And Zotero is another software you use, isn’t it? A. It is. Dr Wright admits that he uses Zotero. {Day4/154:20} - {Day4/155:9} Q. … It’s no coincidence, is it, Dr Wright, that we have a monitor of the same model as yours, with tabs - - a whole series of tabs for programs and files associated with you? A. No, it isn’t a coincidence. Mr Ager - Hanssen provided an interview a while back noting
1,077
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 42 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: helf company and efforts were later made to create documents suggesting that it had been bought in 2011. That's the truth, isn't it, Dr Wright? A. No. What it suggests is, because I'm rather close to my chest with most of my corporations and things - - or I used to be; now everyone knows everything about me - - I had a variety of companies that people didn't know about, so they didn't realise that I actually had over 20 overseas corporations that were well documented, they didn't realise that I'd already been in disputes over these companies, they didn't realise that just shutting down a company doesn't give you assets. I mean, that was probably the most asinine bit. Ira and others actually believing that if they liquidated my companies they would somehow get my intellectual property. So, no, that's what it was all about. Dr Wright blaming third parties (namely Ira Kleiman and others). The Papa Neema emails Appendix B: Schedule of Transcript References 105 REFERENCE QUOTE COMMENT {Day4/148:10} - {Day4/150:9} Q. Let me just see if I can unpick the narrative and if I've got it r ight. First of all, is it right that you say that on 8 September, you told Christen Ager - Hanssen, the then CEO of nChain, that you would request invoices from Denis Mayaka, formerly of Abacus Seychelles, to show your registration of these companies in 2009? A. Yes, that's correct. Q. Then do you say that Mr Ager - Hanssen, you understand, called Mr Mayaka on 9 September 2023, telling him to expect an email from Maze Cyber and send it on to you? A. I do. Q. Then is this right, you say that on 10 Septem ber, Mr Mayaka receives an email from Maze Cyber attaching screenshots of invoices? A. Yes. Q. Then do you say that later that day, Mr Mayaka emailed Stefan Matthews with an email under the name "papa neema@gmail"? A. Well, that's the email address, it' s not the name. Q. But the from the email address "[email protected]"? A. Yes. Q. With a ZIP file containing some screenshots? A. Yes. Q. And that was copied to you? A. It was. Q. You say you then emailed him asking for original invoices and he agreed? A. Correct. Q. And your position is that the invoices shown in the screenshots are real? A. They appear to be, yes. Q. Do you believe, do you understand that the screenshots were photographs taken by Mr Mayaka? A. No, actually, he got them. The screenshots are ones he received from Christen Ager - Hanssen, or a representative thereof. Q. So you think Mr Ager - Hanssen sent Mr Mayaka the screenshots which contained real invoices and were then sent on to you? Dr Wright is evasive in response to questions regarding the provenance of the screenshots of invoices. Appendix B: Schedule of Transcript References 106 REFERENCE QUOTE COMMENT A. I don't actually know if they were real, but he had been talking to Denis. Because he was the CEO of nChain, Denis believed that he should be able to listen to him and trust him - - which is a silly thing, but then we all do silly things - - and then, when he received those, well, screenshots, he forwarded those on to Stefan. After I received that, I went back to Denis and I went, "Why are you sending us screenshots?", in effect, I don't remember my exact wording, and ques tioned him about that, because I wanted the invoices. {Day4/151:19} - {Day4/152:10} Q. Now, you insist, don’t you, in your 11th witness statement that w hatever else, these are not photographs of your monitor? A. No. They are photographs of what I think Christen believed my monitor to be. He’s seen videos, etc, but what he didn’t realise is I don’t run the standard build for nChain. My laptop is a bespoke system, I have it custom made. So while it is Lenovo, it isn’t the same as the other ones. And it is still corporate policy at nChain to run Windows 10 because of some applications we have, but I’m a special case and I run Windows 11. So this is basically someone who believes. It was later discovered that Mr Ager - Hanssen had used a policy update from a VPN that was applied to put malware onto my computer. That wasn’t discovered until September. Mr Ager - Hanssen was fired from nChain and any day now he’l l be facing criminal action. Dr Wright is evasive and blames third parties (Christen Ager -Hanssen) despite not providing any evidence of Mr Ager - Hanssen putting malware into his computer. {Day4/152:16} - {Day4/153:3} {P1/20/9} Q. You have a chain of custody document in the context of these proceedings, don’t you? A. I do. Q. “Spyder.rtf” is the name, isn’t it, of a deleted file from the Samsung Drive which you provided which Mr Madden recovered and which had been backdated to 2017; correct? A. I don’t know if it’s a deleted file on that, but I know what Spyder.rtf is. Q. What sort of document do you say it is? Dr Wright is evasive in response to questions regarding the tabs visible in the screenshots. Appendix B: Schedule of Transcript References 107 REFERENCE QUOTE COMMENT A. The original would have been a corporate policy document about Spyder. The one on that screen, I don’t actually k now. Q. So it’s certainly a document you associate with yourself? A. Oh, it’s one - - I mean, the name is one that I created. Whether it’s that version or not, I don’t know. {Day4/153:13- 21} Q. Dragon Dictate is a form of software you use, isn’t it? A. Yes, but I use a different version than that one. The one being displayed and the one that I have are different. Q. Then the “Z” is a logo for the software Zoter o, isn’t it? A. That’s correct. Q. And Zotero is another software you use, isn’t it? A. It is. Dr Wright admits that he uses Zotero. {Day4/154:20} - {Day4/155:9} Q. … It’s no coincidence, is it, Dr Wright, that we have a monitor of the same model as yours, with tabs - - a whole series of tabs for programs and files associated with you? A. No, it isn’t a coincidence. Mr Ager - Hanssen provided an interview a while back noting
1,820
/content/Copa v Wright - Trial Documents/Hearsay Statements/Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf
Hearsay Statements
part 23 of 52 Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf
36,046
102,615
did it. I - I - look, I - I never asked a lot - I suppose I didn't ask a lot of questions I should have, but there was a lot of things happening at the time. Q.Why do you think you should have asked questions? A.Well, it probably would have been better for my future. Q.Why? Why do you think that? MS MARKOE: Objection. Relevance.Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 62 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2510:51:51 10:51:53 10:51:56 10:52:0210:52:05 10:52:10 10:52:11 10:52:17 10:52:2310:52:28 10:52:33 10:52:39 10:52:48 10:52:5310:52:56 10:53:00 10:53:0110:53:02 10:53:05 10:53:15 10:53:20 10:53:26 10:53:34 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 63 THE DEPONENT: Yeah, just - just for my own peace of mind, I guess. BY MR ROCHE: Q.And what things about the divorce agreement have affected your peace of mind? MS MARKOE: Objection. Relevance. BY MR ROCHE: Q.You can answer. A.Nothing, really. I - look, I was happy enough with that. I still am. You know, my - my concern at the time, I guess, was, "Where am I going to go?" Because I don't have family here; I don't - like, Craig got all the friends in the divorce, too, so - I think it was just a matter of my own insecurities. Q.Okay. I want to switch gears here for a second. We talked a little bit about your history with Craig, and when did you - you said you first met Craig in 1996? A.Yes. Q.What was his occupation at the time? A.He was working for a company called OzEmail, which was a - I guess a - a web-based company here in Sydney. And he - I - I am not sure - I'm not sure what he did for them. I think he was - was a client manager - client manager. I'm not sure.Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 63 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2510:53:36 10:53:39 10:53:42 10:53:48 10:53:5010:53:55 10:53:56 10:53:57 10:53:59 10:54:00 10:54:0110:54:06 10:54:09 10:54:13 10:54:17 10:54:2010:54:24 10:54:34 10:54:3710:54:39 10:54:41 10:54:45 10:54:51 10:54:52 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 64 Q.And at the time you met Craig, what was his educational background? A.I believe he had an undergraduate degree which he got through - through the military, because he was a member of the military for a short time. Q.And this was before you met him? A.Yes. Q.Was he a member of the military when you met him in 1996? A.No, he was not. Q.Okay. And what was his degree in? A.I couldn't tell you. I - I assume it was probably some sort of science-based thing, but - because he liked science and things like that. Q.And when did you get married? A.Late December '96. Q.Okay. And do you know who Calvin Ayre is? MS MARKOE: Objection. Relevance. You can answer it. THE DEPONENT: I don't know, no. I don't know who he is. Oh, wait a minute. Wait a minute. That's the - that's the Canadian guy with the bad hair, isn't it?BY MR ROCHE: Q.He is Canadian. A.Yeah, I've - I only - I'm only aware of him Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 64 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2510:54:55 10:55:04 10:55:09 10:55:09 10:55:1010:55:12 10:55:19 10:55:23 10:55:28 10:55:35 10:55:4110:55:43 10:55:46 10:55:47 10:55:51 10:55:5310:55:55 10:56:02 10:56:0410:56:07 10:56:11 10:56:14 10:56:21 10:56:26 10:56:29 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 65 through - through the articles that I've seen. Q.Okay. Has Craig ever mentioned Calvin Ayre to you? A.No. Q.Do you know who Steven Matthews is? A.He was a client of ours through - I forget if he was working with a credit
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 23 of 52 Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf ### Folder name: Hearsay Statements ### File path: /content/Copa v Wright - Trial Documents/Hearsay Statements/Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf ### File content: did it. I - I - look, I - I never asked a lot - I suppose I didn't ask a lot of questions I should have, but there was a lot of things happening at the time. Q.Why do you think you should have asked questions? A.Well, it probably would have been better for my future. Q.Why? Why do you think that? MS MARKOE: Objection. Relevance.Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 62 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2510:51:51 10:51:53 10:51:56 10:52:0210:52:05 10:52:10 10:52:11 10:52:17 10:52:2310:52:28 10:52:33 10:52:39 10:52:48 10:52:5310:52:56 10:53:00 10:53:0110:53:02 10:53:05 10:53:15 10:53:20 10:53:26 10:53:34 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 63 THE DEPONENT: Yeah, just - just for my own peace of mind, I guess. BY MR ROCHE: Q.And what things about the divorce agreement have affected your peace of mind? MS MARKOE: Objection. Relevance. BY MR ROCHE: Q.You can answer. A.Nothing, really. I - look, I was happy enough with that. I still am. You know, my - my concern at the time, I guess, was, "Where am I going to go?" Because I don't have family here; I don't - like, Craig got all the friends in the divorce, too, so - I think it was just a matter of my own insecurities. Q.Okay. I want to switch gears here for a second. We talked a little bit about your history with Craig, and when did you - you said you first met Craig in 1996? A.Yes. Q.What was his occupation at the time? A.He was working for a company called OzEmail, which was a - I guess a - a web-based company here in Sydney. And he - I - I am not sure - I'm not sure what he did for them. I think he was - was a client manager - client manager. I'm not sure.Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 63 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2510:53:36 10:53:39 10:53:42 10:53:48 10:53:5010:53:55 10:53:56 10:53:57 10:53:59 10:54:00 10:54:0110:54:06 10:54:09 10:54:13 10:54:17 10:54:2010:54:24 10:54:34 10:54:3710:54:39 10:54:41 10:54:45 10:54:51 10:54:52 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 64 Q.And at the time you met Craig, what was his educational background? A.I believe he had an undergraduate degree which he got through - through the military, because he was a member of the military for a short time. Q.And this was before you met him? A.Yes. Q.Was he a member of the military when you met him in 1996? A.No, he was not. Q.Okay. And what was his degree in? A.I couldn't tell you. I - I assume it was probably some sort of science-based thing, but - because he liked science and things like that. Q.And when did you get married? A.Late December '96. Q.Okay. And do you know who Calvin Ayre is? MS MARKOE: Objection. Relevance. You can answer it. THE DEPONENT: I don't know, no. I don't know who he is. Oh, wait a minute. Wait a minute. That's the - that's the Canadian guy with the bad hair, isn't it?BY MR ROCHE: Q.He is Canadian. A.Yeah, I've - I only - I'm only aware of him Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 64 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2510:54:55 10:55:04 10:55:09 10:55:09 10:55:1010:55:12 10:55:19 10:55:23 10:55:28 10:55:35 10:55:4110:55:43 10:55:46 10:55:47 10:55:51 10:55:5310:55:55 10:56:02 10:56:0410:56:07 10:56:11 10:56:14 10:56:21 10:56:26 10:56:29 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 65 through - through the articles that I've seen. Q.Okay. Has Craig ever mentioned Calvin Ayre to you? A.No. Q.Do you know who Steven Matthews is? A.He was a client of ours through - I forget if he was working with a credit
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the authority and impartiality of the judiciary.” 50. In his Closing Submissions for trial, Dr Wright relied heavily on Article 10 rights in seeking to resist COPA’s claim for injunctive relief . However, the case law is consistent that Article 10 provides either no or very limited protection to the right to publish or otherwise communicate false claims. The starting point is the speech of Lord Hobhouse in the important defamation case of Reynolds v. Times Newspapers Ltd and Others [2001] 2 AC 127 where he stated (at 237- 8): “This case is concerned with the problems which arise from the publication of factual statements which are not correct – i.e. do not conform to the truth. This case is not concerned with freedom of expression and opinion. The citizen is at liberty to comment and take part in free discussion. It is of fundamental importance to a free society that this liberty be recognised and protected by the law. The liberty to communicate (and receive) information has a similar place in a free society but it is important always to remember that it is the communication of information not misinformation which is the subject of this liberty. There is no human right to disseminate information that is not true. No public interest is served by publishing or communicating misinformation. The working of a democratic society depends on the members of that society being informed not misinformed. Misleading people and the purveying as facts statements which are not true is destructive of the democratic society and should form no part of such a society. There is no duty to publish what is not true: there is no interest in being misinformed . These are general propositions going far beyond the mere protection of reputations.” (Emphasis added .) It is clear from this passage not only that human rights do not protect a freedom to spread falsehoods, but that the principle extend s beyond cases concerning reputation, given Lord Hobhouse’s broader references to the interests of the public in a democratic society . 51. Lord Hobhouse ’s speech has been relied on in a number of subsequent cases , including: in WXY v Gewanter & Ors [2012] EWHC 496 (Slade J), where it was noted at [62] that: “ It is uncontroversial that there can be no public interest in the publication of false information” ; and by Tugendhat J in Tesla Motors Ltd & Anor v BBC [2012] EWHC 310 (QB) at [43], where he stated: “There is no public interest in the dissemination of malicious falsehoods, and so Art 10 is not engaged.” 52. In ZAM v CFW [2013] EWHC 662, Tugendhat J dealt with the subject at greater length in the context of a claim for a final injunction in a defamation case, under the heading “Injunctions and Freedom of Expression ” at [19]- [23]: 26 “19. The principle of freedom of expression, recognised by English law for centuries, provides that there shall be no interim injunction granted to restrain a threatened publication, if there is any basis upon which a court might decide at a trial that the threatened publication may be lawful. So if it is arguable that the threatened publication may not be defamatory, or if there is material before the court which could form the basis of a defence of any kind, no injunction will be granted before a final judgment is entered. This principle is commonly known in England as the rule in Bonnard v Perryman [1891] 2 Ch 269 (a nineteenth century case in which this much older principle was re-affirmed). … 22. On the other hand, once a final judgment has been entered, whether after a trial, or summarily, a defendant's right to freedom of expression does not preclude the grant of an injunction. On the contrary, a claimant who succeeds in obtaining a final judgment is normally entitled to a permanent injunction to vindicate the right that he has proved that he has. 23. Freedom of expression is valued, amongst other reasons, because it tends to lead to discovery of the truth: R v Secretary of State for the Home Department ex parte Simms [2000] AC 115, 126E -G. So where a defamatory allegation has been proved to be false (as has happened in the present case) there is no public interest in allowing it to be republished, and a strong public interest in preventing the public from being further misinformed. Final or permanent injunctions have been routinely granted after final judgments.” 53. Meanwhile, it is well-established by the jurisprudence of the European Court of Human Rights that the grant of final injunctions in defamation proceedings is compatible with Article 10. Even where Article 10 rights are engaged and such an order impinges upon journalistic freedom of expression, such an order may be justified as being necessary to protect the rights and freedoms of the person who has been defamed: see McVicar v United Kingdom (2002) 35 EHRR at [72] and [82]. Likewise, injunctions prohibiting publication of material obtained in circumstances of commercial confidence are capable of being justified under Article 10(2) even where they impact on a debate on matters of public interest: see Tierbefreier EV v Germany (16.1.14, App. No. 45192/09), at [47] -[60]. Anti-suit injunctions 54. The jurisdiction to grant anti-suit injunctions is one which has developed over time, protecting contractual rights laid down in exclusive jurisdiction and arbitration clauses and preventing parties from pursuing proceedings which would be vexatious or oppressive : see the general statement of principles in Deutsche Bank AG v Highland Crusader Offshore Partners LP [2010] 1 WLR 1023 at [50]. 27 55. One of the types of case in which anti-suit injunctions have been granted is where there is a prospect of
960
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 11 of 20 Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf ### Folder name: Skeletons ### File path: /content/Copa v Wright - Trial Documents/Relief Hearing/Skeletons/Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf ### File content: the authority and impartiality of the judiciary.” 50. In his Closing Submissions for trial, Dr Wright relied heavily on Article 10 rights in seeking to resist COPA’s claim for injunctive relief . However, the case law is consistent that Article 10 provides either no or very limited protection to the right to publish or otherwise communicate false claims. The starting point is the speech of Lord Hobhouse in the important defamation case of Reynolds v. Times Newspapers Ltd and Others [2001] 2 AC 127 where he stated (at 237- 8): “This case is concerned with the problems which arise from the publication of factual statements which are not correct – i.e. do not conform to the truth. This case is not concerned with freedom of expression and opinion. The citizen is at liberty to comment and take part in free discussion. It is of fundamental importance to a free society that this liberty be recognised and protected by the law. The liberty to communicate (and receive) information has a similar place in a free society but it is important always to remember that it is the communication of information not misinformation which is the subject of this liberty. There is no human right to disseminate information that is not true. No public interest is served by publishing or communicating misinformation. The working of a democratic society depends on the members of that society being informed not misinformed. Misleading people and the purveying as facts statements which are not true is destructive of the democratic society and should form no part of such a society. There is no duty to publish what is not true: there is no interest in being misinformed . These are general propositions going far beyond the mere protection of reputations.” (Emphasis added .) It is clear from this passage not only that human rights do not protect a freedom to spread falsehoods, but that the principle extend s beyond cases concerning reputation, given Lord Hobhouse’s broader references to the interests of the public in a democratic society . 51. Lord Hobhouse ’s speech has been relied on in a number of subsequent cases , including: in WXY v Gewanter & Ors [2012] EWHC 496 (Slade J), where it was noted at [62] that: “ It is uncontroversial that there can be no public interest in the publication of false information” ; and by Tugendhat J in Tesla Motors Ltd & Anor v BBC [2012] EWHC 310 (QB) at [43], where he stated: “There is no public interest in the dissemination of malicious falsehoods, and so Art 10 is not engaged.” 52. In ZAM v CFW [2013] EWHC 662, Tugendhat J dealt with the subject at greater length in the context of a claim for a final injunction in a defamation case, under the heading “Injunctions and Freedom of Expression ” at [19]- [23]: 26 “19. The principle of freedom of expression, recognised by English law for centuries, provides that there shall be no interim injunction granted to restrain a threatened publication, if there is any basis upon which a court might decide at a trial that the threatened publication may be lawful. So if it is arguable that the threatened publication may not be defamatory, or if there is material before the court which could form the basis of a defence of any kind, no injunction will be granted before a final judgment is entered. This principle is commonly known in England as the rule in Bonnard v Perryman [1891] 2 Ch 269 (a nineteenth century case in which this much older principle was re-affirmed). … 22. On the other hand, once a final judgment has been entered, whether after a trial, or summarily, a defendant's right to freedom of expression does not preclude the grant of an injunction. On the contrary, a claimant who succeeds in obtaining a final judgment is normally entitled to a permanent injunction to vindicate the right that he has proved that he has. 23. Freedom of expression is valued, amongst other reasons, because it tends to lead to discovery of the truth: R v Secretary of State for the Home Department ex parte Simms [2000] AC 115, 126E -G. So where a defamatory allegation has been proved to be false (as has happened in the present case) there is no public interest in allowing it to be republished, and a strong public interest in preventing the public from being further misinformed. Final or permanent injunctions have been routinely granted after final judgments.” 53. Meanwhile, it is well-established by the jurisprudence of the European Court of Human Rights that the grant of final injunctions in defamation proceedings is compatible with Article 10. Even where Article 10 rights are engaged and such an order impinges upon journalistic freedom of expression, such an order may be justified as being necessary to protect the rights and freedoms of the person who has been defamed: see McVicar v United Kingdom (2002) 35 EHRR at [72] and [82]. Likewise, injunctions prohibiting publication of material obtained in circumstances of commercial confidence are capable of being justified under Article 10(2) even where they impact on a debate on matters of public interest: see Tierbefreier EV v Germany (16.1.14, App. No. 45192/09), at [47] -[60]. Anti-suit injunctions 54. The jurisdiction to grant anti-suit injunctions is one which has developed over time, protecting contractual rights laid down in exclusive jurisdiction and arbitration clauses and preventing parties from pursuing proceedings which would be vexatious or oppressive : see the general statement of principles in Deutsche Bank AG v Highland Crusader Offshore Partners LP [2010] 1 WLR 1023 at [50]. 27 55. One of the types of case in which anti-suit injunctions have been granted is where there is a prospect of
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Closings
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A. As long as the verifier is certain about his device and software. {Day18/10:6} - {Day18/10:15} Q. Yes. And there would be no problem, in principle, with videoing the verification, because that wouldn’t allow anyone to derive the private key; correct? A. It’s correct. Q. And there would be no problem with having somebody minuting every stage of that process, for example an independent observer, because that wouldn’t involve any risk of the private key being compromised? A. Agree. Mr Gao accepting that there would be no concerns in t erms of risking the security of the private key, by having a third party evidencing the verification. {Day18/11:8} - {Day18/11:18} Q. That would all be technically feasible, wouldn't it? A. Yes, but the assumption is that the person is willing to do that publicly. Q. Sure. And if that were done, anyone with access to the blockchain could obtain the public key related to block 9, because it's one of those early blocks, yes? A. Yes. Q. And they could verify the message for themselves, anyone in the world with the technical understanding? A. Yeah, that's the essence of a public proof. Mr Gao accepting that there would be no technical concerns with publishing the verification proof publicly. Appendix B: Schedule of Transcript References 531 {Day18/11:24} - {Day18/12:1} Q. Sure. But the risk of actually compromising the private key, non-existent? A. I agree. Mr Gao specifically confirming that there would be no risk of compromising the private key if the verification is public. {Day18/12:16} - {Day18/13:20} Q. So you considered, does it follow, that what you wrote in your report about the signing sessions, the procedures used and how they might have been subverted, what you wrote in your report on those matters are all matters within your expertise? A. Yes. Q. Dr W right told the court that you weren't an expert on those matters. May we take it that you disagree with him? A. I don't think I'm a professional cryptographer. Q. No, but you had -- A. Within the context of the Bitcoin Blockchain, I'm an expert. Q. And you felt that you had enough expertise to give opinions on the matters in your report? A. Yes, I do. Q. So when Dr Wright said that you were not an appropriate expert to express opinion -- A. Well, if the subject matter goes to the detail of the cryptography itself, I don't think I'm the most qualified person. Q. Does that include matters you actually address in your report? A. No, in the report it doesn't involve specific high level cryptography itself, it's the procedure in the context of blockchain. Q. So t he matters you addressed in your report you felt were within your competence despite the limitations that you've -- A. Sure, but the distinction is like a race car driver, if he's expert in driving but he doesn't necessarily know how to make the car. Mr Gao defending his qualifications and addressing Dr Wright’s criticisms. {G/2/50} First Report of Sarah Meiklejohn {Day18/16:4} - {Day18/16:9} Q. -- scroll down to make sure there isn't an (h) below; do you see that? A. Yes. Q. So you agree that that's your understanding, too, of those sessions, is it? Mr Gao confirming that he accepts Professor Meiklejohn’s summary of the signing sessions with Mr Appendix B: Schedule of Transcript References 532 A. Yes. Matonis and the journalists. {Day18/16:16} - {Day18/17:13} Q. Now, Professor Meiklejohn has pointed out -- and we can look at paragraph 124(c) on page {G/2/51} -- that it would be simple to develop a program to which this command would point and would just output a random string that would match the pattern for an encoded signature; do you see that? That’s paragraph 124(c). A. 24, which? Q. 124(c). A. (c), okay. Q. Do you want to just read that to yourself? I ’ve just Q. Now, it's right, isn't it, that you agree that that could be done, it would be simple to develop a small program with that effect? A. Yes, I agree. Q. But is this right, you stress in your annex to the joint report that the critical point in subverting the process is at the verification stage rather than the signature stage? A. Yeah, the reason is beca use even if there's forgery here, you generally in verifier -- verifying software can still detect it. Mr Gao agreeing that the key point in subverting the signing sessions process is at the verification stage. {Q/3.1/11} Annex A to Joint Statement of Professor Sarah Meiklejohn and Mr Zeming Gao {Day18/18:16} - {Day18/19:15} ”If ... the signer is cheating with the software on the signer ’s side , even if the verifier ’s software is not verified to be genuine, as long as the verifier himself is not colluding with the signer to deceive others, it would not be to the signer’s advantage. This is because, unless the verifier ’s software is designed to always produce a positive result , the result would be either always negativ e or unpredictable, in either case defeating the signer ’s purpose of producing a reliable proof. But if the verifier ’s software is designed toalways produce a positive result , it would be very easy for the verifier to discover the defect by intentionall y using an incorrect signature. The bottom line is that, if the signer ’s purpose is to produce a reliable signature proof, there is no motivation for the signer to tamper with the software on the signer’s side . The focus, therefore, is the software used by the verifier , which the signer does [not] have a motivation to tamper with.” Now, of course, when you refer to not having the -- the signer not having a motivation to tamper with the verification software, that assumes that the signer is not -- Mr Gao accepting there would be a motivation for the signer of a message to tamper with the verifying software. Appendix B: Schedule of Transcript References 533 A. The signer would have. The signer would have the motivation to tamper the verifying software. {Day18/21:25} – {Day/18/22:7} Q. -- for the questions that follow. And then subparagraph (d), the understanding that Professor Meiklejohn derived from the materials was that Mr Andresen had brought his own laptop to the session, but that laptop, his own laptop, wasn't used for the verification. And that's your understanding as well? A.
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 209 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: A. As long as the verifier is certain about his device and software. {Day18/10:6} - {Day18/10:15} Q. Yes. And there would be no problem, in principle, with videoing the verification, because that wouldn’t allow anyone to derive the private key; correct? A. It’s correct. Q. And there would be no problem with having somebody minuting every stage of that process, for example an independent observer, because that wouldn’t involve any risk of the private key being compromised? A. Agree. Mr Gao accepting that there would be no concerns in t erms of risking the security of the private key, by having a third party evidencing the verification. {Day18/11:8} - {Day18/11:18} Q. That would all be technically feasible, wouldn't it? A. Yes, but the assumption is that the person is willing to do that publicly. Q. Sure. And if that were done, anyone with access to the blockchain could obtain the public key related to block 9, because it's one of those early blocks, yes? A. Yes. Q. And they could verify the message for themselves, anyone in the world with the technical understanding? A. Yeah, that's the essence of a public proof. Mr Gao accepting that there would be no technical concerns with publishing the verification proof publicly. Appendix B: Schedule of Transcript References 531 {Day18/11:24} - {Day18/12:1} Q. Sure. But the risk of actually compromising the private key, non-existent? A. I agree. Mr Gao specifically confirming that there would be no risk of compromising the private key if the verification is public. {Day18/12:16} - {Day18/13:20} Q. So you considered, does it follow, that what you wrote in your report about the signing sessions, the procedures used and how they might have been subverted, what you wrote in your report on those matters are all matters within your expertise? A. Yes. Q. Dr W right told the court that you weren't an expert on those matters. May we take it that you disagree with him? A. I don't think I'm a professional cryptographer. Q. No, but you had -- A. Within the context of the Bitcoin Blockchain, I'm an expert. Q. And you felt that you had enough expertise to give opinions on the matters in your report? A. Yes, I do. Q. So when Dr Wright said that you were not an appropriate expert to express opinion -- A. Well, if the subject matter goes to the detail of the cryptography itself, I don't think I'm the most qualified person. Q. Does that include matters you actually address in your report? A. No, in the report it doesn't involve specific high level cryptography itself, it's the procedure in the context of blockchain. Q. So t he matters you addressed in your report you felt were within your competence despite the limitations that you've -- A. Sure, but the distinction is like a race car driver, if he's expert in driving but he doesn't necessarily know how to make the car. Mr Gao defending his qualifications and addressing Dr Wright’s criticisms. {G/2/50} First Report of Sarah Meiklejohn {Day18/16:4} - {Day18/16:9} Q. -- scroll down to make sure there isn't an (h) below; do you see that? A. Yes. Q. So you agree that that's your understanding, too, of those sessions, is it? Mr Gao confirming that he accepts Professor Meiklejohn’s summary of the signing sessions with Mr Appendix B: Schedule of Transcript References 532 A. Yes. Matonis and the journalists. {Day18/16:16} - {Day18/17:13} Q. Now, Professor Meiklejohn has pointed out -- and we can look at paragraph 124(c) on page {G/2/51} -- that it would be simple to develop a program to which this command would point and would just output a random string that would match the pattern for an encoded signature; do you see that? That’s paragraph 124(c). A. 24, which? Q. 124(c). A. (c), okay. Q. Do you want to just read that to yourself? I ’ve just Q. Now, it's right, isn't it, that you agree that that could be done, it would be simple to develop a small program with that effect? A. Yes, I agree. Q. But is this right, you stress in your annex to the joint report that the critical point in subverting the process is at the verification stage rather than the signature stage? A. Yeah, the reason is beca use even if there's forgery here, you generally in verifier -- verifying software can still detect it. Mr Gao agreeing that the key point in subverting the signing sessions process is at the verification stage. {Q/3.1/11} Annex A to Joint Statement of Professor Sarah Meiklejohn and Mr Zeming Gao {Day18/18:16} - {Day18/19:15} ”If ... the signer is cheating with the software on the signer ’s side , even if the verifier ’s software is not verified to be genuine, as long as the verifier himself is not colluding with the signer to deceive others, it would not be to the signer’s advantage. This is because, unless the verifier ’s software is designed to always produce a positive result , the result would be either always negativ e or unpredictable, in either case defeating the signer ’s purpose of producing a reliable proof. But if the verifier ’s software is designed toalways produce a positive result , it would be very easy for the verifier to discover the defect by intentionall y using an incorrect signature. The bottom line is that, if the signer ’s purpose is to produce a reliable signature proof, there is no motivation for the signer to tamper with the software on the signer’s side . The focus, therefore, is the software used by the verifier , which the signer does [not] have a motivation to tamper with.” Now, of course, when you refer to not having the -- the signer not having a motivation to tamper with the verification software, that assumes that the signer is not -- Mr Gao accepting there would be a motivation for the signer of a message to tamper with the verifying software. Appendix B: Schedule of Transcript References 533 A. The signer would have. The signer would have the motivation to tamper the verifying software. {Day18/21:25} – {Day/18/22:7} Q. -- for the questions that follow. And then subparagraph (d), the understanding that Professor Meiklejohn derived from the materials was that Mr Andresen had brought his own laptop to the session, but that laptop, his own laptop, wasn't used for the verification. And that's your understanding as well? A.
1,787
/content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090520-Bitcoin-202224(75057031.1).pdf
Nicholas Bohm Witness Statement - Exhibit
part 1 of 1 20090520-Bitcoin-202224(75057031.1).pdf
285
1,357
Subject: Bitcoin From: Nicholas Bohm <[email protected]> Date: 20/05/2009, 18:23 To: [email protected] I notice a surprising number of "not accepted" at the moment: 0/unconfirmed 20/05/2009 15:09 Generated (not accepted) 29 blocks 20/05/2009 10:54 Generated (50.00 matures in 91 more blocks) 0/unconfirmed 20/05/2009 03:15 Generated (not accepted) 0/unconfirmed 20/05/2009 03:06 Generated (not accepted) 0/unconfirmed 19/05/2009 19:11 Generated (not accepted) 0/unconfirmed 19/05/2009 12:47 Generated (not accepted) 133 blocks 19/05/2009 06:31 Generated 134 blocks 19/05/2009 06:31 Generated 0/unconfirmed 18/05/2009 23:08 Generated (not accepted) 0/unconfirmed 18/05/2009 19:25 Generated (not accepted) 0/unconfirmed 18/05/2009 15:18 Generated (not accepted) 0/unconfirmed 18/05/2009 12:28 Generated (not accepted) 0/unconfirmed 18/05/2009 11:31 Generated (not accepted) 257 blocks 18/05/2009 06:29 Generated 278 blocks 18/05/2009 01:51 Generated 285 blocks 18/05/2009 00:43 Generated 305 blocks 17/05/2009 20:53 Generated 313 blocks 17/05/2009 19:35 Generated 317 blocks 17/05/2009 18:51 Generated 326 blocks 17/05/2009 17:32 Generated 0/unconfirmed 17/05/2009 12:14 Generated (not accepted) 0/unconfirmed 17/05/2009 08:49 Generated (not accepted) 395 blocks 17/05/2009 03:51 Generated 403 blocks 17/05/2009 02:09 Generated 0/unconfirmed 16/05/2009 21:49 Generated (not accepted) 431 blocks 16/05/2009 20:44 Generated 432 blocks 16/05/2009 20:42 Generated 0/unconfirmed 16/05/2009 20:20 Generated (not accepted) 0/unconfirmed 16/05/2009 19:58 Generated (not accepted) 0/unconfirmed 16/05/2009 15:18 Generated (not accepted) 0/unconfirmed 16/05/2009 15:10 Generated (not accepted) 503 blocks 16/05/2009 04:51 Generated 505 blocks 16/05/2009 04:42 Generated 510 blocks 16/05/2009 03:46 Generated 523 blocks 16/05/2009 01:50 Generated 0/unconfirmed 15/05/2009 21:12 Generated (not accepted) Just in case it's worthy of note. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728)Bitcoin mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 2 21/07/2023, 17:10 PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFBitcoin mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 2 of 2 21/07/2023, 17:10
285
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090520-Bitcoin-202224(75057031.1).pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090520-Bitcoin-202224(75057031.1).pdf ### File content: Subject: Bitcoin From: Nicholas Bohm <[email protected]> Date: 20/05/2009, 18:23 To: [email protected] I notice a surprising number of "not accepted" at the moment: 0/unconfirmed 20/05/2009 15:09 Generated (not accepted) 29 blocks 20/05/2009 10:54 Generated (50.00 matures in 91 more blocks) 0/unconfirmed 20/05/2009 03:15 Generated (not accepted) 0/unconfirmed 20/05/2009 03:06 Generated (not accepted) 0/unconfirmed 19/05/2009 19:11 Generated (not accepted) 0/unconfirmed 19/05/2009 12:47 Generated (not accepted) 133 blocks 19/05/2009 06:31 Generated 134 blocks 19/05/2009 06:31 Generated 0/unconfirmed 18/05/2009 23:08 Generated (not accepted) 0/unconfirmed 18/05/2009 19:25 Generated (not accepted) 0/unconfirmed 18/05/2009 15:18 Generated (not accepted) 0/unconfirmed 18/05/2009 12:28 Generated (not accepted) 0/unconfirmed 18/05/2009 11:31 Generated (not accepted) 257 blocks 18/05/2009 06:29 Generated 278 blocks 18/05/2009 01:51 Generated 285 blocks 18/05/2009 00:43 Generated 305 blocks 17/05/2009 20:53 Generated 313 blocks 17/05/2009 19:35 Generated 317 blocks 17/05/2009 18:51 Generated 326 blocks 17/05/2009 17:32 Generated 0/unconfirmed 17/05/2009 12:14 Generated (not accepted) 0/unconfirmed 17/05/2009 08:49 Generated (not accepted) 395 blocks 17/05/2009 03:51 Generated 403 blocks 17/05/2009 02:09 Generated 0/unconfirmed 16/05/2009 21:49 Generated (not accepted) 431 blocks 16/05/2009 20:44 Generated 432 blocks 16/05/2009 20:42 Generated 0/unconfirmed 16/05/2009 20:20 Generated (not accepted) 0/unconfirmed 16/05/2009 19:58 Generated (not accepted) 0/unconfirmed 16/05/2009 15:18 Generated (not accepted) 0/unconfirmed 16/05/2009 15:10 Generated (not accepted) 503 blocks 16/05/2009 04:51 Generated 505 blocks 16/05/2009 04:42 Generated 510 blocks 16/05/2009 03:46 Generated 523 blocks 16/05/2009 01:50 Generated 0/unconfirmed 15/05/2009 21:12 Generated (not accepted) Just in case it's worthy of note. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728)Bitcoin mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 2 21/07/2023, 17:10 PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFBitcoin mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 2 of 2 21/07/2023, 17:10
1,481
/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM38.pdf
Patrick Madden
part 7 of 8 Appendix PM38.pdf
7,566
15,459
17 Ruin problem. Suppose a gambler with unlimited credit starts at a deficit and plays potentially an infinite number of trials to try to reach breakeven. We can calculate the probability he ever reaches break even, or that an attacker ever catches up with the honest chain, as follows value out of thin air taking money that never belonged to the attacker transaction as payment and h containing them. one""publiclly of his own transactions to take back money he recently spent. attacker block +1, and er catching up 19. The strings above have been formatted and separated out for ease of review . Within the raw body of the file in a plain text editor, they present in two groups of text: the first passage shown above (the longest) appears all together. The remaining strings appear in a single place all together, as follows (interspersed with text which appears to have been added ): 20. It can therefore be observed that : a. ID_000073 contains the equivalent text from the Bitcoin White Paper embedded within it. They are saved within the file interspersed with the edited text. b. The strings set out above correspond to the edits shown in red in the comparison screenshot above, suggesting that the text was previously present in ID_000073 and was later deleted . c. T he first extract shown above contains a line break in between the word “Gambler’s” and the word “Ruin”. This line break does not appear on the face of ID_000073, butthere is a corresponding line break at that point in the control Bitcoin White Paper as shown below. This may be indicative that the embedded raw content of ID_000073 13 - 13 - H/145/13{ID_000073} Appendix PM 38 Statistics Assignments/ID_000073 and ID_000142 Page 14of 17 w as sourced from the PDF ID_000865 by a copy and paste operation, and carried across the line break in the middle of the sentence with it5 C onclusion on ID_000073 and ID_000077 21. Taken at face value, the metadata of ID_000073 suggests that it was written prior to the Bitcoin White Paper. However , the embedded content within the file indicates that text of the Bitcoin White Paper was included in an identical form in ID_000073, and then edited away to create the content of ID_000073 while being back-dated, likely through the use of clock manipulation techniques. I n my opinion ID_000073 is therefore not authentic. 22. I have considered whether the features that I have observed would also be consistent with both documents having a common earlier source and then being edited in different directions, but no such common earlier source has been included in the disclosure dataset , and the indication that ID_00073 has been backdated arises independently from the review between that docume nt and ID_00077. 23. I have also compared ID_000073 to ID_000077, and consider that ID_000077 (a later -dated 2005 document) is an authentic document, and that it was used as the precursor donor source to create ID_000073, with ID_000073 being back-dated to ap pear to come earlier in time (in my opinion, likely by the use of clock manipulation techniques as seen with other documents in the disclosure dataset in general, and in the Lynn Wright documents in particular ). This has led to the content of ID_000077 being embedded within the ID_000073 file. A nalysis of ID_000142 24. My conclusions and analysis of ID_000073 applies to ID_000142, for the following reasons. 25. ID_000073 and ID_000142 appear identical on the face of the printed documents. They also have the exact same file capacity of 910,336 bytes. 5T he same line break also appears in ID_000226 and BWP -NB1, but I have taken ID_000865 as a comparator source for this purpose. Appendix PM 38 Statistics Assignments/ID_000073 and ID_000142 Page 14of 17 w as sourced from the PDF ID_000865 by a copy and paste operation, and carried across the line break in the middle of the sentence with it5 C onclusion on ID_000073 and ID_000077 21. Taken at face value, the metadata of ID_000073 suggests that it was written prior to the Bitcoin White Paper. However , the embedded content within the file indicates that text of the Bitcoin White Paper was included in an identical form in ID_000073, and then edited away to create the content of ID_000073 while being back-dated, likely through the use of clock manipulation techniques. I n my opinion ID_000073 is therefore not authentic. 22. I have considered whether the features that I have observed would also be consistent with both documents having a common earlier source and then being edited in different directions, but no such common earlier source has been included in the disclosure dataset , and the indication that ID_00073 has been backdated arises independently from the review between that docume nt and ID_00077. 23. I have also compared ID_000073 to ID_000077, and consider that ID_000077 (a later -dated 2005 document) is an authentic document, and that it was used as the precursor donor source to create ID_000073, with ID_000073 being back-dated to ap pear to come earlier in time (in my opinion, likely by the use of clock manipulation techniques as seen with other documents in the disclosure dataset in general, and in the Lynn Wright documents in particular ). This has led to the content of ID_000077 being embedded within the ID_000073 file. A nalysis of ID_000142 24. My conclusions and analysis of ID_000073 applies to ID_000142, for the following reasons. 25. ID_000073 and ID_000142 appear identical on the face of the printed documents. They also have the exact same file capacity of 910,336 bytes. 5T he same line break also appears in ID_000226 and BWP -NB1,
946
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 7 of 8 Appendix PM38.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM38.pdf ### File content: 17 Ruin problem. Suppose a gambler with unlimited credit starts at a deficit and plays potentially an infinite number of trials to try to reach breakeven. We can calculate the probability he ever reaches break even, or that an attacker ever catches up with the honest chain, as follows value out of thin air taking money that never belonged to the attacker transaction as payment and h containing them. one""publiclly of his own transactions to take back money he recently spent. attacker block +1, and er catching up 19. The strings above have been formatted and separated out for ease of review . Within the raw body of the file in a plain text editor, they present in two groups of text: the first passage shown above (the longest) appears all together. The remaining strings appear in a single place all together, as follows (interspersed with text which appears to have been added ): 20. It can therefore be observed that : a. ID_000073 contains the equivalent text from the Bitcoin White Paper embedded within it. They are saved within the file interspersed with the edited text. b. The strings set out above correspond to the edits shown in red in the comparison screenshot above, suggesting that the text was previously present in ID_000073 and was later deleted . c. T he first extract shown above contains a line break in between the word “Gambler’s” and the word “Ruin”. This line break does not appear on the face of ID_000073, butthere is a corresponding line break at that point in the control Bitcoin White Paper as shown below. This may be indicative that the embedded raw content of ID_000073 13 - 13 - H/145/13{ID_000073} Appendix PM 38 Statistics Assignments/ID_000073 and ID_000142 Page 14of 17 w as sourced from the PDF ID_000865 by a copy and paste operation, and carried across the line break in the middle of the sentence with it5 C onclusion on ID_000073 and ID_000077 21. Taken at face value, the metadata of ID_000073 suggests that it was written prior to the Bitcoin White Paper. However , the embedded content within the file indicates that text of the Bitcoin White Paper was included in an identical form in ID_000073, and then edited away to create the content of ID_000073 while being back-dated, likely through the use of clock manipulation techniques. I n my opinion ID_000073 is therefore not authentic. 22. I have considered whether the features that I have observed would also be consistent with both documents having a common earlier source and then being edited in different directions, but no such common earlier source has been included in the disclosure dataset , and the indication that ID_00073 has been backdated arises independently from the review between that docume nt and ID_00077. 23. I have also compared ID_000073 to ID_000077, and consider that ID_000077 (a later -dated 2005 document) is an authentic document, and that it was used as the precursor donor source to create ID_000073, with ID_000073 being back-dated to ap pear to come earlier in time (in my opinion, likely by the use of clock manipulation techniques as seen with other documents in the disclosure dataset in general, and in the Lynn Wright documents in particular ). This has led to the content of ID_000077 being embedded within the ID_000073 file. A nalysis of ID_000142 24. My conclusions and analysis of ID_000073 applies to ID_000142, for the following reasons. 25. ID_000073 and ID_000142 appear identical on the face of the printed documents. They also have the exact same file capacity of 910,336 bytes. 5T he same line break also appears in ID_000226 and BWP -NB1, but I have taken ID_000865 as a comparator source for this purpose. Appendix PM 38 Statistics Assignments/ID_000073 and ID_000142 Page 14of 17 w as sourced from the PDF ID_000865 by a copy and paste operation, and carried across the line break in the middle of the sentence with it5 C onclusion on ID_000073 and ID_000077 21. Taken at face value, the metadata of ID_000073 suggests that it was written prior to the Bitcoin White Paper. However , the embedded content within the file indicates that text of the Bitcoin White Paper was included in an identical form in ID_000073, and then edited away to create the content of ID_000073 while being back-dated, likely through the use of clock manipulation techniques. I n my opinion ID_000073 is therefore not authentic. 22. I have considered whether the features that I have observed would also be consistent with both documents having a common earlier source and then being edited in different directions, but no such common earlier source has been included in the disclosure dataset , and the indication that ID_00073 has been backdated arises independently from the review between that docume nt and ID_00077. 23. I have also compared ID_000073 to ID_000077, and consider that ID_000077 (a later -dated 2005 document) is an authentic document, and that it was used as the precursor donor source to create ID_000073, with ID_000073 being back-dated to ap pear to come earlier in time (in my opinion, likely by the use of clock manipulation techniques as seen with other documents in the disclosure dataset in general, and in the Lynn Wright documents in particular ). This has led to the content of ID_000077 being embedded within the ID_000073 file. A nalysis of ID_000142 24. My conclusions and analysis of ID_000073 applies to ID_000142, for the following reasons. 25. ID_000073 and ID_000142 appear identical on the face of the printed documents. They also have the exact same file capacity of 910,336 bytes. 5T he same line break also appears in ID_000226 and BWP -NB1,
1,699
/content/Copa v Wright - Trial Documents/Relief Hearing/Skeletons/Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf
Skeletons
part 8 of 20 Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf
19,182
38,517
the claimant ” formulation, and indeed expanded it to “the interest of the person protected by the injunction” so as to include a third party for whose benefit the original orders were made and which the defendant sought to frustrate. Expanding the categories of injunction 26. Judicial comment over the years has repeatedly recognised that new situations may call for new forms of injunction. The overarching principle is that stated by Kitchin LJ in Cartier International AG v British Sky Broadcasting Ltd [2017] Bus LR 1 at [46], echoing Lord Goff in South Carolina Insurance Co [1987] AC 24 at 44. The courts will “adapt to new circumstances by developing their practice in relation to the grant of injunctions where it is necessary and appropriate to do so to avoid injustice .” This view was endorsed by the Privy Council in Convoy Collater al at [56], then by the Supreme Court in Wolverhampton at [21] and [22].58 Changing circumstances include those resulting from developments in information technology and globalization. ( Convoy Collateral [59], [60]). 27. In Cartier itself, the Court upheld the decision to make website blocking injunctions to prevent infringement of intellectual property rights , starting from the domestic law propositions that (i) injunctions could be granted against those who had not themselves infringed rights , if they would protect such rights; (ii) an analogy could be drawn with the 58 Although CSW’s written closings discuss Wolverhampton at para 249, they omit the overarching flexible Cartier principle endorsed in that case and Broad Idea. 19 equitable protective principle underlying Norwich Pharmacal orders; and (iii) the Court’s jurisdiction under s.37(1) was very broad and could “be exercised in new ways ”: see [55]- [56]. Principles governing injunctions to protect IP rights 28. The following principles apply to the discretion to grant injunctive relief in the context of the protection of intellectual property rights . They should be taken into account in relation to the grant of an injunction restraining someone from claiming or seeking to enforce rights in circumstances where a declaration of non-infringement has been granted on the basis of the person having no relevant right . 29. Any relief should be fair, equitable and not unnecessarily complicated or costly. It should be effective, proportionate and dissuasive, and applied in such a manner as to avoid the creation of barriers to legitimate trade and to provide for safeguards against their abuse: Merck v Merck Sharp & Dohme Corp [2017] EWCA Civ 1834 at [307]. The granting of any injunction must be proportionate and have regard to any other competing considerations, including any Article 10 rights of the other party under the Euro pean Convention on Human Rights: see Merck v Merck Sharp & Dohme Corp at [310]. 30. In deciding whether to grant injunctive relief, the Court will balance the competing interests. These will include any effects of refusal of the injunction on activity which would harm legitimate business activities. See Heythrop Zoological Gardens v Captive Animals Protection Society [2017] FSR 242 at [56]-[60] (a case addressing the balancing exercise on an interim injunction basis, where the threshold for an order impinging on Article 10 rights is higher). 31. The time at which the question of granting a final injunction is to be determined is after the Court has determined the matter on the merits (i.e. at the form of order hearing).59 The likelihood of repetition is an important factor in determining whether a final injunction should be granted.60 32. The normal position in IP cases is that, where there has been an infringement, an injunction usually follows, absent clear undertakings or some other reason why that is not going to 59 See Copinger & Skone James on Copyright (18th ed.) at [21-236]. 60 Ibid at [21.238] . 20 happen: see Cantor Gaming v Gameaccount Global Limited [2007] ECC 24 at [101]-[106]. That conclusion was based on a consideration of the cases cited below. 33. The approach in copyright cases was set out by the Master of the Rolls, Lord Woolf, giving the judgment of the Court of Appeal in Phonographic Performance Ltd v Maitra [1998] FSR 749 at 771: “… where a person establishes infringement of copyright and a threat to continue infringement, an injunction will in the ordinary case be granted without restriction. … But the court, when granting an injunction, is still required to exercise a discretion and in so doing there could be circumstances where restriction or refusal of an injunction would be warranted.” 34. In relation to patents, the Court of Appeal in Coflexip SA v Stolt Comex Seaway MS Ltd [2001] RPC 182 put the position as follows at §6-7: “… whenever a court at the end of a trial grants permanent injunctive relief, the purpose should be to give effect to its judgment on liability … The injunction granted should protect the plaintiff from a continuation of the infringements of his rights by the threatened activities of the defendant. But the injunction must also be fair to the defendant.” “… Normally, when a defendant has infringed, the court will assume it is not a one-off activity and will grant an injunction to stop repetition. This course is not inevitable. In a few cases courts have concluded that even though infringement has occurred, no future threat exists. In such cases, injunctive relief has been refused …” 35. In Cantor Gaming , Daniel Alexander QC (sitting as a Deputy High Court Judge) said that the same principles of injunctions (set out in PPL v Saibal and Coflexip ) must apply where a person establishes that there has been a breach of contract which prohibits an act akin to an infringement of an IP right: [104] . 36. The Court may grant injunctive relief in
960
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 8 of 20 Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf ### Folder name: Skeletons ### File path: /content/Copa v Wright - Trial Documents/Relief Hearing/Skeletons/Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf ### File content: the claimant ” formulation, and indeed expanded it to “the interest of the person protected by the injunction” so as to include a third party for whose benefit the original orders were made and which the defendant sought to frustrate. Expanding the categories of injunction 26. Judicial comment over the years has repeatedly recognised that new situations may call for new forms of injunction. The overarching principle is that stated by Kitchin LJ in Cartier International AG v British Sky Broadcasting Ltd [2017] Bus LR 1 at [46], echoing Lord Goff in South Carolina Insurance Co [1987] AC 24 at 44. The courts will “adapt to new circumstances by developing their practice in relation to the grant of injunctions where it is necessary and appropriate to do so to avoid injustice .” This view was endorsed by the Privy Council in Convoy Collater al at [56], then by the Supreme Court in Wolverhampton at [21] and [22].58 Changing circumstances include those resulting from developments in information technology and globalization. ( Convoy Collateral [59], [60]). 27. In Cartier itself, the Court upheld the decision to make website blocking injunctions to prevent infringement of intellectual property rights , starting from the domestic law propositions that (i) injunctions could be granted against those who had not themselves infringed rights , if they would protect such rights; (ii) an analogy could be drawn with the 58 Although CSW’s written closings discuss Wolverhampton at para 249, they omit the overarching flexible Cartier principle endorsed in that case and Broad Idea. 19 equitable protective principle underlying Norwich Pharmacal orders; and (iii) the Court’s jurisdiction under s.37(1) was very broad and could “be exercised in new ways ”: see [55]- [56]. Principles governing injunctions to protect IP rights 28. The following principles apply to the discretion to grant injunctive relief in the context of the protection of intellectual property rights . They should be taken into account in relation to the grant of an injunction restraining someone from claiming or seeking to enforce rights in circumstances where a declaration of non-infringement has been granted on the basis of the person having no relevant right . 29. Any relief should be fair, equitable and not unnecessarily complicated or costly. It should be effective, proportionate and dissuasive, and applied in such a manner as to avoid the creation of barriers to legitimate trade and to provide for safeguards against their abuse: Merck v Merck Sharp & Dohme Corp [2017] EWCA Civ 1834 at [307]. The granting of any injunction must be proportionate and have regard to any other competing considerations, including any Article 10 rights of the other party under the Euro pean Convention on Human Rights: see Merck v Merck Sharp & Dohme Corp at [310]. 30. In deciding whether to grant injunctive relief, the Court will balance the competing interests. These will include any effects of refusal of the injunction on activity which would harm legitimate business activities. See Heythrop Zoological Gardens v Captive Animals Protection Society [2017] FSR 242 at [56]-[60] (a case addressing the balancing exercise on an interim injunction basis, where the threshold for an order impinging on Article 10 rights is higher). 31. The time at which the question of granting a final injunction is to be determined is after the Court has determined the matter on the merits (i.e. at the form of order hearing).59 The likelihood of repetition is an important factor in determining whether a final injunction should be granted.60 32. The normal position in IP cases is that, where there has been an infringement, an injunction usually follows, absent clear undertakings or some other reason why that is not going to 59 See Copinger & Skone James on Copyright (18th ed.) at [21-236]. 60 Ibid at [21.238] . 20 happen: see Cantor Gaming v Gameaccount Global Limited [2007] ECC 24 at [101]-[106]. That conclusion was based on a consideration of the cases cited below. 33. The approach in copyright cases was set out by the Master of the Rolls, Lord Woolf, giving the judgment of the Court of Appeal in Phonographic Performance Ltd v Maitra [1998] FSR 749 at 771: “… where a person establishes infringement of copyright and a threat to continue infringement, an injunction will in the ordinary case be granted without restriction. … But the court, when granting an injunction, is still required to exercise a discretion and in so doing there could be circumstances where restriction or refusal of an injunction would be warranted.” 34. In relation to patents, the Court of Appeal in Coflexip SA v Stolt Comex Seaway MS Ltd [2001] RPC 182 put the position as follows at §6-7: “… whenever a court at the end of a trial grants permanent injunctive relief, the purpose should be to give effect to its judgment on liability … The injunction granted should protect the plaintiff from a continuation of the infringements of his rights by the threatened activities of the defendant. But the injunction must also be fair to the defendant.” “… Normally, when a defendant has infringed, the court will assume it is not a one-off activity and will grant an injunction to stop repetition. This course is not inevitable. In a few cases courts have concluded that even though infringement has occurred, no future threat exists. In such cases, injunctive relief has been refused …” 35. In Cantor Gaming , Daniel Alexander QC (sitting as a Deputy High Court Judge) said that the same principles of injunctions (set out in PPL v Saibal and Coflexip ) must apply where a person establishes that there has been a breach of contract which prohibits an act akin to an infringement of an IP right: [104] . 36. The Court may grant injunctive relief in
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and Time arerecorded in February 2014. This is consistent with the file in question itself beingcreated as a copy (such as with a copy /paste operation or a drag and drop) within the filesystem in 2014. c.I observed an irregularity in that the OS Created Date and T ime is 10 hour 59 minutes earlier than the OS Last Modified Date and Time property. This should not ordinarily be possible in the case where a file is created as a copy of an underlying file: i.In circumstances where a file is copied and pasted on a Windows system, the File Created and Last Accessed timestamps of the resulting new copy would be updated to reflect the current time on the computer’s clock, but the Last{ID_00137 9} {ID_00137 9} {ID_00137 9} {ID_00001 3} {ID_00001 3} {ID_00137 9} {ID_00001 3} {ID_00137 9} Madden Appendix PM 8 Blacknet / ID_001379 , ID_ 001409 (including ID_001408), ID_001016, ID_000013, ID_001295, and related documents Page 7 of 23 Modi fied time should remain unchanged and match the original copy unless a change is made. ii.In circumstances where a copy of the file is sent by email, some systems will not retain the original OS timestamps when saved by the recipient. At the time that the recipient saves the file, in those circumstances, the OS Created, OS Last Modified and Accessed Date and Times should all be the same as each other. iii. I am not aware of any scenario during normal day- to-day operation where the OS Created date could be earlier than the OS Last Modified date withoutthere being a change made to the document , which may therefore indicate that a change was made. d. However, I observed that the diffe rence between the timestamps in question was 11 hours less 1 minute (i.e. 10 hours 59 minutes). This is consistent, in my view, with the irregularity originating not from manipulation of ID_000013, but of poor forensic handling during the disclosure proces s. In particular, I obs erve that, i.The 11 hour difference is consistent with the difference between an Australian time zone and the UK time zone and is also consistent with thetime zone of many other documents from the period which are in thedisclosure dataset. ii.There is still a 1 minute discrepancy, which can be explained by the fact that the Load File that has been included with the disclosed dataset appears toprovide data that is precise only to the nearest minute, a point that I have alsoobserved on all other documents within the dis closure dataset. I therefore understand the Load File information provided to be created from a rounded-up version of the original data, accurate only to the nearest minute. e.I therefore interpret the irregularity in these timestamps as being a result of t he disclosure being produced with a Load File which does not contain the original metadata from which it is sourced, but a version of that data which disregards thetime zones from which it was created and provides data with less accuracy that isordinarily to be expected. f.I therefore do not regard ID_000013 as being inauthentic, despite the irregularitiesobserved which I put down to poor handling.{ID_000013} {ID_000013} Madden Appendix PM 8 Blacknet / ID_001379 , ID_ 001409 (including ID_001408), ID_001016, ID_000013, ID_001295, and related documents Page 8 of 23 21. I pa use to point out that these difficulties with the disclosure dataset have obstructed my analysis at man y junctures during the significant task which I have undertaken of exploring the authenticity of documents within it. This is a good example of a document the authenticity of which would not have be en called into question but for the handling problems, and which I have had to go to additional lengths to investigate and explain , following which I have concluded it to be authentic. The authenticity could have been further investigated, or doubtsquickly resolved, had access to additional information been prov ided, such as a chain of custodians and details of the handling process of the documents, or access to the underlyingforensic images from which the data was extracted. Conclusion on ID_000013 22. Having reviewed the file in detail, I do not doubt the authenticity of ID_000013 and consider it to be a good basis for comparison with ID_001379. Content comparison differences between ID_000013 and ID_001379 23.By comparing ID _000013 and ID_001379 by eye, it is apparent that the entire content of ID_000013 is included within ID_001379. In view of that fact, and the timestamps which Ihave referred to above, I understand ID_000013 to be the earlier of the two documents,authentically created in October 2002, and ID_001379 to be a document which follows it, andwhich has been created based on ID_000013 at a later date
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 3 of 8 Appendix PM8.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM8.pdf ### File content: and Time arerecorded in February 2014. This is consistent with the file in question itself beingcreated as a copy (such as with a copy /paste operation or a drag and drop) within the filesystem in 2014. c.I observed an irregularity in that the OS Created Date and T ime is 10 hour 59 minutes earlier than the OS Last Modified Date and Time property. This should not ordinarily be possible in the case where a file is created as a copy of an underlying file: i.In circumstances where a file is copied and pasted on a Windows system, the File Created and Last Accessed timestamps of the resulting new copy would be updated to reflect the current time on the computer’s clock, but the Last{ID_00137 9} {ID_00137 9} {ID_00137 9} {ID_00001 3} {ID_00001 3} {ID_00137 9} {ID_00001 3} {ID_00137 9} Madden Appendix PM 8 Blacknet / ID_001379 , ID_ 001409 (including ID_001408), ID_001016, ID_000013, ID_001295, and related documents Page 7 of 23 Modi fied time should remain unchanged and match the original copy unless a change is made. ii.In circumstances where a copy of the file is sent by email, some systems will not retain the original OS timestamps when saved by the recipient. At the time that the recipient saves the file, in those circumstances, the OS Created, OS Last Modified and Accessed Date and Times should all be the same as each other. iii. I am not aware of any scenario during normal day- to-day operation where the OS Created date could be earlier than the OS Last Modified date withoutthere being a change made to the document , which may therefore indicate that a change was made. d. However, I observed that the diffe rence between the timestamps in question was 11 hours less 1 minute (i.e. 10 hours 59 minutes). This is consistent, in my view, with the irregularity originating not from manipulation of ID_000013, but of poor forensic handling during the disclosure proces s. In particular, I obs erve that, i.The 11 hour difference is consistent with the difference between an Australian time zone and the UK time zone and is also consistent with thetime zone of many other documents from the period which are in thedisclosure dataset. ii.There is still a 1 minute discrepancy, which can be explained by the fact that the Load File that has been included with the disclosed dataset appears toprovide data that is precise only to the nearest minute, a point that I have alsoobserved on all other documents within the dis closure dataset. I therefore understand the Load File information provided to be created from a rounded-up version of the original data, accurate only to the nearest minute. e.I therefore interpret the irregularity in these timestamps as being a result of t he disclosure being produced with a Load File which does not contain the original metadata from which it is sourced, but a version of that data which disregards thetime zones from which it was created and provides data with less accuracy that isordinarily to be expected. f.I therefore do not regard ID_000013 as being inauthentic, despite the irregularitiesobserved which I put down to poor handling.{ID_000013} {ID_000013} Madden Appendix PM 8 Blacknet / ID_001379 , ID_ 001409 (including ID_001408), ID_001016, ID_000013, ID_001295, and related documents Page 8 of 23 21. I pa use to point out that these difficulties with the disclosure dataset have obstructed my analysis at man y junctures during the significant task which I have undertaken of exploring the authenticity of documents within it. This is a good example of a document the authenticity of which would not have be en called into question but for the handling problems, and which I have had to go to additional lengths to investigate and explain , following which I have concluded it to be authentic. The authenticity could have been further investigated, or doubtsquickly resolved, had access to additional information been prov ided, such as a chain of custodians and details of the handling process of the documents, or access to the underlyingforensic images from which the data was extracted. Conclusion on ID_000013 22. Having reviewed the file in detail, I do not doubt the authenticity of ID_000013 and consider it to be a good basis for comparison with ID_001379. Content comparison differences between ID_000013 and ID_001379 23.By comparing ID _000013 and ID_001379 by eye, it is apparent that the entire content of ID_000013 is included within ID_001379. In view of that fact, and the timestamps which Ihave referred to above, I understand ID_000013 to be the earlier of the two documents,authentically created in October 2002, and ID_001379 to be a document which follows it, andwhich has been created based on ID_000013 at a later date
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to the content of emails being changed as a result. Dr Wright’s descr iption relates more to the day to day operation of the email services and does not provide insight into how historic email was migrated from the retiring infrastructure onto the new infrastructure , and it does not provide an explanation for the anomalies I identif yin the emails. Computing equipment 43. In paragraphs 8 2 to 84 Dr Wright refers to computing equipment on which mail information may be stored. I note that I have not been provided with access to that computing equipment. If I did so, it would be possible to conduct further analysis in respect of the claim about their treatment of emailheaders. However, the lack of access to that equipment does not weaken the conclusions that I have been able to express about the emails. 20 - 20 - H/241/20{E/4/26-27} {E/4/29-30} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 21 of 25 Migration process 44. In paragraph 95 Dr Wright refers to a process of migration and states as follows: This time, adjustments were made in Active Directory which could affect various system configurations, including email headers. During the transition from the ‘ridges- estate.com’ domain to the ‘information- defense.com’ domain the business underwent a process that included rebuilding accounts in the Microsoft Exchange server. This proc ess would inherently result in changes to email headers, specifically the originating domain and potentially other metadata. 45. In my experience, old emails will not be affected by such a process in the way that is suggested here. While it is true that new m essages sent after the migration process would exhibit different metadata, the content of past messages would not be altered. a. I therefore disagree with Dr Wright that this would “in herently result in changes to email headers”. Email headers form part of the content written to the email and are not subject to change in the way suggested. b. While I note that Dr Wright describes the use of Active Directory functionality in connection with the exchange servers, this again would not affect the content of mail messages in the way suggested. 46. I am not aware of any system which would programmatically modify the content of historic messages in this manner. 47. Finally, I also do not agree with Dr Wright’s explanation for the supposed change in email header which he gives at paragraph 97. Further, as I have explained above, t he emails that I have analysed exhibit a range of additional anomalies which cannot be explained in that way. ID_001711 48. Dr Wright has referred to ID_001711 at his paragraph 98 and has explained that h e considers the headers to have changed and to be “separate email stores originally that have been merged”. In my opinion, the explanation given again does not account for the irregularities in this message or the set of messages to which it relates. 49. First, it would be highly anomalous for such a change to occur, for similar reasons to those which I Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 21 of 25 Migration process 44. In paragraph 95 Dr Wright refers to a process of migration and states as follows: This time, adjustments were made in Active Directory which could affect various system configurations, including email headers. During the transition from the ‘ridges- estate.com’ domain to the ‘information- defense.com’ domain the business underwent a process that included rebuilding accounts in the Microsoft Exchange server. This proc ess would inherently result in changes to email headers, specifically the originating domain and potentially other metadata. 45. In my experience, old emails will not be affected by such a process in the way that is suggested here. While it is true that new m essages sent after the migration process would exhibit different metadata, the content of past messages would not be altered. a. I therefore disagree with Dr Wright that this would “in herently result in changes to email headers”. Email headers form part of the content written to the email and are not subject to change in the way suggested. b. While I note that Dr Wright describes the use of Active Directory functionality in connection with the exchange servers, this again would not affect the content of mail messages in the way suggested. 46. I am not aware of any system which would programmatically modify the content of historic messages in this manner. 47. Finally, I also do not agree with Dr Wright’s explanation for the supposed change in email header which he gives at paragraph 97. Further, as I have explained above, t he emails that I have analysed exhibit a range of additional anomalies which cannot be explained in that way. ID_001711 48. Dr Wright has referred to ID_001711 at his paragraph 98 and has explained that h e considers the headers to have changed and to be “separate email stores originally that have been merged”. In my opinion, the explanation given again does not account for the irregularities in this message or the set of messages to which it relates. 49. First, it would be highly anomalous for such a change to occur, for similar reasons to those which I 21 - 21 - H/241/21{E/4/32} {E/4/33} {ID_001711} {E/4/33} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 22 of 25 ha ve explained in relation to ID_000464 and ID_000465 above and in Appendix PM18. 50. Second, my analysis of ID_001711 is set out in Appendix PM18 from paragraph 35 to 68, in the context of a set of various different emails bearing similar characteristics. The different emails present with similar content but are inconsistent in their times, time zones, purported senders and recipients, and contain other anomalies in their T ransmission Headers. 51. Third, there is no original native email in the disclosure dataset, but only copies in the form of forwards and replies, the content of which is freely editable at the point of sending. 52. In my opinion, the content of ID_001711
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 10 of 12 Appendix PM45.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM45.pdf ### File content: to the content of emails being changed as a result. Dr Wright’s descr iption relates more to the day to day operation of the email services and does not provide insight into how historic email was migrated from the retiring infrastructure onto the new infrastructure , and it does not provide an explanation for the anomalies I identif yin the emails. Computing equipment 43. In paragraphs 8 2 to 84 Dr Wright refers to computing equipment on which mail information may be stored. I note that I have not been provided with access to that computing equipment. If I did so, it would be possible to conduct further analysis in respect of the claim about their treatment of emailheaders. However, the lack of access to that equipment does not weaken the conclusions that I have been able to express about the emails. 20 - 20 - H/241/20{E/4/26-27} {E/4/29-30} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 21 of 25 Migration process 44. In paragraph 95 Dr Wright refers to a process of migration and states as follows: This time, adjustments were made in Active Directory which could affect various system configurations, including email headers. During the transition from the ‘ridges- estate.com’ domain to the ‘information- defense.com’ domain the business underwent a process that included rebuilding accounts in the Microsoft Exchange server. This proc ess would inherently result in changes to email headers, specifically the originating domain and potentially other metadata. 45. In my experience, old emails will not be affected by such a process in the way that is suggested here. While it is true that new m essages sent after the migration process would exhibit different metadata, the content of past messages would not be altered. a. I therefore disagree with Dr Wright that this would “in herently result in changes to email headers”. Email headers form part of the content written to the email and are not subject to change in the way suggested. b. While I note that Dr Wright describes the use of Active Directory functionality in connection with the exchange servers, this again would not affect the content of mail messages in the way suggested. 46. I am not aware of any system which would programmatically modify the content of historic messages in this manner. 47. Finally, I also do not agree with Dr Wright’s explanation for the supposed change in email header which he gives at paragraph 97. Further, as I have explained above, t he emails that I have analysed exhibit a range of additional anomalies which cannot be explained in that way. ID_001711 48. Dr Wright has referred to ID_001711 at his paragraph 98 and has explained that h e considers the headers to have changed and to be “separate email stores originally that have been merged”. In my opinion, the explanation given again does not account for the irregularities in this message or the set of messages to which it relates. 49. First, it would be highly anomalous for such a change to occur, for similar reasons to those which I Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 21 of 25 Migration process 44. In paragraph 95 Dr Wright refers to a process of migration and states as follows: This time, adjustments were made in Active Directory which could affect various system configurations, including email headers. During the transition from the ‘ridges- estate.com’ domain to the ‘information- defense.com’ domain the business underwent a process that included rebuilding accounts in the Microsoft Exchange server. This proc ess would inherently result in changes to email headers, specifically the originating domain and potentially other metadata. 45. In my experience, old emails will not be affected by such a process in the way that is suggested here. While it is true that new m essages sent after the migration process would exhibit different metadata, the content of past messages would not be altered. a. I therefore disagree with Dr Wright that this would “in herently result in changes to email headers”. Email headers form part of the content written to the email and are not subject to change in the way suggested. b. While I note that Dr Wright describes the use of Active Directory functionality in connection with the exchange servers, this again would not affect the content of mail messages in the way suggested. 46. I am not aware of any system which would programmatically modify the content of historic messages in this manner. 47. Finally, I also do not agree with Dr Wright’s explanation for the supposed change in email header which he gives at paragraph 97. Further, as I have explained above, t he emails that I have analysed exhibit a range of additional anomalies which cannot be explained in that way. ID_001711 48. Dr Wright has referred to ID_001711 at his paragraph 98 and has explained that h e considers the headers to have changed and to be “separate email stores originally that have been merged”. In my opinion, the explanation given again does not account for the irregularities in this message or the set of messages to which it relates. 49. First, it would be highly anomalous for such a change to occur, for similar reasons to those which I 21 - 21 - H/241/21{E/4/32} {E/4/33} {ID_001711} {E/4/33} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 22 of 25 ha ve explained in relation to ID_000464 and ID_000465 above and in Appendix PM18. 50. Second, my analysis of ID_001711 is set out in Appendix PM18 from paragraph 35 to 68, in the context of a set of various different emails bearing similar characteristics. The different emails present with similar content but are inconsistent in their times, time zones, purported senders and recipients, and contain other anomalies in their T ransmission Headers. 51. Third, there is no original native email in the disclosure dataset, but only copies in the form of forwards and replies, the content of which is freely editable at the point of sending. 52. In my opinion, the content of ID_001711
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T he design is also not consistent with the design the web page would have had in 2009 (the date shown in the footer). At that time, the site used a Bookmarks image and a Secured by RapidSSL image which are not present in the video. c.Ther e does not appear to have been any time that both of these elements were present on the we b pa ge in the manner shown in the video at the same time . 26.I have shown instances of the footer in the homepage of Anonymousspeech.com above, but I alsosearched widely across the data available on the Wayback Machine to confirm this was representativ e o f the data available . Although it was not possible to log in to the live site through the Waybac k Mach ine (and the website has since shut down) , it is possible to observe that the footer is similar across the various pages of that website and appears to update consistently across the site as a whole , w ith the copyright indication updating each year and the same icon changes. This is also true on pages relating to pricing and purchases. For example, the footer at the page leading to purchase of “Anonymous hosting” services updates in a consistent manner with all three designs as shown below : April 2010 https://web.archive.org/web/201004100 41735/http://www.anonymousspeech.co m/anonymous_hosting_linux.aspx April 2012 https://web.archive.org/web/201204221 12359/http://www.anonymousspeech.co m/anonymous_hosting_linux.aspx March 2015 https://web.archive.org/web/201503171 24203/https://www.anonymousspeech.c om/anonymous_hosting_linux.aspx January 2020 (still showing the 2019 date) https://web.archive.org/web/202001220 90543/http://www.anonymousspeech.co m:80/anonymous_hosting_linux.aspx 14 - 14 - H/241/14 Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 15 of 25 Summary - Exhibit CSW Vistomail Videos - 27. For the reasons above, it ismy view that the videos in Exhibits CSW10- 13 do not show the computer browsing a website authentically associated with the AnonymousS peech account for Satoshi Nakamoto. Passport and ID_004550 28. I observed that Dr Wright appears to hold up his Australian passport to view in the camera in two videos: 29. I note that the passport image contains the following information and investigated how thatinformation related to the disclosure d ataset. Specifically I note the following details : The passport number N2511450The date of issue 23 Jun 2010The date of expiry 23 Jun 2020 Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 15 of 25 Summary - Exhibit CSW Vistomail Videos - 27. For the reasons above, it ismy view that the videos in Exhibits CSW10- 13 do not show the computer browsing a website authentically associated with the AnonymousS peech account for Satoshi Nakamoto. Passport and ID_004550 28. I observed that Dr Wright appears to hold up his Australian passport to view in the camera in two videos: 29. I note that the passport image contains the following information and investigated how thatinformation related to the disclosure d ataset. Specifically I note the following details : The passport number N2511450The date of issue 23 Jun 2010The date of expiry 23 Jun 2020 15 - 15 - H/241/15{F/153} - {F/156} {ID_004550} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 16 of 25 30.Searching the disclosure dataset for the passport number, I observed a small number of hits in the dataset , one of which was irregular because it appeared to pre- date the date of the passport. That is ID_004550. The document is a PDF relating to “Wright Internat ional Investments Limited” and the appointment of Craig Steven Wright as director of that company. The document is dated on its face to “this 4thday of August, 2009”. T he content of the PDF presents as follows: 31.However as can be seen in the screenshot above, the identifying information for Dr Wright lists his passport number as being N2511450. I am aware that the issuing of a new passport to a person will Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 16 of 25 30.Searching the disclosure dataset for the passport number, I observed a small number of hits in the dataset , one of which was irregular because it appeared to pre- date the date of the passport. That is ID_004550. The document is a PDF relating to “Wright Internat ional Investments Limited” and the appointment of Craig Steven Wright as director of that company. The document is dated on its face to “this 4thday of August, 2009”. T he content of the PDF presents as follows: 31.However as can be seen in the screenshot above, the identifying information for Dr Wright lists his passport number as being N2511450. I am aware that the issuing of a new passport to a person will 16 - 16 - H/241/16{ID_004550} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 17 of 25 re sult in a new passport number being allocated to the passport.1According to the date on the face of the passport as shown in Exhibit CSW12, that passport had not yet been issued by 4thAugust 2009 but was not issued until 23 June 2010. 32.It is therefore my view that ID_004550 is not authentic to the date on its face. 33.I observe that the internal metadata of the document ID_004550 is given as Thursday, 23 October 2014 12:19:47 UTC. In my opinion, that is likely to be the true date of the document, as it is several years after the issue date of the passport r eferred to in that document (but before the passport ha d e xpired). Exchange servers 34.In paragraphs 60 to 92 of his Fourth Witness S tatement , Dr Wright discusses his emails and describ es t ransfers of emails between exchange servers . I have been asked by Bird & Bird to review this secti on o f the statement , and comment on the information provided as it relates to the question of migrati on o f emails between servers. This topic arose in connection with my analysis at Appendix PM18 a nd t he explanation provided in respect of how the “Kleiman email ” mentioned in the
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 6 of 12 Appendix PM45.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM45.pdf ### File content: T he design is also not consistent with the design the web page would have had in 2009 (the date shown in the footer). At that time, the site used a Bookmarks image and a Secured by RapidSSL image which are not present in the video. c.Ther e does not appear to have been any time that both of these elements were present on the we b pa ge in the manner shown in the video at the same time . 26.I have shown instances of the footer in the homepage of Anonymousspeech.com above, but I alsosearched widely across the data available on the Wayback Machine to confirm this was representativ e o f the data available . Although it was not possible to log in to the live site through the Waybac k Mach ine (and the website has since shut down) , it is possible to observe that the footer is similar across the various pages of that website and appears to update consistently across the site as a whole , w ith the copyright indication updating each year and the same icon changes. This is also true on pages relating to pricing and purchases. For example, the footer at the page leading to purchase of “Anonymous hosting” services updates in a consistent manner with all three designs as shown below : April 2010 https://web.archive.org/web/201004100 41735/http://www.anonymousspeech.co m/anonymous_hosting_linux.aspx April 2012 https://web.archive.org/web/201204221 12359/http://www.anonymousspeech.co m/anonymous_hosting_linux.aspx March 2015 https://web.archive.org/web/201503171 24203/https://www.anonymousspeech.c om/anonymous_hosting_linux.aspx January 2020 (still showing the 2019 date) https://web.archive.org/web/202001220 90543/http://www.anonymousspeech.co m:80/anonymous_hosting_linux.aspx 14 - 14 - H/241/14 Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 15 of 25 Summary - Exhibit CSW Vistomail Videos - 27. For the reasons above, it ismy view that the videos in Exhibits CSW10- 13 do not show the computer browsing a website authentically associated with the AnonymousS peech account for Satoshi Nakamoto. Passport and ID_004550 28. I observed that Dr Wright appears to hold up his Australian passport to view in the camera in two videos: 29. I note that the passport image contains the following information and investigated how thatinformation related to the disclosure d ataset. Specifically I note the following details : The passport number N2511450The date of issue 23 Jun 2010The date of expiry 23 Jun 2020 Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 15 of 25 Summary - Exhibit CSW Vistomail Videos - 27. For the reasons above, it ismy view that the videos in Exhibits CSW10- 13 do not show the computer browsing a website authentically associated with the AnonymousS peech account for Satoshi Nakamoto. Passport and ID_004550 28. I observed that Dr Wright appears to hold up his Australian passport to view in the camera in two videos: 29. I note that the passport image contains the following information and investigated how thatinformation related to the disclosure d ataset. Specifically I note the following details : The passport number N2511450The date of issue 23 Jun 2010The date of expiry 23 Jun 2020 15 - 15 - H/241/15{F/153} - {F/156} {ID_004550} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 16 of 25 30.Searching the disclosure dataset for the passport number, I observed a small number of hits in the dataset , one of which was irregular because it appeared to pre- date the date of the passport. That is ID_004550. The document is a PDF relating to “Wright Internat ional Investments Limited” and the appointment of Craig Steven Wright as director of that company. The document is dated on its face to “this 4thday of August, 2009”. T he content of the PDF presents as follows: 31.However as can be seen in the screenshot above, the identifying information for Dr Wright lists his passport number as being N2511450. I am aware that the issuing of a new passport to a person will Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 16 of 25 30.Searching the disclosure dataset for the passport number, I observed a small number of hits in the dataset , one of which was irregular because it appeared to pre- date the date of the passport. That is ID_004550. The document is a PDF relating to “Wright Internat ional Investments Limited” and the appointment of Craig Steven Wright as director of that company. The document is dated on its face to “this 4thday of August, 2009”. T he content of the PDF presents as follows: 31.However as can be seen in the screenshot above, the identifying information for Dr Wright lists his passport number as being N2511450. I am aware that the issuing of a new passport to a person will 16 - 16 - H/241/16{ID_004550} Madden Appendix PM4 5 Dr Wright’s 4th Witness Statement and Vistomail video exhibits Page 17 of 25 re sult in a new passport number being allocated to the passport.1According to the date on the face of the passport as shown in Exhibit CSW12, that passport had not yet been issued by 4thAugust 2009 but was not issued until 23 June 2010. 32.It is therefore my view that ID_004550 is not authentic to the date on its face. 33.I observe that the internal metadata of the document ID_004550 is given as Thursday, 23 October 2014 12:19:47 UTC. In my opinion, that is likely to be the true date of the document, as it is several years after the issue date of the passport r eferred to in that document (but before the passport ha d e xpired). Exchange servers 34.In paragraphs 60 to 92 of his Fourth Witness S tatement , Dr Wright discusses his emails and describ es t ransfers of emails between exchange servers . I have been asked by Bird & Bird to review this secti on o f the statement , and comment on the information provided as it relates to the question of migrati on o f emails between servers. This topic arose in connection with my analysis at Appendix PM18 a nd t he explanation provided in respect of how the “Kleiman email ” mentioned in the
1,910
/content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf
Martti Malmi - Exhibits
part 10 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf
44,150
86,849
>>>> I tried deleting and re-enabling the feature, no help. Oh well. >>> >>> I think this has something to do with the underscore character in your >>> username; MediaWiki handles them as spaces. I could ask SF Support >>> about this. >> >> Or could you control the MediaWiki with your account nakamoto2? > > Oh, sorry for spamming with emails, but the problem is indeed with the > underscore character: > http://apps.sourceforge.net/trac/sourceforge/ticket/300 > SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 11/06/2009 22:24 The site layout is looking nicer. More impressive looking. There are a lot of things you can say on the sourceforge site that I can't say on my own site. Even so, I'm uncomfortable with explicitly saying "consider it an investment". That's a dangerous thing to say and you should delete that bullet point. It's OK if they come to that conclusion on their own, but we can't pitch it as that. A few details: the FAQ says "see section 2.3", but the sections aren't numbered. Also, could you delete the last sentence on the FAQ "They are planned to be hidden in v0.1.6, since they're just confusing and annoying and there's no reason for users to have to see them." -- that's not really something I meant to say publicly. The links to sites to help set up 8333 port forwarding is great. favicon is a nice touch. Someone came up with the word "cryptocurrency"... maybe it's a word we should use when describing Bitcoin, do you like it? Sourceforge is so slow right now I can't even get the login page to load. Maybe due to the site reorg they just did. I'll keep trying and try to get you that logo stats thing. [email protected] wrote: > Now that the project web is up and running, do you think that setting up > a custom VHOST for the bitcoin.org domain would be a good idea? > Instructions: > http://apps.sourceforge.net/trac/sourceforge/wiki/Custom%20VHOSTs > > Also, could you please send me a link to a SF Logo for statistics, as > instructed at: > http://apps.sourceforge.net/trac/sourceforge/wiki/Use%20of%20sflogo%20for%20statistics%20tracki ng > > SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 14/06/2009 21:30 [email protected] wrote: > I made the changes. You could also register to the site or use the admin > account to make necessary changes yourself, since the pages are located > in the wiki. Thanks, I've been really busy lately. I registered username "satoshi". Since there's no SSL login, I want to mainly use that account with sub-admin powers and use the admin account as little as possible. I created a "Moderators" group to give my satoshi account as much editing control as possible without the ability to overthrow everything. There's something weird with the download bar on the right covering things up, like on the new account registration it covers up the entry fields unless you make the browser really wide, and the homepage it covers up the screenshots. (with Firefox) SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 21/07/2009 04:14 I know this sounds really retarded, but I still haven't been able to get the sourceforge login page to load, so I haven't been able to read it either. https://sourceforge.net/account/login.php Hal isn't currently actively involved. He helped me a lot defending the design on the Cryptography list, and with initial testing when it was first released. He carried this torch years ago with his Reusable Proof Of Work (RPOW). I'm not going to be much help right now either, pretty busy with work, and need a break from it after 18 months development. It would help if there was something for people to use it for. We need an application to bootstrap it. Any ideas? There are donors I can tap if we come up with something that needs funding, but they want to be anonymous, which makes it hard to actually do anything with it. [email protected] wrote: > Hi, > > I made a post on the Bitcoin developer's forum at SF about a month ago > and sent you, David and Hal a notification about it to your > users.sourceforge.net emails. A few days ago I wondered why no one had > replied, and tried if the SF mail aliases even work - and they didn't, > at least in the case of my account. So could you please forward this > message to the others? > > Best regards, > sirius-m > SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 24/08/2009 23:00 That's a good point that since you know how many coins exist and how fast new ones are created, you could set a support price based on the amount of legacy currency you have and be sure you'll have enough to meet all demands. I had imagined an auction, but it would be far simpler and more confidence inspiring to back it at a specific exchange rate. Offering currency to back bitcoins would attract freebie seekers, with the benefit of attracting a lot of publicity. At first it would mostly be seen as a way to get free money for your computer's idle time. Maybe pitched like help support the future of e-commerce and get a little money for your computer's spare cycles. As people cash in and actually get paid, word would spread exponentially. It might help to keep the minimum transaction size above an amount which a typical user would be able to accumulate with one computer, so that users have to trade with each other for someone to collect enough to cash in. Aggregators would set up shop to buy bitcoins in smaller increments, which would add confidence in users ability to sell bitcoins if there are more available buyers than just you. People would obviously be sceptical at first that the backing will hold up against an onslaught of people trying to get the free money, but as the competition raises the proof-of-work difficulty, it should become clear that bitcoins
1,004
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 10 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf ### Folder name: Martti Malmi - Exhibits ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf ### File content: >>>> I tried deleting and re-enabling the feature, no help. Oh well. >>> >>> I think this has something to do with the underscore character in your >>> username; MediaWiki handles them as spaces. I could ask SF Support >>> about this. >> >> Or could you control the MediaWiki with your account nakamoto2? > > Oh, sorry for spamming with emails, but the problem is indeed with the > underscore character: > http://apps.sourceforge.net/trac/sourceforge/ticket/300 > SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 11/06/2009 22:24 The site layout is looking nicer. More impressive looking. There are a lot of things you can say on the sourceforge site that I can't say on my own site. Even so, I'm uncomfortable with explicitly saying "consider it an investment". That's a dangerous thing to say and you should delete that bullet point. It's OK if they come to that conclusion on their own, but we can't pitch it as that. A few details: the FAQ says "see section 2.3", but the sections aren't numbered. Also, could you delete the last sentence on the FAQ "They are planned to be hidden in v0.1.6, since they're just confusing and annoying and there's no reason for users to have to see them." -- that's not really something I meant to say publicly. The links to sites to help set up 8333 port forwarding is great. favicon is a nice touch. Someone came up with the word "cryptocurrency"... maybe it's a word we should use when describing Bitcoin, do you like it? Sourceforge is so slow right now I can't even get the login page to load. Maybe due to the site reorg they just did. I'll keep trying and try to get you that logo stats thing. [email protected] wrote: > Now that the project web is up and running, do you think that setting up > a custom VHOST for the bitcoin.org domain would be a good idea? > Instructions: > http://apps.sourceforge.net/trac/sourceforge/wiki/Custom%20VHOSTs > > Also, could you please send me a link to a SF Logo for statistics, as > instructed at: > http://apps.sourceforge.net/trac/sourceforge/wiki/Use%20of%20sflogo%20for%20statistics%20tracki ng > > SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 14/06/2009 21:30 [email protected] wrote: > I made the changes. You could also register to the site or use the admin > account to make necessary changes yourself, since the pages are located > in the wiki. Thanks, I've been really busy lately. I registered username "satoshi". Since there's no SSL login, I want to mainly use that account with sub-admin powers and use the admin account as little as possible. I created a "Moderators" group to give my satoshi account as much editing control as possible without the ability to overthrow everything. There's something weird with the download bar on the right covering things up, like on the new account registration it covers up the entry fields unless you make the browser really wide, and the homepage it covers up the screenshots. (with Firefox) SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 21/07/2009 04:14 I know this sounds really retarded, but I still haven't been able to get the sourceforge login page to load, so I haven't been able to read it either. https://sourceforge.net/account/login.php Hal isn't currently actively involved. He helped me a lot defending the design on the Cryptography list, and with initial testing when it was first released. He carried this torch years ago with his Reusable Proof Of Work (RPOW). I'm not going to be much help right now either, pretty busy with work, and need a break from it after 18 months development. It would help if there was something for people to use it for. We need an application to bootstrap it. Any ideas? There are donors I can tap if we come up with something that needs funding, but they want to be anonymous, which makes it hard to actually do anything with it. [email protected] wrote: > Hi, > > I made a post on the Bitcoin developer's forum at SF about a month ago > and sent you, David and Hal a notification about it to your > users.sourceforge.net emails. A few days ago I wondered why no one had > replied, and tried if the SF mail aliases even work - and they didn't, > at least in the case of my account. So could you please forward this > message to the others? > > Best regards, > sirius-m > SUBJECT : Re: Bitcoin FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 24/08/2009 23:00 That's a good point that since you know how many coins exist and how fast new ones are created, you could set a support price based on the amount of legacy currency you have and be sure you'll have enough to meet all demands. I had imagined an auction, but it would be far simpler and more confidence inspiring to back it at a specific exchange rate. Offering currency to back bitcoins would attract freebie seekers, with the benefit of attracting a lot of publicity. At first it would mostly be seen as a way to get free money for your computer's idle time. Maybe pitched like help support the future of e-commerce and get a little money for your computer's spare cycles. As people cash in and actually get paid, word would spread exponentially. It might help to keep the minimum transaction size above an amount which a typical user would be able to accumulate with one computer, so that users have to trade with each other for someone to collect enough to cash in. Aggregators would set up shop to buy bitcoins in smaller increments, which would add confidence in users ability to sell bitcoins if there are more available buyers than just you. People would obviously be sceptical at first that the backing will hold up against an onslaught of people trying to get the free money, but as the competition raises the proof-of-work difficulty, it should become clear that bitcoins
1,723
/content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
Closings
part 98 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
236,795
438,889
to be Satoshi, weren’t you? A. I agreed to do it my way. I would prove to people who I am, because I'd spoken to them, because I knew things, because of my work. I went up to Gavin and I told him about the development issues, I explained what we did, things that were not public. I went on an email - not just emails, but I had phone calls with him, and I talked him through things that only he and Satoshi knew, and that’s why he came out to England. I had nothing to do with any of this. Dr Wright’s explanation is inconsistent with his evidence, in which he has not revealed anything that Satoshi knew that was not already in the public domain. {L12/2/2} - 00000547_item.msg {Day7/144:18} - {Day7/145:9} Q. Let’s forget about proof in - several hundred years ago. You were rejecting every form of objectively verifiable proof, weren’t y ou. A. No - Q. Objectively verifiable? A. Again, it’s not several hundred years ago. A certain author who did a Harry Potter series only did it recently. A certain author who did a whole lot of - Q. You're still not answering my question. A. No, I am. You're trying to equate something that is exactly the opposite of British law, for a thousand years, actually going back to Roman times, on identity law, and people want to equate that, because there are a lot of people in Silicon Valley who h ate the idea of having identity; they want to have an Dr Wright is not answering the question that is asked, and provides an evasive and irrelevant answer. Appendix B: Schedule of Transcript References 244 REFERENCE QUOTE COMMENT anonymous system, mainly because there's more money in Google outside - {Day7/146:22} - {Day7/148 :17} Q. I appreciate you're desperate to make Mr MacGregor the villain. But if we look to the top of the page, you object to signing on the basis that it would be definitive proof of your controlling the keys and it was that proof that you controlled the keys that was objectionable to you. That's what you said, isn't it? A. No, it is only proof that I controlled the keys. It isn't proof of identity. Q. "A signed message is definitive ... I control the keys completely. If it is copied ... there is no way t o control it. Even deleting a file is not removing it. Files can be recovered and I doubt Gavin would allow us to wipe his machines." That's objecting on the basis that the keys could be compromised, not on the basis that you had a principled objection to signing at all, isn't it? A. No, what you have just said is utterly wrong. Now, what you've just said is the key is compromised. This is wrong. I could give you a signed message and you can validate it on a third party computer, but what I'm saying here i s, I can no longer control who has that message. When I did the exercise for the Australian Tax Office, the way that I did it was I encrypted a file - or, sorry, they encrypted a file and I decrypted it. Now, that proves categorically that I have the key. If I can answer the question you put in that file, I must have decrypted it. If I can send you back the file, I must have decrypted it. But there is no proof I have the key other than the party who sent it to me. My requirement, very simply, was Gavin can know, he's not telling anyone. Q. Okay, we'll move on. You go on to say that you were objecting, in the last paragraph, because you'd said that you couldn't control the keys without help. You said that to the government. That was the nature of the objecti on you were pointing out to Mr MacGregor, isn't it? A. No, that's a different issue. We could have gone through things like signing off on the trust and everything like - that we ended up doing, but, no, I wasn't going to just have it out there. I wasn't going to go into attributing myself to Satoshi publicly that way. No way I was going to basically have this mantra that everyone wants of possession equals identity. Dr Wright is asked about the basis of his objections to the signing session, he is evasive and rambling in response and refers to an “exercise” he did for the ATO. Appendix B: Schedule of Transcript References 245 REFERENCE QUOTE COMMENT {Day7/148:24} - {Day7/149:7} Q. You agreed, didn't you, and you undertook signing sessions with GQ, the BBC and The Economist, right? A. No, I had sessions where I showed keys. The agreement was that all of the other stuff would be put in. What was called a "proof pack" was meant to go out. That was meant to put together my history, my work, the patents I'd been filing. None of it went. The proof pack was actually sending t he proof, but none of the proof got sent. Dr Wright blaming unidentified third parties for not providing the “proof pack”. {L12/172/1} - 00000671_item.msg {Day7/150:8} - {Day7/150:22} "My view remains that we verify the early blocks for the media. I si gn a message to prove my control of these. What I also do is do this as a signed - only session with JM [Jon Matonis] and [Gavin Andresen] and not move blocks." You were proposing, at that stage, to Mr MacGregor that you would conduct a signing session wit h the journalists, just as you had with Mr Matonis and Mr Andresen, weren't you? A. No, as I just explained, it's not signing. I would show that I could verify the early blocks. I did not say sign, I said control and possession. I agreed that I would do t hat for the - what then had to happen was a proper proof session. You verify all my stuff, you go through how I created the Bitcoin White Paper - - Dr Wright not accepting the obvious truth of his email to Mr MacGregor, denying that he said “sign” even tho ugh the email refers multiple times to “sign”. {Day7/150:23} - {Day7/151:6} Q. But you were proposing, weren't you, a signature session with the journalists as with Mr Matonis and Mr Andresen, weren't you? A.
1,077
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 98 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: to be Satoshi, weren’t you? A. I agreed to do it my way. I would prove to people who I am, because I'd spoken to them, because I knew things, because of my work. I went up to Gavin and I told him about the development issues, I explained what we did, things that were not public. I went on an email - not just emails, but I had phone calls with him, and I talked him through things that only he and Satoshi knew, and that’s why he came out to England. I had nothing to do with any of this. Dr Wright’s explanation is inconsistent with his evidence, in which he has not revealed anything that Satoshi knew that was not already in the public domain. {L12/2/2} - 00000547_item.msg {Day7/144:18} - {Day7/145:9} Q. Let’s forget about proof in - several hundred years ago. You were rejecting every form of objectively verifiable proof, weren’t y ou. A. No - Q. Objectively verifiable? A. Again, it’s not several hundred years ago. A certain author who did a Harry Potter series only did it recently. A certain author who did a whole lot of - Q. You're still not answering my question. A. No, I am. You're trying to equate something that is exactly the opposite of British law, for a thousand years, actually going back to Roman times, on identity law, and people want to equate that, because there are a lot of people in Silicon Valley who h ate the idea of having identity; they want to have an Dr Wright is not answering the question that is asked, and provides an evasive and irrelevant answer. Appendix B: Schedule of Transcript References 244 REFERENCE QUOTE COMMENT anonymous system, mainly because there's more money in Google outside - {Day7/146:22} - {Day7/148 :17} Q. I appreciate you're desperate to make Mr MacGregor the villain. But if we look to the top of the page, you object to signing on the basis that it would be definitive proof of your controlling the keys and it was that proof that you controlled the keys that was objectionable to you. That's what you said, isn't it? A. No, it is only proof that I controlled the keys. It isn't proof of identity. Q. "A signed message is definitive ... I control the keys completely. If it is copied ... there is no way t o control it. Even deleting a file is not removing it. Files can be recovered and I doubt Gavin would allow us to wipe his machines." That's objecting on the basis that the keys could be compromised, not on the basis that you had a principled objection to signing at all, isn't it? A. No, what you have just said is utterly wrong. Now, what you've just said is the key is compromised. This is wrong. I could give you a signed message and you can validate it on a third party computer, but what I'm saying here i s, I can no longer control who has that message. When I did the exercise for the Australian Tax Office, the way that I did it was I encrypted a file - or, sorry, they encrypted a file and I decrypted it. Now, that proves categorically that I have the key. If I can answer the question you put in that file, I must have decrypted it. If I can send you back the file, I must have decrypted it. But there is no proof I have the key other than the party who sent it to me. My requirement, very simply, was Gavin can know, he's not telling anyone. Q. Okay, we'll move on. You go on to say that you were objecting, in the last paragraph, because you'd said that you couldn't control the keys without help. You said that to the government. That was the nature of the objecti on you were pointing out to Mr MacGregor, isn't it? A. No, that's a different issue. We could have gone through things like signing off on the trust and everything like - that we ended up doing, but, no, I wasn't going to just have it out there. I wasn't going to go into attributing myself to Satoshi publicly that way. No way I was going to basically have this mantra that everyone wants of possession equals identity. Dr Wright is asked about the basis of his objections to the signing session, he is evasive and rambling in response and refers to an “exercise” he did for the ATO. Appendix B: Schedule of Transcript References 245 REFERENCE QUOTE COMMENT {Day7/148:24} - {Day7/149:7} Q. You agreed, didn't you, and you undertook signing sessions with GQ, the BBC and The Economist, right? A. No, I had sessions where I showed keys. The agreement was that all of the other stuff would be put in. What was called a "proof pack" was meant to go out. That was meant to put together my history, my work, the patents I'd been filing. None of it went. The proof pack was actually sending t he proof, but none of the proof got sent. Dr Wright blaming unidentified third parties for not providing the “proof pack”. {L12/172/1} - 00000671_item.msg {Day7/150:8} - {Day7/150:22} "My view remains that we verify the early blocks for the media. I si gn a message to prove my control of these. What I also do is do this as a signed - only session with JM [Jon Matonis] and [Gavin Andresen] and not move blocks." You were proposing, at that stage, to Mr MacGregor that you would conduct a signing session wit h the journalists, just as you had with Mr Matonis and Mr Andresen, weren't you? A. No, as I just explained, it's not signing. I would show that I could verify the early blocks. I did not say sign, I said control and possession. I agreed that I would do t hat for the - what then had to happen was a proper proof session. You verify all my stuff, you go through how I created the Bitcoin White Paper - - Dr Wright not accepting the obvious truth of his email to Mr MacGregor, denying that he said “sign” even tho ugh the email refers multiple times to “sign”. {Day7/150:23} - {Day7/151:6} Q. But you were proposing, weren't you, a signature session with the journalists as with Mr Matonis and Mr Andresen, weren't you? A.
1,709
/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Fifth Expert Report of Patrick Madden.pdf
Patrick Madden
part 12 of 20 Fifth Expert Report of Patrick Madden.pdf
17,602
39,084
a factor I considered in my analysis. 126. I therefore consider that the authenticity of this document {ID_006565} should be considered at least as unreliable, without further supporting evidence. It may be possible to come to a more concluded view if I was provided access to the computing systems used to author and store this document and the emails associated with it. The attachment “C Wright.zipx” 127. The next attachment is a Zip file that contains five files. When opened in 7Zip it presents as follows: Lock file 128. The last file listed “~$ABACUS SEYCHELLES LTD.dotx” is an MS word lock file: a. The lock file is typically a hidden file in Windows and indicates that a file with a similar name (but without a leading ~) is locked for editing. b. Inside the file it has recorded the name of “denis Mayaka” as the registered user. I observe that “denis” is typed with a lower case “d” while “Mayaka” has a Capital “M”, though this does not affect my analysis itself. Fifth expert report of Patrick Madden Page 40 of 66 c. The lock file is also typically created in the same location as the document file itself. In this instance a template .dotx file. d. Lock files are typically deleted when the document to which they relate has been closed, and only remain when an error occurs and a document is not properly closed. e. I consider it somewhat unusual that this lock file is included in the zip file without the template itself. It is possible that this could have happened through normal computer use, but the circumstances are still somewhat unusual. 129. Although a lock file indicates that a main document file (to which it relates) is being edited or opened, there is no accompanying file “ABACUS SEYCHELLES LTD.dotx” to which this lock file relates included in the Zip archive. I also note that there is no “ AO invoive” file with 18 June 2012 timestamps attributed to the lock file. 130. The Last Accessed timestamps for all of these files is captured in the Zip file as being 18 June 2012 at 18:08. This is the same time captured by the zip file as being the Created and Modified time of the lock file, and indicates the setting of the compute r clock at the time that the zip was created. 131. I have considered two possible ways of how this could have occurred: a. If the user had the template .DOTX file open at the time, while preparing the content of this zip incorrectly selected the lock file when intending to select the template file. However, this all occurred with the clock set around 11 months after the previo us invoice in the folder was Last Modified, which is unusual. b. The lock file may have remained in the folder if MS Word did not successfully exit and remove the lock file. The template file is removed from the folder, and any other files that may have been created in the folder. The user creates a zip file of the fold er, expecting only the four ZIP files to be included, but it incidentally also captures the lock file. Invoices in Zip files 132. Turning to the four Zipx files. Each of these contains a single .DOCX file as demonstrated with one of the zips presented in 7Zip below: Fifth expert report of Patrick Madden Page 41 of 66 133. All four documents have been password protected and digitally signed. These are not actually DOCX files as shown in their file extensions: they are .DOC files with an incorrect extension, though this is not itself an issue. The table below lists the file timestamps captured in the zipx files. Name File Created (zip) File Modified (zip) File Accessed (zip) AO Invoive 191083e.docx 30/07/2009 17:37:00 30/07/2009 17:37:35 31/07/2009 11:14:07 AO Invoive 234115e.docx 29/07/2010 09:43:28 29/07/2010 09:45:14 29/07/2010 09:45:04 AO Invoive 262821.docx 29/06/2011 09:59:18 29/06/2011 10:05:31 29/06/2011 10:04:40 AO Invoive 278120.docx 15/07/2011 07:49:35 15/07/2011 07:47:21 15/07/2011 07:49:35 134. I produce at Exhibit PM -R 5.1 a schedule listing the prominent metadata properties for the four invoices4. Spelling mistake across four invoices 135. I observe that all four documents share a spelling mistake in the filename “Invoive” rather than “Invoice”: a. This is an apparent mistake that is not repeated within the content of the documents or their properties. b. I consider it irregular that four separate files created and put into four separate zip files at yearly intervals over a two year period can exhibit such a consistent spelling mistake. c. It is correct that the letters “V” and “C” are adjacent to each other on a keyboard, and that the spelling mistake is therefore an easy one to make on occasion. d. However, in this example, the mistake would need to have been repeated four times over the course of two years, and captured contemporaneously in each of the four occasions when the 4 The file “AO Invoive 191083e.doc” includes two copies of the same digital signature, but I have reported on the details of the signature only once Fifth expert report of Patrick Madden Page 42 of 66 individual files were captured into the individual zip files, unless the documents were created one from another.
881
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 12 of 20 Fifth Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Fifth Expert Report of Patrick Madden.pdf ### File content: a factor I considered in my analysis. 126. I therefore consider that the authenticity of this document {ID_006565} should be considered at least as unreliable, without further supporting evidence. It may be possible to come to a more concluded view if I was provided access to the computing systems used to author and store this document and the emails associated with it. The attachment “C Wright.zipx” 127. The next attachment is a Zip file that contains five files. When opened in 7Zip it presents as follows: Lock file 128. The last file listed “~$ABACUS SEYCHELLES LTD.dotx” is an MS word lock file: a. The lock file is typically a hidden file in Windows and indicates that a file with a similar name (but without a leading ~) is locked for editing. b. Inside the file it has recorded the name of “denis Mayaka” as the registered user. I observe that “denis” is typed with a lower case “d” while “Mayaka” has a Capital “M”, though this does not affect my analysis itself. Fifth expert report of Patrick Madden Page 40 of 66 c. The lock file is also typically created in the same location as the document file itself. In this instance a template .dotx file. d. Lock files are typically deleted when the document to which they relate has been closed, and only remain when an error occurs and a document is not properly closed. e. I consider it somewhat unusual that this lock file is included in the zip file without the template itself. It is possible that this could have happened through normal computer use, but the circumstances are still somewhat unusual. 129. Although a lock file indicates that a main document file (to which it relates) is being edited or opened, there is no accompanying file “ABACUS SEYCHELLES LTD.dotx” to which this lock file relates included in the Zip archive. I also note that there is no “ AO invoive” file with 18 June 2012 timestamps attributed to the lock file. 130. The Last Accessed timestamps for all of these files is captured in the Zip file as being 18 June 2012 at 18:08. This is the same time captured by the zip file as being the Created and Modified time of the lock file, and indicates the setting of the compute r clock at the time that the zip was created. 131. I have considered two possible ways of how this could have occurred: a. If the user had the template .DOTX file open at the time, while preparing the content of this zip incorrectly selected the lock file when intending to select the template file. However, this all occurred with the clock set around 11 months after the previo us invoice in the folder was Last Modified, which is unusual. b. The lock file may have remained in the folder if MS Word did not successfully exit and remove the lock file. The template file is removed from the folder, and any other files that may have been created in the folder. The user creates a zip file of the fold er, expecting only the four ZIP files to be included, but it incidentally also captures the lock file. Invoices in Zip files 132. Turning to the four Zipx files. Each of these contains a single .DOCX file as demonstrated with one of the zips presented in 7Zip below: Fifth expert report of Patrick Madden Page 41 of 66 133. All four documents have been password protected and digitally signed. These are not actually DOCX files as shown in their file extensions: they are .DOC files with an incorrect extension, though this is not itself an issue. The table below lists the file timestamps captured in the zipx files. Name File Created (zip) File Modified (zip) File Accessed (zip) AO Invoive 191083e.docx 30/07/2009 17:37:00 30/07/2009 17:37:35 31/07/2009 11:14:07 AO Invoive 234115e.docx 29/07/2010 09:43:28 29/07/2010 09:45:14 29/07/2010 09:45:04 AO Invoive 262821.docx 29/06/2011 09:59:18 29/06/2011 10:05:31 29/06/2011 10:04:40 AO Invoive 278120.docx 15/07/2011 07:49:35 15/07/2011 07:47:21 15/07/2011 07:49:35 134. I produce at Exhibit PM -R 5.1 a schedule listing the prominent metadata properties for the four invoices4. Spelling mistake across four invoices 135. I observe that all four documents share a spelling mistake in the filename “Invoive” rather than “Invoice”: a. This is an apparent mistake that is not repeated within the content of the documents or their properties. b. I consider it irregular that four separate files created and put into four separate zip files at yearly intervals over a two year period can exhibit such a consistent spelling mistake. c. It is correct that the letters “V” and “C” are adjacent to each other on a keyboard, and that the spelling mistake is therefore an easy one to make on occasion. d. However, in this example, the mistake would need to have been repeated four times over the course of two years, and captured contemporaneously in each of the four occasions when the 4 The file “AO Invoive 191083e.doc” includes two copies of the same digital signature, but I have reported on the details of the signature only once Fifth expert report of Patrick Madden Page 42 of 66 individual files were captured into the individual zip files, unless the documents were created one from another.
1,588
/content/Copa v Wright - Trial Documents/Expert Reports/Arthur Rosendahl/Second Expert Report of Arthur Rosendahl.pdf
Arthur Rosendahl
part 3 of 6 Second Expert Report of Arthur Rosendahl.pdf
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same with similar examples later on. 6 of Tuesday 24 March 2009 at 17:33:15 UTC, the full string being accordingly 20090324173315 . InotehoweverthatthetimeisactuallycodedinsidethePDFfile as 11:33:15 UTC-6, which results in a full timestamp string of D:20090324113315- 06'00. A PDF viewer will usually display times in the user’s time zone, regardless of the time zone of the timestamp string. e.A series of 41 further edits took place on 1 December 2023. These included setting PDF XMP metadata as pdfxmpcreatedate={2008-10-03T13:49:58-07:00} (a date and time corresponding to the creation date of the 2008 version of the Bit- coin White Paper - chunk 931, at 10:13:47 AM), and then 15 minutes later, set- ting the XMP metadata to pdfxmpcreatedate={2009-03-24T11:33:15-06:00} (chunk 944, 10:28:40 AM), as well as other modifications to how the metadata was coded. Although these dates match the creation dates and times of the different versions of the Bitcoin White Paper, the field in question in fact refers to some- thing different, called “metadata stream” in the specification of the PDF format. The BWP stores its metadata in a structure called the “document information dictionary” (this is what I refer to as metadata elsewhere in my reports). These fields are not present in the original BWP documents. The commands then deleted these XMP fields a few minutes later (at 10.29.53 AM). f.Three days later, on 4 December 2023, at chunks 1097 to 1106, different values of the author key are typed in the PDF metadata. First, the name ‘ Michael Hicks ’ being set as the metadata author at 16:33:28, with that text being deleted three minutes later and replaced with ‘ Satoshi Nakamoto ’. 26. In this way, the commands used to specifically set metadata evolved from 22 November 2023 to 4 December 2023, with some changes being reverted (such as the author name key and XMP metadata shown above), with others being introduced in the final version (such as the pdfcreationdate andpdfmoddate keys). 2.2.4 Final edits in December 2023 to file L main.tex 27. 5 December 2023 then saw extensive activity in the domain of editing and setting of fonts, formulas, and metadata, with chunks 1107 to 1252 recording edits in mostly Lmain.tex , and a further 8 edits the following day. This included specifying specific fonts files to be used (such as OpenSymbol.ttf ) and edits to formulae (such as replacing the literal Greek letter with the L ATEX command \\lambda. 28. The file was then edited a further 7 times on 10-12 December 2023, with an alteration to an embedded diagram and deletion of a small amount of text. 7 2.3 Other edits and other files 29. I will not go through all the other 1505 chunks in detail as it would be extremely tedious and will instead focus on a few salient ones, as follows: a.chunk 681 sees the creation of CE-Cash-main.tex with a prose similar to the Bitcoin White Paper from March 2009. At that point it was given the same title as the March 2009 Bitcoin White Paper, but less than five minutes later, at chunk 694, we can see the title being altered to what I understand to be an earlier one (“Electronic Cash Without a Trusted Third Party ”); b.immediately afterwards, from chunks 697 to 744, we can see the text is edited backwards to match the text of the abstract. I note that the Excel file at this place reads almost exactly like my comparison table 3.5 from my First Report; c.atchunk762,file ABitCoin 2007.tex iscreatedon22November2023at19:47:50.435. A large amount of file content is then pasted in shortly afterwards 10 seconds later, with further edits taking place over the next minute including the addition of the wordNakamoto ; d.at that point a new file BC2.tex is created, quite a short file, which contains Lua code in an apparent attempt at combining two fonts together in one a maths formula. This is similar to formulae in the BWP (which use the main maths font Times New Roman, but the font OpenSymbol for a few characters within those formulae). I do not think this Lua code could ever work but did not investigate further for the purpose of this Report; e.similar edits are made to many other files in the project over the TC period up to 13 December 2023 at 13:10:15.858; and f.last but not least, at chunk 1405 (still on 5 December 2023), Lmain.tex is created anew, and contents added to it resulting in a file identical to the document that was provided to me in the course of my Stage 2 instructions in my First Report. 30. I note that this is consistent with the findings in the genealogy in my First Report. 2.3.1 Other candidate documents 31. Over the course of all these edits and additions, several other files are created, five of which attracted my attention because I realised they were further candidates for being the L ATEX source of the original Bitcoin White Paper, in addition to the fourteen from my First Report. Out of completeness, I have looked at these against the table of “problematic packages” to which I refer in my First Report — they align with my analysis and I am informed by Bird & Bird that it is not necessary to do a deeper 8 analysis of these. Nevertheless, I will also assign single capital letters to them (skipping O to avoid confusions) and give an quick summary: PShoosmiths.tex (1068 lines): contains all 7 problematic packages identified in sec- tion 3.7 of my First Report; QmBitcoin.tex (1136 lines): all 7 packages; Rmain03.tex (1091 lines): all 7 packages; Smain310.tex (534 lines): only 2 out of the 7 packages: fontspec, and luacode; and Tmainpdf.tex (1121): all 7 problematic packages. 3 The second tranche 3.1 Introduction 32. Although this export from the “Maths (OLD)” project was provided to me later, it actually provides data about prior editing, as is clear from the timestamps. The data in thisprojectwaseditedinthefewdaysimmediatelypriortothere-creation3ofmain.tex , and the data was subsequently copied into main.tex leading to the series of further edits described above. 33. The most relevant file for analysis in this project is the file named BitcoinSN.tex . This is clear because the vast majority of edits recorded in chunks.xlsx are made to that one file (1369 out of a total 1602), and because the final
1,048
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 3 of 6 Second Expert Report of Arthur Rosendahl.pdf ### Folder name: Arthur Rosendahl ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Arthur Rosendahl/Second Expert Report of Arthur Rosendahl.pdf ### File content: same with similar examples later on. 6 of Tuesday 24 March 2009 at 17:33:15 UTC, the full string being accordingly 20090324173315 . InotehoweverthatthetimeisactuallycodedinsidethePDFfile as 11:33:15 UTC-6, which results in a full timestamp string of D:20090324113315- 06'00. A PDF viewer will usually display times in the user’s time zone, regardless of the time zone of the timestamp string. e.A series of 41 further edits took place on 1 December 2023. These included setting PDF XMP metadata as pdfxmpcreatedate={2008-10-03T13:49:58-07:00} (a date and time corresponding to the creation date of the 2008 version of the Bit- coin White Paper - chunk 931, at 10:13:47 AM), and then 15 minutes later, set- ting the XMP metadata to pdfxmpcreatedate={2009-03-24T11:33:15-06:00} (chunk 944, 10:28:40 AM), as well as other modifications to how the metadata was coded. Although these dates match the creation dates and times of the different versions of the Bitcoin White Paper, the field in question in fact refers to some- thing different, called “metadata stream” in the specification of the PDF format. The BWP stores its metadata in a structure called the “document information dictionary” (this is what I refer to as metadata elsewhere in my reports). These fields are not present in the original BWP documents. The commands then deleted these XMP fields a few minutes later (at 10.29.53 AM). f.Three days later, on 4 December 2023, at chunks 1097 to 1106, different values of the author key are typed in the PDF metadata. First, the name ‘ Michael Hicks ’ being set as the metadata author at 16:33:28, with that text being deleted three minutes later and replaced with ‘ Satoshi Nakamoto ’. 26. In this way, the commands used to specifically set metadata evolved from 22 November 2023 to 4 December 2023, with some changes being reverted (such as the author name key and XMP metadata shown above), with others being introduced in the final version (such as the pdfcreationdate andpdfmoddate keys). 2.2.4 Final edits in December 2023 to file L main.tex 27. 5 December 2023 then saw extensive activity in the domain of editing and setting of fonts, formulas, and metadata, with chunks 1107 to 1252 recording edits in mostly Lmain.tex , and a further 8 edits the following day. This included specifying specific fonts files to be used (such as OpenSymbol.ttf ) and edits to formulae (such as replacing the literal Greek letter with the L ATEX command \\lambda. 28. The file was then edited a further 7 times on 10-12 December 2023, with an alteration to an embedded diagram and deletion of a small amount of text. 7 2.3 Other edits and other files 29. I will not go through all the other 1505 chunks in detail as it would be extremely tedious and will instead focus on a few salient ones, as follows: a.chunk 681 sees the creation of CE-Cash-main.tex with a prose similar to the Bitcoin White Paper from March 2009. At that point it was given the same title as the March 2009 Bitcoin White Paper, but less than five minutes later, at chunk 694, we can see the title being altered to what I understand to be an earlier one (“Electronic Cash Without a Trusted Third Party ”); b.immediately afterwards, from chunks 697 to 744, we can see the text is edited backwards to match the text of the abstract. I note that the Excel file at this place reads almost exactly like my comparison table 3.5 from my First Report; c.atchunk762,file ABitCoin 2007.tex iscreatedon22November2023at19:47:50.435. A large amount of file content is then pasted in shortly afterwards 10 seconds later, with further edits taking place over the next minute including the addition of the wordNakamoto ; d.at that point a new file BC2.tex is created, quite a short file, which contains Lua code in an apparent attempt at combining two fonts together in one a maths formula. This is similar to formulae in the BWP (which use the main maths font Times New Roman, but the font OpenSymbol for a few characters within those formulae). I do not think this Lua code could ever work but did not investigate further for the purpose of this Report; e.similar edits are made to many other files in the project over the TC period up to 13 December 2023 at 13:10:15.858; and f.last but not least, at chunk 1405 (still on 5 December 2023), Lmain.tex is created anew, and contents added to it resulting in a file identical to the document that was provided to me in the course of my Stage 2 instructions in my First Report. 30. I note that this is consistent with the findings in the genealogy in my First Report. 2.3.1 Other candidate documents 31. Over the course of all these edits and additions, several other files are created, five of which attracted my attention because I realised they were further candidates for being the L ATEX source of the original Bitcoin White Paper, in addition to the fourteen from my First Report. Out of completeness, I have looked at these against the table of “problematic packages” to which I refer in my First Report — they align with my analysis and I am informed by Bird & Bird that it is not necessary to do a deeper 8 analysis of these. Nevertheless, I will also assign single capital letters to them (skipping O to avoid confusions) and give an quick summary: PShoosmiths.tex (1068 lines): contains all 7 problematic packages identified in sec- tion 3.7 of my First Report; QmBitcoin.tex (1136 lines): all 7 packages; Rmain03.tex (1091 lines): all 7 packages; Smain310.tex (534 lines): only 2 out of the 7 packages: fontspec, and luacode; and Tmainpdf.tex (1121): all 7 problematic packages. 3 The second tranche 3.1 Introduction 32. Although this export from the “Maths (OLD)” project was provided to me later, it actually provides data about prior editing, as is clear from the timestamps. The data in thisprojectwaseditedinthefewdaysimmediatelypriortothere-creation3ofmain.tex , and the data was subsequently copied into main.tex leading to the series of further edits described above. 33. The most relevant file for analysis in this project is the file named BitcoinSN.tex . This is clear because the vast majority of edits recorded in chunks.xlsx are made to that one file (1369 out of a total 1602), and because the final
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/content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf
Martti Malmi - Exhibits
part 5 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf
44,150
86,849
If the real transaction reaches 90% and the double-spent tx reaches 10%, the double-spender only gets a 10% chance of not paying, and 90% chance his money gets spent. For almost any type of goods, that's not going to be worth it for the scammer. Information based goods like access to website or downloads are non-fencible. Nobody is going to be able to make a living off stealing access to websites or downloads. They can go to the file sharing networks to steal that. Most instant-access products aren't going to have a huge incentive to steal. If a merchant actually has a problem with theft, they can make the customer wait 2 minutes, or wait for something in e-mail, which many already do. If they really want to optimize, and it's a large download, they could cancel the download in the middle if the transaction comes back double-spent. If it's website access, typically it wouldn't be a big deal to let the customer have access for 5 minutes and then cut off access if it's rejected. Many such sites have a free trial anyway. Satoshi [in response to a question about scale] 100,000 block generating nodes is a good ballpark large-scale size to think about. Propagating a transaction across the whole network twice would consume a total of US$ 0.02 of bandwidth at today's prices. In practice, many would be burning off excess allocated bandwidth or unlimited plans with one of the cheaper backbones. There could be millions of SPV clients. They only matter in how many transactions they generate. If they pay 1 or 2 cents transaction fees, they pay for themselves. I've coded it so you can pay any optional amount of transaction fees you want. When the incentive subsidy eventually tapers off, it may be necessary to put a market-determined transaction fee on your transactions to make sure nodes process them promptly. To think about what a really huge transaction load would look like, I look at the existing credit card network. I found some more estimates about how many transactions are online purchases. It's about 15 million tx per day for the entire e-commerce load of the Internet worldwide. At 1KB per transaction, that would be 15GB of bandwidth for each block generating node per day, or about two DVD movies worth. Seems do-able even with today's technology. Important to remember, even if Bitcoin caught on at dot-com rates of growth, it would still take years to become any substantial fraction of all transactions. I believe hardware has already recently become strong enough to handle large scale, but if there's any doubt about that, bandwidth speeds, prices, disk space and computing power will be much greater by the time it's needed. Satoshi > One other question I had... What prevents the single node with the most > CPU power from generating and retaining the majority of the BitCoins? > If every node is working independently of all others, if one is > significantly more powerful than the others, isn't it probable that this > node will reach the proper conclusion before other nodes? An > underpowered node may get lucky once in a while, but if they are at a > significant horsepower advantage I would expect the majority of BitCoins > to be generated by the most powerful node. It's not like a race where if one car is twice as fast, it'll always win. It's an SHA-256 that takes less than a microsecond, and each guess has an independent chance of success. Each computer's chance of finding a hash collision is linearly proportional to it's CPU power. A computer that's half as fast would get half as many coins. [question about what to backup] The files are in "%appdata%\\Bitcoin", that's the directory to backup. %appdata% is per-user access privilege. Most new programs like Firefox store their settings files there, despite the headwind of Microsoft changing the directory name with every Windows release and being full of spaces and so long it runs off the screen. [question about what to backup] The directory is "%appdata%\\Bitcoin" It has spaces in it so you need the quotes cd "%appdata%\\bitcoin" On XP it would typically be: C:\\Documents and Settings\\[username]\\Application Data\\Bitcoin Backup that whole directory. All data files are in that directory. There are no temporary files. [question about what to backup] The crucial file to backup is wallet.dat. If bitcoin is running then you have to backup the whole %appdata%\\bitcoin directory including the database subdirectory, but even if it's not running it certainly feels safer to always backup the whole directory. The database unfortunately names its files "log.0000000001". To the rest of the world, "log" means delete-at-will, but to database people it means delete-and-lose-everything-in-your-other-files. I tried to put them out of harm's way by putting them in the database subdirectory. Later I'll write code to flush the logs after every wallet change so wallet.dat will be standalone safe almost all the time. > > You know, I think there were a lot more people interested in the 90's, > > but after more than a decade of failed Trusted Third Party based systems > > (Digicash, etc), they see it as a lost cause. I hope they can make the > > distinction that this is the first time I know of that we're trying a > > non-trust-based system. > > Yea, that was the primary feature that caught my eye. The real trick > will be to get people to actually value the Bitcoins so that they become > currency. Hal sort of alluded to the possibility that it could be seen as a long-odds investment. I would be surprised if 10 years from now we're not using electronic currency in some way, now that we know a way to do it that won't inevitably get dumbed down when the trusted third party gets cold feet. Once it gets bootstrapped, there are so many applications if you could effortlessly pay a few cents to a website as easily as dropping
1,004
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 5 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf ### Folder name: Martti Malmi - Exhibits ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf ### File content: If the real transaction reaches 90% and the double-spent tx reaches 10%, the double-spender only gets a 10% chance of not paying, and 90% chance his money gets spent. For almost any type of goods, that's not going to be worth it for the scammer. Information based goods like access to website or downloads are non-fencible. Nobody is going to be able to make a living off stealing access to websites or downloads. They can go to the file sharing networks to steal that. Most instant-access products aren't going to have a huge incentive to steal. If a merchant actually has a problem with theft, they can make the customer wait 2 minutes, or wait for something in e-mail, which many already do. If they really want to optimize, and it's a large download, they could cancel the download in the middle if the transaction comes back double-spent. If it's website access, typically it wouldn't be a big deal to let the customer have access for 5 minutes and then cut off access if it's rejected. Many such sites have a free trial anyway. Satoshi [in response to a question about scale] 100,000 block generating nodes is a good ballpark large-scale size to think about. Propagating a transaction across the whole network twice would consume a total of US$ 0.02 of bandwidth at today's prices. In practice, many would be burning off excess allocated bandwidth or unlimited plans with one of the cheaper backbones. There could be millions of SPV clients. They only matter in how many transactions they generate. If they pay 1 or 2 cents transaction fees, they pay for themselves. I've coded it so you can pay any optional amount of transaction fees you want. When the incentive subsidy eventually tapers off, it may be necessary to put a market-determined transaction fee on your transactions to make sure nodes process them promptly. To think about what a really huge transaction load would look like, I look at the existing credit card network. I found some more estimates about how many transactions are online purchases. It's about 15 million tx per day for the entire e-commerce load of the Internet worldwide. At 1KB per transaction, that would be 15GB of bandwidth for each block generating node per day, or about two DVD movies worth. Seems do-able even with today's technology. Important to remember, even if Bitcoin caught on at dot-com rates of growth, it would still take years to become any substantial fraction of all transactions. I believe hardware has already recently become strong enough to handle large scale, but if there's any doubt about that, bandwidth speeds, prices, disk space and computing power will be much greater by the time it's needed. Satoshi > One other question I had... What prevents the single node with the most > CPU power from generating and retaining the majority of the BitCoins? > If every node is working independently of all others, if one is > significantly more powerful than the others, isn't it probable that this > node will reach the proper conclusion before other nodes? An > underpowered node may get lucky once in a while, but if they are at a > significant horsepower advantage I would expect the majority of BitCoins > to be generated by the most powerful node. It's not like a race where if one car is twice as fast, it'll always win. It's an SHA-256 that takes less than a microsecond, and each guess has an independent chance of success. Each computer's chance of finding a hash collision is linearly proportional to it's CPU power. A computer that's half as fast would get half as many coins. [question about what to backup] The files are in "%appdata%\\Bitcoin", that's the directory to backup. %appdata% is per-user access privilege. Most new programs like Firefox store their settings files there, despite the headwind of Microsoft changing the directory name with every Windows release and being full of spaces and so long it runs off the screen. [question about what to backup] The directory is "%appdata%\\Bitcoin" It has spaces in it so you need the quotes cd "%appdata%\\bitcoin" On XP it would typically be: C:\\Documents and Settings\\[username]\\Application Data\\Bitcoin Backup that whole directory. All data files are in that directory. There are no temporary files. [question about what to backup] The crucial file to backup is wallet.dat. If bitcoin is running then you have to backup the whole %appdata%\\bitcoin directory including the database subdirectory, but even if it's not running it certainly feels safer to always backup the whole directory. The database unfortunately names its files "log.0000000001". To the rest of the world, "log" means delete-at-will, but to database people it means delete-and-lose-everything-in-your-other-files. I tried to put them out of harm's way by putting them in the database subdirectory. Later I'll write code to flush the logs after every wallet change so wallet.dat will be standalone safe almost all the time. > > You know, I think there were a lot more people interested in the 90's, > > but after more than a decade of failed Trusted Third Party based systems > > (Digicash, etc), they see it as a lost cause. I hope they can make the > > distinction that this is the first time I know of that we're trying a > > non-trust-based system. > > Yea, that was the primary feature that caught my eye. The real trick > will be to get people to actually value the Bitcoins so that they become > currency. Hal sort of alluded to the possibility that it could be seen as a long-odds investment. I would be surprised if 10 years from now we're not using electronic currency in some way, now that we know a way to do it that won't inevitably get dumbed down when the trusted third party gets cold feet. Once it gets bootstrapped, there are so many applications if you could effortlessly pay a few cents to a website as easily as dropping
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/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM47.pdf
Patrick Madden
part 3 of 11 Appendix PM47.pdf
10,694
21,176
different file with a similar name attributed to it, requiring a number to be appended to distinguish between them. This therefore suggests that another file exists, likely named “IDSES~1 .DOC”, but which has not been disclosed. MSWord files: Internal Metadata Timestamps 10. I set out some excerpts from the metadata of ID_004544 below for convenience. File Name IDSDES~2.DOC Internal Created Date 12/04/2009 21:18:00 Internal Last Modified Date 12/04/2009 21:18:00 Internal Last Print - Date 11/04/2009 01:08:00 Revision 2 Edit time (minutes) 2649 Edit time 1day, 20hours, 9 minutes 11. The internal L ast P rinted date of ID_004544 is recorded as 11 April 2009 at 01:08. It is 1 day, 20 hours, and 10 minutes before the recorded internal C reated and M odified timestamps for the document. This is 1 minute more than the recorded E dit time of the document. a. T he fact that the time since printing is longer than the E dit time is not in herently anomalous, because the timestamps in question are recorded with minute- level precision and therefore automatically round up or down to the nearest minute. 5 - 5 - H/289/5{ID_004544} Madden Appendix PM47 Centrebet document Page 6 of 28 b. It is however unusual, in that under normal operating conditions this would require that the document was printed within 1 minute of being created1; c. T he Document would then have had to remain open , and the primary document in focus, for 44 hours and 9 minutes thereafter before being saved.2It was not printed a gain within this time per iod (though it could have been printed after that). 12. The matching C reated and Last Modified internal timestamps , taken together with the Revision C ount of 2 , is typical of a Save -As operation being used to create the document. 13. The use of a Save- As operat ion would typically result in the Edit time being reset as well , at the point of that Save As operating being performed. However, the document has retained the Edit time information . I initially consider ed this to be anomalous. However, I consider it can be explained in the following ways: a. F irst, I note the application name in the document is “Microsoft Office Outlook”. This does not actually indicate that it was edited or created in Microsoft Office Outlook. MS Outlook does not support editing DOCX files. b. In fact, the presence of “Microsoft Office Outlook” as the application name in a docx file is typical of a docx file saved using MS Word 2003 SP3, when installed with the necessary compatibility pack to allow compatibility with DOCX files. (This is an unusual and presumably unintended characteristic of that software.) c. A further unusual characteristic of MS Word 2003 when installed with that compatibility pack, is that conducting a “save as” function to create a DOCX file may not reset the E dit time , unlike with other versions of MS Word. 14. In view of these characteristics I consider ID_004544 to have been saved by the use of a Save As function in MS Word 2003 SP3, with the DOCX compatibility pack installed. 1E ither created as a new document, or by a save -as opera�on from a pre -exis�ng document resul�ng in a reset of the E dit �me . 2T he same approach to edit �me analysis should be taken as explained in detail throughout my main report and in other Appendices (including PM24) and I do not repeat the detail here. Madden Appendix PM47 Centrebet document Page 6 of 28 b. It is however unusual, in that under normal operating conditions this would require that the document was printed within 1 minute of being created1; c. T he Document would then have had to remain open , and the primary document in focus, for 44 hours and 9 minutes thereafter before being saved.2It was not printed a gain within this time per iod (though it could have been printed after that). 12. The matching C reated and Last Modified internal timestamps , taken together with the Revision C ount of 2 , is typical of a Save -As operation being used to create the document. 13. The use of a Save- As operat ion would typically result in the Edit time being reset as well , at the point of that Save As operating being performed. However, the document has retained the Edit time information . I initially consider ed this to be anomalous. However, I consider it can be explained in the following ways: a. F irst, I note the application name in the document is “Microsoft Office Outlook”. This does not actually indicate that it was edited or created in Microsoft Office Outlook. MS Outlook does not support editing DOCX files. b. In fact, the presence of “Microsoft Office Outlook” as the application name in a docx file is typical of a docx file saved using MS Word 2003 SP3, when installed with the necessary compatibility pack to allow compatibility with DOCX files. (This is an unusual and presumably unintended characteristic of that software.) c. A further unusual characteristic of MS Word 2003 when installed with that compatibility pack, is that conducting a “save as” function to create a DOCX file may not reset the E dit time , unlike with other versions of MS Word. 14. In view of these characteristics I consider ID_004544 to have been saved by the use of a Save As function in MS Word 2003 SP3, with the DOCX compatibility pack installed. 1E ither created as a new document, or by a save -as opera�on from a pre -exis�ng document resul�ng in a reset of the E dit �me . 2T he same approach to edit �me analysis should be taken as explained in detail throughout
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 3 of 11 Appendix PM47.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM47.pdf ### File content: different file with a similar name attributed to it, requiring a number to be appended to distinguish between them. This therefore suggests that another file exists, likely named “IDSES~1 .DOC”, but which has not been disclosed. MSWord files: Internal Metadata Timestamps 10. I set out some excerpts from the metadata of ID_004544 below for convenience. File Name IDSDES~2.DOC Internal Created Date 12/04/2009 21:18:00 Internal Last Modified Date 12/04/2009 21:18:00 Internal Last Print - Date 11/04/2009 01:08:00 Revision 2 Edit time (minutes) 2649 Edit time 1day, 20hours, 9 minutes 11. The internal L ast P rinted date of ID_004544 is recorded as 11 April 2009 at 01:08. It is 1 day, 20 hours, and 10 minutes before the recorded internal C reated and M odified timestamps for the document. This is 1 minute more than the recorded E dit time of the document. a. T he fact that the time since printing is longer than the E dit time is not in herently anomalous, because the timestamps in question are recorded with minute- level precision and therefore automatically round up or down to the nearest minute. 5 - 5 - H/289/5{ID_004544} Madden Appendix PM47 Centrebet document Page 6 of 28 b. It is however unusual, in that under normal operating conditions this would require that the document was printed within 1 minute of being created1; c. T he Document would then have had to remain open , and the primary document in focus, for 44 hours and 9 minutes thereafter before being saved.2It was not printed a gain within this time per iod (though it could have been printed after that). 12. The matching C reated and Last Modified internal timestamps , taken together with the Revision C ount of 2 , is typical of a Save -As operation being used to create the document. 13. The use of a Save- As operat ion would typically result in the Edit time being reset as well , at the point of that Save As operating being performed. However, the document has retained the Edit time information . I initially consider ed this to be anomalous. However, I consider it can be explained in the following ways: a. F irst, I note the application name in the document is “Microsoft Office Outlook”. This does not actually indicate that it was edited or created in Microsoft Office Outlook. MS Outlook does not support editing DOCX files. b. In fact, the presence of “Microsoft Office Outlook” as the application name in a docx file is typical of a docx file saved using MS Word 2003 SP3, when installed with the necessary compatibility pack to allow compatibility with DOCX files. (This is an unusual and presumably unintended characteristic of that software.) c. A further unusual characteristic of MS Word 2003 when installed with that compatibility pack, is that conducting a “save as” function to create a DOCX file may not reset the E dit time , unlike with other versions of MS Word. 14. In view of these characteristics I consider ID_004544 to have been saved by the use of a Save As function in MS Word 2003 SP3, with the DOCX compatibility pack installed. 1E ither created as a new document, or by a save -as opera�on from a pre -exis�ng document resul�ng in a reset of the E dit �me . 2T he same approach to edit �me analysis should be taken as explained in detail throughout my main report and in other Appendices (including PM24) and I do not repeat the detail here. Madden Appendix PM47 Centrebet document Page 6 of 28 b. It is however unusual, in that under normal operating conditions this would require that the document was printed within 1 minute of being created1; c. T he Document would then have had to remain open , and the primary document in focus, for 44 hours and 9 minutes thereafter before being saved.2It was not printed a gain within this time per iod (though it could have been printed after that). 12. The matching C reated and Last Modified internal timestamps , taken together with the Revision C ount of 2 , is typical of a Save -As operation being used to create the document. 13. The use of a Save- As operat ion would typically result in the Edit time being reset as well , at the point of that Save As operating being performed. However, the document has retained the Edit time information . I initially consider ed this to be anomalous. However, I consider it can be explained in the following ways: a. F irst, I note the application name in the document is “Microsoft Office Outlook”. This does not actually indicate that it was edited or created in Microsoft Office Outlook. MS Outlook does not support editing DOCX files. b. In fact, the presence of “Microsoft Office Outlook” as the application name in a docx file is typical of a docx file saved using MS Word 2003 SP3, when installed with the necessary compatibility pack to allow compatibility with DOCX files. (This is an unusual and presumably unintended characteristic of that software.) c. A further unusual characteristic of MS Word 2003 when installed with that compatibility pack, is that conducting a “save as” function to create a DOCX file may not reset the E dit time , unlike with other versions of MS Word. 14. In view of these characteristics I consider ID_004544 to have been saved by the use of a Save As function in MS Word 2003 SP3, with the DOCX compatibility pack installed. 1E ither created as a new document, or by a save -as opera�on from a pre -exis�ng document resul�ng in a reset of the E dit �me . 2T he same approach to edit �me analysis should be taken as explained in detail throughout
1,537
/content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
Closings
part 131 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
236,795
438,889
{Day9/43:1- 11} Q. Now, the way it was presented was that C01N had provided you with a computer and software, and Hotwire, with a printer, payment for hours worked and superannuation, all on an independent contractor basis, not on an employment basis; do you understand? Dr Pang confirms that he believed he was working on an employment basis, not an independent contractor basis. Appendix B: Schedule of Transcript References 327 REFERENCE QUOTE COMMENT A. I believe it was on an employment basis, as far as I understand. I received a printer, which I' ve got, I've received laptop, but I don't recall any software at all that I have got a physical or digital copy of. The only access to any software was the Xero accounting software that I use online. {Day9/43:17} - {Day9/44:3} Q. Page 50, please {L11/363/50}, of the document - actually, page 49 {L11/363/49}. There is a whole section of the report concerned with R&D tax offsets in relation to you, and at paragraph 246, over the page {L11/363/50}, the ATO said that the taxpayer had provided - so that's C01N - had provided contradictory accounts about whether Dr Pang was a contractor or employee and how Dr Pang was paid, including from Dr Pang himsel f, and your position is that you were an employee and certainly didn't receive any licences in payment; correct? A. Correct. Dr Pang again confirms that he believed he was an employee and that he did not receive any licences in payment. CROSS - EXAMINAT ION OF MR ROBERT JENKINS BY JONATHAN MOSS {L2/102/3} Dr Wright’s BDO CV dated 2 May 2007 {Day9/49:20} - {Day9/50:2} Q. Now, back at the beginning of paragraph 11, you use the phrased "genesis log entry", but there are no documents attached to your statement, nor any other documents that COPA can find in these - what has been disclosed in these proceedings that refer to this term being used. Do you accept there are no documents that record that specific term? A. That's correct. Mr Jenkins accepts there are no documents with the term “genesis log entry” in these proceedings. {E/6} First Witness Statement of Robert Jenkins {Day9/53:3} - {Day9/54:2} Q. You last saw this firewall up close and personal, so to speak, I presume in June 2000, when you left Vodafone; is that right? A. That’s correct, yes. Q. So your memory of the technical details is now nearly 24 years old; is that right? A. You could say that, yes. Q. Let's just unpick a little bit of what you say in that paragraph bearing in mind that considerable lapse of time. You say the entries each had their own identifier; is that right? A. That's correct, row number 1, row number 2, row number 3, etc. Mr Jenkins provides a description of the log system created by Dr Wright, which appears very basic. Appendix B: Schedule of Transcript References 328 REFERENCE QUOTE COMMENT Q. You have taken my next question away from me, Mr Jenkins. So the first entry would have be en, say, 1; the second entry, 2; the third, 3, so on and so on; is that right? A. That's correct, yes. Q. So what was being in effect created was a sequential database? A. Not really. You could - you could refer to it as a - like a text file rather than a database. A "database" has other connotations. But, yes, certainly a text file. {Day9/54:16} - {Day9/56:9} Q. And then it’s in paragraph 16 that you talk about “eGold” {E/6/5}, and you say this would have been in the period 2000 to 2001; is that right? A. Around 2000/2001/2, around that period; correct. Q. You say in your statement, in fairness to you: “This would have been in the period ... 2000- 2002.” Correct? That’s the top - A. That’s correct. Q. -- the top of paragraph 16. And then, if we just look at the second sentence of paragraph 16, you say it was before eBay and before PayPal - I'll read the entire two sentences out: "So when I was working at COMindico, I remember Craig and I talked about eGold. This would have been in the period ... 2000- 2002. It was before eBay and before PayPal and buying stuff online and paying for it was incredibly difficult ..." So you say there that - and we're in the period 2000 to 2002, that this was before eBay and PayPal; correct? A. Before eBay and PayPal was readily available in Australia, that's correct. Q. Right. Now, eBay launched in 1995, didn't it, Mr Jenkins? A. It could well have launched in 1995. Whether it was ubiquitous and readily available in Australia is a different matter. Q. And PayPal launched in 1998, and indeed it had its IPO in February 2002, and eBay bought PayPal in October 2002. Your statement here says "this was before eBay and before PayP al", but that can't be correct, so what are you actually saying in this sentence, Mr Jenkins? A. What I'm saying here is that whilst eBay might have been available and other online platforms available to pay for something online, there wasn't an easy mean s of paying for things like what the service that PayPal provides, and the only option, and it goes on in that paragraph to say essentially there When questioned about the availability of eBay and Paypal in Australia before 2000, Mr Jenkins clarifies that he meant before they were “readily” av ailable, the wording of which is not reflected at paragraph 16 of his witness statement. Appendix B: Schedule of Transcript References 329 REFERENCE QUOTE COMMENT is only at the time an escrow - like service that was available at that time in Australia. Q. Okay, well, tha t wasn't very clearly originally, but we understand now what your evidence is on that point. A. Apologies. {Day9/58:12} - {Day9/59:5} Q. Mr Jenkins, could we please look at the tenth page of your statement now {E/6/10}. These are the four documents that are supported in your witness statement. These are the documents that you were shown when you prepared this statement and you will note that the first of those is the transcript that I've just taken you to. Do you accept that you read this transcript before giving - before this witness statement in these proceedings was finalised? A. Interesting you say that, because I was never sent
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 131 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: {Day9/43:1- 11} Q. Now, the way it was presented was that C01N had provided you with a computer and software, and Hotwire, with a printer, payment for hours worked and superannuation, all on an independent contractor basis, not on an employment basis; do you understand? Dr Pang confirms that he believed he was working on an employment basis, not an independent contractor basis. Appendix B: Schedule of Transcript References 327 REFERENCE QUOTE COMMENT A. I believe it was on an employment basis, as far as I understand. I received a printer, which I' ve got, I've received laptop, but I don't recall any software at all that I have got a physical or digital copy of. The only access to any software was the Xero accounting software that I use online. {Day9/43:17} - {Day9/44:3} Q. Page 50, please {L11/363/50}, of the document - actually, page 49 {L11/363/49}. There is a whole section of the report concerned with R&D tax offsets in relation to you, and at paragraph 246, over the page {L11/363/50}, the ATO said that the taxpayer had provided - so that's C01N - had provided contradictory accounts about whether Dr Pang was a contractor or employee and how Dr Pang was paid, including from Dr Pang himsel f, and your position is that you were an employee and certainly didn't receive any licences in payment; correct? A. Correct. Dr Pang again confirms that he believed he was an employee and that he did not receive any licences in payment. CROSS - EXAMINAT ION OF MR ROBERT JENKINS BY JONATHAN MOSS {L2/102/3} Dr Wright’s BDO CV dated 2 May 2007 {Day9/49:20} - {Day9/50:2} Q. Now, back at the beginning of paragraph 11, you use the phrased "genesis log entry", but there are no documents attached to your statement, nor any other documents that COPA can find in these - what has been disclosed in these proceedings that refer to this term being used. Do you accept there are no documents that record that specific term? A. That's correct. Mr Jenkins accepts there are no documents with the term “genesis log entry” in these proceedings. {E/6} First Witness Statement of Robert Jenkins {Day9/53:3} - {Day9/54:2} Q. You last saw this firewall up close and personal, so to speak, I presume in June 2000, when you left Vodafone; is that right? A. That’s correct, yes. Q. So your memory of the technical details is now nearly 24 years old; is that right? A. You could say that, yes. Q. Let's just unpick a little bit of what you say in that paragraph bearing in mind that considerable lapse of time. You say the entries each had their own identifier; is that right? A. That's correct, row number 1, row number 2, row number 3, etc. Mr Jenkins provides a description of the log system created by Dr Wright, which appears very basic. Appendix B: Schedule of Transcript References 328 REFERENCE QUOTE COMMENT Q. You have taken my next question away from me, Mr Jenkins. So the first entry would have be en, say, 1; the second entry, 2; the third, 3, so on and so on; is that right? A. That's correct, yes. Q. So what was being in effect created was a sequential database? A. Not really. You could - you could refer to it as a - like a text file rather than a database. A "database" has other connotations. But, yes, certainly a text file. {Day9/54:16} - {Day9/56:9} Q. And then it’s in paragraph 16 that you talk about “eGold” {E/6/5}, and you say this would have been in the period 2000 to 2001; is that right? A. Around 2000/2001/2, around that period; correct. Q. You say in your statement, in fairness to you: “This would have been in the period ... 2000- 2002.” Correct? That’s the top - A. That’s correct. Q. -- the top of paragraph 16. And then, if we just look at the second sentence of paragraph 16, you say it was before eBay and before PayPal - I'll read the entire two sentences out: "So when I was working at COMindico, I remember Craig and I talked about eGold. This would have been in the period ... 2000- 2002. It was before eBay and before PayPal and buying stuff online and paying for it was incredibly difficult ..." So you say there that - and we're in the period 2000 to 2002, that this was before eBay and PayPal; correct? A. Before eBay and PayPal was readily available in Australia, that's correct. Q. Right. Now, eBay launched in 1995, didn't it, Mr Jenkins? A. It could well have launched in 1995. Whether it was ubiquitous and readily available in Australia is a different matter. Q. And PayPal launched in 1998, and indeed it had its IPO in February 2002, and eBay bought PayPal in October 2002. Your statement here says "this was before eBay and before PayP al", but that can't be correct, so what are you actually saying in this sentence, Mr Jenkins? A. What I'm saying here is that whilst eBay might have been available and other online platforms available to pay for something online, there wasn't an easy mean s of paying for things like what the service that PayPal provides, and the only option, and it goes on in that paragraph to say essentially there When questioned about the availability of eBay and Paypal in Australia before 2000, Mr Jenkins clarifies that he meant before they were “readily” av ailable, the wording of which is not reflected at paragraph 16 of his witness statement. Appendix B: Schedule of Transcript References 329 REFERENCE QUOTE COMMENT is only at the time an escrow - like service that was available at that time in Australia. Q. Okay, well, tha t wasn't very clearly originally, but we understand now what your evidence is on that point. A. Apologies. {Day9/58:12} - {Day9/59:5} Q. Mr Jenkins, could we please look at the tenth page of your statement now {E/6/10}. These are the four documents that are supported in your witness statement. These are the documents that you were shown when you prepared this statement and you will note that the first of those is the transcript that I've just taken you to. Do you accept that you read this transcript before giving - before this witness statement in these proceedings was finalised? A. Interesting you say that, because I was never sent
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/content/Copa v Wright - Trial Documents/Skeletons/Openings/Developers' Skeleton Argument IL-2022-000069 (Trial commencing 5 February 2024).pdf
Openings
part 13 of 37 Developers' Skeleton Argument IL-2022-000069 (Trial commencing 5 February 2024).pdf
35,151
73,420
daughters at {L9/382/42} ¶230. Dr Wright’s tactless response (at {L13/452/27}) was that Professor Rees’ daughters did not know everything that Professor Rees did. b) Changing stories to meet revised circumstances: a notable example of that was Dr Wright’s change of tack from saying that his companies issued shares in return for bitcoins to asserting that only equitable interests in bitcoins held overseas by the Tulip Trust were transferred in return for the issue of shares: see paragraphs 22 to 23 of Appendix 1. That change came on 18 February 2014 shortly after the ruling at paragraph 18.b) of Appendix 1 that GST would be payable on such a subscription. c) Unsubstantiated claims in relation to the holding of Bitcoin addresses: Dr Wright was unable to prove his ownership or control of relevant addresses 102 {L10/68}. 103 One by Alan Batey dated 11 November 2015 at {L11/1} and another by Dr Nick Sharples dated 17 November 2015 at {L10/493}. 104 See {L9/382/49} at ¶¶263-265. 34 and asserted ownership of an address that was not his: see paragraph 43 of Appendix 1. d) The deployment of unlikely and back-dated documents: see paragraphs 29 to 37, 44 to 46 and 50 of Appendix 1. As noted at paragraph 34 of Appendix 1, Dr Wright admitted to back-dating some of the invoices. e) The production of fake emails to support his account of events: see paragraphs 32.d) and 52.b) of Appendix 1. As will be seen below, in the Kleiman proceedings Dr Wright generally disclaimed reliance on many of the emails that he had previously presented to the ATO. f) Pseudo-technical explanations that lacked substance: see paragraphs 32.c), 46 and 50.a) of Appendix 1. This included the ATO raising concern at script being run that may have been designed to produce inauthentic content which bears the indicia of a staged-controlled demonstration: see paragraph 46.c) of Appendix 1. 3. The Kleiman proceedings 94. Carter Conrad Jr (David Kleiman’s business partner) sent an email to a number of David Kleiman’s friends on 29 April 2013 advising them of David Kleiman’s death.105 Dr Wright responded shortly afterwards saying that David Kleiman would be missed.106 95. Ten months later, on 11 February 2014, Dr Wright sent an unsolicited email to David Kleiman’s father, Louis Kleiman. In that email he stated that “Your son Dave and I are two of the three key people behind Bitcoin” and invited Mr Kleiman to save a file named “wallet.dat”.107 96. So was set in motion a chain of events which led to proceedings being commenced by W&KID and the estate of David Kleiman against Dr Wright. Those proceedings were commenced on 14 February 2018 on the footing that Dr Wright and David Kleiman were involved in Bitcoin from its inception and both accumulated a vast wealth of 105 {L17/368/60}. 106 {L17/368/66}. 107 {L8/349/1}. 35 bitcoins from 2009 through to 2013 together with valuable intellectual property, but which Dr Wright had (in effect) stolen from David Kleiman108 (including through the NSW proceedings).109 97. It is convenient to take the story of the Kleiman proceedings in two parts. First, addressing the nature of Dr Wright’s initial contact with the Kleiman family. Second, addressing the nature of the proceedings and the somewhat skewed question that it fell to the jury to decide. a. The initial dealings between Dr Wright and the Kleiman family 98. Dr Wright’s initial contact with Louis Kleiman on 11 February 2014 seems to have coincided with two events. a) First, Dr Wright’s introduction by Stefan Matthews to Rob Macgregor. That introduction was made on 3 February 2014.110 A follow up call with Mr Macgregor regarding bitcoin processing and trading seems to have taken place the following day.111 b) Second, a step-up in the audits being undertaken by the ATO in relation to Dr Wright’s claims for repayment of GST. As noted at paragraph 23 of Appendix 1, a meeting had been scheduled for 18 February 2014. Ahead of that meeting Clayton Utz had prepared a presentation which referred to: i) “R&D Conducted in US in conjunction with David Kleiman, a JVCo former as W&K Info Defense Research LLC”112 (although no such R&D had been conducted: see paragraphs 71 to 73 above) and relied on the Consent Orders in the NSW proceedings.113 ii) A new explanation of the manner in which Bitcoin had been used in the subscription for shares, which depended upon the existence of a supposed offshore trust: see paragraph 23 of Appendix 1. 108 {L14/114/3} at ¶¶4-12. 109 {L14/114/25} at ¶90 et seq. 110 {L8/340/2}: Mr Matthews suggested that Dr Wright had been focussed on designing a payment processing solution for the gambling and porn sectors based around a bitcoin trading platform. 111 {L8/343/1}. 112 {L8/326/6}. 113 {L8/326/8}. 36 99. A few points stand out from Dr Wright’s dealings with the Kleiman family from February 2014: a) First, Dr Wright initially suggested that he and David Kleiman were two of three key people behind Bitcoin.114 In due course, it emerged that the supposed third person that Dr Wright suggested was “behind Bitcoin” was Gareth Williams, the junior analyst at GCHQ who had been found dead in a sports holdall in the bath in his flat in Pimlico on 23 August 2010.115 There is no record of any dealings between Dr Wright and Mr Williams. In Dr Wright’s deposition in the Kleiman proceedings he asserted that he had spoken to Mr Williams during a videoconference sometime in 2011, several months after Mr Williams had died.116 So was repeated Dr Wright’s reliance upon implausible dealings with the recently deceased. b) Second, Dr Wright advised Ira Kleiman that David Kleiman controlled the [email protected] email account, whereas he, Dr Wright, controlled the [email protected] account.117
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 13 of 37 Developers' Skeleton Argument IL-2022-000069 (Trial commencing 5 February 2024).pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/Developers' Skeleton Argument IL-2022-000069 (Trial commencing 5 February 2024).pdf ### File content: daughters at {L9/382/42} ¶230. Dr Wright’s tactless response (at {L13/452/27}) was that Professor Rees’ daughters did not know everything that Professor Rees did. b) Changing stories to meet revised circumstances: a notable example of that was Dr Wright’s change of tack from saying that his companies issued shares in return for bitcoins to asserting that only equitable interests in bitcoins held overseas by the Tulip Trust were transferred in return for the issue of shares: see paragraphs 22 to 23 of Appendix 1. That change came on 18 February 2014 shortly after the ruling at paragraph 18.b) of Appendix 1 that GST would be payable on such a subscription. c) Unsubstantiated claims in relation to the holding of Bitcoin addresses: Dr Wright was unable to prove his ownership or control of relevant addresses 102 {L10/68}. 103 One by Alan Batey dated 11 November 2015 at {L11/1} and another by Dr Nick Sharples dated 17 November 2015 at {L10/493}. 104 See {L9/382/49} at ¶¶263-265. 34 and asserted ownership of an address that was not his: see paragraph 43 of Appendix 1. d) The deployment of unlikely and back-dated documents: see paragraphs 29 to 37, 44 to 46 and 50 of Appendix 1. As noted at paragraph 34 of Appendix 1, Dr Wright admitted to back-dating some of the invoices. e) The production of fake emails to support his account of events: see paragraphs 32.d) and 52.b) of Appendix 1. As will be seen below, in the Kleiman proceedings Dr Wright generally disclaimed reliance on many of the emails that he had previously presented to the ATO. f) Pseudo-technical explanations that lacked substance: see paragraphs 32.c), 46 and 50.a) of Appendix 1. This included the ATO raising concern at script being run that may have been designed to produce inauthentic content which bears the indicia of a staged-controlled demonstration: see paragraph 46.c) of Appendix 1. 3. The Kleiman proceedings 94. Carter Conrad Jr (David Kleiman’s business partner) sent an email to a number of David Kleiman’s friends on 29 April 2013 advising them of David Kleiman’s death.105 Dr Wright responded shortly afterwards saying that David Kleiman would be missed.106 95. Ten months later, on 11 February 2014, Dr Wright sent an unsolicited email to David Kleiman’s father, Louis Kleiman. In that email he stated that “Your son Dave and I are two of the three key people behind Bitcoin” and invited Mr Kleiman to save a file named “wallet.dat”.107 96. So was set in motion a chain of events which led to proceedings being commenced by W&KID and the estate of David Kleiman against Dr Wright. Those proceedings were commenced on 14 February 2018 on the footing that Dr Wright and David Kleiman were involved in Bitcoin from its inception and both accumulated a vast wealth of 105 {L17/368/60}. 106 {L17/368/66}. 107 {L8/349/1}. 35 bitcoins from 2009 through to 2013 together with valuable intellectual property, but which Dr Wright had (in effect) stolen from David Kleiman108 (including through the NSW proceedings).109 97. It is convenient to take the story of the Kleiman proceedings in two parts. First, addressing the nature of Dr Wright’s initial contact with the Kleiman family. Second, addressing the nature of the proceedings and the somewhat skewed question that it fell to the jury to decide. a. The initial dealings between Dr Wright and the Kleiman family 98. Dr Wright’s initial contact with Louis Kleiman on 11 February 2014 seems to have coincided with two events. a) First, Dr Wright’s introduction by Stefan Matthews to Rob Macgregor. That introduction was made on 3 February 2014.110 A follow up call with Mr Macgregor regarding bitcoin processing and trading seems to have taken place the following day.111 b) Second, a step-up in the audits being undertaken by the ATO in relation to Dr Wright’s claims for repayment of GST. As noted at paragraph 23 of Appendix 1, a meeting had been scheduled for 18 February 2014. Ahead of that meeting Clayton Utz had prepared a presentation which referred to: i) “R&D Conducted in US in conjunction with David Kleiman, a JVCo former as W&K Info Defense Research LLC”112 (although no such R&D had been conducted: see paragraphs 71 to 73 above) and relied on the Consent Orders in the NSW proceedings.113 ii) A new explanation of the manner in which Bitcoin had been used in the subscription for shares, which depended upon the existence of a supposed offshore trust: see paragraph 23 of Appendix 1. 108 {L14/114/3} at ¶¶4-12. 109 {L14/114/25} at ¶90 et seq. 110 {L8/340/2}: Mr Matthews suggested that Dr Wright had been focussed on designing a payment processing solution for the gambling and porn sectors based around a bitcoin trading platform. 111 {L8/343/1}. 112 {L8/326/6}. 113 {L8/326/8}. 36 99. A few points stand out from Dr Wright’s dealings with the Kleiman family from February 2014: a) First, Dr Wright initially suggested that he and David Kleiman were two of three key people behind Bitcoin.114 In due course, it emerged that the supposed third person that Dr Wright suggested was “behind Bitcoin” was Gareth Williams, the junior analyst at GCHQ who had been found dead in a sports holdall in the bath in his flat in Pimlico on 23 August 2010.115 There is no record of any dealings between Dr Wright and Mr Williams. In Dr Wright’s deposition in the Kleiman proceedings he asserted that he had spoken to Mr Williams during a videoconference sometime in 2011, several months after Mr Williams had died.116 So was repeated Dr Wright’s reliance upon implausible dealings with the recently deceased. b) Second, Dr Wright advised Ira Kleiman that David Kleiman controlled the [email protected] email account, whereas he, Dr Wright, controlled the [email protected] account.117
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version, which was both on their Unix and their VMS machines; Solaris, which w as my preferred one, had its own version; IBM had its own version; and then these were taken and integrated into Linux and the ANSI free version. So the original was that sleep/sleep_for, etc, was actually in other versions of C. Q. And in addition, your claim must be that you happen to have come up with the name spacing "std::chrono", and the class type milliseconds and the identical syntax which was later proposed and used in the actual Chrono time library, right? A. No, actually, "standard" means it's a standard library. So as I explained in my witness statement, you can embed any standard library that you want. I was a - - as it says on Integyrs, my company, I created custom libraries. So if you look at the 2009 web page that I had from that, I created custom libraries. This is also on my Ridge Estates findings going back to 2001/2/3. Now, on top of this, what he's saying there is, this is Appendix B: Schedule of Transcript References 144 REFERENCE QUOTE COMMENT standard "::". The "::" is a standard C++ format going back to the beginning of C, not C++. On top of that, "millis econds" is a standard term for milliseconds, and that isn't a standard way of writing, it is one particular out of an unbounded way of listing them. So all you're saying is, that function has milliseconds. A simulation package where you're actually simulating different node agents has time, yes. Q. This is a syntax of a kind which would classically be used in the true Chrono library, isn't it, Dr Wright? A. Actually, no. If we look, once again, "nextState.pow", "nextState.pow", "nextState.pow" and "int total_pow [equals]", what we have is a simulation. So we have taken a simulation system and we are creating a state - based simulate. Like, I was talking earlier, my Lord, in this week about how we had state - based systems where state 1, state 2, state 3 is effectively the hash chain, where you have competitions if there is an orphan fork, ie you have two miners or nodes discover at the same time. Now to simulate that, what I was doing at the time was going, if we have two honest miners and one dishonest min er, then I could simulate that. Now, in here we have "pow", being the amount of proof - of - work, so that I could look at the differences and say where this would occur so I could actually figure out whether I was right in my idea of a byzantine general problem. Q. Once again, Dr Wright, I'm going to put to you that that is, as the creator of the Chrono library has said in relation to this document, nonsense, and he will address it in cross - examination, if it's put to him. {Day5/119:21} - {Day5/120/8} {L1/169/1} "Honest2.C++" ID_004713 {PTR - F/70/1} Q. And once again, the same references to "chrono" and "random", and on the basis of those, I put to you that this is another forged document? A. No. I've been developing random number generation algorithms since the '80s. Now, one of the main functions o f being in gaming, which I was, I don't think anyone's disputing that, is, my Lord, you have to have very secure random number generation. So I've been writing random number generators for a long time. I wrote them for Lasseter's, MGM Grand, Playboy Gaming , GCS, Centrebet, Sportingbet. I can keep going on, if you like, but we'll just go through the list of casinos I've worked with. Dr Wright claiming that anachronistic references to terms associated with C++ were related to his own supposed development of random number generation algorithms. Overleaf LaTeX Files {Day5/122:21} - {Day5/123:14} I think you're aware of this as a post by Mr Ager - Hanssen in which he claimed that your browsing history showed you accessing an online Q&A, with the heading on the page, "Was Dr Wright claiming to have shown Shoosmiths the files Appendix B: Schedule of Transcript References 145 REFERENCE QUOTE COMMENT anything in Satoshi Nakamoto's original Bitcoin paper compiled in LaTeX?". Yes? You see that? A. I do. Q. You did in fact access that site, as shown, in September 2023, didn't you? A. Yes, as he captured. The reason being that - - Q. I'm jus t at the moment asking you whether you accessed that site, Dr Wright. A. Yes, I did. Q. Then, it was on 27 November 2023, wasn't it, that your solicitors, by then Shoosmiths, for the first time said that you had some files on the Overleaf web - based LaTeX editor which were relevant to this case? A. I don't know when they told you. I had already shown Shoosmiths in September, I believe it was. associated with the Overleaf based LaTeX editor in September, despite the fact that they were first revealed to COPA on 27 November 2023. This was subsequently contradicted by Shoosmiths, who, in response to Bird & Bird’s query, confirmed that demonstrations took place in October and November 2023, but did not confirm that they were shown the files in September 2023, or that any demonstrations took place that month, see {M/3/15}, {M/3/48} (and in fact could not have, as Shoosmiths were not instructed until the beginning of October, per {M/3/48}). {Day5/125:7} - {Day5/126:21} A. To make it clear, the use of the US litigation disclosure fell into thi s. There wasn't another disclosure exercise. There probably should have been, but what happened was the 2019 capture and disclosure, and the subsequent 2020 one, for the US case, was reused in this. Q. I'm going to proceed carefully because of privilege. But we'll get back to this conversation later. Paragraph 17, Shoosmiths record that you told them that a folder entitled "Bitcoin" was on the Overleaf editor containing certain LaTeX files. And then they write this: "We understand from our client that reve rse - engineering of LaTeX code which so precisely reproduces the White Paper from the published PDF versions of the White Paper would be practically infeasible ..." Do you see that? A. I do. Q. So your position then was that LaTeX files of yours in the Bitcoin folder on Overleaf precisely reproduced the White Paper? Dr Wright admits failings in the disclosure exercise
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 58 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: version, which was both on their Unix and their VMS machines; Solaris, which w as my preferred one, had its own version; IBM had its own version; and then these were taken and integrated into Linux and the ANSI free version. So the original was that sleep/sleep_for, etc, was actually in other versions of C. Q. And in addition, your claim must be that you happen to have come up with the name spacing "std::chrono", and the class type milliseconds and the identical syntax which was later proposed and used in the actual Chrono time library, right? A. No, actually, "standard" means it's a standard library. So as I explained in my witness statement, you can embed any standard library that you want. I was a - - as it says on Integyrs, my company, I created custom libraries. So if you look at the 2009 web page that I had from that, I created custom libraries. This is also on my Ridge Estates findings going back to 2001/2/3. Now, on top of this, what he's saying there is, this is Appendix B: Schedule of Transcript References 144 REFERENCE QUOTE COMMENT standard "::". The "::" is a standard C++ format going back to the beginning of C, not C++. On top of that, "millis econds" is a standard term for milliseconds, and that isn't a standard way of writing, it is one particular out of an unbounded way of listing them. So all you're saying is, that function has milliseconds. A simulation package where you're actually simulating different node agents has time, yes. Q. This is a syntax of a kind which would classically be used in the true Chrono library, isn't it, Dr Wright? A. Actually, no. If we look, once again, "nextState.pow", "nextState.pow", "nextState.pow" and "int total_pow [equals]", what we have is a simulation. So we have taken a simulation system and we are creating a state - based simulate. Like, I was talking earlier, my Lord, in this week about how we had state - based systems where state 1, state 2, state 3 is effectively the hash chain, where you have competitions if there is an orphan fork, ie you have two miners or nodes discover at the same time. Now to simulate that, what I was doing at the time was going, if we have two honest miners and one dishonest min er, then I could simulate that. Now, in here we have "pow", being the amount of proof - of - work, so that I could look at the differences and say where this would occur so I could actually figure out whether I was right in my idea of a byzantine general problem. Q. Once again, Dr Wright, I'm going to put to you that that is, as the creator of the Chrono library has said in relation to this document, nonsense, and he will address it in cross - examination, if it's put to him. {Day5/119:21} - {Day5/120/8} {L1/169/1} "Honest2.C++" ID_004713 {PTR - F/70/1} Q. And once again, the same references to "chrono" and "random", and on the basis of those, I put to you that this is another forged document? A. No. I've been developing random number generation algorithms since the '80s. Now, one of the main functions o f being in gaming, which I was, I don't think anyone's disputing that, is, my Lord, you have to have very secure random number generation. So I've been writing random number generators for a long time. I wrote them for Lasseter's, MGM Grand, Playboy Gaming , GCS, Centrebet, Sportingbet. I can keep going on, if you like, but we'll just go through the list of casinos I've worked with. Dr Wright claiming that anachronistic references to terms associated with C++ were related to his own supposed development of random number generation algorithms. Overleaf LaTeX Files {Day5/122:21} - {Day5/123:14} I think you're aware of this as a post by Mr Ager - Hanssen in which he claimed that your browsing history showed you accessing an online Q&A, with the heading on the page, "Was Dr Wright claiming to have shown Shoosmiths the files Appendix B: Schedule of Transcript References 145 REFERENCE QUOTE COMMENT anything in Satoshi Nakamoto's original Bitcoin paper compiled in LaTeX?". Yes? You see that? A. I do. Q. You did in fact access that site, as shown, in September 2023, didn't you? A. Yes, as he captured. The reason being that - - Q. I'm jus t at the moment asking you whether you accessed that site, Dr Wright. A. Yes, I did. Q. Then, it was on 27 November 2023, wasn't it, that your solicitors, by then Shoosmiths, for the first time said that you had some files on the Overleaf web - based LaTeX editor which were relevant to this case? A. I don't know when they told you. I had already shown Shoosmiths in September, I believe it was. associated with the Overleaf based LaTeX editor in September, despite the fact that they were first revealed to COPA on 27 November 2023. This was subsequently contradicted by Shoosmiths, who, in response to Bird & Bird’s query, confirmed that demonstrations took place in October and November 2023, but did not confirm that they were shown the files in September 2023, or that any demonstrations took place that month, see {M/3/15}, {M/3/48} (and in fact could not have, as Shoosmiths were not instructed until the beginning of October, per {M/3/48}). {Day5/125:7} - {Day5/126:21} A. To make it clear, the use of the US litigation disclosure fell into thi s. There wasn't another disclosure exercise. There probably should have been, but what happened was the 2019 capture and disclosure, and the subsequent 2020 one, for the US case, was reused in this. Q. I'm going to proceed carefully because of privilege. But we'll get back to this conversation later. Paragraph 17, Shoosmiths record that you told them that a folder entitled "Bitcoin" was on the Overleaf editor containing certain LaTeX files. And then they write this: "We understand from our client that reve rse - engineering of LaTeX code which so precisely reproduces the White Paper from the published PDF versions of the White Paper would be practically infeasible ..." Do you see that? A. I do. Q. So your position then was that LaTeX files of yours in the Bitcoin folder on Overleaf precisely reproduced the White Paper? Dr Wright admits failings in the disclosure exercise
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had accepted instructions to be an expert, an independent expert in this case? A. I do not think that's the case. Appendix B: Schedule of Transcript References 545 REFERENCE QUOTE COMMENT DAY 19 CROSS -EXAMINATION OF DR CRAIG STEVEN WRIGHT BY MR HOUGH KC {Day19/8:2} - {Day19/9:3} Q. You're also aware, I believe, that Ontier sent an email to your current solicitors, Shoosmiths, that day, February, disputing that version and saying that you first provided them with log -in details on 9 March. Are you aware of that communication? A. I am. Q. Are you also awa re that Shoosmiths passed on Ontier's response by letter to COPA and the developers on the following day, 9 February? A. I am. Q. Do you recall that Ontier's version was put to you on Day 5 of this trial {Day5/46:25}, 9 February, and you disputed it saying , and I quote?: "... I have the emails in disclosure stating that they ..."That's Ontier:"... had access [to MYOB] from 2019." A. I do. Q. Do you recall you were questioned again on the topic when you were called to give evidence on Day 15, last Friday, th e 23rd? A. I do. Q. And you repeated that Ontier had received log- in details in late 2019. A. Yes. Q. And you said that you had the emails to prove that? A. I do. Dr Wright continues to maintain that he has the emails to prove that he had received log- in details in late 2019, despite the documents provided having been found by Mr Madden to be inauthentic or manipulated. Chain of three emails dated 2 December 2019 from Dr Wright to Simon Cohen at Ontier {X/59/1} {Day19/9:13} – {Day19/10:1} Q. May we now go back in time to late 2019 and have on screen {X/59/1}. We see here a chain of three emails, dated 2 December 2019, and if we look at the bottom of the page, an email from you to Simon Cohen at Ontier, 2 nd December Dr Wr ight accepting that the old email (the first one in the chain), is genuine. Appendix B: Schedule of Transcript References 546 REFERENCE QUOTE COMMENT 2019, 12.38, with the title, "... Old ID Email" and the text just "Attached"; do you see that? A. I do. Q. You sent an email on that date at that time with that text, didn't you? A. I believe so, yes. Q. And what was attached, is this right, was a chain of emails with your Australian lawyers concerning your company Information Defense? A. Yes. {Day19/10:10} - {Day19/11:17} Q. Then, at the top of the page, we see an email from you, [email protected], 2 December 2019, 15.56, addressed to Simon Cohen, subject line, "... Old ID Email", and "image002.png" attachment; do you see that? A. I do. Q. And the text says: "An old Inform ation defense file about the IP. "Including Blacknet. "To my lawyer in Au. "I will waive privilege with Michael." Do you see that? A. I do. Q. And that, too, was a genuine email sent from you to Mr Cohen on that date, wasn't it? A. It is. Q. So, this exchange of emails took place on 2 December 2019 and what we are seeing here is a genuine exchange of emails? A. It's not the entirety, no. Q. Is this a genuine exchange of emails? A. It's a partial exchange of the emails. There are other parts. Q. What do you say are the other parts? A. There was a later follow -up, and on 5 March, there was a follow -up from Oliver Cain, who noted that AlixPartners had started, but not completed, the report, which was based on MYOB. Q. That wasn 't a document that was disclosed by your lawyers and explained on Monday, was it? A. No, it's not. Q. You're aware, aren't you, that Mr Cohen is no longer at Ontier? A. I am. Dr Wright’s response in relation to a genuine exchange of emails is evasive, and the 5 March follow -up from Oliver Cain was not provided; the inference is clear that it does not exist and is another fabrication. Appendix B: Schedule of Transcript References 547 REFERENCE QUOTE COMMENT Chain of emails dated 18 February 2024 {X/56/1} {Day19/12:19} - {Day19/13:3} Q. Now, it's right, isn't it, that, as Lord Grabiner explained on Monday, the email at the top of that chain was a genuine email sent from your wife to the solicitors at Shoosmiths? A. I believe so. I didn't send it, but I know she sent one. Q. And the previous email in the chain, the one at the bottom of the page, was a genuine email from you to your wife, wasn't it? A. Yes, I forwarded an email. Dr Wright is evasive regarding whether the email to Shoosmiths is genuine, and evasive as to his own involvement in it being sent to them. Email document attached to Ms Watts email to Shoosmiths dated 18 February 2024 email sent by Dr Wright to Ontier on 2 December 2019 {Day19/13:4} – {Day19/13:19} {X/56/2} Q. {X/56/2}, please. Now, this is the email document attached to Ms Watts email to Shoosmiths of 18 February 2024, timed at 12.56, right? A. Looks like it, yes. Q. And you had sent that document to your wife for onward transmission to Shoosmiths by you r email to her of 18 February ‘24 at 11.39, right? A. Well, I sent it to my wife. I wasn’t involved in the forwarding. Q. But you intended that it be transmitted onward to Shoosmiths; correct? A. No, my wife thought it would be a good idea to send it to them. Q. You knew that’s what she was doing? A. She told me that she was going to and I didn’t object. Dr Wright blames his wife in relation to onward transmission of the email document to Shoosmiths. {Day19/13:25 } – {Day19/14:24} {X/56/2} {X/59/1} Q. Now, what we see here is two emails we’ve been looking at. On the left- hand side, the email which Ms Watts forwarded to Shoosmiths, and on the right -hand side the email which you had sent to Ontier on 2 December 2019; do you see that? A. I do. Q. And you see the subject heading is the same between the two; correct? Dr Wright maintains the authenticity of the two different emails on the basis of responding to the same
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 214 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: had accepted instructions to be an expert, an independent expert in this case? A. I do not think that's the case. Appendix B: Schedule of Transcript References 545 REFERENCE QUOTE COMMENT DAY 19 CROSS -EXAMINATION OF DR CRAIG STEVEN WRIGHT BY MR HOUGH KC {Day19/8:2} - {Day19/9:3} Q. You're also aware, I believe, that Ontier sent an email to your current solicitors, Shoosmiths, that day, February, disputing that version and saying that you first provided them with log -in details on 9 March. Are you aware of that communication? A. I am. Q. Are you also awa re that Shoosmiths passed on Ontier's response by letter to COPA and the developers on the following day, 9 February? A. I am. Q. Do you recall that Ontier's version was put to you on Day 5 of this trial {Day5/46:25}, 9 February, and you disputed it saying , and I quote?: "... I have the emails in disclosure stating that they ..."That's Ontier:"... had access [to MYOB] from 2019." A. I do. Q. Do you recall you were questioned again on the topic when you were called to give evidence on Day 15, last Friday, th e 23rd? A. I do. Q. And you repeated that Ontier had received log- in details in late 2019. A. Yes. Q. And you said that you had the emails to prove that? A. I do. Dr Wright continues to maintain that he has the emails to prove that he had received log- in details in late 2019, despite the documents provided having been found by Mr Madden to be inauthentic or manipulated. Chain of three emails dated 2 December 2019 from Dr Wright to Simon Cohen at Ontier {X/59/1} {Day19/9:13} – {Day19/10:1} Q. May we now go back in time to late 2019 and have on screen {X/59/1}. We see here a chain of three emails, dated 2 December 2019, and if we look at the bottom of the page, an email from you to Simon Cohen at Ontier, 2 nd December Dr Wr ight accepting that the old email (the first one in the chain), is genuine. Appendix B: Schedule of Transcript References 546 REFERENCE QUOTE COMMENT 2019, 12.38, with the title, "... Old ID Email" and the text just "Attached"; do you see that? A. I do. Q. You sent an email on that date at that time with that text, didn't you? A. I believe so, yes. Q. And what was attached, is this right, was a chain of emails with your Australian lawyers concerning your company Information Defense? A. Yes. {Day19/10:10} - {Day19/11:17} Q. Then, at the top of the page, we see an email from you, [email protected], 2 December 2019, 15.56, addressed to Simon Cohen, subject line, "... Old ID Email", and "image002.png" attachment; do you see that? A. I do. Q. And the text says: "An old Inform ation defense file about the IP. "Including Blacknet. "To my lawyer in Au. "I will waive privilege with Michael." Do you see that? A. I do. Q. And that, too, was a genuine email sent from you to Mr Cohen on that date, wasn't it? A. It is. Q. So, this exchange of emails took place on 2 December 2019 and what we are seeing here is a genuine exchange of emails? A. It's not the entirety, no. Q. Is this a genuine exchange of emails? A. It's a partial exchange of the emails. There are other parts. Q. What do you say are the other parts? A. There was a later follow -up, and on 5 March, there was a follow -up from Oliver Cain, who noted that AlixPartners had started, but not completed, the report, which was based on MYOB. Q. That wasn 't a document that was disclosed by your lawyers and explained on Monday, was it? A. No, it's not. Q. You're aware, aren't you, that Mr Cohen is no longer at Ontier? A. I am. Dr Wright’s response in relation to a genuine exchange of emails is evasive, and the 5 March follow -up from Oliver Cain was not provided; the inference is clear that it does not exist and is another fabrication. Appendix B: Schedule of Transcript References 547 REFERENCE QUOTE COMMENT Chain of emails dated 18 February 2024 {X/56/1} {Day19/12:19} - {Day19/13:3} Q. Now, it's right, isn't it, that, as Lord Grabiner explained on Monday, the email at the top of that chain was a genuine email sent from your wife to the solicitors at Shoosmiths? A. I believe so. I didn't send it, but I know she sent one. Q. And the previous email in the chain, the one at the bottom of the page, was a genuine email from you to your wife, wasn't it? A. Yes, I forwarded an email. Dr Wright is evasive regarding whether the email to Shoosmiths is genuine, and evasive as to his own involvement in it being sent to them. Email document attached to Ms Watts email to Shoosmiths dated 18 February 2024 email sent by Dr Wright to Ontier on 2 December 2019 {Day19/13:4} – {Day19/13:19} {X/56/2} Q. {X/56/2}, please. Now, this is the email document attached to Ms Watts email to Shoosmiths of 18 February 2024, timed at 12.56, right? A. Looks like it, yes. Q. And you had sent that document to your wife for onward transmission to Shoosmiths by you r email to her of 18 February ‘24 at 11.39, right? A. Well, I sent it to my wife. I wasn’t involved in the forwarding. Q. But you intended that it be transmitted onward to Shoosmiths; correct? A. No, my wife thought it would be a good idea to send it to them. Q. You knew that’s what she was doing? A. She told me that she was going to and I didn’t object. Dr Wright blames his wife in relation to onward transmission of the email document to Shoosmiths. {Day19/13:25 } – {Day19/14:24} {X/56/2} {X/59/1} Q. Now, what we see here is two emails we’ve been looking at. On the left- hand side, the email which Ms Watts forwarded to Shoosmiths, and on the right -hand side the email which you had sent to Ontier on 2 December 2019; do you see that? A. I do. Q. And you see the subject heading is the same between the two; correct? Dr Wright maintains the authenticity of the two different emails on the basis of responding to the same
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IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES INTELLECTUAL PROPERTY LIST (ChD) Claim No: IL -2021 -000019 BETWEEN: (1) CRYPTO OPEN PATENT ALLIANCE Claimant -and- (1) DR CRAIG STEVEN WRIGHT Defendant COPA’S FOURTH HEARSAY NOTICE DATED 23 JANUARY 2023 PURSUANT TO §2 CIVIL EVIDENCE ACT 1995 AND CPR r.33.2 1. Notice is hereby given that at the trial of this action COPA intends to rely on the account listed below as being a true statement of the understanding of its maker . 2. The Witness Statement of Andreas Furche dated 1 August 2023 . Andreas Furche has indicated that he is unable or unwilling to give evidence at trial due to other commitments. He is an independent third party who has provided confirmation of facts within his own knowledge. He is located overseas in Australia. The evidence has been taken in a man ner than is compliant with CPR 57AC, and COPA’s solicitors have provided a suitable confirmation of compliance. 3. COPA intends to rely on t he relevant facts and conclusions contained in the document which is clear on its face. I t is neither necessary nor proportionate, having regard to the nature of their evidence and the fact that the author is located in a foreign jurisdiction overseas , to apply for an order from the Court requiring the attendance of that witness at Trial to give evidence or by deposition. 23 JANUARY 2024 BIRD & BIRD LLP
246
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 COPA's Fourth CEA Notice.pdf ### Folder name: Hearsay Statements ### File path: /content/Copa v Wright - Trial Documents/Hearsay Statements/COPA's Fourth CEA Notice.pdf ### File content: IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES INTELLECTUAL PROPERTY LIST (ChD) Claim No: IL -2021 -000019 BETWEEN: (1) CRYPTO OPEN PATENT ALLIANCE Claimant -and- (1) DR CRAIG STEVEN WRIGHT Defendant COPA’S FOURTH HEARSAY NOTICE DATED 23 JANUARY 2023 PURSUANT TO §2 CIVIL EVIDENCE ACT 1995 AND CPR r.33.2 1. Notice is hereby given that at the trial of this action COPA intends to rely on the account listed below as being a true statement of the understanding of its maker . 2. The Witness Statement of Andreas Furche dated 1 August 2023 . Andreas Furche has indicated that he is unable or unwilling to give evidence at trial due to other commitments. He is an independent third party who has provided confirmation of facts within his own knowledge. He is located overseas in Australia. The evidence has been taken in a man ner than is compliant with CPR 57AC, and COPA’s solicitors have provided a suitable confirmation of compliance. 3. COPA intends to rely on t he relevant facts and conclusions contained in the document which is clear on its face. I t is neither necessary nor proportionate, having regard to the nature of their evidence and the fact that the author is located in a foreign jurisdiction overseas , to apply for an order from the Court requiring the attendance of that witness at Trial to give evidence or by deposition. 23 JANUARY 2024 BIRD & BIRD LLP
524
/content/Copa v Wright - Trial Documents/Skeletons/Closings/COPA's Closing Submissions.pdf
Closings
part 22 of 82 COPA's Closing Submissions.pdf
90,245
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to anyone, and the pair is known as a keypair.245 A digital signature acts to verify the signing of a given message and involves three algorithms: KeyGen, Sign and Verify.246 There are several standardised digital signature schemes, with the one being used in Bitcoin known as ECDSA (Elliptic C urve Digital Signature Algorithm).247 The curve used in Bitcoin is secp256k1, and ECDSA signatures are usually encoded and expressed as 64 alphanumeric characters. 240 Meiklejohn, at §21(a) {G/2/9} . 241 {G/2/9} . 242 Joint statement of Prof Meiklejohn and Zem Gao at §2 {Q/3/2} . 243 Meiklejohn §24 {G/2/9} . 244 Meiklejohn §25 {G/2/10} . 245 Meiklejohn §31 {G/2/11} . 246 Meiklejohn §32 and Fig. 1 {G/2/12} . 247 Meiklejohn §34 {G/2/13} . 57 Transacting in Bitcoin 156. Bitcoin users can identify themselves using, for example, their publ ic key or (more commonly) addresses, which are alphanumeric identifiers that are different from, but often related to the public key.248 Prior to 2012, the only type of address used in Bitcoin transactions was a pay -to-public -key-hash (P2PKH), whereas send ing to a public key was referred to as pay -to-public key (P2PK).249 157. When addresses are derived from public keys, each address has its associated private key that can be used to sign messages. Accordingly, given an address, a public key, a signature and a m essage, anyone can verify whether or not (a) the address was derived from the public key and (b) the signature and signed message are valid for that public key. 250 It is these properties that allow Bitcoin users to transfer ownership of bitcoins they posse ss such that they can be independently verified, but without disclosing the real world identity of the individual with the private key. 158. A transaction contains, in its simplest form, an input corresponding to the sender and one output corresponding to the recipient. 251 The transaction output consists of the recipient’s address and the value of bitcoin sent to that address. A Bitcoin transaction also contains a digital signature from the sender, where the message being signed contains the rest of the inform ation detailing the transaction. 252 This allows peers on the network to verify the transaction, as they can look at the address, public key and signature to check that the public key aligns with the address and the signature verifies it. 253 159. As transactions are public, it is possible to check to see if the address was used before, to confirm that the address did in fact receive the number of bitcoin it is now spending.254 To prevent double spending, Bitcoin tracks which transaction outputs are uns pent and allows only those unspent outputs to spend the coins they receive.255 248 Meiklejohn §36 {G/2/13} . 249 Meiklejohn §38 {G/ 2/14} . 250 Meiklejohn §39 {G/2/14} . 251 Meiklejohn §43 {G/2/15} . 252 Ibid. 253 Meiklejohn §44 {G/2/15} . 254 Ibid. 255 Ibid. 58 Transaction Ordering 160. As different peers on the network will see transactions at different times, transaction ordering is essential to ensure that there is no instance of bitcoins being recorded as being sent to two different users.256 This is the role of the Bitcoin blockchain, which acts as a ledger of all valid transactions propagated through the network. 161. The first block in the Bitcoin blockchain was Block 0 (the Genesis Bloc k) which was hardcoded into the Bitcoin software. It was produced on 3 January 2009 at 18:15:05 UTC and contains a single coin generation transaction. 257 The script used to input this transaction contains an encoded message which when decoded reads “The Ti mes 03/Jan/2009 Chancellor on brink of second bailout for banks ”. The purpose of using this Times headline message was apparently to show that the Genesis Block could not have been created before that date. 258 162. The initial block reward was 50 Bitcoin, but that halves with every 210,000 blocks. It is presently 6.25 bitcoin. The total number of bitcoin capable of being generated as rewards is capped at 21 million bitcoins in total. 259 Bitcoin is configured to have a new block produced every 10 minutes on average. This means that the target hash needs to change according to the collective computing power of the peers competing in the mining process. 260 The difficulty level itself changes according to the expected time to produce blocks divided by the actual time, meaning that difficulty increase or decrease depending on the collective computation power. 261 Blockchain Forks 163. If Bitcoin participants want to change parameters of the system, this can be done by consensus of those on the network. Any rule change which is backwards -compatible is known as a soft fork. 262 A backwards -incompatible change is known as a hard fork, which creates two different blockc hains diverging at a single block.263 The most popular cryptocurrency based on the White Paper and Genesis Block is Bitcoin. Further hard 256 Meiklejohn §58 {G/2/20} . 257 Meiklejohn §59 {G/2/21} . 258 Ibid. 259 Meiklejohn §69 {G/2/28} . 260 Meiklejohn §71 {G/2/29} . 261 Ibid. 262 Meiklejohn §76 {G/2/33} . 263 Meiklejohn §78 {G/2/34} . 59 forks have created the cryptocurrencies Bitcoin Cash, and Bitcoin Satoshi Vision. Wright asserts that his Bitcoin Satoshi Vision blockchain is the real "Bitcoin". To avoid an uninteresting and irrelevant terminology debate we refer to these cryptocurrency systems by their ticker symbols: BTC, BCH, and BSV. Storage and Use of Bitcoin 164. Typically, users store bitcoins in an electronic wallet, a piece of software that stores private keys and keeps track of any associated transactions. This can be run on a computer or mobile device.264 Wallets often provide users with a recovery phrase, so that if the device containing the wa llet is corrupted or lost, it can still be downloaded again and reused.265 Solutions to the risks entailed in storing bitcoin on one’s own device include storing on an exchange and cold storage (on an offline computer or written down). 266 165. It is also possibl e to use multi -signature addresses, whereby any participant who produces a valid signature completes and validates the transaction. A related concept is that of Secret Sharing, with the most common version of being known as Shamir Secret Sharing.267 This concept involves the user splitting a private key using a cryptographic primitive and giving “slices” to different users. Then, depending on how the sharing has been performed, a certain number of individuals in a group (sometimes all, but in other cases only a lesser number of the set) can reconstruct the private key. 268 Security of Digital Signatures
1,101
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 22 of 82 COPA's Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/COPA's Closing Submissions.pdf ### File content: to anyone, and the pair is known as a keypair.245 A digital signature acts to verify the signing of a given message and involves three algorithms: KeyGen, Sign and Verify.246 There are several standardised digital signature schemes, with the one being used in Bitcoin known as ECDSA (Elliptic C urve Digital Signature Algorithm).247 The curve used in Bitcoin is secp256k1, and ECDSA signatures are usually encoded and expressed as 64 alphanumeric characters. 240 Meiklejohn, at §21(a) {G/2/9} . 241 {G/2/9} . 242 Joint statement of Prof Meiklejohn and Zem Gao at §2 {Q/3/2} . 243 Meiklejohn §24 {G/2/9} . 244 Meiklejohn §25 {G/2/10} . 245 Meiklejohn §31 {G/2/11} . 246 Meiklejohn §32 and Fig. 1 {G/2/12} . 247 Meiklejohn §34 {G/2/13} . 57 Transacting in Bitcoin 156. Bitcoin users can identify themselves using, for example, their publ ic key or (more commonly) addresses, which are alphanumeric identifiers that are different from, but often related to the public key.248 Prior to 2012, the only type of address used in Bitcoin transactions was a pay -to-public -key-hash (P2PKH), whereas send ing to a public key was referred to as pay -to-public key (P2PK).249 157. When addresses are derived from public keys, each address has its associated private key that can be used to sign messages. Accordingly, given an address, a public key, a signature and a m essage, anyone can verify whether or not (a) the address was derived from the public key and (b) the signature and signed message are valid for that public key. 250 It is these properties that allow Bitcoin users to transfer ownership of bitcoins they posse ss such that they can be independently verified, but without disclosing the real world identity of the individual with the private key. 158. A transaction contains, in its simplest form, an input corresponding to the sender and one output corresponding to the recipient. 251 The transaction output consists of the recipient’s address and the value of bitcoin sent to that address. A Bitcoin transaction also contains a digital signature from the sender, where the message being signed contains the rest of the inform ation detailing the transaction. 252 This allows peers on the network to verify the transaction, as they can look at the address, public key and signature to check that the public key aligns with the address and the signature verifies it. 253 159. As transactions are public, it is possible to check to see if the address was used before, to confirm that the address did in fact receive the number of bitcoin it is now spending.254 To prevent double spending, Bitcoin tracks which transaction outputs are uns pent and allows only those unspent outputs to spend the coins they receive.255 248 Meiklejohn §36 {G/2/13} . 249 Meiklejohn §38 {G/ 2/14} . 250 Meiklejohn §39 {G/2/14} . 251 Meiklejohn §43 {G/2/15} . 252 Ibid. 253 Meiklejohn §44 {G/2/15} . 254 Ibid. 255 Ibid. 58 Transaction Ordering 160. As different peers on the network will see transactions at different times, transaction ordering is essential to ensure that there is no instance of bitcoins being recorded as being sent to two different users.256 This is the role of the Bitcoin blockchain, which acts as a ledger of all valid transactions propagated through the network. 161. The first block in the Bitcoin blockchain was Block 0 (the Genesis Bloc k) which was hardcoded into the Bitcoin software. It was produced on 3 January 2009 at 18:15:05 UTC and contains a single coin generation transaction. 257 The script used to input this transaction contains an encoded message which when decoded reads “The Ti mes 03/Jan/2009 Chancellor on brink of second bailout for banks ”. The purpose of using this Times headline message was apparently to show that the Genesis Block could not have been created before that date. 258 162. The initial block reward was 50 Bitcoin, but that halves with every 210,000 blocks. It is presently 6.25 bitcoin. The total number of bitcoin capable of being generated as rewards is capped at 21 million bitcoins in total. 259 Bitcoin is configured to have a new block produced every 10 minutes on average. This means that the target hash needs to change according to the collective computing power of the peers competing in the mining process. 260 The difficulty level itself changes according to the expected time to produce blocks divided by the actual time, meaning that difficulty increase or decrease depending on the collective computation power. 261 Blockchain Forks 163. If Bitcoin participants want to change parameters of the system, this can be done by consensus of those on the network. Any rule change which is backwards -compatible is known as a soft fork. 262 A backwards -incompatible change is known as a hard fork, which creates two different blockc hains diverging at a single block.263 The most popular cryptocurrency based on the White Paper and Genesis Block is Bitcoin. Further hard 256 Meiklejohn §58 {G/2/20} . 257 Meiklejohn §59 {G/2/21} . 258 Ibid. 259 Meiklejohn §69 {G/2/28} . 260 Meiklejohn §71 {G/2/29} . 261 Ibid. 262 Meiklejohn §76 {G/2/33} . 263 Meiklejohn §78 {G/2/34} . 59 forks have created the cryptocurrencies Bitcoin Cash, and Bitcoin Satoshi Vision. Wright asserts that his Bitcoin Satoshi Vision blockchain is the real "Bitcoin". To avoid an uninteresting and irrelevant terminology debate we refer to these cryptocurrency systems by their ticker symbols: BTC, BCH, and BSV. Storage and Use of Bitcoin 164. Typically, users store bitcoins in an electronic wallet, a piece of software that stores private keys and keeps track of any associated transactions. This can be run on a computer or mobile device.264 Wallets often provide users with a recovery phrase, so that if the device containing the wa llet is corrupted or lost, it can still be downloaded again and reused.265 Solutions to the risks entailed in storing bitcoin on one’s own device include storing on an exchange and cold storage (on an offline computer or written down). 266 165. It is also possibl e to use multi -signature addresses, whereby any participant who produces a valid signature completes and validates the transaction. A related concept is that of Secret Sharing, with the most common version of being known as Shamir Secret Sharing.267 This concept involves the user splitting a private key using a cryptographic primitive and giving “slices” to different users. Then, depending on how the sharing has been performed, a certain number of individuals in a group (sometimes all, but in other cases only a lesser number of the set) can reconstruct the private key. 268 Security of Digital Signatures
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/content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090129-Re_[bitcoin-list] Problems-80862.pdf
Nicholas Bohm Witness Statement - Exhibit
part 1 of 1 20090129-Re_[bitcoin-list] Problems-80862.pdf
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Subject: Re: [bitcoin-list] Problems From: Nicholas Bohm <[email protected]> Date: 29/01/2009, 15:09 To: [email protected] I have had no further problems since I ceased running a daily late evening scheduled operation consisting of a wipe of various folders containing temporary files using Eraser. Whether this operation accounted for the crashes I don't know, as Eraser has never had that effect before, and typically ignores any file it finds to be in use. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFRe: [bitcoin-list] Problems mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:09
118
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090129-Re_[bitcoin-list] Problems-80862.pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090129-Re_[bitcoin-list] Problems-80862.pdf ### File content: Subject: Re: [bitcoin-list] Problems From: Nicholas Bohm <[email protected]> Date: 29/01/2009, 15:09 To: [email protected] I have had no further problems since I ceased running a daily late evening scheduled operation consisting of a wipe of various folders containing temporary files using Eraser. Whether this operation accounted for the crashes I don't know, as Eraser has never had that effect before, and typically ignores any file it finds to be in use. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFRe: [bitcoin-list] Problems mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:09
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/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM31.pdf
Patrick Madden
part 3 of 4 Appendix PM31.pdf
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difficult to d raw any firm conclusion from that based on the data available, and I do not do so. H yperlinks within ID_000395 itself 22.Returning to the content of ID_000395, it can be observed that there are two hyperlinks within the document itself : a.I n the “bibliography” section on page 15, item 7 includes a hyperlink with text indicating it points to the website coastlinesolutions.com: b.in the “ cases reference” section on page 20, item 3 1 includes a hyperlink with text indicating it points to the ICCWBO website: 23. T hose are the only two hyperlinks in this document . H/132/7{ID_000395} {ID_000395} Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 8 of 15 24. H owever, neither hyperlink actually points directly to the websites that are listed on their face . I nstead, they point t o the Wayback Machine (web.archive.org), as can be observed whe n hove ring the mouse over each link: 25.The two URLs themselves reproduced here as text are: a.https://web.archive.org/web/20151123120157/http:/www.coastlinesolutions.com/new s.htm and b.https://web.archive.org/web/20151123120157/http:/www.iccwbo.org/home/menu_ba nking.asp 26.P art of the way the Wayback Machine operates is that when it captures a specific web page , th at web page goes through a conversion p rocess : a. T he capture of the webpage is assigned a timestamp in the form YYYYMMDDHHmmss corresponding to when it is create d. b. The capture is hosted at archive.org, it is assigned a URL containing that YYYYMMDDHHmmss timestamp. c.I f the page being captured contains hyperlinks to any other web pages, then those hyperlinks are also converted to point to web archives. This is done by adding a URL prefix to any hyperlinks, again containing the same YYYYMMDDHHmmss timestamp. H/132/8 Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 9 of 15 d. Thi s means that when browsing the Wayback Machine, clicking from page to another keeps the user within archived pages on archive.org (instead of just linking out to whatever is the modern/current version of the page , which would not be helpful). If the Wayback Machine has captured a linked page, it will direct the user to whatever isthe nearest capture in time to the YYYYMMDDHHmmss timestamp that is beingrequested. 27.As can be observed in this case, b oth URLs contain timestamps in the form YYYYMMDDHHmmss , both of them being 20151123120157. This corresponds to a date and time of 23 November 2015 at 12:01 and 57 seconds. 28.By clicking on the links, I observed that neit her of them had been captured by the Wayback machine on 23 November 2015. a.The nearest capture of the coastlinesolutions.com reference was dated 8 Dece mber 2015, at which time, it simply displayed a 404 Not Found Error, as seen in thescreenshot below (and a printout copy is at Exhibit PM31 .2): b.The second reference, to iccwbo.org, also did not resolve to any capture, but instead redirected to an archived version of an error page. A screenshot of a 302 error is shown in the screenshot below. The redirected page is shown in printout at ExhibitPM31 .3 and in the second screenshot below. H/132/9{H/134} Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 10 of 15 c. The U RL of the redirected error page was https://web.archive.org/web/20151208230651/http://www.iccwbo.org/errorpages/404. aspx?aspxerrorpath=/home/~/error -pages/404.aspx , indicating a capture date of 8 December 2015. 29.This led me to the initial view that : a.the hy perlinks in Document ID_000395 were not sourced from any actual Wayback Machine archive of www.iccwbo.org or www.coastlinesolutions.com , because there was not any archive of those pages corresponding to their timestamps. Instead, clicking on the links took me to the neares t archive in time to the indicated timestamp, which did not have useful content for either of the two pages. b.Inst ead, they appear to have been copied and pasted from a Wayback Machine (web.archive.org) page that refers to b oth iccwbo.org and coastlinesolutions.com. H/132/10{ID_000395} Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 11 of 15 c.Thi s would account for the URLs not referring to actual archive snapshots at the time in question and not containing useful content at the nearest archive point in time, because it would indicate that they had been generated automatically. d. I t the refore appeared likely that the source of copying and pasting was a snapshot that had been captured on 23 November 2015 at 12:01 and 57 seconds , because that is the timestamp which had been applied to both URLs. This is consistent with the way the Wayback Machine archives pages that contain hyperlinks out to other pages. 30. It would not have been possible, in 2008, to anticipate such specific references to the dates of Wayback Machine captures which had not yet occurred, and these observations are ther efore consistent with the document ID_000395 being created at some point after 23 November2015, based on t he dates of the timestamps for the captures. Con tinuing analysis on wayback machine archive 31.I w as not initially able to take this analysis about the Wayback Machine any further, so I then explained to Bird & Bird about the irregularities with the URL and my preliminaryconclusions about it. Bird & Bird subsequently provided me with the following URL link which they had identified as
894
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 3 of 4 Appendix PM31.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM31.pdf ### File content: difficult to d raw any firm conclusion from that based on the data available, and I do not do so. H yperlinks within ID_000395 itself 22.Returning to the content of ID_000395, it can be observed that there are two hyperlinks within the document itself : a.I n the “bibliography” section on page 15, item 7 includes a hyperlink with text indicating it points to the website coastlinesolutions.com: b.in the “ cases reference” section on page 20, item 3 1 includes a hyperlink with text indicating it points to the ICCWBO website: 23. T hose are the only two hyperlinks in this document . H/132/7{ID_000395} {ID_000395} Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 8 of 15 24. H owever, neither hyperlink actually points directly to the websites that are listed on their face . I nstead, they point t o the Wayback Machine (web.archive.org), as can be observed whe n hove ring the mouse over each link: 25.The two URLs themselves reproduced here as text are: a.https://web.archive.org/web/20151123120157/http:/www.coastlinesolutions.com/new s.htm and b.https://web.archive.org/web/20151123120157/http:/www.iccwbo.org/home/menu_ba nking.asp 26.P art of the way the Wayback Machine operates is that when it captures a specific web page , th at web page goes through a conversion p rocess : a. T he capture of the webpage is assigned a timestamp in the form YYYYMMDDHHmmss corresponding to when it is create d. b. The capture is hosted at archive.org, it is assigned a URL containing that YYYYMMDDHHmmss timestamp. c.I f the page being captured contains hyperlinks to any other web pages, then those hyperlinks are also converted to point to web archives. This is done by adding a URL prefix to any hyperlinks, again containing the same YYYYMMDDHHmmss timestamp. H/132/8 Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 9 of 15 d. Thi s means that when browsing the Wayback Machine, clicking from page to another keeps the user within archived pages on archive.org (instead of just linking out to whatever is the modern/current version of the page , which would not be helpful). If the Wayback Machine has captured a linked page, it will direct the user to whatever isthe nearest capture in time to the YYYYMMDDHHmmss timestamp that is beingrequested. 27.As can be observed in this case, b oth URLs contain timestamps in the form YYYYMMDDHHmmss , both of them being 20151123120157. This corresponds to a date and time of 23 November 2015 at 12:01 and 57 seconds. 28.By clicking on the links, I observed that neit her of them had been captured by the Wayback machine on 23 November 2015. a.The nearest capture of the coastlinesolutions.com reference was dated 8 Dece mber 2015, at which time, it simply displayed a 404 Not Found Error, as seen in thescreenshot below (and a printout copy is at Exhibit PM31 .2): b.The second reference, to iccwbo.org, also did not resolve to any capture, but instead redirected to an archived version of an error page. A screenshot of a 302 error is shown in the screenshot below. The redirected page is shown in printout at ExhibitPM31 .3 and in the second screenshot below. H/132/9{H/134} Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 10 of 15 c. The U RL of the redirected error page was https://web.archive.org/web/20151208230651/http://www.iccwbo.org/errorpages/404. aspx?aspxerrorpath=/home/~/error -pages/404.aspx , indicating a capture date of 8 December 2015. 29.This led me to the initial view that : a.the hy perlinks in Document ID_000395 were not sourced from any actual Wayback Machine archive of www.iccwbo.org or www.coastlinesolutions.com , because there was not any archive of those pages corresponding to their timestamps. Instead, clicking on the links took me to the neares t archive in time to the indicated timestamp, which did not have useful content for either of the two pages. b.Inst ead, they appear to have been copied and pasted from a Wayback Machine (web.archive.org) page that refers to b oth iccwbo.org and coastlinesolutions.com. H/132/10{ID_000395} Madden Appendix PM 31 “UCP 500.doc ” / ID_00 0395 and ID_0 04041 Page 11 of 15 c.Thi s would account for the URLs not referring to actual archive snapshots at the time in question and not containing useful content at the nearest archive point in time, because it would indicate that they had been generated automatically. d. I t the refore appeared likely that the source of copying and pasting was a snapshot that had been captured on 23 November 2015 at 12:01 and 57 seconds , because that is the timestamp which had been applied to both URLs. This is consistent with the way the Wayback Machine archives pages that contain hyperlinks out to other pages. 30. It would not have been possible, in 2008, to anticipate such specific references to the dates of Wayback Machine captures which had not yet occurred, and these observations are ther efore consistent with the document ID_000395 being created at some point after 23 November2015, based on t he dates of the timestamps for the captures. Con tinuing analysis on wayback machine archive 31.I w as not initially able to take this analysis about the Wayback Machine any further, so I then explained to Bird & Bird about the irregularities with the URL and my preliminaryconclusions about it. Bird & Bird subsequently provided me with the following URL link which they had identified as
1,761
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Closings
part 119 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
236,795
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COMMENT Q. Are you able to point to any evidence of any earlier use of the expression "UTXO" than that? A. Not while s itting here, no. {L4/97.1/21} main.cpp, 10 January 2009 issue of Bitcoin code file {Day8/121:19- 24} Now, CheckBlock had six checks, didn't it? A. At the particular time, I don't recall. Q. The issue of the Bitcoin Core software? A. There are multiple version and talking about my software from 15 years ago, I don't recall the exact structure without it in front of me. Dr Wright is admitting that he cannot remember the details of what is claimed to be his own source code. {Day8/123:6} - {Day8/125:18} {L4/97.1/22} main.cpp {L4/98.1/8} main.h Q. And then, fourthly, we can see that it checked transactions? A. Yes. Q. What was that? A. That it checks transactions? Q. Yes, what was the check of the transactions? A. Basically making sure that they are valid, that the transactions that have been received follow the rules, etc. Q. So what sort of thing? A. What sort of thing. So, basically, Bitcoin uses script. The way that you'd have to then check would be does the key work, does other policies work, are the output and script valid. It's a predicate. So, what we're functionally doing in here is ensuring that all of the input and output is structured correctly, that if there's a message with an ECDSA key that the correct previous block had been signed. Q. So I remember you talking the other day -- I can't remember which day it was -- about how, when you w ere first running the Bitcoin software, it hadn't been -- the mining that had been absorbing all of your electricity, as it were, it was doing ECDSA checks in relation to the underlying transactions; is that right? A. And much more. Q. Okay, but when you're talking about ECDSA checking, is that what you're talking about in relation to -- A. That particular part, yes. Dr Wright incorrectly identifies ECDSA signatures as one of the trans action checks carried out by the CheckBlock function. Appendix B: Schedule of Transcript References 296 REFERENCE QUOTE COMMENT Q. Okay. Can we go then to what check transactions actually is. It's at {L4/98.1/8}. And there were just three checks in check transaction s. We can see it at the bottom. They were just: "Basic checks that don't depend on any context." Do you see that? A. It's a bit more than that. Each of these calls other areas. If you look at -- Q. I'm going to go to them. If we can turn over the page {L4/98.1/9}, we can see the first one: "if (vin.empty ... vout.empty ... "return error ..." That was checking that there was at least one input and one output, right? A. Yes. Q. Secondly, it was checking that the amount spent wasn't negative, right? A. Co rrect. Q. And then, thirdly, it was checking that if there was a CoinBase transaction, the scriptSig was of a certain size between 2 and 100 bytes, right? A. Mm -hm. Q. And if it wasn't a CoinBase transaction, then the input had to be the output of anoth er transaction, right? A. Yes. Q. It did not involve checking ECDSA signatures, did it? A. Again, that then calls these other functions. Q. Dr Wright, you're wrong about that? A. I am not wrong about that. If you note this, the diagram that you had is hierarchical. So, that particular function calls the next function, and when you're talking about checking CheckSig in that particular one, then that's ECDSA, but it's not in that core. {Day8/126:11} - {Day8/127:22} {L4/97.1/23} main.cpp Q. Now, it is within AcceptBlock that the signatures are checked, isn't it? A. Basically what we have is a series of functions that each of these call other functions. So, where you're trying to say that each of these don't do all of that, the diagram tha t these guys don't like is a functional call mapping each of these areas down. Q. I'm not asking you about any diagrams, I'm asking you about what is in the CheckBlock function, and you told me that within the CheckBlock function were checks of ECDSA signatures. Dr Wright is pressed on his incorrect assertion that the CheckBlock function contains an ECDSA signature check, and denies that is what he said. Mellor J requesting Dr Wright to identify where the calls are for Appendix B: Schedule of Transcript References 297 REFERENCE QUOTE COMMENT A. If it's a header and everything else is underneath it, then that is part of the entire function and you are checking everything. So when you have one function follow another to be correct, then all of those sub functions are part of the same fu nction. Q. I'm afraid you're wrong, Dr Wright. If we want to explore how you get to signatures from the AcceptBlock function, I can take you there. Do you want me to do that? A. Like I said, the block includes both the full check and each of these. So wh en you have a transaction that you have checked, it then goes into the block and it's put into a binary tree structure. All of that is checked as part of the entire function. What you're doing is pulling out each individual call and saying that it's separa te. It isn't. Q. We have looked at what the CheckBlock function contains and you have said it contains an ECDSA signature check. It doesn't, does it? A. That's not what I said. Q. Well, we can see what you said. A. What I said was, the function include s all of the processes in that. CheckBlock doesn't work unless each of the called functions are there. MR JUSTICE MELLOR: You're going to have to show us where you say these calls are in the code, Dr Wright. the ECDSA signature check in the code. {Day8/129:13} - {Day8/130:11} {L4/97.1/16} main.cpp Q. And if we go to the top of {L4/97.1/16}, we can see that we get to the "VerifySignature" function; do you see that? A. I do. Q. So, the verification of signatures was part of the AcceptBlock function, not the CheckBlock function; do you agree? A. I have not looked at the original code since about 2017, and the way that I would look at it would be in UML, etc. So the diagrams
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 119 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: COMMENT Q. Are you able to point to any evidence of any earlier use of the expression "UTXO" than that? A. Not while s itting here, no. {L4/97.1/21} main.cpp, 10 January 2009 issue of Bitcoin code file {Day8/121:19- 24} Now, CheckBlock had six checks, didn't it? A. At the particular time, I don't recall. Q. The issue of the Bitcoin Core software? A. There are multiple version and talking about my software from 15 years ago, I don't recall the exact structure without it in front of me. Dr Wright is admitting that he cannot remember the details of what is claimed to be his own source code. {Day8/123:6} - {Day8/125:18} {L4/97.1/22} main.cpp {L4/98.1/8} main.h Q. And then, fourthly, we can see that it checked transactions? A. Yes. Q. What was that? A. That it checks transactions? Q. Yes, what was the check of the transactions? A. Basically making sure that they are valid, that the transactions that have been received follow the rules, etc. Q. So what sort of thing? A. What sort of thing. So, basically, Bitcoin uses script. The way that you'd have to then check would be does the key work, does other policies work, are the output and script valid. It's a predicate. So, what we're functionally doing in here is ensuring that all of the input and output is structured correctly, that if there's a message with an ECDSA key that the correct previous block had been signed. Q. So I remember you talking the other day -- I can't remember which day it was -- about how, when you w ere first running the Bitcoin software, it hadn't been -- the mining that had been absorbing all of your electricity, as it were, it was doing ECDSA checks in relation to the underlying transactions; is that right? A. And much more. Q. Okay, but when you're talking about ECDSA checking, is that what you're talking about in relation to -- A. That particular part, yes. Dr Wright incorrectly identifies ECDSA signatures as one of the trans action checks carried out by the CheckBlock function. Appendix B: Schedule of Transcript References 296 REFERENCE QUOTE COMMENT Q. Okay. Can we go then to what check transactions actually is. It's at {L4/98.1/8}. And there were just three checks in check transaction s. We can see it at the bottom. They were just: "Basic checks that don't depend on any context." Do you see that? A. It's a bit more than that. Each of these calls other areas. If you look at -- Q. I'm going to go to them. If we can turn over the page {L4/98.1/9}, we can see the first one: "if (vin.empty ... vout.empty ... "return error ..." That was checking that there was at least one input and one output, right? A. Yes. Q. Secondly, it was checking that the amount spent wasn't negative, right? A. Co rrect. Q. And then, thirdly, it was checking that if there was a CoinBase transaction, the scriptSig was of a certain size between 2 and 100 bytes, right? A. Mm -hm. Q. And if it wasn't a CoinBase transaction, then the input had to be the output of anoth er transaction, right? A. Yes. Q. It did not involve checking ECDSA signatures, did it? A. Again, that then calls these other functions. Q. Dr Wright, you're wrong about that? A. I am not wrong about that. If you note this, the diagram that you had is hierarchical. So, that particular function calls the next function, and when you're talking about checking CheckSig in that particular one, then that's ECDSA, but it's not in that core. {Day8/126:11} - {Day8/127:22} {L4/97.1/23} main.cpp Q. Now, it is within AcceptBlock that the signatures are checked, isn't it? A. Basically what we have is a series of functions that each of these call other functions. So, where you're trying to say that each of these don't do all of that, the diagram tha t these guys don't like is a functional call mapping each of these areas down. Q. I'm not asking you about any diagrams, I'm asking you about what is in the CheckBlock function, and you told me that within the CheckBlock function were checks of ECDSA signatures. Dr Wright is pressed on his incorrect assertion that the CheckBlock function contains an ECDSA signature check, and denies that is what he said. Mellor J requesting Dr Wright to identify where the calls are for Appendix B: Schedule of Transcript References 297 REFERENCE QUOTE COMMENT A. If it's a header and everything else is underneath it, then that is part of the entire function and you are checking everything. So when you have one function follow another to be correct, then all of those sub functions are part of the same fu nction. Q. I'm afraid you're wrong, Dr Wright. If we want to explore how you get to signatures from the AcceptBlock function, I can take you there. Do you want me to do that? A. Like I said, the block includes both the full check and each of these. So wh en you have a transaction that you have checked, it then goes into the block and it's put into a binary tree structure. All of that is checked as part of the entire function. What you're doing is pulling out each individual call and saying that it's separa te. It isn't. Q. We have looked at what the CheckBlock function contains and you have said it contains an ECDSA signature check. It doesn't, does it? A. That's not what I said. Q. Well, we can see what you said. A. What I said was, the function include s all of the processes in that. CheckBlock doesn't work unless each of the called functions are there. MR JUSTICE MELLOR: You're going to have to show us where you say these calls are in the code, Dr Wright. the ECDSA signature check in the code. {Day8/129:13} - {Day8/130:11} {L4/97.1/16} main.cpp Q. And if we go to the top of {L4/97.1/16}, we can see that we get to the "VerifySignature" function; do you see that? A. I do. Q. So, the verification of signatures was part of the AcceptBlock function, not the CheckBlock function; do you agree? A. I have not looked at the original code since about 2017, and the way that I would look at it would be in UML, etc. So the diagrams
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context that he originally intended to present this as a development note from before the inception of the Bitcoin system. 174.5. Rory Cellan -Jones {C/5/1} – Mr Cellan -Jones is a technology journalist who was involved in the 2016 signing sessions, which he addresses in his evidence. He was told that Dr Wright could prove he was Satoshi a nd in reliance on that he transferred bitcoin on 4 May 2016 to the Bitcoin address that Satoshi used for the first transaction, on the understanding that Dr Wright would send it back. To date Mr Cellan -Jones has not received this Bitcoin back. This evidenc e was unchallenged. As set out above, Mr Cellan- Jones was subject to an unjustified personal attack by Dr Wright. 174.6. Zooko Wilcox- O’Hearn {C/6/1} – Mr Wilcox -O’Hearn is a computer scientist in the field of cryptography and cryptocurrency. He wrote early blogposts about Bitcoin and states that he never received any Bitcoin from Satoshi, as Dr Wright has claimed he did. This evidence was barely challenged, and Mr Wilcox - O’Hearn was a clear and conscientious witness. He also revealed how passionate he was abou t Satoshi Nakamoto, referring to him as his “ hero” and saying with some force that if, as alleged by Dr Wright, he had received bitcoin from his hero, he would certainly have remembered it. 293 He was also very clear that he had not 292 {L1/115/1} . 293 {Day14/80:14} . 66 downloaded the Bitcoin source code for a number of years, explaining that he did not even use Windows at the time (the bitcoin software having been Windows - only until at least 2010).294 Whilst he wanted the system to work, he thought it might be a glorious failure.295 When it was put to him that he must have become more actively involved earlier, he replied disarmingly: “ You underestimate my laziness and procrastination.”296 It is thus clear that Dr Wright’s claims to have sent Bitcoin to Mr Wilcox O’Hearn were failed guesswork, based on the public information that he was the first person to have blogged about bitcoin, shortly after its release. 174.7. Dustin Trammell {C/7/1} – Mr Trammell is an Information Security Research Scientist who corresponded with Satoshi in January 2009. He gives evidence of his correspondence with Satoshi and exhibits it. He denies a claim Dr Wright made in his evidence in the Granath proceedings that Dr Wright as Satoshi shared Bitcoin code with him. This evidence was unchallenged. Dr Wright must therefore be taken to concede that his claim that code was shared with Mr Trammell was unfounded and false. 174.8. John Hudson {C/8/1} – Mr Hudson is the lead designer of the font Nirmala UI and confirms it was not publicly available until March 2012 at the earliest. This is relevant to a number of Mr Madden’s findings that documents of Dr Wright are not authentic to their suggested dates and have been backdated. This evidence was unchallenged. 174.9. Adam Back {C/9/1} {C/21/1} – Dr Back is a cryptographer and inventor of “Hashcash”, which was cited in the White Paper. He gives evidence of some email communications with Satoshi which had not previously been made publi c. They undermine Dr Wright’s accounts of his work on the White Paper before its release (as largely reiterated in Wright 1). For instance, Dr Wright says that Wei Dai’s work profoundly influenced his development of Bitcoin for years, whereas Dr Back’s emails show that he told Satoshi about Wei Dai’s work on 21 August 2008 and that Satoshi had not previously known of it. This is also telling because 294 See for instance {Day14/75:1} . 295 {Day14/78:14} . 296 {Day14/81:2} . 67 Dr Wright’s supposed precursor drafts of the White Paper (said to predate August 2008) have the reference to Wei Dai’s B -money paper. Dr Back also provided a short second statement rebutting some of the claims Dr Wright makes about Dr Back’s attitude and interactions with Satoshi. Dr Back gave clear and cogent evidence, backed up by contemporaneous documents. The attempts by Mr Orr KC to press Dr Back to agree with Dr Wright that the proof -of-work in Bitcoin owed no meaningful debt to Hashcash were valiant but hopeless. 297 It was also striking how clearly superior Dr Back was to Dr Wright in terms of technica l knowledge about the Bitcoin system and code and the ability to parse and convey that information. Dr Back was challenged on his independence, but this attack was baseless. 174.10. Nicholas Bohm {C/10/1} – Mr Bohm was a retired solicitor who corresponded with Sa toshi shortly after the release of Bitcoin in January 2009. Mr Bohm has provided evidence of his email communications with Satoshi that were not before made public (and to which Dr Wright had never referred). He has also provided a version of the White P aper that he downloaded in January 2009, which Mr Madden has authenticated 298 and which is used as a control copy. This evidence was unchallenged. 174.11. Ben Ford {C/11/1} – Mr Ford is the director of a company trading as DataStation who gives evidence about a DataStation notepad which is one of Dr Wright’s Reliance Documents (ID_004018).299 This presents as being a set of pre -release development notes on the Bitcoin concept. Mr Ford explains that the notepad was not printed until 22 May 2012. Dr Wright has reacted to this evidence in his Chain of Custody schedule by saying that the notes were written in 2011 / 2012. Again, this cover story has its own difficulties that wi ll be explored at trial. This evidence was unchallenged. 174.12. Steve Lee {C/12/1} – Mr Lee is a board member of COPA. He is a Bitcoin developer and works for a team called Spiral, which is funded by Block, Inc (a Represented Party). He gives evidence on the chilling effect of Dr Wright’s 297 See for example the exchange from {Day13/45:2} - {Day13/53:22} . 298 See Appendix PM3, from §41 {H/20/14} . 299 {L7/471/1} . 68 claims to be Satoshi, giving examples of how Dr Wright wishes to people to lose their families and be subject to criminal law sanctions (including reference to the death penalty). This evidence was largely unchallenged. It is remarkable how short a time Mr Lee was in the witness box, given that his evidence is the primary evidence from COPA as to the need for the declaratory and injunctive relief. None of his evidence that goes to relief was challenged. Instead, there were s ome inconsequential fishing questions about his and Block’s role
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 25 of 82 COPA's Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/COPA's Closing Submissions.pdf ### File content: context that he originally intended to present this as a development note from before the inception of the Bitcoin system. 174.5. Rory Cellan -Jones {C/5/1} – Mr Cellan -Jones is a technology journalist who was involved in the 2016 signing sessions, which he addresses in his evidence. He was told that Dr Wright could prove he was Satoshi a nd in reliance on that he transferred bitcoin on 4 May 2016 to the Bitcoin address that Satoshi used for the first transaction, on the understanding that Dr Wright would send it back. To date Mr Cellan -Jones has not received this Bitcoin back. This evidenc e was unchallenged. As set out above, Mr Cellan- Jones was subject to an unjustified personal attack by Dr Wright. 174.6. Zooko Wilcox- O’Hearn {C/6/1} – Mr Wilcox -O’Hearn is a computer scientist in the field of cryptography and cryptocurrency. He wrote early blogposts about Bitcoin and states that he never received any Bitcoin from Satoshi, as Dr Wright has claimed he did. This evidence was barely challenged, and Mr Wilcox - O’Hearn was a clear and conscientious witness. He also revealed how passionate he was abou t Satoshi Nakamoto, referring to him as his “ hero” and saying with some force that if, as alleged by Dr Wright, he had received bitcoin from his hero, he would certainly have remembered it. 293 He was also very clear that he had not 292 {L1/115/1} . 293 {Day14/80:14} . 66 downloaded the Bitcoin source code for a number of years, explaining that he did not even use Windows at the time (the bitcoin software having been Windows - only until at least 2010).294 Whilst he wanted the system to work, he thought it might be a glorious failure.295 When it was put to him that he must have become more actively involved earlier, he replied disarmingly: “ You underestimate my laziness and procrastination.”296 It is thus clear that Dr Wright’s claims to have sent Bitcoin to Mr Wilcox O’Hearn were failed guesswork, based on the public information that he was the first person to have blogged about bitcoin, shortly after its release. 174.7. Dustin Trammell {C/7/1} – Mr Trammell is an Information Security Research Scientist who corresponded with Satoshi in January 2009. He gives evidence of his correspondence with Satoshi and exhibits it. He denies a claim Dr Wright made in his evidence in the Granath proceedings that Dr Wright as Satoshi shared Bitcoin code with him. This evidence was unchallenged. Dr Wright must therefore be taken to concede that his claim that code was shared with Mr Trammell was unfounded and false. 174.8. John Hudson {C/8/1} – Mr Hudson is the lead designer of the font Nirmala UI and confirms it was not publicly available until March 2012 at the earliest. This is relevant to a number of Mr Madden’s findings that documents of Dr Wright are not authentic to their suggested dates and have been backdated. This evidence was unchallenged. 174.9. Adam Back {C/9/1} {C/21/1} – Dr Back is a cryptographer and inventor of “Hashcash”, which was cited in the White Paper. He gives evidence of some email communications with Satoshi which had not previously been made publi c. They undermine Dr Wright’s accounts of his work on the White Paper before its release (as largely reiterated in Wright 1). For instance, Dr Wright says that Wei Dai’s work profoundly influenced his development of Bitcoin for years, whereas Dr Back’s emails show that he told Satoshi about Wei Dai’s work on 21 August 2008 and that Satoshi had not previously known of it. This is also telling because 294 See for instance {Day14/75:1} . 295 {Day14/78:14} . 296 {Day14/81:2} . 67 Dr Wright’s supposed precursor drafts of the White Paper (said to predate August 2008) have the reference to Wei Dai’s B -money paper. Dr Back also provided a short second statement rebutting some of the claims Dr Wright makes about Dr Back’s attitude and interactions with Satoshi. Dr Back gave clear and cogent evidence, backed up by contemporaneous documents. The attempts by Mr Orr KC to press Dr Back to agree with Dr Wright that the proof -of-work in Bitcoin owed no meaningful debt to Hashcash were valiant but hopeless. 297 It was also striking how clearly superior Dr Back was to Dr Wright in terms of technica l knowledge about the Bitcoin system and code and the ability to parse and convey that information. Dr Back was challenged on his independence, but this attack was baseless. 174.10. Nicholas Bohm {C/10/1} – Mr Bohm was a retired solicitor who corresponded with Sa toshi shortly after the release of Bitcoin in January 2009. Mr Bohm has provided evidence of his email communications with Satoshi that were not before made public (and to which Dr Wright had never referred). He has also provided a version of the White P aper that he downloaded in January 2009, which Mr Madden has authenticated 298 and which is used as a control copy. This evidence was unchallenged. 174.11. Ben Ford {C/11/1} – Mr Ford is the director of a company trading as DataStation who gives evidence about a DataStation notepad which is one of Dr Wright’s Reliance Documents (ID_004018).299 This presents as being a set of pre -release development notes on the Bitcoin concept. Mr Ford explains that the notepad was not printed until 22 May 2012. Dr Wright has reacted to this evidence in his Chain of Custody schedule by saying that the notes were written in 2011 / 2012. Again, this cover story has its own difficulties that wi ll be explored at trial. This evidence was unchallenged. 174.12. Steve Lee {C/12/1} – Mr Lee is a board member of COPA. He is a Bitcoin developer and works for a team called Spiral, which is funded by Block, Inc (a Represented Party). He gives evidence on the chilling effect of Dr Wright’s 297 See for example the exchange from {Day13/45:2} - {Day13/53:22} . 298 See Appendix PM3, from §41 {H/20/14} . 299 {L7/471/1} . 68 claims to be Satoshi, giving examples of how Dr Wright wishes to people to lose their families and be subject to criminal law sanctions (including reference to the death penalty). This evidence was largely unchallenged. It is remarkable how short a time Mr Lee was in the witness box, given that his evidence is the primary evidence from COPA as to the need for the declaratory and injunctive relief. None of his evidence that goes to relief was challenged. Instead, there were s ome inconsequential fishing questions about his and Block’s role
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UK as well, isn't it? A. No, it's consistent with someone doing work in the UK. I used to have my time zone set to America when I was doing American work. {Day15/52:17} - {Day15/53:9} {CSW/31/1} - TimeDoc2.pdf MR JUSTICE MELLOR: I’m not sure that was counsel’s suggestion. What his question was: it would have been perfectly possible to write this document today and backdate its timestamp? It’s a pretty simpl e question. A. I don’t think it would be feasible, my Lord. I think it would actually lead to changes. The software available online isn’t the same versions. The ones that are downloaded are the patched ones with no security problems. This means that I would have to have a version of the software that isn't the one downloaded, that it would just be sitting in my drawer waiting for me to do it on a version of Windows, including all the old patches, then zipped with an old ZIPX thing that doesn't exist any more. I don't think it's feasible. I think the reason that no one's showing you could do this is I don't believe it's feasible. The difference would be the versioning would be the new versions that are downloadable, not the patched versions that weren't. Mellor J intervenes to make Dr Wright answer the question. Dr Wright then suggests, implausibly, that it would not have been possible to backdate the document’s timestamp. {Day15/53:18} - {Day15/54:6} Q. Well, Dr Wright, just before our break, this point, so that it's been put to you. As Mr Madden's found, it would just be a matter of downloading the software available today and Dr Wright attempting to explain that the forgery would have been technically Appendix B: Schedule of Transcript References 490 REFERENCE QUOTE COMMENT rewriting this document to produce a forgery. That's all it would involve, isn't it? A. No. As you note, it's a version that is an unpatched version. So you would have to actually download the source code, remove the patching, go back to a vulnerable version of OpenOffice that was patched intentionally and removed. You could probably find that if you talk to the right developers -- which I haven't done, most of them are associated with COPA -- and then build a version, but that would be a huge effort. I'm talking a month of work for a document. advanced to produce, and therefore it is less likely to have been done. To the contrary, Mr Madden’s expert evidence indicates that to produce such forgery would have been simple. {Day15/54:14- 22} {CSW/31/2} TimeDoc2 MR HOUGH: May we have on screen {CSW/31/2}. Continuing with the TimeDoc 2 document and looking now at an example of the images in the document, Dr Wright, Mr Madden found that those were embedded picture images of low resolution and pixelated by comparison with those in the Bitcoin White Paper. Do you agree with that finding? A. Yes, they weren't coded using the LaTeX in the same way. I was experimenting with different things at the time. Dr Wright is unable to provide an actual explanation for what he did to create the images in the document, just that he experimented with ’different things’. Comparison between Wright’s TimeDoc2 document and the actual Bitcoin White Paper {Day15/55:1- 15} A. Yes, and the White Paper, as I've shown, was done in LaTeX, and the creation in LaTeX of the image leads to differences when you export it as an SVN. Q. We obviously dispute that the White Paper was created in LaTeX, Dr Wright, but the pixela ted images in your document are consistent with them having been screenshots from the Bitcoin White Paper images simply inserted into the document; that's right, isn't it? A. No, completely different. If they were screenshots, they wouldn't have the - - the same sort of depth. It's actually darker. What they relate to are other versions of the image file that I've played with where I was experimenting with converting from the images rather than in, like, the native LaTeX output into image files tha t I could use on a website, etc. Q. So you -- in this later document, you produced worse quality images through experimentation, Dr Wright? A. Yes. I was looking at putting them on the website at one stage, and the information in the LaTeX export needs to be converted into, well, common images for people to be able to download. Dr Wright implausibly suggesting that the worse quality images found in his document were because he deliberately made them worse quality to be able to put them on a website. Appendix B: Schedule of Transcript References 491 REFERENCE QUOTE COMMENT {Day15/56:17} - {Day15/57:15} Q. Dr Wright, I've put to you that some of your documents contain positive indicia of forgery. But it's right to say, isn't it, that it is possible to create a document with more or fewer indicia of forgery; corr ect? Can you at least accept that? A. Not the way you're putting it, no. I mean, the words I'd use probably aren't the ones I should use in court, but, no, I disagree. And you already know that I have image files in LaTeX I could -- and they go back to this sort of time frame. I could have easily had different levels now created. I could have had them high resolution. Q. This -- this -- A. And if I took a screenshot, by the way, I could do a screenshot -- I've got an 8K card that would be way better than the existing White Paper. Q. Dr Wright, I am not interested in your boasts about cards that you possess that would allow you to forge it even better. Focusing upon the document. Mr Madden found that this document, TimeDoc 2.zip, which contained t he PDF, was hash identical to a file on the Samsung Drive in a folder entitled "BDO". Would you accept that finding? A. Possibly. Dr Wright not accepting of the obvious truth, and a simple proposition, that it is possible to produce documents with more or fewer indicia of forgery. {Day15/57:25} - {Day15/59:12} Q. Dr Wright, this document, TimeDoc 2.pdf, is not a document which was in your original disclosure; would you accept that? A. I would, because the Samsung Drive wasn't imaged correctly. Q. So this was a document that you didn't have until September 2 023, and then suddenly, in the
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 194 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: UK as well, isn't it? A. No, it's consistent with someone doing work in the UK. I used to have my time zone set to America when I was doing American work. {Day15/52:17} - {Day15/53:9} {CSW/31/1} - TimeDoc2.pdf MR JUSTICE MELLOR: I’m not sure that was counsel’s suggestion. What his question was: it would have been perfectly possible to write this document today and backdate its timestamp? It’s a pretty simpl e question. A. I don’t think it would be feasible, my Lord. I think it would actually lead to changes. The software available online isn’t the same versions. The ones that are downloaded are the patched ones with no security problems. This means that I would have to have a version of the software that isn't the one downloaded, that it would just be sitting in my drawer waiting for me to do it on a version of Windows, including all the old patches, then zipped with an old ZIPX thing that doesn't exist any more. I don't think it's feasible. I think the reason that no one's showing you could do this is I don't believe it's feasible. The difference would be the versioning would be the new versions that are downloadable, not the patched versions that weren't. Mellor J intervenes to make Dr Wright answer the question. Dr Wright then suggests, implausibly, that it would not have been possible to backdate the document’s timestamp. {Day15/53:18} - {Day15/54:6} Q. Well, Dr Wright, just before our break, this point, so that it's been put to you. As Mr Madden's found, it would just be a matter of downloading the software available today and Dr Wright attempting to explain that the forgery would have been technically Appendix B: Schedule of Transcript References 490 REFERENCE QUOTE COMMENT rewriting this document to produce a forgery. That's all it would involve, isn't it? A. No. As you note, it's a version that is an unpatched version. So you would have to actually download the source code, remove the patching, go back to a vulnerable version of OpenOffice that was patched intentionally and removed. You could probably find that if you talk to the right developers -- which I haven't done, most of them are associated with COPA -- and then build a version, but that would be a huge effort. I'm talking a month of work for a document. advanced to produce, and therefore it is less likely to have been done. To the contrary, Mr Madden’s expert evidence indicates that to produce such forgery would have been simple. {Day15/54:14- 22} {CSW/31/2} TimeDoc2 MR HOUGH: May we have on screen {CSW/31/2}. Continuing with the TimeDoc 2 document and looking now at an example of the images in the document, Dr Wright, Mr Madden found that those were embedded picture images of low resolution and pixelated by comparison with those in the Bitcoin White Paper. Do you agree with that finding? A. Yes, they weren't coded using the LaTeX in the same way. I was experimenting with different things at the time. Dr Wright is unable to provide an actual explanation for what he did to create the images in the document, just that he experimented with ’different things’. Comparison between Wright’s TimeDoc2 document and the actual Bitcoin White Paper {Day15/55:1- 15} A. Yes, and the White Paper, as I've shown, was done in LaTeX, and the creation in LaTeX of the image leads to differences when you export it as an SVN. Q. We obviously dispute that the White Paper was created in LaTeX, Dr Wright, but the pixela ted images in your document are consistent with them having been screenshots from the Bitcoin White Paper images simply inserted into the document; that's right, isn't it? A. No, completely different. If they were screenshots, they wouldn't have the - - the same sort of depth. It's actually darker. What they relate to are other versions of the image file that I've played with where I was experimenting with converting from the images rather than in, like, the native LaTeX output into image files tha t I could use on a website, etc. Q. So you -- in this later document, you produced worse quality images through experimentation, Dr Wright? A. Yes. I was looking at putting them on the website at one stage, and the information in the LaTeX export needs to be converted into, well, common images for people to be able to download. Dr Wright implausibly suggesting that the worse quality images found in his document were because he deliberately made them worse quality to be able to put them on a website. Appendix B: Schedule of Transcript References 491 REFERENCE QUOTE COMMENT {Day15/56:17} - {Day15/57:15} Q. Dr Wright, I've put to you that some of your documents contain positive indicia of forgery. But it's right to say, isn't it, that it is possible to create a document with more or fewer indicia of forgery; corr ect? Can you at least accept that? A. Not the way you're putting it, no. I mean, the words I'd use probably aren't the ones I should use in court, but, no, I disagree. And you already know that I have image files in LaTeX I could -- and they go back to this sort of time frame. I could have easily had different levels now created. I could have had them high resolution. Q. This -- this -- A. And if I took a screenshot, by the way, I could do a screenshot -- I've got an 8K card that would be way better than the existing White Paper. Q. Dr Wright, I am not interested in your boasts about cards that you possess that would allow you to forge it even better. Focusing upon the document. Mr Madden found that this document, TimeDoc 2.zip, which contained t he PDF, was hash identical to a file on the Samsung Drive in a folder entitled "BDO". Would you accept that finding? A. Possibly. Dr Wright not accepting of the obvious truth, and a simple proposition, that it is possible to produce documents with more or fewer indicia of forgery. {Day15/57:25} - {Day15/59:12} Q. Dr Wright, this document, TimeDoc 2.pdf, is not a document which was in your original disclosure; would you accept that? A. I would, because the Samsung Drive wasn't imaged correctly. Q. So this was a document that you didn't have until September 2 023, and then suddenly, in the
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follows: Fifth expert report of Patrick Madden Page 11 of 66 34. I observe that, a. it includes an indication that “You replied to this message on 17/10/2014 at 06:21” b. the email addresses for sender and recipient present normally, and that they present an address popup window when hovered over as shown below: Fifth expert report of Patrick Madden Page 12 of 66 35. By contrast the email message {ID_001414} exhibits some abnormalities. As shown below it exhibits the irregular “on behalf of” characteristic seen with some other email documents within the disclosure dataset: 36. While both email addresses in the ‘From’ field produce an address popup window, the recipient address is unavailable and is selectable as plain text as below, a characteristic also seen with some other irregular emails: Fifth expert report of Patrick Madden Page 13 of 66 37. Returning to {ID_001396}, inspecting the Outlook specific metadata I confirmed the internal metadata timestamps as follows. The PR_Creation_Time and PR_Last Modification timestamps are consistent with the email message having been exported from MS Outlook into an individual MSG file just under an hour after it was authored and sent: Record GMT timestamp PR_CLIENT_SUBMIT_TIME 04:30, 17/10/2014 PR_CREATION_TIME 05:22, 17/10/2014 PR_LAST_MODIFICATION_TIME 05:22, 17/10/2014 PR_MESSAGE_DELIVERY_TIME 04:30, 17/10/2014 38. The manner in which this was conducted has preserved the content of the email message, and other metadata pertinent to the message, such as the record that the email had been replied to just under an hour after it was sent (“You replied to this message on 17/10/2014 at 06:21 ”). 39. While I discuss the content of the message in more detail below, I cannot find a reason to doubt the authenticity of this document. 40. The same cannot be said for ID_001414, which has the following timestamps recorded in the file: Record GMT timestamp PR_CLIENT_SUBMIT_TIME 04:30, 17/10/2014 PR_CREATION_TIME 22:43, 08/08/2019 PR_LAST_MODIFICATION_TIME 22:43, 08/08/2019 PR_MESSAGE_DELIVERY_TIME 04:30, 17/10/2014 41. I observe that in addition to the anomalous presentation of the email sender and recipient fields, and the omission of the Replied to record, {ID_001414} has also had some other timestamps removed or obscured. 42. Considering these points {ID_001414} appears to have been handled poorly and not to be a good forensic copy of the email, and I do not consider that the .MSG file is an ideal contender for forensic examination. Had it not been for the presence of {ID_00139 6} within the disclosure dataset, I would have assessed the .MSG file {ID_001414} as unreliable and likely contaminated during the preservation or processing stages. Fifth expert report of Patrick Madden Page 14 of 66 Chain of custody information 43. The chain of custody information provided in relation to these two files is as follows: Document ID Devices/accounts from which obtained Date of collection Collector ID_001396 AP ref: F0030927 - 0001 -01 Unknown Date unknown: Data collected by ATO and provided to eLaw/LaxonLex. 21 May 2019 - Data transferred to AlixPartners via Box from eLaw as a production set and loaded directly to Relativity eLaw ID_001414 AP ref: E0030531 - 0001 -01 Laptop – ASUS R552J – System Serial Number - DAN0CY467767442 with 1500 GB capacity Custodian: Bobby Wilson, Hotwire PE 4 February 2019 AlixPartners Note: Contains encrypted Bitlocker partition protected with unknown credentials, other partitions (including user partition) are not encrypted and appear readable; HW0327 BOBBY WILSON HOTWIREPE. Drive removed from laptop and imaged using a Tableau TD2u wri te blocker to encrypted disk. Laptop remained on site. 44. Of these, a. For {ID_001414}, the information provided indicates that the anomalous timestamps are likely the result of handling errors after collection, and may relate to how the emails were handled after the imaging of the drive. It appears to have been exported in a way that did not preserve it forensically intact, causing metadata to be overwritten and/or lost. b. For {ID_001396}, the information provided indicates that it was collected by the ATO which I understand to be in connection with earlier litigation, and the metadata does seem to have been preserved. Dr Wright’s analysis of the Transmission header of the email 45. I do not agree with Dr Wright’s analysis of this email (in either of its forms) for the reasons set out below. 46. The portion of the email message that Dr Wright used for his analysis is the Transmission header. I have established that this was identical between {ID_001396} and {ID_001414}. Although {ID_001414} exhibits differences in other areas, those do not affect Dr Wright’s analysis or mine. 47. Dr Wright has not shown the plain text of the Transmission header of the email message, but has used a method available in MS Outlook. This is that he has opened the document using MS Outlook, and he has clicked on “File” and the “Properties” to produce a copy of the screenshot Fifth expert report of Patrick Madden Page 15 of 66 that follows paragraph 43 on his Eleventh Witness Statement {CSW/1/8}. This is an acceptable way to view a Transmission header. 48. I agree that the Transmission header indicates that the email was transmitted by abacus - offshore.com using Google email infrastructure. There are several indicators of this within the Transmission header. 49. The below extract from the Transmission header relates to the first hop or transmission step that the email undertook.
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 5 of 20 Fifth Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Fifth Expert Report of Patrick Madden.pdf ### File content: follows: Fifth expert report of Patrick Madden Page 11 of 66 34. I observe that, a. it includes an indication that “You replied to this message on 17/10/2014 at 06:21” b. the email addresses for sender and recipient present normally, and that they present an address popup window when hovered over as shown below: Fifth expert report of Patrick Madden Page 12 of 66 35. By contrast the email message {ID_001414} exhibits some abnormalities. As shown below it exhibits the irregular “on behalf of” characteristic seen with some other email documents within the disclosure dataset: 36. While both email addresses in the ‘From’ field produce an address popup window, the recipient address is unavailable and is selectable as plain text as below, a characteristic also seen with some other irregular emails: Fifth expert report of Patrick Madden Page 13 of 66 37. Returning to {ID_001396}, inspecting the Outlook specific metadata I confirmed the internal metadata timestamps as follows. The PR_Creation_Time and PR_Last Modification timestamps are consistent with the email message having been exported from MS Outlook into an individual MSG file just under an hour after it was authored and sent: Record GMT timestamp PR_CLIENT_SUBMIT_TIME 04:30, 17/10/2014 PR_CREATION_TIME 05:22, 17/10/2014 PR_LAST_MODIFICATION_TIME 05:22, 17/10/2014 PR_MESSAGE_DELIVERY_TIME 04:30, 17/10/2014 38. The manner in which this was conducted has preserved the content of the email message, and other metadata pertinent to the message, such as the record that the email had been replied to just under an hour after it was sent (“You replied to this message on 17/10/2014 at 06:21 ”). 39. While I discuss the content of the message in more detail below, I cannot find a reason to doubt the authenticity of this document. 40. The same cannot be said for ID_001414, which has the following timestamps recorded in the file: Record GMT timestamp PR_CLIENT_SUBMIT_TIME 04:30, 17/10/2014 PR_CREATION_TIME 22:43, 08/08/2019 PR_LAST_MODIFICATION_TIME 22:43, 08/08/2019 PR_MESSAGE_DELIVERY_TIME 04:30, 17/10/2014 41. I observe that in addition to the anomalous presentation of the email sender and recipient fields, and the omission of the Replied to record, {ID_001414} has also had some other timestamps removed or obscured. 42. Considering these points {ID_001414} appears to have been handled poorly and not to be a good forensic copy of the email, and I do not consider that the .MSG file is an ideal contender for forensic examination. Had it not been for the presence of {ID_00139 6} within the disclosure dataset, I would have assessed the .MSG file {ID_001414} as unreliable and likely contaminated during the preservation or processing stages. Fifth expert report of Patrick Madden Page 14 of 66 Chain of custody information 43. The chain of custody information provided in relation to these two files is as follows: Document ID Devices/accounts from which obtained Date of collection Collector ID_001396 AP ref: F0030927 - 0001 -01 Unknown Date unknown: Data collected by ATO and provided to eLaw/LaxonLex. 21 May 2019 - Data transferred to AlixPartners via Box from eLaw as a production set and loaded directly to Relativity eLaw ID_001414 AP ref: E0030531 - 0001 -01 Laptop – ASUS R552J – System Serial Number - DAN0CY467767442 with 1500 GB capacity Custodian: Bobby Wilson, Hotwire PE 4 February 2019 AlixPartners Note: Contains encrypted Bitlocker partition protected with unknown credentials, other partitions (including user partition) are not encrypted and appear readable; HW0327 BOBBY WILSON HOTWIREPE. Drive removed from laptop and imaged using a Tableau TD2u wri te blocker to encrypted disk. Laptop remained on site. 44. Of these, a. For {ID_001414}, the information provided indicates that the anomalous timestamps are likely the result of handling errors after collection, and may relate to how the emails were handled after the imaging of the drive. It appears to have been exported in a way that did not preserve it forensically intact, causing metadata to be overwritten and/or lost. b. For {ID_001396}, the information provided indicates that it was collected by the ATO which I understand to be in connection with earlier litigation, and the metadata does seem to have been preserved. Dr Wright’s analysis of the Transmission header of the email 45. I do not agree with Dr Wright’s analysis of this email (in either of its forms) for the reasons set out below. 46. The portion of the email message that Dr Wright used for his analysis is the Transmission header. I have established that this was identical between {ID_001396} and {ID_001414}. Although {ID_001414} exhibits differences in other areas, those do not affect Dr Wright’s analysis or mine. 47. Dr Wright has not shown the plain text of the Transmission header of the email message, but has used a method available in MS Outlook. This is that he has opened the document using MS Outlook, and he has clicked on “File” and the “Properties” to produce a copy of the screenshot Fifth expert report of Patrick Madden Page 15 of 66 that follows paragraph 43 on his Eleventh Witness Statement {CSW/1/8}. This is an acceptable way to view a Transmission header. 48. I agree that the Transmission header indicates that the email was transmitted by abacus - offshore.com using Google email infrastructure. There are several indicators of this within the Transmission header. 49. The below extract from the Transmission header relates to the first hop or transmission step that the email undertook.
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and time stamp in each of them : a.ID_000553 contains a date and time s tamp which decodes as 21/10/2008 15:32:29. b.The same timestamp in ID_000554 decodes as 21/10/2008 15:34:15 c.These are both 10 hours behind the OS file created timestamp provided with thedataset. Although no time zone offset was provided with that supplied metadata, it isconsistent with the OS file created timestamps being expressed in British SummerTime (UTC+ 1) and the encoded OLE timestamps being encoded from UTC+11 . Although it confirms my view that the provided metadata is not reliable as to thetimezone in which it is expressed, I do not draw any conclusions about theauthenticity of the document based on the possible explanation of the difference. d.The presence of these tags in the metadata does not inform my analysis further, asthere would be no visible difference between them depending on whether they were authentically created in 2008 or whether they were created at a different time by the use of clock manipulation techniques to artificially set the computer clock to 2008. 69. Secondly, I observed the inclusion of the user profile name on the computer used to interact with the document. For ID_000553 and ID_000554 this is recorded as “Admin” (a username which I note corresponds to the recorded author name for some otherdocuments such as ID_001007 and other documents in the disclosure dataset) . However,{ID_000375} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_001007} Madden Appe ndix PM10 “Source code flowcharts ” ID_000553 – ID_000554 – ID_000375 Page 26 of 27 this fact is not sufficient to assist my analysis , in view of the fact that “Admin” would be a common username for an administrator account. Conclusions on ID_000375 and ID_000554 70. As I have explained in the course of the analysis above, I consider ID_000554 (TIF) to have been created based on ID_000375 (PDF). 71. ID_000375 contains significant hallmarks of document manipulation which indicate that the text has been edited to add the words “BitCoin main.h” and to change the date on the face of the document to 2008; and within the document, there are traces o f the previous title indicating the use of the Code2flow website to generate the document . 72. Although they bear contextual dates in 2008, I do not consider it would have been possible to generate ID_000375 at that date, which I have confirmed based on severa l independent observations. In particular, the software used to generate it is hosted on a URL which was not registered until 2012, the file contains embedded fonts which aremarked as copyright © 2015 and the software used to author the PDF was not released until February 2016. 73. ID_000554 and ID_000375 do contain metadata timestamps purporting to indicate that they originate from 2008. However, in view of the impossibility of creating those documents in 2008, it is my opinion that those 2008 metadata tim estamps are generated by simply changing the clock setting on the computer used to generate them , or the more complex method of manually altering them with the use of a hex editor. 74. It therefore follows that in my opinion neither ID_000375 nor ID_000554 is authentic to their purported 2008 creation dates. From the information available they were createdafter 13/02/2016 in a manner that both obfuscated their content and represented them as having been created in 2008. Conclusions on ID_000553 75. Although ID_000554 (TIFF) appears to have its origin in ID_000375 (PDF), I could find no equivalent PDF corresponding to ID_000553 within the data set provided. 76. Without a predecessor PDF document to use for comparison purposes, and in light of the minimal metadata available for TIFF documents, I cannot draw any certain conclusions as to the authenticity of ID_000553 itself. However, I can say with some certainty t hat the document is an electronically converted version of another document, and that that{ID_000375} {ID_000554} {ID_000375} {ID_000375} {ID_000554} {ID_000375} {ID_000375} {ID_000554} {ID_000553} {ID_000554} {ID_000375} {ID_000553} {ID_000553} Madden Appe ndix PM10 “Source code flowcharts ” ID_000553 – ID_000554 – ID_000375 Page 27 of 27 original document (which is not available to me) would very likely enable the authenticity of ID_000553 to be investigated more thoroughly. 77. I was not able to invest igate ID_000553 further on its own, save for conducting a comparative analysis in the context of ID_000554 and ID_000375. In view of the close similarity between ID_000554 and ID_000553 (in terms of their timestamps, content, relative locations of content within the document, apparent similarities in their manner of production, similarities in their visual flowchart style, level of pixell ation, TIFF file format, and use of binary colour encoding), ID_000554 appears to have been generated in a very s imilar way to ID_000553. If that is the case, g iven that ID_000554 was generated through the use of an online tool which did not appear to exist at the purported creationdate in 2008, the same conclusions regarding the origins and apparent inauthenticity ofID_000554 and ID_000375 would appear to apply equally to ID_000553, unless further analysis of the underlying original document behind it can be provided together with anyadditional information as to the circumstances of its creation .{ID_000553} {ID_000553} {ID_000554} {ID_000375} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_000375} {ID_000553}
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 8 of 8 Appendix PM10.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM10.pdf ### File content: and time stamp in each of them : a.ID_000553 contains a date and time s tamp which decodes as 21/10/2008 15:32:29. b.The same timestamp in ID_000554 decodes as 21/10/2008 15:34:15 c.These are both 10 hours behind the OS file created timestamp provided with thedataset. Although no time zone offset was provided with that supplied metadata, it isconsistent with the OS file created timestamps being expressed in British SummerTime (UTC+ 1) and the encoded OLE timestamps being encoded from UTC+11 . Although it confirms my view that the provided metadata is not reliable as to thetimezone in which it is expressed, I do not draw any conclusions about theauthenticity of the document based on the possible explanation of the difference. d.The presence of these tags in the metadata does not inform my analysis further, asthere would be no visible difference between them depending on whether they were authentically created in 2008 or whether they were created at a different time by the use of clock manipulation techniques to artificially set the computer clock to 2008. 69. Secondly, I observed the inclusion of the user profile name on the computer used to interact with the document. For ID_000553 and ID_000554 this is recorded as “Admin” (a username which I note corresponds to the recorded author name for some otherdocuments such as ID_001007 and other documents in the disclosure dataset) . However,{ID_000375} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_001007} Madden Appe ndix PM10 “Source code flowcharts ” ID_000553 – ID_000554 – ID_000375 Page 26 of 27 this fact is not sufficient to assist my analysis , in view of the fact that “Admin” would be a common username for an administrator account. Conclusions on ID_000375 and ID_000554 70. As I have explained in the course of the analysis above, I consider ID_000554 (TIF) to have been created based on ID_000375 (PDF). 71. ID_000375 contains significant hallmarks of document manipulation which indicate that the text has been edited to add the words “BitCoin main.h” and to change the date on the face of the document to 2008; and within the document, there are traces o f the previous title indicating the use of the Code2flow website to generate the document . 72. Although they bear contextual dates in 2008, I do not consider it would have been possible to generate ID_000375 at that date, which I have confirmed based on severa l independent observations. In particular, the software used to generate it is hosted on a URL which was not registered until 2012, the file contains embedded fonts which aremarked as copyright © 2015 and the software used to author the PDF was not released until February 2016. 73. ID_000554 and ID_000375 do contain metadata timestamps purporting to indicate that they originate from 2008. However, in view of the impossibility of creating those documents in 2008, it is my opinion that those 2008 metadata tim estamps are generated by simply changing the clock setting on the computer used to generate them , or the more complex method of manually altering them with the use of a hex editor. 74. It therefore follows that in my opinion neither ID_000375 nor ID_000554 is authentic to their purported 2008 creation dates. From the information available they were createdafter 13/02/2016 in a manner that both obfuscated their content and represented them as having been created in 2008. Conclusions on ID_000553 75. Although ID_000554 (TIFF) appears to have its origin in ID_000375 (PDF), I could find no equivalent PDF corresponding to ID_000553 within the data set provided. 76. Without a predecessor PDF document to use for comparison purposes, and in light of the minimal metadata available for TIFF documents, I cannot draw any certain conclusions as to the authenticity of ID_000553 itself. However, I can say with some certainty t hat the document is an electronically converted version of another document, and that that{ID_000375} {ID_000554} {ID_000375} {ID_000375} {ID_000554} {ID_000375} {ID_000375} {ID_000554} {ID_000553} {ID_000554} {ID_000375} {ID_000553} {ID_000553} Madden Appe ndix PM10 “Source code flowcharts ” ID_000553 – ID_000554 – ID_000375 Page 27 of 27 original document (which is not available to me) would very likely enable the authenticity of ID_000553 to be investigated more thoroughly. 77. I was not able to invest igate ID_000553 further on its own, save for conducting a comparative analysis in the context of ID_000554 and ID_000375. In view of the close similarity between ID_000554 and ID_000553 (in terms of their timestamps, content, relative locations of content within the document, apparent similarities in their manner of production, similarities in their visual flowchart style, level of pixell ation, TIFF file format, and use of binary colour encoding), ID_000554 appears to have been generated in a very s imilar way to ID_000553. If that is the case, g iven that ID_000554 was generated through the use of an online tool which did not appear to exist at the purported creationdate in 2008, the same conclusions regarding the origins and apparent inauthenticity ofID_000554 and ID_000375 would appear to apply equally to ID_000553, unless further analysis of the underlying original document behind it can be provided together with anyadditional information as to the circumstances of its creation .{ID_000553} {ID_000553} {ID_000554} {ID_000375} {ID_000553} {ID_000554} {ID_000553} {ID_000554} {ID_000375} {ID_000553}
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dated 2002 on its face and contains wording which appears in the White Paper. However, the document bears metadata indicating that it was created in 2014. Further, the sections which reflect content of the White Paper are incongruous with the rest of the document, which describes an IT security project without any transactional features. 193.2. Another document, ID_000013 {L1/80/1} , is similar to ID_001379 and appears to be authentic to 2002. However, the wording appearing in the White Paper does not feature in this document, supporting COPA’s case that that wording was introduced after the document had been produced. 193.3. A third document, ID_001016 {L7/211/1} , contains an email address “[email protected] ”, and Dr Wright’s signature alongside a date “15/Mar/2009”. However, the domain Intergyrs.com was not registered until about 6 weeks after that, so that the document must be backdated. 194. The BlackNet documents share a common theme with a number of the other documents Dr Wright has forged, in that there is a genuine underlying document into which he has sought to retrospectively introduce Bitcoin concepts. This has evidently been done to try and give the impression that all of Dr Wright’s activities led up to the creation of Bitcoin. 333 See Appendix PM42 at {H/209/7} , especially §§31ff. 334 {Q/2/9} . 76 (3) NAB Records [ID_003455] (with attachments) – Appendix PM17 {H/78/1} 195. The NAB records ({L15/101/1} and {L/15/102/1} ) comprise screenshots in an email from Dr Wright to his colleague Jimmy Nguyen that appear on their face to come from Dr Wright’s personal internet banking records. They appear to show purchase of hosting services from Anonymousspeech, which might support Dr Wright’s claim that he purchased both the Satoshi Vistomail email account and the bitcoin.org domain from that organization. He has repeatedly asserted that he could “categorically ” prove his ownership of Satoshi accounts by way of his bank accounts / credit cards statements.335 196. The Madden Report demonstrated that these records are inauthentic, because the screenshots were taken at a time (in 2018) when the records (from 2008) could not have been accessed. Dr Placks agrees with this conclusion.336 Following the service of the Madden Report, Dr Wright admitted that these bank records are not authentic,337 and he has disclosed entirely different copies of bank records over the period which do not show the same transactions. As explained below, Dr Wright has come up with an excuse for the original records being fakes , but it is wholly unconvincing. (4) Spoofed Email [ID_001546] – Appendix PM21 {H/104/1} 197. Appendix PM21 addresses emails which appear to have been sent by Satoshi Nakamoto and appear on their face to support Dr Wright’s case on the Identity Issue. However, Mr Madden has determined that “spoofing” techniques were used to set the “sender” details to indicate a false origin; an email address unconnected to the actual sender.338 Mr Madden’s conclusions link the spoofed emails to Dr Wright’s own mailbox. COPA has included one of these in its list of forgeries (ID_001546 {L8/338/1} ); a 2014 email apparently being from Satoshi to Uyen Nguyen (Dr Wright ’s erstwhile associate) . For that email, the spoofing is indicated by simple use of the cursor over the email addresses, but there are also multiple indicia in the transmission header . COPA also points also to another (ID_002586) as evidence of the same techniques.339 335 See his article, “Evidence and Law” dated 12 April 2019 {L14/451/ 3} and a transcript of a Daily Exchange April 2019 interview with him by Fred Schebesta at {O4/25/34} . 336 {Q/2/9} . 337 See letter from Travers Smith dated 27 September 2023 {M/2/205} . 338 See Appendix PM21 at §6-35 {H/104/2} . 339 See Appendix PM21 at §§36- 55 {H/104/10} . 77 (5) Bitcoin.exe [ID_000739] – Appendix PM12 {H/68/1} 198. This is a different type of forgery from most of the others, in that it is an example of Dr Wright seeking to lay a false trail thorough doctored program code. Dr Wright has disclosed a bitcoin.exe file, ID_000739 {L3/474/1} (along with four others), which contains signs of hex editing of the .exe files (which are of course publicly available) to suggest that Dr Wright was an author of the code. The files also contain metadata irregularities. 199. Using a standard hex editor, Mr Madden was able to determine that the name Satoshi Nakamoto was replaced by Dr Craig Wright in the copyright notice. Mr Madden states that these changes are more consistent with edits being made in hexadecimal by way of binary editing, rather than being different compiled versions of the same code. Further, when checking the checksum for ID_000739, Mr Madden found that the checksum set out in the header was invalid, i.e. the checksum matched the genuine bitcoin file but the amends made by Dr Wright changed the actual checksum when that was checked. (6) Timecoin ODT [ID_000254] – Appendix PM2 {H/17/1} 200. This is a Reliance Document which purports to be a precursor to the White Paper: {L2/441/1} . In reality it is a modified version of the published White Paper (PDF), and there are numerous indicia of forgery: 200.1. Notes appear in the text in a font (Arial) different from that in the main text and different from the font attributed to the empty lines above and below the notes, consistent with the font having been derived from a flowchart that appears in the published White Paper in the relevant places. 200.2. An odd “OBJ” symbol appears below text where,
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 34 of 51 COPA v Wright - Opening Skeleton of COPA.pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/COPA v Wright - Opening Skeleton of COPA.pdf ### File content: dated 2002 on its face and contains wording which appears in the White Paper. However, the document bears metadata indicating that it was created in 2014. Further, the sections which reflect content of the White Paper are incongruous with the rest of the document, which describes an IT security project without any transactional features. 193.2. Another document, ID_000013 {L1/80/1} , is similar to ID_001379 and appears to be authentic to 2002. However, the wording appearing in the White Paper does not feature in this document, supporting COPA’s case that that wording was introduced after the document had been produced. 193.3. A third document, ID_001016 {L7/211/1} , contains an email address “[email protected] ”, and Dr Wright’s signature alongside a date “15/Mar/2009”. However, the domain Intergyrs.com was not registered until about 6 weeks after that, so that the document must be backdated. 194. The BlackNet documents share a common theme with a number of the other documents Dr Wright has forged, in that there is a genuine underlying document into which he has sought to retrospectively introduce Bitcoin concepts. This has evidently been done to try and give the impression that all of Dr Wright’s activities led up to the creation of Bitcoin. 333 See Appendix PM42 at {H/209/7} , especially §§31ff. 334 {Q/2/9} . 76 (3) NAB Records [ID_003455] (with attachments) – Appendix PM17 {H/78/1} 195. The NAB records ({L15/101/1} and {L/15/102/1} ) comprise screenshots in an email from Dr Wright to his colleague Jimmy Nguyen that appear on their face to come from Dr Wright’s personal internet banking records. They appear to show purchase of hosting services from Anonymousspeech, which might support Dr Wright’s claim that he purchased both the Satoshi Vistomail email account and the bitcoin.org domain from that organization. He has repeatedly asserted that he could “categorically ” prove his ownership of Satoshi accounts by way of his bank accounts / credit cards statements.335 196. The Madden Report demonstrated that these records are inauthentic, because the screenshots were taken at a time (in 2018) when the records (from 2008) could not have been accessed. Dr Placks agrees with this conclusion.336 Following the service of the Madden Report, Dr Wright admitted that these bank records are not authentic,337 and he has disclosed entirely different copies of bank records over the period which do not show the same transactions. As explained below, Dr Wright has come up with an excuse for the original records being fakes , but it is wholly unconvincing. (4) Spoofed Email [ID_001546] – Appendix PM21 {H/104/1} 197. Appendix PM21 addresses emails which appear to have been sent by Satoshi Nakamoto and appear on their face to support Dr Wright’s case on the Identity Issue. However, Mr Madden has determined that “spoofing” techniques were used to set the “sender” details to indicate a false origin; an email address unconnected to the actual sender.338 Mr Madden’s conclusions link the spoofed emails to Dr Wright’s own mailbox. COPA has included one of these in its list of forgeries (ID_001546 {L8/338/1} ); a 2014 email apparently being from Satoshi to Uyen Nguyen (Dr Wright ’s erstwhile associate) . For that email, the spoofing is indicated by simple use of the cursor over the email addresses, but there are also multiple indicia in the transmission header . COPA also points also to another (ID_002586) as evidence of the same techniques.339 335 See his article, “Evidence and Law” dated 12 April 2019 {L14/451/ 3} and a transcript of a Daily Exchange April 2019 interview with him by Fred Schebesta at {O4/25/34} . 336 {Q/2/9} . 337 See letter from Travers Smith dated 27 September 2023 {M/2/205} . 338 See Appendix PM21 at §6-35 {H/104/2} . 339 See Appendix PM21 at §§36- 55 {H/104/10} . 77 (5) Bitcoin.exe [ID_000739] – Appendix PM12 {H/68/1} 198. This is a different type of forgery from most of the others, in that it is an example of Dr Wright seeking to lay a false trail thorough doctored program code. Dr Wright has disclosed a bitcoin.exe file, ID_000739 {L3/474/1} (along with four others), which contains signs of hex editing of the .exe files (which are of course publicly available) to suggest that Dr Wright was an author of the code. The files also contain metadata irregularities. 199. Using a standard hex editor, Mr Madden was able to determine that the name Satoshi Nakamoto was replaced by Dr Craig Wright in the copyright notice. Mr Madden states that these changes are more consistent with edits being made in hexadecimal by way of binary editing, rather than being different compiled versions of the same code. Further, when checking the checksum for ID_000739, Mr Madden found that the checksum set out in the header was invalid, i.e. the checksum matched the genuine bitcoin file but the amends made by Dr Wright changed the actual checksum when that was checked. (6) Timecoin ODT [ID_000254] – Appendix PM2 {H/17/1} 200. This is a Reliance Document which purports to be a precursor to the White Paper: {L2/441/1} . In reality it is a modified version of the published White Paper (PDF), and there are numerous indicia of forgery: 200.1. Notes appear in the text in a font (Arial) different from that in the main text and different from the font attributed to the empty lines above and below the notes, consistent with the font having been derived from a flowchart that appears in the published White Paper in the relevant places. 200.2. An odd “OBJ” symbol appears below text where,
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it still took me more than a year to bring the code up to snuff ; among other things, I had to teach myself Lua, the scripting language that’s embedded in LuaTeX . Fortunately for me, LuaTeX was adding new capabi lities and was also maturing rapidly around the same time, so that it wasn't preposterous anymore to ask normal users to switch from pdfLaTeX to LuaLaTeX to compile their documents. I worked on the selnolig package very intensively all through the fall of 2012 and into the spring of 2013. I posted a first complete version of selnolig to the CTAN[the Comprehensive TeX Archive Network, a website which allows users to download software packages for use with LaTeX ] in May 2013 at https://ctan.org/ctan -ann/id/mailman.4 27.1369694287.5851.ctan - [email protected] , a copy of which is at Exhibit ML1 . 6.After I provided that answer, Bird & Bird showed me the preamble section s of two LaTeX documents , the texts of which are both in Exhibit ML2 . It is possible to see that a package labelled selnolig is called upon at line 42 of each document (using the line numbers shown in Exhibit ML 2). Bird & Bird has asked me whether this would have been possible in 2007. The selnolig package which I uploaded to the CTAN in May 2013 could certainly not have run successfully on versions of LuaLaTeX that existed before 2011. Indeed, I to ok c are to include in the aforementioned announcement to the CTAN a caveat that the selnolig package required “a recent LuaLaTeX format (for example those from TeXLive2012 or 2013)”. I p osted this requirement precisely because I was aware of the fact that earlier versions of LuaLaTeX did not provide all of the functionality that was needed for the selnolig package to run properly. 7.I am not aware of any other LaTeX package that is named selnolig. I came up with the name selnolig by myself in 2011, as an abbreviation for “ selective non-use of typographic lig atures”. I chose this nam e car efully, so as to avoid any possible confusion with the names of any other software piece I was aware of . F or sure , there was no package called selnolig on the CTAN until I uploaded mine in May 2013. 1 https://tex.stackexchange.com/questions/28437/can -one-more -or-less-automatically -suppress -ligatures -for- certain -words , dated 14 September 2011 C/20/2{D/502} {D/503} DECLARATION I understand that the purpose of this witness statement is to set out matters of fact of which I have personal knowledge. I understand that it is not my function to argue the case, either generally or on particular points, or to take the court through the documents in the case. This witness statement sets out only my personal knowledge and recollection, in my own words. On points that I understand to be important in the case, I have stated honestly (a) how well I recall matters and (b) whether my memory has been refreshed by considering documents, if so how and when. I have not been asked or encouraged by anyone to include in this statement anything that is not my own account, to the best of my ability and recollection, of events I witnessed or matters of which I have personal knowledge. I believe th e facts stated in this statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth. SIGNED: Mico Loretan DATED: 6 November 2023 C/20/3
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 2 of 2 Witness Statement of Dr Mico Loretan.pdf ### Folder name: Witness Statements ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Witness Statement of Dr Mico Loretan.pdf ### File content: it still took me more than a year to bring the code up to snuff ; among other things, I had to teach myself Lua, the scripting language that’s embedded in LuaTeX . Fortunately for me, LuaTeX was adding new capabi lities and was also maturing rapidly around the same time, so that it wasn't preposterous anymore to ask normal users to switch from pdfLaTeX to LuaLaTeX to compile their documents. I worked on the selnolig package very intensively all through the fall of 2012 and into the spring of 2013. I posted a first complete version of selnolig to the CTAN[the Comprehensive TeX Archive Network, a website which allows users to download software packages for use with LaTeX ] in May 2013 at https://ctan.org/ctan -ann/id/mailman.4 27.1369694287.5851.ctan - [email protected] , a copy of which is at Exhibit ML1 . 6.After I provided that answer, Bird & Bird showed me the preamble section s of two LaTeX documents , the texts of which are both in Exhibit ML2 . It is possible to see that a package labelled selnolig is called upon at line 42 of each document (using the line numbers shown in Exhibit ML 2). Bird & Bird has asked me whether this would have been possible in 2007. The selnolig package which I uploaded to the CTAN in May 2013 could certainly not have run successfully on versions of LuaLaTeX that existed before 2011. Indeed, I to ok c are to include in the aforementioned announcement to the CTAN a caveat that the selnolig package required “a recent LuaLaTeX format (for example those from TeXLive2012 or 2013)”. I p osted this requirement precisely because I was aware of the fact that earlier versions of LuaLaTeX did not provide all of the functionality that was needed for the selnolig package to run properly. 7.I am not aware of any other LaTeX package that is named selnolig. I came up with the name selnolig by myself in 2011, as an abbreviation for “ selective non-use of typographic lig atures”. I chose this nam e car efully, so as to avoid any possible confusion with the names of any other software piece I was aware of . F or sure , there was no package called selnolig on the CTAN until I uploaded mine in May 2013. 1 https://tex.stackexchange.com/questions/28437/can -one-more -or-less-automatically -suppress -ligatures -for- certain -words , dated 14 September 2011 C/20/2{D/502} {D/503} DECLARATION I understand that the purpose of this witness statement is to set out matters of fact of which I have personal knowledge. I understand that it is not my function to argue the case, either generally or on particular points, or to take the court through the documents in the case. This witness statement sets out only my personal knowledge and recollection, in my own words. On points that I understand to be important in the case, I have stated honestly (a) how well I recall matters and (b) whether my memory has been refreshed by considering documents, if so how and when. I have not been asked or encouraged by anyone to include in this statement anything that is not my own account, to the best of my ability and recollection, of events I witnessed or matters of which I have personal knowledge. I believe th e facts stated in this statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth. SIGNED: Mico Loretan DATED: 6 November 2023 C/20/3
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KLD. 157. Bird & Bird has asked me to comment on that passage. 158. I agree that connecting a drive to a computer in this way, when it is intended for forensic imaging, risks contamination of the drive. It is a basic proc edure in forensic imaging that drives should not be handled in this way by connecting a drive to computing equipment which might alter it, and it is well known in the field that proper preservation of evidence requires proper care to be taken to avoid data being spoiled, overwritten or deleted. 159. However, I do not consider that the explanation given accounts for the indications in the Stroz DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 53 of 69 53 Report, or the other indications of inauthenticity that I have explained above, for the following reasons. Behaviour of software listed by Dr Wright 160. Dr Wright lists five software systems at paragr aph 30 of his statement. However, in my opinion those systems would not be expected to interfere with the internal transactional logs of the BDO Image, or the Recycle Bin of the Samsung Drive, or the other factors that I have analysed above. 161. Overall, the explanation is rather vague and does not provide a detailed explanation that enables a response. However, addressing each of the software systems: a. WinUndelete: WinUndelete is a file recovery utility which allows recovery of deleted files (although in my experience, I have also seen it used as a tool for checking that files have been securely deleted so that they cannot be recovered). The homepage of the tool is at https://www.winundelete.com/ (Exhibit PM-R3.16 ). That web page also lists the features of the tool, and specifically states that it does no t change or harm the Recycle Bin. Therefore, the software appears to be specifically configured to avoid the activity observed in relation to the Samsung Drive: b. Storage Sense is a utility that can be enabled on Windows 10 and Windows 11, to automatically deletes temporary files and Recycle Bin items when a computer is running low on disk space. It is a Microsoft Windows Setting found in the System>Storage menu under Windows 10. However, this could not have led to the deletion of the Recycle Bin on the Samsung Drive, because the Samsung Drive is an external USB drive, not the system drive where Windows is installed. The Microsoft Support Page for Storage Sense ( https://support.microsoft.com/en- us/windows/manage-drive-space-with-storage-sense-654f6ada-7bfc-45e5-966b- e24aded96ad5 ) (Exhibit PM-R3.17 ) states that Storage Sense does not run on other drives than the system drive on which Windows is installed, as shown below.7 Therefore, Storage Sense cannot explain the deletion of the Recycle Bin. 7 Further, Storage Sense only runs wh en a computer is in low disk space mo de, and there is no indication that Dr Wright’s computer is low on disk space . DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 54 of 69 54 c. VMWare is a utility for running virtual machines. I am familiar with VMWare and use it in connection with my forensic investigations. I have never come across any circumstance in which VMWare would cause external files to be deleted without specific user interaction. If it did do so, it would not be suitable for its purpose of running isolated virtual machines. d. SAMBA shares : Samba is a protocol for sharing file, folder, and printer access across a network between machines. It is a protocol for enabling shared access and not a file management or deletion utility. I am not aware of any circumstances where having a machine using a Samba share would cause the machine to delete files on a removable storage disk, which would be quite unusual and not within the scope of its use at all. e. Symbolic links are a form of file shortcut, where a file is stored in one location on a computer and a link created in another location, allowing the us er to actually interact with the target file by interacting with the symbolic link. However, the presence of a symbolic link would not cause data deletion or changes to metadata information of files in a removable storage drive and it is not associated with the deletion of the Recycle Bin. If a symbolic link was made and then the link was deleted, it would not cause the target file to be deleted, but only the link (unless the user also took specific action to cause the target file to be deleted). Even then, I would not expect it to interact with files in the Recycle Bin. 162. As I have stated above, the BDO Image itself coul d not be edited without first mounting the image as if it was a physical storage drive. This typically requires active user interaction and I agree with Stroz Friedberg that it is not available with an y tools built into windows. Even if the BDO Image was mounted as a disk in addition to the check that Dr Wright states he carried out, I still would not expect the Recycle Bin to be emptied automati cally or any other operations to take place that might account for the various anomalies described above. 163. The delete d file “ESDT.PDF” was not only emptied from the Recycle Bin in September 2023, but it must have also been sent to the Recycle Bin after 16
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 17 of 20 Third Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Third Expert Report of Patrick Madden.pdf ### File content: KLD. 157. Bird & Bird has asked me to comment on that passage. 158. I agree that connecting a drive to a computer in this way, when it is intended for forensic imaging, risks contamination of the drive. It is a basic proc edure in forensic imaging that drives should not be handled in this way by connecting a drive to computing equipment which might alter it, and it is well known in the field that proper preservation of evidence requires proper care to be taken to avoid data being spoiled, overwritten or deleted. 159. However, I do not consider that the explanation given accounts for the indications in the Stroz DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 53 of 69 53 Report, or the other indications of inauthenticity that I have explained above, for the following reasons. Behaviour of software listed by Dr Wright 160. Dr Wright lists five software systems at paragr aph 30 of his statement. However, in my opinion those systems would not be expected to interfere with the internal transactional logs of the BDO Image, or the Recycle Bin of the Samsung Drive, or the other factors that I have analysed above. 161. Overall, the explanation is rather vague and does not provide a detailed explanation that enables a response. However, addressing each of the software systems: a. WinUndelete: WinUndelete is a file recovery utility which allows recovery of deleted files (although in my experience, I have also seen it used as a tool for checking that files have been securely deleted so that they cannot be recovered). The homepage of the tool is at https://www.winundelete.com/ (Exhibit PM-R3.16 ). That web page also lists the features of the tool, and specifically states that it does no t change or harm the Recycle Bin. Therefore, the software appears to be specifically configured to avoid the activity observed in relation to the Samsung Drive: b. Storage Sense is a utility that can be enabled on Windows 10 and Windows 11, to automatically deletes temporary files and Recycle Bin items when a computer is running low on disk space. It is a Microsoft Windows Setting found in the System>Storage menu under Windows 10. However, this could not have led to the deletion of the Recycle Bin on the Samsung Drive, because the Samsung Drive is an external USB drive, not the system drive where Windows is installed. The Microsoft Support Page for Storage Sense ( https://support.microsoft.com/en- us/windows/manage-drive-space-with-storage-sense-654f6ada-7bfc-45e5-966b- e24aded96ad5 ) (Exhibit PM-R3.17 ) states that Storage Sense does not run on other drives than the system drive on which Windows is installed, as shown below.7 Therefore, Storage Sense cannot explain the deletion of the Recycle Bin. 7 Further, Storage Sense only runs wh en a computer is in low disk space mo de, and there is no indication that Dr Wright’s computer is low on disk space . DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 54 of 69 54 c. VMWare is a utility for running virtual machines. I am familiar with VMWare and use it in connection with my forensic investigations. I have never come across any circumstance in which VMWare would cause external files to be deleted without specific user interaction. If it did do so, it would not be suitable for its purpose of running isolated virtual machines. d. SAMBA shares : Samba is a protocol for sharing file, folder, and printer access across a network between machines. It is a protocol for enabling shared access and not a file management or deletion utility. I am not aware of any circumstances where having a machine using a Samba share would cause the machine to delete files on a removable storage disk, which would be quite unusual and not within the scope of its use at all. e. Symbolic links are a form of file shortcut, where a file is stored in one location on a computer and a link created in another location, allowing the us er to actually interact with the target file by interacting with the symbolic link. However, the presence of a symbolic link would not cause data deletion or changes to metadata information of files in a removable storage drive and it is not associated with the deletion of the Recycle Bin. If a symbolic link was made and then the link was deleted, it would not cause the target file to be deleted, but only the link (unless the user also took specific action to cause the target file to be deleted). Even then, I would not expect it to interact with files in the Recycle Bin. 162. As I have stated above, the BDO Image itself coul d not be edited without first mounting the image as if it was a physical storage drive. This typically requires active user interaction and I agree with Stroz Friedberg that it is not available with an y tools built into windows. Even if the BDO Image was mounted as a disk in addition to the check that Dr Wright states he carried out, I still would not expect the Recycle Bin to be emptied automati cally or any other operations to take place that might account for the various anomalies described above. 163. The delete d file “ESDT.PDF” was not only emptied from the Recycle Bin in September 2023, but it must have also been sent to the Recycle Bin after 16
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Wright” . 61.T his indicates that the email was not extracted from the mailbox of [email protected] . 62. N o corresponding “received” email from the mailbox [email protected] has been disclosed in the disclosure dataset. 63.T his is therefore not indicative of there being any access to the [email protected] mailbo x. That email address was merely listed as a recipient. Unusual within the dataset 64.I remark that t his email message is one of the few examples within the email dataset wher e t here is no Transmission header at all . While this is not anomalous for a sent item, the majority of the email messages in this disclosure dataset have included at least some, even if minimal, transmission information due to the technologies in use. Other than remarking on it as unusual, I do not draw a conclusion from this observati on. Metadata analysis 65. I next inspected the MSG metadata with Outlookspy. I did not identify anythin g that migh t i nform the analysis about any connection with [email protected] . I did observe that although the message reports on the face of it to have been sent on 01/11/2013, the PR_Creation Time indicates a date of 09/10/2013; however, I do not draw any conclusionsfrom that in connection with the current analysis. 66.I t is not possible to determine if this email message was ever received in th e “s [email protected] ” mail box. 67.A s the email address “ [email protected] ” is a recipient to this email message, it would require no a uthentication and cannot be used to indicate anything more than the author bei ng aw are of the email address and typing it in at the time of authoring the email .18 - 18 - H/104/18 Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 19 of 27 Com parator set of sample emails 68.After conducting my comparative review of the emails above, I was also provided with a dataset of sample email messages purporting to have been sent between Satoshi Nakamoto and 4 different people. Source of comparator emails 69. I am informed by Bird & Bird that these have been provided as the following exhibits to witness statements: a.Exhibit NB1 b.Exhibit AB1 c.Exhibit DT2 d.Exhibit MM1 70. I ha ve not been provided with the corresponding witness statements , or access to the computing equipment on which they are stored or any forensic images of that computing equipment. I understand the messages have been exported by the recipients themselves from their own infrastructure. I have not had oversight of this process. I am instructed that it is not my role to try to determine their authenticity, and I have been asked to look at the files for comparative purposes and assess them based on the information available in the documentsthemselves . 71. I a m also informed by Bird & Bird that this Exhibit NB1 is the same Exhibit NB1 that contained the version of the Bitcoin White Paper, BWP-NB1, which I scrutinised at AppendixPM3. I was not aware of these emails at the point that I conducted that analysis in Appendix PM3 . Observati ons on comparator emails. 72.My review was technical in nature. I disregarded the written content of the body of the emailsother than to corroborate them against the technical characteristics observed. 73.I approached my review as follows: a.I isolated the emails which were recorded as being sent from one of the three email addresses listed at the start of this report “[email protected]”, “[email protected]”, and [email protected] (“Satoshi addresses” ). Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 19 of 27 Com parator set of sample emails 68.After conducting my comparative review of the emails above, I was also provided with a dataset of sample email messages purporting to have been sent between Satoshi Nakamoto and 4 different people. Source of comparator emails 69. I am informed by Bird & Bird that these have been provided as the following exhibits to witness statements: a.Exhibit NB1 b.Exhibit AB1 c.Exhibit DT2 d.Exhibit MM1 70. I ha ve not been provided with the corresponding witness statements , or access to the computing equipment on which they are stored or any forensic images of that computing equipment. I understand the messages have been exported by the recipients themselves from their own infrastructure. I have not had oversight of this process. I am instructed that it is not my role to try to determine their authenticity, and I have been asked to look at the files for comparative purposes and assess them based on the information available in the documentsthemselves . 71. I a m also informed by Bird & Bird that this Exhibit NB1 is the same Exhibit NB1 that contained the version of the Bitcoin White Paper, BWP-NB1, which I scrutinised at AppendixPM3. I was not aware of these emails at the point that I conducted that analysis in Appendix PM3 . Observati ons on comparator emails. 72.My review
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 10 of 15 Appendix PM21.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM21.pdf ### File content: Wright” . 61.T his indicates that the email was not extracted from the mailbox of [email protected] . 62. N o corresponding “received” email from the mailbox [email protected] has been disclosed in the disclosure dataset. 63.T his is therefore not indicative of there being any access to the [email protected] mailbo x. That email address was merely listed as a recipient. Unusual within the dataset 64.I remark that t his email message is one of the few examples within the email dataset wher e t here is no Transmission header at all . While this is not anomalous for a sent item, the majority of the email messages in this disclosure dataset have included at least some, even if minimal, transmission information due to the technologies in use. Other than remarking on it as unusual, I do not draw a conclusion from this observati on. Metadata analysis 65. I next inspected the MSG metadata with Outlookspy. I did not identify anythin g that migh t i nform the analysis about any connection with [email protected] . I did observe that although the message reports on the face of it to have been sent on 01/11/2013, the PR_Creation Time indicates a date of 09/10/2013; however, I do not draw any conclusionsfrom that in connection with the current analysis. 66.I t is not possible to determine if this email message was ever received in th e “s [email protected] ” mail box. 67.A s the email address “ [email protected] ” is a recipient to this email message, it would require no a uthentication and cannot be used to indicate anything more than the author bei ng aw are of the email address and typing it in at the time of authoring the email .18 - 18 - H/104/18 Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 19 of 27 Com parator set of sample emails 68.After conducting my comparative review of the emails above, I was also provided with a dataset of sample email messages purporting to have been sent between Satoshi Nakamoto and 4 different people. Source of comparator emails 69. I am informed by Bird & Bird that these have been provided as the following exhibits to witness statements: a.Exhibit NB1 b.Exhibit AB1 c.Exhibit DT2 d.Exhibit MM1 70. I ha ve not been provided with the corresponding witness statements , or access to the computing equipment on which they are stored or any forensic images of that computing equipment. I understand the messages have been exported by the recipients themselves from their own infrastructure. I have not had oversight of this process. I am instructed that it is not my role to try to determine their authenticity, and I have been asked to look at the files for comparative purposes and assess them based on the information available in the documentsthemselves . 71. I a m also informed by Bird & Bird that this Exhibit NB1 is the same Exhibit NB1 that contained the version of the Bitcoin White Paper, BWP-NB1, which I scrutinised at AppendixPM3. I was not aware of these emails at the point that I conducted that analysis in Appendix PM3 . Observati ons on comparator emails. 72.My review was technical in nature. I disregarded the written content of the body of the emailsother than to corroborate them against the technical characteristics observed. 73.I approached my review as follows: a.I isolated the emails which were recorded as being sent from one of the three email addresses listed at the start of this report “[email protected]”, “[email protected]”, and [email protected] (“Satoshi addresses” ). Madden Appendix PM 21 Satoshi Nakamoto messages /ID_001199, ID_001546, and ID_002586 Page 19 of 27 Com parator set of sample emails 68.After conducting my comparative review of the emails above, I was also provided with a dataset of sample email messages purporting to have been sent between Satoshi Nakamoto and 4 different people. Source of comparator emails 69. I am informed by Bird & Bird that these have been provided as the following exhibits to witness statements: a.Exhibit NB1 b.Exhibit AB1 c.Exhibit DT2 d.Exhibit MM1 70. I ha ve not been provided with the corresponding witness statements , or access to the computing equipment on which they are stored or any forensic images of that computing equipment. I understand the messages have been exported by the recipients themselves from their own infrastructure. I have not had oversight of this process. I am instructed that it is not my role to try to determine their authenticity, and I have been asked to look at the files for comparative purposes and assess them based on the information available in the documentsthemselves . 71. I a m also informed by Bird & Bird that this Exhibit NB1 is the same Exhibit NB1 that contained the version of the Bitcoin White Paper, BWP-NB1, which I scrutinised at AppendixPM3. I was not aware of these emails at the point that I conducted that analysis in Appendix PM3 . Observati ons on comparator emails. 72.My review
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Closings
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Separately, Satoshi wrote to Wei Dai on 22 August 2008 in the following terms {L3/195}: “I was very interested to read your b-money page. I'm getting ready to release a paper that expands on your ideas into a complete working system. Adam Back (hashcash.org) noticed the similarities and pointed me to your site. I need to find out the year of publication of your b-money page for the citation in my paper. It'll look like: [1] W. Dai, "b-money," http://www.weidai.com/bmoney.txt, (2006?).” 133. Two points emerge from that email. First, it shows that the prompt for Satoshi Nakamoto’s approach to Wei Dai, was Wei Dai’s b-money page, rather than something else. Second, the effect of inserting a reference to Wei Dai’s b-money page as a first reference to the Bitcoin White Paper, would have been to lead to Dr Back’s paper becoming the sixth reference – as in fact it was in the version published by Satoshi in October 2008: {L3/231/8}. Thus, it is clear that there was no reference in 48 the Bitcoin White Paper to Wei Dai’s b-money page until it was mentioned to Satoshi by Adam Back. 134. Wei Dai responded to Satoshi Nakamoto at some point afterwards as follows {L14/99/3}: “Hi Satoshi. b-money was announced on the cypherpunks mailing list in 1998. Here's the archived post: https://cypherpunks.venona.com/date/1998/11/msg00941.html There are some discussions of it at https://cypherpunks.venona.com/date/1998/12/msg00194.html. Thanks for letting me know about your paper. I'll take a look at it and let you know if I have any comments or questions.” 135. There were no further dealings between Satoshi and Wei Dai until the Bitcoin White Paper was published. 136. Nevertheless, Wright1¶92 {E/1/18} took a wild guess as to what Satoshi’s dealings with Wei Dai might have been, stating: “Wei Dai was a distinguished academic who had previously proposed a digital currency concept called B-Money, which profoundly impacted my thinking. His work was highly influential and laid the groundwork for some ideas incorporated into the Bitcoin project. Notably, Wei Dai's contributions were the first that I acknowledged in the White Paper. After I provided him with a copy of the White Paper, he played a significant role in the development process, guiding me to various signature algorithm libraries, including his secure hash algorithm {SHA-256), which I successfully incorporated into the Bitcoin code base.” 137. Wei Dai was asked by Bird & Bird to comment on that evidence and has confirmed that was not what happened {C/28/3}: “1. I’m not a “distinguished academic” and has actually never worked in academia. 2. My understanding (from Satoshi’s first email to me) is that Satoshi only became aware of b-money when he learned about it from Adam Back, which is after he had completed the draft of the whitepaper that he sent to Adam, so it seems wrong that I profoundly impacted Satoshi’s thinking. 3. I did not play a significant role in the development process of Bitcoin. Specifically I did not guide Satoshi to “various signature algorithm libraries, including his secure hash algorithm (SHA-256)”. 4. You can see the entirety of my communications with Satoshi at https://gwern.net/doc/bitcoin/2008-nakamoto.” 138. At Wright11¶370 {CSW/1/69}, Dr Wright further tried to suggest that he had been aware of Wei Dai’s b-money proposal prior to his dealings with Dr Back, but was not 49 aware of Wei Dai’s b-money page. That might seem an odd point of detail for Dr Wright to persist with in light of the exchanges with Dr Back and Wei Dai described above. However, Dr Wright was compelled to argue the point because of prior publications by him asserting longstanding familiarity with Wei Dai’s work. Regrettably that story of longstanding familiarity with Wei Dai is a further pack of lies. 139. In an article entitled “Fully Peer-to-Peer” published on 6 June 2019 {L15/88/1}, Dr Wright had referred to enrolling at the University of Newcastle in 2005 as a post-graduate researcher between 2005 and 2009. He stated that entering the university gave him access to the work of Graham Wrightson and Andreas Furche {L15/88/2}. He went on to say at {L15/88/3}: “I did not put down that I was Satoshi when I talked to them. I was just another postgraduate researcher and student. … … In a conversation that I had when I started my degree with Prof Graham Wrightson, I saw that the separate networks and communication infrastructure would end up merging. … Prof Wrightson knew of Wei Dai, and pointed me towards a paper titled “Knowledge-Based Communication Processes in Building Design” that he knew of because of his work in machine learning. Both Adam Back and Prof Wrightson directed me to Wei Dai. 戴维 turned out to be another cypherpunk, and he was an incredibly helpful one. I used some of his code in the original release of Bitcoin — with his permission. Andreas Furche knew of Hal Finney and Adam Back. So I emailed people. I was researching in 2005, and came to the conclusion that I could build something. By 2007, I was ready to start.” 140. Every element of that account was imagined: a) Professor Wrightson had retired from the University of Newcastle on 9 August 2000 and had no further contact with it: {C/17.1/4} and {C/17.1/11}. He does not recall ever meeting, speaking or working with an individual named Craig Steven Wright {C/17.1/11} and does not know of Wei Dai {C/17.1/11}. b) Andreas Furche left Newcastle University with Professor Wrightson (and halfway through his PhD) and completed it at Macquarie Furche1¶6-7 {C/13/2} and Furche1¶27 {C/13/6}. He had never heard of Adam Back: Furche1¶36 {C/13/7}. 50 c) Wei Dai had never written a paper entitled Knowledge-Based Communication Processes in Building Design”: {C/28/1}. That seems to be a reference to a paper about the use of CAD systems in the construction industry written by someone else called Wei Dai from the Commonwealth Scientific and Industrial Research Organisation in Victoria, Australia {L1/17/1}. d) As to the use of code from Wei Dai, Wei Dai has stated {C/28/1}: “I did not directly supply any code to Satoshi. (Again you can see the entirety of my
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 17 of 59 BTC Core Developers' Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/BTC Core Developers' Closing Submissions.pdf ### File content: Separately, Satoshi wrote to Wei Dai on 22 August 2008 in the following terms {L3/195}: “I was very interested to read your b-money page. I'm getting ready to release a paper that expands on your ideas into a complete working system. Adam Back (hashcash.org) noticed the similarities and pointed me to your site. I need to find out the year of publication of your b-money page for the citation in my paper. It'll look like: [1] W. Dai, "b-money," http://www.weidai.com/bmoney.txt, (2006?).” 133. Two points emerge from that email. First, it shows that the prompt for Satoshi Nakamoto’s approach to Wei Dai, was Wei Dai’s b-money page, rather than something else. Second, the effect of inserting a reference to Wei Dai’s b-money page as a first reference to the Bitcoin White Paper, would have been to lead to Dr Back’s paper becoming the sixth reference – as in fact it was in the version published by Satoshi in October 2008: {L3/231/8}. Thus, it is clear that there was no reference in 48 the Bitcoin White Paper to Wei Dai’s b-money page until it was mentioned to Satoshi by Adam Back. 134. Wei Dai responded to Satoshi Nakamoto at some point afterwards as follows {L14/99/3}: “Hi Satoshi. b-money was announced on the cypherpunks mailing list in 1998. Here's the archived post: https://cypherpunks.venona.com/date/1998/11/msg00941.html There are some discussions of it at https://cypherpunks.venona.com/date/1998/12/msg00194.html. Thanks for letting me know about your paper. I'll take a look at it and let you know if I have any comments or questions.” 135. There were no further dealings between Satoshi and Wei Dai until the Bitcoin White Paper was published. 136. Nevertheless, Wright1¶92 {E/1/18} took a wild guess as to what Satoshi’s dealings with Wei Dai might have been, stating: “Wei Dai was a distinguished academic who had previously proposed a digital currency concept called B-Money, which profoundly impacted my thinking. His work was highly influential and laid the groundwork for some ideas incorporated into the Bitcoin project. Notably, Wei Dai's contributions were the first that I acknowledged in the White Paper. After I provided him with a copy of the White Paper, he played a significant role in the development process, guiding me to various signature algorithm libraries, including his secure hash algorithm {SHA-256), which I successfully incorporated into the Bitcoin code base.” 137. Wei Dai was asked by Bird & Bird to comment on that evidence and has confirmed that was not what happened {C/28/3}: “1. I’m not a “distinguished academic” and has actually never worked in academia. 2. My understanding (from Satoshi’s first email to me) is that Satoshi only became aware of b-money when he learned about it from Adam Back, which is after he had completed the draft of the whitepaper that he sent to Adam, so it seems wrong that I profoundly impacted Satoshi’s thinking. 3. I did not play a significant role in the development process of Bitcoin. Specifically I did not guide Satoshi to “various signature algorithm libraries, including his secure hash algorithm (SHA-256)”. 4. You can see the entirety of my communications with Satoshi at https://gwern.net/doc/bitcoin/2008-nakamoto.” 138. At Wright11¶370 {CSW/1/69}, Dr Wright further tried to suggest that he had been aware of Wei Dai’s b-money proposal prior to his dealings with Dr Back, but was not 49 aware of Wei Dai’s b-money page. That might seem an odd point of detail for Dr Wright to persist with in light of the exchanges with Dr Back and Wei Dai described above. However, Dr Wright was compelled to argue the point because of prior publications by him asserting longstanding familiarity with Wei Dai’s work. Regrettably that story of longstanding familiarity with Wei Dai is a further pack of lies. 139. In an article entitled “Fully Peer-to-Peer” published on 6 June 2019 {L15/88/1}, Dr Wright had referred to enrolling at the University of Newcastle in 2005 as a post-graduate researcher between 2005 and 2009. He stated that entering the university gave him access to the work of Graham Wrightson and Andreas Furche {L15/88/2}. He went on to say at {L15/88/3}: “I did not put down that I was Satoshi when I talked to them. I was just another postgraduate researcher and student. … … In a conversation that I had when I started my degree with Prof Graham Wrightson, I saw that the separate networks and communication infrastructure would end up merging. … Prof Wrightson knew of Wei Dai, and pointed me towards a paper titled “Knowledge-Based Communication Processes in Building Design” that he knew of because of his work in machine learning. Both Adam Back and Prof Wrightson directed me to Wei Dai. 戴维 turned out to be another cypherpunk, and he was an incredibly helpful one. I used some of his code in the original release of Bitcoin — with his permission. Andreas Furche knew of Hal Finney and Adam Back. So I emailed people. I was researching in 2005, and came to the conclusion that I could build something. By 2007, I was ready to start.” 140. Every element of that account was imagined: a) Professor Wrightson had retired from the University of Newcastle on 9 August 2000 and had no further contact with it: {C/17.1/4} and {C/17.1/11}. He does not recall ever meeting, speaking or working with an individual named Craig Steven Wright {C/17.1/11} and does not know of Wei Dai {C/17.1/11}. b) Andreas Furche left Newcastle University with Professor Wrightson (and halfway through his PhD) and completed it at Macquarie Furche1¶6-7 {C/13/2} and Furche1¶27 {C/13/6}. He had never heard of Adam Back: Furche1¶36 {C/13/7}. 50 c) Wei Dai had never written a paper entitled Knowledge-Based Communication Processes in Building Design”: {C/28/1}. That seems to be a reference to a paper about the use of CAD systems in the construction industry written by someone else called Wei Dai from the Commonwealth Scientific and Industrial Research Organisation in Victoria, Australia {L1/17/1}. d) As to the use of code from Wei Dai, Wei Dai has stated {C/28/1}: “I did not directly supply any code to Satoshi. (Again you can see the entirety of my
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Arthur Rosendahl
part 37 of 40 First Expert Report of Arthur Rosendahl.pdf
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even these less significant observations become more significant when considering the fact that they overlap with each other, and with other problems that I have observed; and g. Finally, other packages are much more complex - as with fontspec above. 190. TEX is a programming language, and a very versatile one at that, such that one can theoretically do anything with it, including redefining all commands and packages to have a different meaning than the standard one. However, even under this hypothesis, I must conclude that none of the L ATEX files could have been the source of the original Bitcoin White Paper in March 2009, nor have any of them been modified from a slightly different file that had been used at that time to create the BWP. 57 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 a. Making such packages could be a complex task, and I have not seen any indication that such complex packages were used and it is not described in Dr Wright’s statement; b. To the contrary, the syntax used in all of them perfectly matches for the versions released much later; c. If Dr Wright had made his own packages, it would be surprising if he had used the identical syntax and function names to the versions which were eventually released publicly by their authors (in some cases many years later). While such an artefact may be a simple coincidence in one case, in my opinion it could not be an explanation across all of the many issues that have been observed; d. I have in mind that different packages are different, and some are easier to modify than others. For example, the command \\AddToShipoutPictureBG* in the pack- ageeso-picisarelativelyminorvariation, sincethecommandalreadyexistedunder a different name, and would therefore have been a very minor modification. How- ever, I cannot see any reason that the modification to command names in this way would be desirable when using a publicly-available and widely-used package, as it would have no practical effect on the document. Even if the modification to the command name was made, it is not clear that the name chosen would have precisely matched the name that was chosen by the package’s developer when the future release was created; e. In other cases, the packages are comparatively less important to the output of the files - for example, the hidelinks option of the package hyperref did not exist in 2009 and removing that would not cause a large change to the output, though it is still an observable difference in the way links would be displayed in PDF file; f. However, even these less significant observations become more significant when considering the fact that they overlap with each other, and with other problems that I have observed; and g. Finally, other packages are much more complex - as with fontspec above. 190. TEX is a programming language, and a very versatile one at that, such that one can theoretically do anything with it, including redefining all commands and packages to have a different meaning than the standard one. However, even under this hypothesis, I must conclude that none of the L ATEX files could have been the source of the original Bitcoin White Paper in March 2009, nor have any of them been modified from a slightly different file that had been used at that time to create the BWP. 57 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA6857 - 57 - G/7/57 Taking into account both streams of analysis 191. Pausing to bring together the two parts of my analysis, I have approached this by two methods of reasoning that independently lead me to the same conclusion. The BWP was created in OpenOffice, as is evident from inspecting the relevant files at every level, from the fine details of its typographical presentation, down to the binary digits of the PDF. Similarly, the L ATEX source files provided cannot be the source of such a document, for the reasons given. 3.12.1 Observation about image creation 192. I will conclude this chapter with a hypothesis I formulated when looking back at the matrix 3.6, which was after I had formed the conclusions above, while trying to under- stand whether it was possible to ascertain anything more about how the candidate files were produced. I noticed that among those candidates that use fewer of those problem- atic packages, it can be seen that the diagrams are usually in PNG format. This led me to consider that the diagrams in the simpler L ATEX files had first been created as PNG files, that were then replaced by TikZ code over the course of editing (either via inclusion of a separate PDF file, or directly), and that brings me to the fourth and last chapter of this report. 58 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 Taking into account both streams of analysis 191. Pausing to bring together the two parts of my analysis, I have approached this by two methods of reasoning that independently lead me to the same conclusion. The BWP was created in OpenOffice, as is evident from inspecting the relevant files at every level, from the fine details of its typographical presentation, down to the binary digits of the PDF. Similarly, the L ATEX source files provided cannot be the source of such a document, for the reasons given. 3.12.1 Observation about image creation 192. I will conclude this chapter with a hypothesis I formulated when looking back at the matrix 3.6, which was after I had formed the conclusions above, while trying to under- stand whether it was possible to ascertain anything more about how the candidate files were produced. I noticed that among those candidates that use fewer of those problem- atic packages, it can be seen that the diagrams are usually in PNG format. This led me to consider that the diagrams in the simpler L ATEX files had first been created as PNG files, that were then replaced by TikZ code over the course of editing (either via inclusion of a separate PDF file, or directly), and that brings me to the fourth and last chapter of this report. 58 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA6858 - 58 - G/7/58 Chapter 4 Diagramming and conversion tools 193. This chapter will be rather short because of time constraints towards the end of my instruction. During the conclusions above, I mentioned to Bird & Bird that automatic conversion tools existed which can be used to create L ATEX documents, one of which had been mentioned by Dr Wright in his statement. Bird & Bird asked me to comment on those tools and consider how they would convert the Bitcoin White Paper, and I have looked at three of them: conversion to L ATEXwith the extension Writer2L ATEX, the conversion tool called Aspose, and Pandoc. 4.1 OpenOffice 4.1.1
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 37 of 40 First Expert Report of Arthur Rosendahl.pdf ### Folder name: Arthur Rosendahl ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Arthur Rosendahl/First Expert Report of Arthur Rosendahl.pdf ### File content: even these less significant observations become more significant when considering the fact that they overlap with each other, and with other problems that I have observed; and g. Finally, other packages are much more complex - as with fontspec above. 190. TEX is a programming language, and a very versatile one at that, such that one can theoretically do anything with it, including redefining all commands and packages to have a different meaning than the standard one. However, even under this hypothesis, I must conclude that none of the L ATEX files could have been the source of the original Bitcoin White Paper in March 2009, nor have any of them been modified from a slightly different file that had been used at that time to create the BWP. 57 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 a. Making such packages could be a complex task, and I have not seen any indication that such complex packages were used and it is not described in Dr Wright’s statement; b. To the contrary, the syntax used in all of them perfectly matches for the versions released much later; c. If Dr Wright had made his own packages, it would be surprising if he had used the identical syntax and function names to the versions which were eventually released publicly by their authors (in some cases many years later). While such an artefact may be a simple coincidence in one case, in my opinion it could not be an explanation across all of the many issues that have been observed; d. I have in mind that different packages are different, and some are easier to modify than others. For example, the command \\AddToShipoutPictureBG* in the pack- ageeso-picisarelativelyminorvariation, sincethecommandalreadyexistedunder a different name, and would therefore have been a very minor modification. How- ever, I cannot see any reason that the modification to command names in this way would be desirable when using a publicly-available and widely-used package, as it would have no practical effect on the document. Even if the modification to the command name was made, it is not clear that the name chosen would have precisely matched the name that was chosen by the package’s developer when the future release was created; e. In other cases, the packages are comparatively less important to the output of the files - for example, the hidelinks option of the package hyperref did not exist in 2009 and removing that would not cause a large change to the output, though it is still an observable difference in the way links would be displayed in PDF file; f. However, even these less significant observations become more significant when considering the fact that they overlap with each other, and with other problems that I have observed; and g. Finally, other packages are much more complex - as with fontspec above. 190. TEX is a programming language, and a very versatile one at that, such that one can theoretically do anything with it, including redefining all commands and packages to have a different meaning than the standard one. However, even under this hypothesis, I must conclude that none of the L ATEX files could have been the source of the original Bitcoin White Paper in March 2009, nor have any of them been modified from a slightly different file that had been used at that time to create the BWP. 57 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA6857 - 57 - G/7/57 Taking into account both streams of analysis 191. Pausing to bring together the two parts of my analysis, I have approached this by two methods of reasoning that independently lead me to the same conclusion. The BWP was created in OpenOffice, as is evident from inspecting the relevant files at every level, from the fine details of its typographical presentation, down to the binary digits of the PDF. Similarly, the L ATEX source files provided cannot be the source of such a document, for the reasons given. 3.12.1 Observation about image creation 192. I will conclude this chapter with a hypothesis I formulated when looking back at the matrix 3.6, which was after I had formed the conclusions above, while trying to under- stand whether it was possible to ascertain anything more about how the candidate files were produced. I noticed that among those candidates that use fewer of those problem- atic packages, it can be seen that the diagrams are usually in PNG format. This led me to consider that the diagrams in the simpler L ATEX files had first been created as PNG files, that were then replaced by TikZ code over the course of editing (either via inclusion of a separate PDF file, or directly), and that brings me to the fourth and last chapter of this report. 58 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA68 Taking into account both streams of analysis 191. Pausing to bring together the two parts of my analysis, I have approached this by two methods of reasoning that independently lead me to the same conclusion. The BWP was created in OpenOffice, as is evident from inspecting the relevant files at every level, from the fine details of its typographical presentation, down to the binary digits of the PDF. Similarly, the L ATEX source files provided cannot be the source of such a document, for the reasons given. 3.12.1 Observation about image creation 192. I will conclude this chapter with a hypothesis I formulated when looking back at the matrix 3.6, which was after I had formed the conclusions above, while trying to under- stand whether it was possible to ascertain anything more about how the candidate files were produced. I noticed that among those candidates that use fewer of those problem- atic packages, it can be seen that the diagrams are usually in PNG format. This led me to consider that the diagrams in the simpler L ATEX files had first been created as PNG files, that were then replaced by TikZ code over the course of editing (either via inclusion of a separate PDF file, or directly), and that brings me to the fourth and last chapter of this report. 58 DocuSign Envelope ID: 1FBDC1CB-92F0-425F-93DA-C34DE293EA6858 - 58 - G/7/58 Chapter 4 Diagramming and conversion tools 193. This chapter will be rather short because of time constraints towards the end of my instruction. During the conclusions above, I mentioned to Bird & Bird that automatic conversion tools existed which can be used to create L ATEX documents, one of which had been mentioned by Dr Wright in his statement. Bird & Bird asked me to comment on those tools and consider how they would convert the Bitcoin White Paper, and I have looked at three of them: conversion to L ATEXwith the extension Writer2L ATEX, the conversion tool called Aspose, and Pandoc. 4.1 OpenOffice 4.1.1
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Nicholas Bohm Witness Statement - Exhibit
part 1 of 1 20090201-Re_Another crash-114913(75056999.1).pdf
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Subject: Re: Another crash From: Nicholas Bohm <[email protected]> Date: 01/02/2009, 11:52 To: [email protected] Satoshi Nakamoto wrote: I guess I'd better send this from here also in case there's more e-mail problems. I got this message safely from both addresses. Good news! I pinpointed the bug. The bug could occur if your computer had trouble doing a DNS lookup. Quite possible. I subscribe to NASA's image of the day collection through Google Reader (an RSS reader), and for some time I have found that when I click the link for the NASA site, I get a Firefox error page saying "couldn't find the server); but clicking "try again" gets me through each time. This might be a DNS lookup error, presumably. The fix is at: http://www.upload.ae/file/14540/bc015-rar.html I've downloaded it and am running 015. Thanks for all your help and patience with this. I pleased if it's a help - there's always some discomfort in being the bearer of bad tidings! Just for completeness, I'll answer the questions in your earlier message: - Is there anything in db.log? No - What operating system are you using? Windows XP Service Pack 3 - When it crashes, does it put up any other message boxes that say anything else? See the two screenshots attached. I haven't got the file mentioned there, e02_appcompat.txt - it is deleted by sending the error report, which I did before thinking to make a copy. However, I sent you the corresponding file for an earlier crash attached to my message of 25th January.Re: Another crash mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 3 21/07/2023, 17:10 There is also the Event Viewer report, as follows: First, probably when the crash occurs: Event Type: Error Event Source: Application Error Event Category: None Event ID: 1000 Date: 01/02/2009 Time: 07:56:58 User: N/A Computer: HP91914945127 Description: Faulting application bitcoin.exe, version 0.0.0.0, faulting module bitcoin.exe, version 0.0.0.0, fault address 0x000be368. For more information, see Help and Support Center at http://go.microsoft.com/fwlink/events.asp . Data: 0000: 41 70 70 6c 69 63 61 74 Applicat 0008: 69 6f 6e 20 46 61 69 6c ion Fail 0010: 75 72 65 20 20 62 69 74 ure bit 0018: 63 6f 69 6e 2e 65 78 65 coin.exe 0020: 20 30 2e 30 2e 30 2e 30 0.0.0.0 0028: 20 69 6e 20 62 69 74 63 in bitc 0030: 6f 69 6e 2e 65 78 65 20 oin.exe 0038: 30 2e 30 2e 30 2e 30 20 0.0.0.0 0040: 61 74 20 6f 66 66 73 65 at offse 0048: 74 20 30 30 30 62 65 33 t 000be3 0050: 36 38 0d 0a 68.. Second, when I send the error report: Event Type: Error Event Source: Application Error Event Category: None Event ID: 1001 Date: 01/02/2009 Time: 10:30:12 User: N/A Computer: HP91914945127 Description: Fault bucket 1123899417. For more information, see Help and Support Center at http://go.microsoft.com/fwlink/events.asp . Data: 0000: 42 75 63 6b 65 74 3a 20 Bucket: 0008: 31 31 32 33 38 39 39 34 11238994 0010: 31 37 0d 0a 17.. - What does it do when it crashes? Is the UI hung or is it still usable? See the first screenshot: the UI is still visible, and doesn't close until the error report is sent. I'm not sure whether it's usable, as I hadn't thought to try.Re: Another crash mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 2 of 3 21/07/2023, 17:10 I'll let you know of course if I have anything further to report. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FF Deleted:Bitcoin error.png The original MIME headers for this a�achment are: Content-Type: image/png; name="Bitcoin error.png" Content-Transfer-Encoding: base64 Content-Disposi�on: inline; filename="Bitcoin error.png" Deleted:Bitcoin error2.png The original MIME headers for this a�achment are: Content-Type: image/png; name="Bitcoin error2.png" Content-Transfer-Encoding: base64 Content-Disposi�on: inline; filename="Bitcoin error2.png" Attachments: Deleted:Bitcoin error.png 203 bytes Deleted:Bitcoin error2.png 205 bytesRe: Another crash mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 3 of 3 21/07/2023, 17:10
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090201-Re_Another crash-114913(75056999.1).pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090201-Re_Another crash-114913(75056999.1).pdf ### File content: Subject: Re: Another crash From: Nicholas Bohm <[email protected]> Date: 01/02/2009, 11:52 To: [email protected] Satoshi Nakamoto wrote: I guess I'd better send this from here also in case there's more e-mail problems. I got this message safely from both addresses. Good news! I pinpointed the bug. The bug could occur if your computer had trouble doing a DNS lookup. Quite possible. I subscribe to NASA's image of the day collection through Google Reader (an RSS reader), and for some time I have found that when I click the link for the NASA site, I get a Firefox error page saying "couldn't find the server); but clicking "try again" gets me through each time. This might be a DNS lookup error, presumably. The fix is at: http://www.upload.ae/file/14540/bc015-rar.html I've downloaded it and am running 015. Thanks for all your help and patience with this. I pleased if it's a help - there's always some discomfort in being the bearer of bad tidings! Just for completeness, I'll answer the questions in your earlier message: - Is there anything in db.log? No - What operating system are you using? Windows XP Service Pack 3 - When it crashes, does it put up any other message boxes that say anything else? See the two screenshots attached. I haven't got the file mentioned there, e02_appcompat.txt - it is deleted by sending the error report, which I did before thinking to make a copy. However, I sent you the corresponding file for an earlier crash attached to my message of 25th January.Re: Another crash mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 3 21/07/2023, 17:10 There is also the Event Viewer report, as follows: First, probably when the crash occurs: Event Type: Error Event Source: Application Error Event Category: None Event ID: 1000 Date: 01/02/2009 Time: 07:56:58 User: N/A Computer: HP91914945127 Description: Faulting application bitcoin.exe, version 0.0.0.0, faulting module bitcoin.exe, version 0.0.0.0, fault address 0x000be368. For more information, see Help and Support Center at http://go.microsoft.com/fwlink/events.asp . Data: 0000: 41 70 70 6c 69 63 61 74 Applicat 0008: 69 6f 6e 20 46 61 69 6c ion Fail 0010: 75 72 65 20 20 62 69 74 ure bit 0018: 63 6f 69 6e 2e 65 78 65 coin.exe 0020: 20 30 2e 30 2e 30 2e 30 0.0.0.0 0028: 20 69 6e 20 62 69 74 63 in bitc 0030: 6f 69 6e 2e 65 78 65 20 oin.exe 0038: 30 2e 30 2e 30 2e 30 20 0.0.0.0 0040: 61 74 20 6f 66 66 73 65 at offse 0048: 74 20 30 30 30 62 65 33 t 000be3 0050: 36 38 0d 0a 68.. Second, when I send the error report: Event Type: Error Event Source: Application Error Event Category: None Event ID: 1001 Date: 01/02/2009 Time: 10:30:12 User: N/A Computer: HP91914945127 Description: Fault bucket 1123899417. For more information, see Help and Support Center at http://go.microsoft.com/fwlink/events.asp . Data: 0000: 42 75 63 6b 65 74 3a 20 Bucket: 0008: 31 31 32 33 38 39 39 34 11238994 0010: 31 37 0d 0a 17.. - What does it do when it crashes? Is the UI hung or is it still usable? See the first screenshot: the UI is still visible, and doesn't close until the error report is sent. I'm not sure whether it's usable, as I hadn't thought to try.Re: Another crash mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 2 of 3 21/07/2023, 17:10 I'll let you know of course if I have anything further to report. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FF Deleted:Bitcoin error.png The original MIME headers for this a�achment are: Content-Type: image/png; name="Bitcoin error.png" Content-Transfer-Encoding: base64 Content-Disposi�on: inline; filename="Bitcoin error.png" Deleted:Bitcoin error2.png The original MIME headers for this a�achment are: Content-Type: image/png; name="Bitcoin error2.png" Content-Transfer-Encoding: base64 Content-Disposi�on: inline; filename="Bitcoin error2.png" Attachments: Deleted:Bitcoin error.png 203 bytes Deleted:Bitcoin error2.png 205 bytesRe: Another crash mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 3 of 3 21/07/2023, 17:10
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A number of email addresses have been associated with Satoshi. These have included: [email protected]; [email protected] ; and [email protected] . The last of those three was used in the emails to Adam Back and Wei Dai of late August 2008, while the first was used to post the White Paper in October 2008. 17. Over the period from 31 October 2008 to January 2009, Satoshi wrote a series of emai ls to the Metzdowd List. In one, dated 8 November 2008, Satoshi explained that the code had been written before the White Paper.15 In another, dated 14 November 2008, Satoshi 9 See email of 20 August 2008, exhibited by Mr Back at {D/80/1} . 10 See email exchange of 21 August 2008, exhibited by Mr Back at {D/76/1} . 11 See email of 22 August 2008 {L3/195/1} . 12 The email to the Metzdowd List may be found at {L3/278/1} . As noted above, the Bitcoin White Paper as released on 31 October 2008 is ID_000226 and may be found at {L3/2 31/1} . 13 As noted above, the White Paper as released on 24 March 2009 is ID_000865 and may be found at {L5/26/1}. 14 The Defence takes issue with that proposition, but the effect of the MIT License was ordered to be heard as part of a second trial following the resolution of the Identity Issue : see CCMC Order at {B/7/6} , §34-35. 15 {L3/290/2} . 9 claimed to be “better with code than with words ”. In a third , dated 17 November 2008, Satoshi wrote of having worked through various “little details over the last year and a half while coding [Bitcoin] ”, adding that the source code for the system was coming soon but was available on request in the meantime .16 Release of the Bitcoin Source Code and creation of the early blocks 18. On 3 January 2009 (GMT), Satoshi created the first block of the Bitcoin blockchain, on the basis of the framework set forth in the White Paper. This is referred to as Block 0 or the “Genesis Block ”. On 9 January 2009 (GMT), the second block in the blockchain (known as Block 1) was mined. Meanwhile, on 8 January 2009, Satoshi published a link to the first release of the Bitcoin executable file and the related source code on SourceForge (the “Bitcoin Code ”), announcing the release to the Metzdowd List.17 Before releasing the source code, Satoshi shared source code with developers, including Ray Dilling er and Hal Finney. Shortly afterwards , the first transaction in the Bitcoin blockchain was recorded in Block 170, involving the transfer of 10 Bitcoins from Satoshi to Mr Finney (which had been created as a result of the mining of Block 9). Satoshi’s later communications and his departure 19. Over the period from early 2009 to late 2010, Satoshi released a series of further versio ns of the Bitcoin Code (up to Bitcoin 0.3.19 on 13 December 2010). Satoshi communicate d messages about the system by means of Bitcoin forums, and also exchanged private emails with a number of individuals. Some of these emails were published, while other s were not. Meanwhile, from mid-2009, a community of developers emerged who contributed to the iterations of the code. 20. At the end of 2010, Satoshi informed a developer, Gavin Andresen, of an intention to step back from day-to-day Bitcoin management. Satoshi left Mr Andresen with administrative privileges for the source code repository. In December 2010, Mr Andresen established a new code repository on GitHub. While Dr Wright insists that he as Satoshi was very unhappy about this, Mr Andresen posted contemporaneously that he was acting with Satoshi’s blessing and emails recently disclosed between Satoshi and Mr Andresen 16 {L3/306/1} . 17 {L4/63/1} . 10 bear this out.18 Meanwhile , on 13 December 2010, Satoshi updated nearly all the Bitcoin files on SourceForge, amending the copyright notices (in version 0.3.19) so that they referred to “Bitcoin Developers” in place of “Satoshi Nakamoto”. In April 2011, Satoshi sent a final series of emails and at the same time handed over the network alert key and broadcast code to a number of developers. The last email uncontroversially attributed to Satoshi was written to Gavin Andresen on 26 April 2011.19 21. Since Satoshi’s departure , a series of individua ls have been speculatively identified as Satoshi, including Mr Finney (who died in 2014), Mr Szabo and a man called Dorian Nakamoto . Each of those three denied the rumours. Dr Wright is also not the only individual to have claimed to be Satoshi and numerous others have, for example, registered the White Paper as their copyright at the USPTO.20 Dr Wright and his Life up to 2011 22. Dr Wright is an IT security professional with a range of academic interests, who claims more than 16 Master’s degrees and two doctoral degrees, including a PhD in Computer Science and Economics from Charles Sturt University .21 He was born and raised in Australia, and spent most of his life there until late 2015. 23. In the early to mid-1990s , he worked at OzEmail (an ISP in Australia ) as a corporate account manager .22 In 1997- 1998, he held a post as IT security consultant for the Australian Stock Exchange , where he developed IT security systems.23 24. From 1997 to 2003 he worked primarily through DeMorgan Information Security Systems Ltd (“DeMorgan ”), an IT security consultancy business that he founded.24 In 1998, DeMorgan was
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 4 of 51 COPA v Wright - Opening Skeleton of COPA.pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/COPA v Wright - Opening Skeleton of COPA.pdf ### File content: A number of email addresses have been associated with Satoshi. These have included: [email protected]; [email protected] ; and [email protected] . The last of those three was used in the emails to Adam Back and Wei Dai of late August 2008, while the first was used to post the White Paper in October 2008. 17. Over the period from 31 October 2008 to January 2009, Satoshi wrote a series of emai ls to the Metzdowd List. In one, dated 8 November 2008, Satoshi explained that the code had been written before the White Paper.15 In another, dated 14 November 2008, Satoshi 9 See email of 20 August 2008, exhibited by Mr Back at {D/80/1} . 10 See email exchange of 21 August 2008, exhibited by Mr Back at {D/76/1} . 11 See email of 22 August 2008 {L3/195/1} . 12 The email to the Metzdowd List may be found at {L3/278/1} . As noted above, the Bitcoin White Paper as released on 31 October 2008 is ID_000226 and may be found at {L3/2 31/1} . 13 As noted above, the White Paper as released on 24 March 2009 is ID_000865 and may be found at {L5/26/1}. 14 The Defence takes issue with that proposition, but the effect of the MIT License was ordered to be heard as part of a second trial following the resolution of the Identity Issue : see CCMC Order at {B/7/6} , §34-35. 15 {L3/290/2} . 9 claimed to be “better with code than with words ”. In a third , dated 17 November 2008, Satoshi wrote of having worked through various “little details over the last year and a half while coding [Bitcoin] ”, adding that the source code for the system was coming soon but was available on request in the meantime .16 Release of the Bitcoin Source Code and creation of the early blocks 18. On 3 January 2009 (GMT), Satoshi created the first block of the Bitcoin blockchain, on the basis of the framework set forth in the White Paper. This is referred to as Block 0 or the “Genesis Block ”. On 9 January 2009 (GMT), the second block in the blockchain (known as Block 1) was mined. Meanwhile, on 8 January 2009, Satoshi published a link to the first release of the Bitcoin executable file and the related source code on SourceForge (the “Bitcoin Code ”), announcing the release to the Metzdowd List.17 Before releasing the source code, Satoshi shared source code with developers, including Ray Dilling er and Hal Finney. Shortly afterwards , the first transaction in the Bitcoin blockchain was recorded in Block 170, involving the transfer of 10 Bitcoins from Satoshi to Mr Finney (which had been created as a result of the mining of Block 9). Satoshi’s later communications and his departure 19. Over the period from early 2009 to late 2010, Satoshi released a series of further versio ns of the Bitcoin Code (up to Bitcoin 0.3.19 on 13 December 2010). Satoshi communicate d messages about the system by means of Bitcoin forums, and also exchanged private emails with a number of individuals. Some of these emails were published, while other s were not. Meanwhile, from mid-2009, a community of developers emerged who contributed to the iterations of the code. 20. At the end of 2010, Satoshi informed a developer, Gavin Andresen, of an intention to step back from day-to-day Bitcoin management. Satoshi left Mr Andresen with administrative privileges for the source code repository. In December 2010, Mr Andresen established a new code repository on GitHub. While Dr Wright insists that he as Satoshi was very unhappy about this, Mr Andresen posted contemporaneously that he was acting with Satoshi’s blessing and emails recently disclosed between Satoshi and Mr Andresen 16 {L3/306/1} . 17 {L4/63/1} . 10 bear this out.18 Meanwhile , on 13 December 2010, Satoshi updated nearly all the Bitcoin files on SourceForge, amending the copyright notices (in version 0.3.19) so that they referred to “Bitcoin Developers” in place of “Satoshi Nakamoto”. In April 2011, Satoshi sent a final series of emails and at the same time handed over the network alert key and broadcast code to a number of developers. The last email uncontroversially attributed to Satoshi was written to Gavin Andresen on 26 April 2011.19 21. Since Satoshi’s departure , a series of individua ls have been speculatively identified as Satoshi, including Mr Finney (who died in 2014), Mr Szabo and a man called Dorian Nakamoto . Each of those three denied the rumours. Dr Wright is also not the only individual to have claimed to be Satoshi and numerous others have, for example, registered the White Paper as their copyright at the USPTO.20 Dr Wright and his Life up to 2011 22. Dr Wright is an IT security professional with a range of academic interests, who claims more than 16 Master’s degrees and two doctoral degrees, including a PhD in Computer Science and Economics from Charles Sturt University .21 He was born and raised in Australia, and spent most of his life there until late 2015. 23. In the early to mid-1990s , he worked at OzEmail (an ISP in Australia ) as a corporate account manager .22 In 1997- 1998, he held a post as IT security consultant for the Australian Stock Exchange , where he developed IT security systems.23 24. From 1997 to 2003 he worked primarily through DeMorgan Information Security Systems Ltd (“DeMorgan ”), an IT security consultancy business that he founded.24 In 1998, DeMorgan was
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get some anticipation going. Even if hardly anyone else is posting, I have seen project forums where most of the posts are the author announcing what's going on with the latest changes. Users can see progress going on, see that it's improving and supported and not abandonware. It's a little like a blog in that case, but easier for users to use it as a searchable FAQ and better organized. Whenever I google search software questions, most of the hits are forum posts. SUBJECT : Re: linux-0.1.6-test7 FROM: Satoshi Nakamoto <[email protected]> TO: Liberty Standard <[email protected]> CC: Martti Malmi <[email protected]> DATE: 18/11/2009 04:35 Finally an easy one. I see a way that could happen on a long operation such as the initial download. The TryLock bug is unrelated to the db stuff. Fix will be in test8. I've been able to reproduce the db::open/close exception 3 times now on 32-bit linux by hitting it with a continuous flood of non-stop requests. It looks like even periodically closing the wallet.dat database to flush it gets the db::close exceptions. I'm disabling the wallet flush feature on Linux. On Linux we'll never close a database handle until we're ready to exit. So far with this disabled, no exceptions. I'm also implementing the orderly initial block download. Instead of naively requesting all the blocks at once, it'll request batches of 500 at a time. This way, it'll receive the blocks before the retry timeout, so it shouldn't go requesting it from other nodes unless it actually doesn't receive them or it's too slow. The change is in the requestee's side, so this functionality won't be visible until your initial block download is coming from a node that has the new version. I'm going to test this some more before sending test8. Liberty Standard wrote: > I started with a fresh data directory with test7. Blocks started to > download much faster. It only took about 15 seconds where it took a few > minutes previously with the Linux build. It crashed once while it was > downloading blocks with the following message in the terminal. > > ../include/wx/thrimpl.cpp(50): assert "m_internal" failed in TryLock(): > wxMutex::TryLock(): not initialized [in child thread] > Trace/breakpoint trap > > I've included my log file, but I forgot to back it up before restarting > bitcoin, so I'm not sure at what point in the log file the crash occurred. > > Fortunately I haven't encountered the segmentation fault yet. The > frequency of segmentation faults in the previous builds varied quite a > bit, so I'll keep running it and let you know if i run into any problems. > > > > On Tue, Nov 17, 2009 at 5:41 AM, Satoshi Nakamoto <[email protected] > <mailto:[email protected]> > wrote: > > test 7: > > Backup your data directory before running this, just in case. > > Workaround for the Db::open/Db::close "Bad file descriptor" > exception. Might also make the initial block download faster. The > workaround is to open the database handles and keep them open for > the duration of the program, which is actually the more common thing > to do anyway. If we're not closing and opening all the time, the > error shouldn't get a chance to happen. > > The one exception is wallet.dat, which I still close after writing > is finished so I can flush the transaction logs into the dat file, > making the dat file standalone. That way if someone does a backup > while Bitcoin is running, they'll get a wallet.dat that is valid by > itself without the database transaction logs. > > This is a restructuring of the database handling, so we might find > some new deadlocks. Usually if it deadlocks, either the UI will > stop repainting, or it'll stop using CPU even though it still says > Generating. > > SUBJECT : Re: Db::open/Db::close "Bad file descriptor" exception FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 18/11/2009 05:14 Thanks. The db::open/close errors confirm the pattern. More interesting is the zombie sockets activity towards the end, and the socket thread monitor tripped but didn't get it going again. Was the machine disconnected from the net? MSG_DONTWAIT in test5 solved the zombie problem for Liberty. What test version were you running? (I should print the test version in the log) [email protected] wrote: > Here's the logs in case they're still useful. > >> I have an idea for a workaround, but it depends on what files the >> errors are on. If you've accumulated several errors in db.log, could >> you send it to me? (even if it's rather simple and boring) Is the file >> listed always blkindex.dat, or does it include addr.dat or wallet.dat >> too? > SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 18/11/2009 05:32 That's great, this is going to fun! I'll research what people say about the two. [email protected] wrote: > I installed both phpBB3 and Simple Machines Forum, which are kind of > the market leaders among the open source forums. SMF's interface looks > better on the first look, especially the admin panel. What do you > think, shall we go with SMF or phpBB3? > > SUBJECT : SMF forum, need a mod installed FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 20/11/2009 05:14 I've been configuring the SMF forum. They're saying SMF is better written than phpBB and more reliable, so if I can get SMF to look right, that's the preferable choice. Most forums run vBulletin (big-boards.com lists 1376 vBulletin, 275 Invision, 245 phpBB and 41 SMF), so if you don't look like vBulletin or Invision, it looks like you compromised because you couldn't afford vBulletin. SMF's UI started out further away from the standard look, but I've been able to use CSS to make it look more like the others. I've done as much as I can with CSS, the rest requires editing PHP files and uploading images. The forum doesn't have a built in
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 26 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf ### Folder name: Martti Malmi - Exhibits ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf ### File content: get some anticipation going. Even if hardly anyone else is posting, I have seen project forums where most of the posts are the author announcing what's going on with the latest changes. Users can see progress going on, see that it's improving and supported and not abandonware. It's a little like a blog in that case, but easier for users to use it as a searchable FAQ and better organized. Whenever I google search software questions, most of the hits are forum posts. SUBJECT : Re: linux-0.1.6-test7 FROM: Satoshi Nakamoto <[email protected]> TO: Liberty Standard <[email protected]> CC: Martti Malmi <[email protected]> DATE: 18/11/2009 04:35 Finally an easy one. I see a way that could happen on a long operation such as the initial download. The TryLock bug is unrelated to the db stuff. Fix will be in test8. I've been able to reproduce the db::open/close exception 3 times now on 32-bit linux by hitting it with a continuous flood of non-stop requests. It looks like even periodically closing the wallet.dat database to flush it gets the db::close exceptions. I'm disabling the wallet flush feature on Linux. On Linux we'll never close a database handle until we're ready to exit. So far with this disabled, no exceptions. I'm also implementing the orderly initial block download. Instead of naively requesting all the blocks at once, it'll request batches of 500 at a time. This way, it'll receive the blocks before the retry timeout, so it shouldn't go requesting it from other nodes unless it actually doesn't receive them or it's too slow. The change is in the requestee's side, so this functionality won't be visible until your initial block download is coming from a node that has the new version. I'm going to test this some more before sending test8. Liberty Standard wrote: > I started with a fresh data directory with test7. Blocks started to > download much faster. It only took about 15 seconds where it took a few > minutes previously with the Linux build. It crashed once while it was > downloading blocks with the following message in the terminal. > > ../include/wx/thrimpl.cpp(50): assert "m_internal" failed in TryLock(): > wxMutex::TryLock(): not initialized [in child thread] > Trace/breakpoint trap > > I've included my log file, but I forgot to back it up before restarting > bitcoin, so I'm not sure at what point in the log file the crash occurred. > > Fortunately I haven't encountered the segmentation fault yet. The > frequency of segmentation faults in the previous builds varied quite a > bit, so I'll keep running it and let you know if i run into any problems. > > > > On Tue, Nov 17, 2009 at 5:41 AM, Satoshi Nakamoto <[email protected] > <mailto:[email protected]> > wrote: > > test 7: > > Backup your data directory before running this, just in case. > > Workaround for the Db::open/Db::close "Bad file descriptor" > exception. Might also make the initial block download faster. The > workaround is to open the database handles and keep them open for > the duration of the program, which is actually the more common thing > to do anyway. If we're not closing and opening all the time, the > error shouldn't get a chance to happen. > > The one exception is wallet.dat, which I still close after writing > is finished so I can flush the transaction logs into the dat file, > making the dat file standalone. That way if someone does a backup > while Bitcoin is running, they'll get a wallet.dat that is valid by > itself without the database transaction logs. > > This is a restructuring of the database handling, so we might find > some new deadlocks. Usually if it deadlocks, either the UI will > stop repainting, or it'll stop using CPU even though it still says > Generating. > > SUBJECT : Re: Db::open/Db::close "Bad file descriptor" exception FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 18/11/2009 05:14 Thanks. The db::open/close errors confirm the pattern. More interesting is the zombie sockets activity towards the end, and the socket thread monitor tripped but didn't get it going again. Was the machine disconnected from the net? MSG_DONTWAIT in test5 solved the zombie problem for Liberty. What test version were you running? (I should print the test version in the log) [email protected] wrote: > Here's the logs in case they're still useful. > >> I have an idea for a workaround, but it depends on what files the >> errors are on. If you've accumulated several errors in db.log, could >> you send it to me? (even if it's rather simple and boring) Is the file >> listed always blkindex.dat, or does it include addr.dat or wallet.dat >> too? > SUBJECT : Re: Forum FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 18/11/2009 05:32 That's great, this is going to fun! I'll research what people say about the two. [email protected] wrote: > I installed both phpBB3 and Simple Machines Forum, which are kind of > the market leaders among the open source forums. SMF's interface looks > better on the first look, especially the admin panel. What do you > think, shall we go with SMF or phpBB3? > > SUBJECT : SMF forum, need a mod installed FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 20/11/2009 05:14 I've been configuring the SMF forum. They're saying SMF is better written than phpBB and more reliable, so if I can get SMF to look right, that's the preferable choice. Most forums run vBulletin (big-boards.com lists 1376 vBulletin, 275 Invision, 245 phpBB and 41 SMF), so if you don't look like vBulletin or Invision, it looks like you compromised because you couldn't afford vBulletin. SMF's UI started out further away from the standard look, but I've been able to use CSS to make it look more like the others. I've done as much as I can with CSS, the rest requires editing PHP files and uploading images. The forum doesn't have a built in
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would have had access to these emails in June 2019 but not preserved any of them by any means is risible. Failures of Cryptographic Proof – the Sartre B log P ost and its Aftermath 242. Dr Wright’s most spectacular failure of proof was the Sartre blog post. The expectation of his entire team, including Mr MacGregor, Mr Matthews and Mr Ayre , was that on 2 May 2016 Dr Wright would issue a blog including a message signed with a key associated with one of the early blocks on the Bitcoin blockchain. That expectation was shared by Mr Andresen, Mr Matonis, the media outlets to which Dr Wright had given interviews and the media consultants with whom he had worked. Instead, the “Sartre blog” post which Dr Wright issued404 provided an over-complicated explanation of a means of verifying a cryptographic signature and presented a signature which had simply been lifted from the public blockchain. As set out above, those who had been supporting Dr Wright reacted with expressions of panic and betrayal. 243. It is common ground between the parties’ experts that the Sartre blog post proved nothing. Prof Meiklejohn explains that all the main cryptographic objects in the post “can be derived directly from the data for the [Satoshi / Finney] Transaction and the Block 9 Generation Transaction, which due to the nature of the blockchain are available to everyone. ” She adds: “This data is thus replayed from those transactions, which… means it provides no cryptographic evidence of the possession of the associated private key.”405 Mr Gao accepts this point .406 401 {L15/133/5} . 402 {L16/272/192} , internal p192 -193. 403 For example, much of Satoshi’s email communication with Mr Bohm of 2009 used the Vistomail account (e.g. email of 25 January 2009 {D/93/1} ). Those emails were not in the public domain before service of evidence in these proceedings. 404 {L18/257/1} . 405 Meiklejohn §§135 -137 {G/2/60} . 406 Gao 1, §308 {I/2/60} ; joint expert statement at §2 {Q/3/2} . 97 244. Dr Wright has since sought to explain away this failure of proof by two excuses: (a) that the Sartre blog post was altered between his draft and the published version; and (b) that it was never intended to provide actual proof of his claim to be Satoshi , but rather to state his principled opposition to providing such cryptographic proof.407 As to the first of those points, his own draft of the blog post (sent on 29 April 2016) was largely the same as the published version, and his own team read it as intended to provide proof by a valid signature. As to the second, it is plain from the email correspondence from the time (summarised above) that it was intended to give such proof. Even Mr Matthews can only attempt to defend Dr Wright by saying that he was committing an act of “sabotage ” to embarrass Mr MacGregor , which is both a bizarre explanation and conflicts with Dr Wright’s own account .408 245. The aftermath of the Sartre blog post is equally striking. Over the following 48 hours (from 2 to 4 May 2016), Dr Wright’s supporters pressed him to provide some form of objectively verifiable proof in one of various forms. As explained above, on 3 May 2016 the blog post was issued in his name entitled “Extraordinary Claims Require Extraordinary Proof ”,409 promising over the following days to post a series of pieces to “lay the foundations for [his] extraordinary claim ”, including “transferring bitcoin from an early block ”. The post concluded: “I will present what I believe to be ‘extraordinary proof’ and ask only that it be independently validated.” However, that proof never came. 246. It was arranged that Mr Cellan -Jones and Mr Andresen would transfer Bitcoin to addresses associated with Satoshi, and that they would be sent back. Mr Cellan -Jones explains how on 4 May 2016 he sent 0.01701 Bitcoin (at a current valuation, worth around £600) to the address used in the first Bitcoin transaction with Hal Finney. This sum was never returned , and Dr Wright failed to follow up on what Mr Cellan -Jones describes as a “simple and comprehensive way for Wright to prove that he was Satoshi ”.410 As recounted above, Mr Andresen made a similar transfer , which was also never returned. 247. Dr Wright did not provide any other form of proof . In the two days between 2 and 4 May 2016, he told his team that he was taking steps to gain access to Satoshi’s PGP key to 407 Wright 1, §217-220 {E/2/37} . 408 Matthews 1, §104 {E/5/22} . 409 {L13/262/1} . 410 Cellan -Jones §16, {C/5/4} . 98 sign a message with that (something he now says is impossible or infeasible). He dodged their questions, while trying to divert them with a short article about the Genesis Block (which anyone could have written from publicly available information) .411 In the end, he did not provide any proof and the “big reveal” project fell apart. 248. The natural conclusion to be drawn from this remarkable sequence of events is that Dr Wright did not provide proper proof because he could not do so. The suggestion that he took a principled stand against offering cryptographic proof is contradicted by (a) the fact that he engaged in the various private signing sessions with the aim that they should be fully written up in articles and (b) the fact that his
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 43 of 51 COPA v Wright - Opening Skeleton of COPA.pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/COPA v Wright - Opening Skeleton of COPA.pdf ### File content: would have had access to these emails in June 2019 but not preserved any of them by any means is risible. Failures of Cryptographic Proof – the Sartre B log P ost and its Aftermath 242. Dr Wright’s most spectacular failure of proof was the Sartre blog post. The expectation of his entire team, including Mr MacGregor, Mr Matthews and Mr Ayre , was that on 2 May 2016 Dr Wright would issue a blog including a message signed with a key associated with one of the early blocks on the Bitcoin blockchain. That expectation was shared by Mr Andresen, Mr Matonis, the media outlets to which Dr Wright had given interviews and the media consultants with whom he had worked. Instead, the “Sartre blog” post which Dr Wright issued404 provided an over-complicated explanation of a means of verifying a cryptographic signature and presented a signature which had simply been lifted from the public blockchain. As set out above, those who had been supporting Dr Wright reacted with expressions of panic and betrayal. 243. It is common ground between the parties’ experts that the Sartre blog post proved nothing. Prof Meiklejohn explains that all the main cryptographic objects in the post “can be derived directly from the data for the [Satoshi / Finney] Transaction and the Block 9 Generation Transaction, which due to the nature of the blockchain are available to everyone. ” She adds: “This data is thus replayed from those transactions, which… means it provides no cryptographic evidence of the possession of the associated private key.”405 Mr Gao accepts this point .406 401 {L15/133/5} . 402 {L16/272/192} , internal p192 -193. 403 For example, much of Satoshi’s email communication with Mr Bohm of 2009 used the Vistomail account (e.g. email of 25 January 2009 {D/93/1} ). Those emails were not in the public domain before service of evidence in these proceedings. 404 {L18/257/1} . 405 Meiklejohn §§135 -137 {G/2/60} . 406 Gao 1, §308 {I/2/60} ; joint expert statement at §2 {Q/3/2} . 97 244. Dr Wright has since sought to explain away this failure of proof by two excuses: (a) that the Sartre blog post was altered between his draft and the published version; and (b) that it was never intended to provide actual proof of his claim to be Satoshi , but rather to state his principled opposition to providing such cryptographic proof.407 As to the first of those points, his own draft of the blog post (sent on 29 April 2016) was largely the same as the published version, and his own team read it as intended to provide proof by a valid signature. As to the second, it is plain from the email correspondence from the time (summarised above) that it was intended to give such proof. Even Mr Matthews can only attempt to defend Dr Wright by saying that he was committing an act of “sabotage ” to embarrass Mr MacGregor , which is both a bizarre explanation and conflicts with Dr Wright’s own account .408 245. The aftermath of the Sartre blog post is equally striking. Over the following 48 hours (from 2 to 4 May 2016), Dr Wright’s supporters pressed him to provide some form of objectively verifiable proof in one of various forms. As explained above, on 3 May 2016 the blog post was issued in his name entitled “Extraordinary Claims Require Extraordinary Proof ”,409 promising over the following days to post a series of pieces to “lay the foundations for [his] extraordinary claim ”, including “transferring bitcoin from an early block ”. The post concluded: “I will present what I believe to be ‘extraordinary proof’ and ask only that it be independently validated.” However, that proof never came. 246. It was arranged that Mr Cellan -Jones and Mr Andresen would transfer Bitcoin to addresses associated with Satoshi, and that they would be sent back. Mr Cellan -Jones explains how on 4 May 2016 he sent 0.01701 Bitcoin (at a current valuation, worth around £600) to the address used in the first Bitcoin transaction with Hal Finney. This sum was never returned , and Dr Wright failed to follow up on what Mr Cellan -Jones describes as a “simple and comprehensive way for Wright to prove that he was Satoshi ”.410 As recounted above, Mr Andresen made a similar transfer , which was also never returned. 247. Dr Wright did not provide any other form of proof . In the two days between 2 and 4 May 2016, he told his team that he was taking steps to gain access to Satoshi’s PGP key to 407 Wright 1, §217-220 {E/2/37} . 408 Matthews 1, §104 {E/5/22} . 409 {L13/262/1} . 410 Cellan -Jones §16, {C/5/4} . 98 sign a message with that (something he now says is impossible or infeasible). He dodged their questions, while trying to divert them with a short article about the Genesis Block (which anyone could have written from publicly available information) .411 In the end, he did not provide any proof and the “big reveal” project fell apart. 248. The natural conclusion to be drawn from this remarkable sequence of events is that Dr Wright did not provide proper proof because he could not do so. The suggestion that he took a principled stand against offering cryptographic proof is contradicted by (a) the fact that he engaged in the various private signing sessions with the aim that they should be fully written up in articles and (b) the fact that his
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is not accepting the obvious truth regarding Satoshi’s communications with Adam Back. Appendix B: Schedule of Transcript References 167 REFERENCE QUOTE COMMENT advantage in terms of the partial results accumulated helping create further the partial - collisions more cheaply." Do you see that? A. I do. Q. And then the final email {D/74/1}, which is C00002540. {L4/162/1}. This is Satoshi's email, which I think we looked at last week, of 10 January 2009, expressing gratitude to Dr Back and pointing him to the open source implementation of Bitcoin, yes? A. It is. Q. Now, those are the email communications between Satoshi and Dr Back? A. Not all of them. Q. Well, Dr Back wasn't dismissive at all, was he? A. Oh, completely. He said he hasn't read my paper, and he still didn't later, and he pointed out to other failed attempts and basically fobbed me off going, "Look, other people have tried it". Q. He doesn't say that in any of these emails, does he? A. He actually does. Micromint was an old system that everyone in the industry knew that failed for certain reasons. Q. You say in your witness statement: "... he stated that digital cash had been attempted before and was bound to fail." That doesn't appear in any of these em ails, does it? A. No, he hasn't included all of the emails, and he also hasn't included the extensive communications that himself and I had on Twitter and direct messages. Q. But presumably they're not communications you're fortunate enough to have in any copies anywhere? A. No, because all of my Twitter was shut down by a certain COPA member, Mr Dorsey. Q. Put aside your allegations for a moment and answer the questions. A. It's not an allegation. My Twitter was shut down by Jack Dorsey personally, and I was banned for a time until X - well, Twitter was sold and then I was allowed back on. I was completely banned from that platform, I'm completely banned from LinkedIn, wh ere other COPA members are involved, and don't have accounts on them. So I was kicked off that platform and I don't have any of the communications. Of course, some of those are public and in the Wayback Appendix B: Schedule of Transcript References 168 REFERENCE QUOTE COMMENT Machine, so talks with Adam Back are available demons trating that I was communicating with him. {Day6/68:6} - {Day6/70:3} Q. Well, I'm going to suggest to you that as Dr Back says in his witness statement, he pro vided his communications with Satoshi and that you are simply inventing the supposed additional communications where he said things which are flatly inconsistent with his actual emails. A. No, but I'll also suggest that what I've been calling it a chain o f hash based proof - of - work, etc, is exactly what I've been calling it, which wasn't publicly known. On top of that, Adam didn't go on the forum, didn't connect to anything, didn't try out any of the system, didn't even read the Bitcoin White Paper, des pite my giving it to him, which he did announce and discuss with me, both publicly and privately in '12, '13 and '14. He put that on his Twitter -- Q. So when Dr Back says that he's provided a complete set of his email correspondence, he's lying? A. Or h e's lost them. Q. He says in his witness statement of these emails, that was the extent of it, and that he's provided a copy of his email correspondence. A. This morning, yesterday and the day before, he also promoted to people that Bitcoin will go up in price and that if you buy now you'll get rich. He has never promoted an actual solution. The only thing that he does every single day on his feeds and promotion is to tell people to buy into a Ponzi, "if you buy BTC, it will go to the moon and you will ge t rich", that is a quote from one of his things. Technically, that's actually a breach of the financial services legislation, and Dr Wright asked about Satoshi’s email communications with Dr Back. Rather than answering the question, Dr W right responds by making multiple (unsubstantiated) accusations against Dr Back. Appendix B: Schedule of Transcript References 169 REFERENCE QUOTE COMMENT telling people to buy into a risky asset is not only highly irresponsible, but also criminal. So, where he is saying these things, the only thing he says is about "get rich quick, buy into this, it has to go to a million". Q. Dr Wright, how was that an answer to any of my questions? A. Well, if you're going to be dishonest in selling to people and getting people to buy into a h ighly speculative asset ... he told people online - Q. Pause there. Pause there. None of this is an answer to any of my questions, is it? A. Actually, yes, it is - Q. These are just allegations against people you don't like, aren't they, Dr Wright? A. No, actually, on his Twitter, where he said, "Sell your house, take out a mortgage, put all the money into Bitcoin because you can't lose it" -- {L14/482/1} - April 2019 Article by Wright with reference to Toumas Aura (C00001010) {Day6/71:3 -6} {Just answering this question and keeping it to this question, when you refer to "the Aurora paper", do you intend to refer to a paper by Tuomas Aura? A. Yes. Dr Wright is mistaking Professor Aura’s surname for “Aurora”. {L3/231/1} Bitcoin White Paper {Day6/72:25} - {Day6/73:24} Q. {L13/492/1}, please. Page 2, please {L13/492/2}. Do you recognise this as a long article written by Andrew O'Hagan called, "The Satoshi Affair"? A. No, I recognise a fiction book. Q. Page 24, please {L13/492/24}, the quotation near the top: "'We all have a narcissistic hubris', Wright told me. He wanted to take May's BlackNet idea further. He was also enthusiastic, in those early days, about Hashcash and B - money. The idea behind H ashcash, a 'proof - of - work' algorithm where each of a group of computers performs a small task that can be instantly verified ..." Then there's a short explanation in brackets: "... was 'totally necessary for the building of bitcoin'. Wright said that h e spoke to Adam Dr Wright is not accepting obvious truth of the account given in The Satoshi
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 68 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: is not accepting the obvious truth regarding Satoshi’s communications with Adam Back. Appendix B: Schedule of Transcript References 167 REFERENCE QUOTE COMMENT advantage in terms of the partial results accumulated helping create further the partial - collisions more cheaply." Do you see that? A. I do. Q. And then the final email {D/74/1}, which is C00002540. {L4/162/1}. This is Satoshi's email, which I think we looked at last week, of 10 January 2009, expressing gratitude to Dr Back and pointing him to the open source implementation of Bitcoin, yes? A. It is. Q. Now, those are the email communications between Satoshi and Dr Back? A. Not all of them. Q. Well, Dr Back wasn't dismissive at all, was he? A. Oh, completely. He said he hasn't read my paper, and he still didn't later, and he pointed out to other failed attempts and basically fobbed me off going, "Look, other people have tried it". Q. He doesn't say that in any of these emails, does he? A. He actually does. Micromint was an old system that everyone in the industry knew that failed for certain reasons. Q. You say in your witness statement: "... he stated that digital cash had been attempted before and was bound to fail." That doesn't appear in any of these em ails, does it? A. No, he hasn't included all of the emails, and he also hasn't included the extensive communications that himself and I had on Twitter and direct messages. Q. But presumably they're not communications you're fortunate enough to have in any copies anywhere? A. No, because all of my Twitter was shut down by a certain COPA member, Mr Dorsey. Q. Put aside your allegations for a moment and answer the questions. A. It's not an allegation. My Twitter was shut down by Jack Dorsey personally, and I was banned for a time until X - well, Twitter was sold and then I was allowed back on. I was completely banned from that platform, I'm completely banned from LinkedIn, wh ere other COPA members are involved, and don't have accounts on them. So I was kicked off that platform and I don't have any of the communications. Of course, some of those are public and in the Wayback Appendix B: Schedule of Transcript References 168 REFERENCE QUOTE COMMENT Machine, so talks with Adam Back are available demons trating that I was communicating with him. {Day6/68:6} - {Day6/70:3} Q. Well, I'm going to suggest to you that as Dr Back says in his witness statement, he pro vided his communications with Satoshi and that you are simply inventing the supposed additional communications where he said things which are flatly inconsistent with his actual emails. A. No, but I'll also suggest that what I've been calling it a chain o f hash based proof - of - work, etc, is exactly what I've been calling it, which wasn't publicly known. On top of that, Adam didn't go on the forum, didn't connect to anything, didn't try out any of the system, didn't even read the Bitcoin White Paper, des pite my giving it to him, which he did announce and discuss with me, both publicly and privately in '12, '13 and '14. He put that on his Twitter -- Q. So when Dr Back says that he's provided a complete set of his email correspondence, he's lying? A. Or h e's lost them. Q. He says in his witness statement of these emails, that was the extent of it, and that he's provided a copy of his email correspondence. A. This morning, yesterday and the day before, he also promoted to people that Bitcoin will go up in price and that if you buy now you'll get rich. He has never promoted an actual solution. The only thing that he does every single day on his feeds and promotion is to tell people to buy into a Ponzi, "if you buy BTC, it will go to the moon and you will ge t rich", that is a quote from one of his things. Technically, that's actually a breach of the financial services legislation, and Dr Wright asked about Satoshi’s email communications with Dr Back. Rather than answering the question, Dr W right responds by making multiple (unsubstantiated) accusations against Dr Back. Appendix B: Schedule of Transcript References 169 REFERENCE QUOTE COMMENT telling people to buy into a risky asset is not only highly irresponsible, but also criminal. So, where he is saying these things, the only thing he says is about "get rich quick, buy into this, it has to go to a million". Q. Dr Wright, how was that an answer to any of my questions? A. Well, if you're going to be dishonest in selling to people and getting people to buy into a h ighly speculative asset ... he told people online - Q. Pause there. Pause there. None of this is an answer to any of my questions, is it? A. Actually, yes, it is - Q. These are just allegations against people you don't like, aren't they, Dr Wright? A. No, actually, on his Twitter, where he said, "Sell your house, take out a mortgage, put all the money into Bitcoin because you can't lose it" -- {L14/482/1} - April 2019 Article by Wright with reference to Toumas Aura (C00001010) {Day6/71:3 -6} {Just answering this question and keeping it to this question, when you refer to "the Aurora paper", do you intend to refer to a paper by Tuomas Aura? A. Yes. Dr Wright is mistaking Professor Aura’s surname for “Aurora”. {L3/231/1} Bitcoin White Paper {Day6/72:25} - {Day6/73:24} Q. {L13/492/1}, please. Page 2, please {L13/492/2}. Do you recognise this as a long article written by Andrew O'Hagan called, "The Satoshi Affair"? A. No, I recognise a fiction book. Q. Page 24, please {L13/492/24}, the quotation near the top: "'We all have a narcissistic hubris', Wright told me. He wanted to take May's BlackNet idea further. He was also enthusiastic, in those early days, about Hashcash and B - money. The idea behind H ashcash, a 'proof - of - work' algorithm where each of a group of computers performs a small task that can be instantly verified ..." Then there's a short explanation in brackets: "... was 'totally necessary for the building of bitcoin'. Wright said that h e spoke to Adam Dr Wright is not accepting obvious truth of the account given in The Satoshi
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itself as a blog to prove possession of a private key, just as Mr Matthews and Mr Andresen expected, and each of these blogs failed by that standard, didn't it, both your draft and the final version? A. No, as I said, if I sign as Craig Wright, Satoshi. So, no, I was nev er intending in that one. What I promised was, if you did the proof session, if you did everything that I wanted put together, if you put together my hundreds of papers, if you put together my thousands of patents and all the work I'd been doing, if you showed the scaling work I was doing and you went through that process, then I would have signed. The only way that I could sign is to have my identity known first, because of what I am, what I've done. Appendix B: Schedule of Transcript References 251 REFERENCE QUOTE COMMENT DAY 8 CROSS - EXAMINATION OF DR CRAIG WRIGHT BY JONATHAN HOUGH KC {L11/285} Implementation deed, dated 7 January 2016 {Day8/6:15} – {Day8/7:21} Q. Page 10, please {L11/285/10}, middle of the page, clause 7, "Craig Wright", 7.2(a): "Craig Wright has entered into an Employment Contract with Tyche Consulting Limited dated 26 October 2015 at a salary of £160,000 [sterling] per annum. The p arties acknowledge and agree that Craig Wright may subsequently become employed by a related body corporate ..." Do you say that that statement, that you'd entered into an employment contract with Tyche Consulting Limited of that date, in this contract whi ch you signed is wrong? A. I do. There was never any tax with HMRC filed, and on that day, the documentation that I had to sign with my wife was approximately 1,200 pages in total, a little bit more, probably. We had 100 different documents to sign for al l of the IP, I didn't have any solicitors with me, because I was in the UK, not Australia, and I had no chance to read them. So, I looked through the things very quickly, I didn't analyse them in detail. Q. So, you say that you signed this agreement, incl uding the term headed "Craig Wright", without reading the agreement or the term headed "Craig Wright"? A. In full, no, I hadn't. I'll also note, the email you brought up yesterday has a statement saying that my wife and I are ready to start a family. When we came to the UK, my wife and I were in our mid- 40s, my wife had three children already, we weren't looking at having children and family, as that email states. So, my Lord, it was well known that my wife and I were not looking at having more children. Having admitted that he stated he was not Tyche, Dr Wright is asked about the Implementation Deed that states that he entered into an employment contract with Tyche Consulting Limited. Dr Wright is evasive in response, claiming that he did not read the agre ement fully. {L10/426} - Tyche Consulting Limited, Employment Contract, Craig Wright, 26th October 2015. {Day8/7:22} - {Day8/8:7} Q. {L10/426/1}, please. This is a document in your disclosure, "Tyche Consulting Limited, Employment Contract, Craig Wright, 26th October 2015". Page 2, please {L10/426/2}, I Dr Wright denying, implausibly, that the signature on the Tyche Consulting Appendix B: Schedule of Transcript References 252 REFERENCE QUOTE COMMENT think an introductory page signed apparently by you. Is that your signature? A. Actually, no, it's not. I've said how I sign with "G"s etc. That's actually not my signature. There's no Wright, there's no anything else and there's a big flourish at the end with a "G". There's plenty of fake my signatures and that's definitely one of them. Employment Contract at {L10/426/2} is his. {Day8/8:8 -15} Q. So you say that this contract was not signed you despite the apparent signature, yes? A. At that date, I wasn't living at that address, we had already moved out. A lot of people thought we were still living at 43 Gordon in October, and that's why WIRED and Gizmodo camped out, but actually, in August of that year, we already had the shipping containers come in and we moved, so that's incorrect. Dr Wright denying that the signature in the Tyche Consulting Employment Contract at {L10/426/2} is his. His ev idence here is also inconsistent with Mr Matthews’ witness statement at paragraph 72, in which he states that the family’s belongings were shipped to the UK “in or around October and November 2015”. {Day8/8:16} - {Day8/9:11} Q. So, this employment contrac t, apparently bearing your signature, was not one of the many hundreds of pages of documentation that you signed on that date without reading them? A. Well, it doesn't contain my signature. If you look at my other signatures, where I have them, as I've said, I have a little trick where I do a sort of "C" on the "G". That doesn't really look like a "Craig S Wright". I've never once in my life signed without putting "Craig S Wright" individually, and I can't make out "Craig S Wright" out of that signature at all. Dr Wright discussing his signature - see also his comments at {Day4/129:23} – {Day4/130:16}. {Day8/9:3 -23} Q. Would you accept that this is yet another document in your disclosure which you’ve identified as a fake which was not identified as a fake when disclosure was given? A. No, actually, that’s incorrect. This document comes from one of the ex- staff laptop s. That is in the disclosure platform. It’s listed that it comes from a staff laptop accessing Ramona, my wife’s, email, when that employee had no legal rights to access her email. Dr Wright blaming third parties (his solic itors) for disclosing this document, claiming that he told them that it was from an unauthorised source. Appendix B: Schedule of Transcript References 253 REFERENCE QUOTE COMMENT Q. Pause there, a couple of simple questions. This was a document disclosed by solicitors on your behalf in these proceedings; correct? A. Yes. Q. And when disclosing this document, your solicitors did not identify it in correspondence as a fake, did they? A. I don’t know what they did. I told them that – and it’s in the disclos ure platform, that it’s from an unauthorised source. So in the disclosure platform, it notes it. I can’t say what the solicitors have done after the disclosure platform notes
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 101 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: itself as a blog to prove possession of a private key, just as Mr Matthews and Mr Andresen expected, and each of these blogs failed by that standard, didn't it, both your draft and the final version? A. No, as I said, if I sign as Craig Wright, Satoshi. So, no, I was nev er intending in that one. What I promised was, if you did the proof session, if you did everything that I wanted put together, if you put together my hundreds of papers, if you put together my thousands of patents and all the work I'd been doing, if you showed the scaling work I was doing and you went through that process, then I would have signed. The only way that I could sign is to have my identity known first, because of what I am, what I've done. Appendix B: Schedule of Transcript References 251 REFERENCE QUOTE COMMENT DAY 8 CROSS - EXAMINATION OF DR CRAIG WRIGHT BY JONATHAN HOUGH KC {L11/285} Implementation deed, dated 7 January 2016 {Day8/6:15} – {Day8/7:21} Q. Page 10, please {L11/285/10}, middle of the page, clause 7, "Craig Wright", 7.2(a): "Craig Wright has entered into an Employment Contract with Tyche Consulting Limited dated 26 October 2015 at a salary of £160,000 [sterling] per annum. The p arties acknowledge and agree that Craig Wright may subsequently become employed by a related body corporate ..." Do you say that that statement, that you'd entered into an employment contract with Tyche Consulting Limited of that date, in this contract whi ch you signed is wrong? A. I do. There was never any tax with HMRC filed, and on that day, the documentation that I had to sign with my wife was approximately 1,200 pages in total, a little bit more, probably. We had 100 different documents to sign for al l of the IP, I didn't have any solicitors with me, because I was in the UK, not Australia, and I had no chance to read them. So, I looked through the things very quickly, I didn't analyse them in detail. Q. So, you say that you signed this agreement, incl uding the term headed "Craig Wright", without reading the agreement or the term headed "Craig Wright"? A. In full, no, I hadn't. I'll also note, the email you brought up yesterday has a statement saying that my wife and I are ready to start a family. When we came to the UK, my wife and I were in our mid- 40s, my wife had three children already, we weren't looking at having children and family, as that email states. So, my Lord, it was well known that my wife and I were not looking at having more children. Having admitted that he stated he was not Tyche, Dr Wright is asked about the Implementation Deed that states that he entered into an employment contract with Tyche Consulting Limited. Dr Wright is evasive in response, claiming that he did not read the agre ement fully. {L10/426} - Tyche Consulting Limited, Employment Contract, Craig Wright, 26th October 2015. {Day8/7:22} - {Day8/8:7} Q. {L10/426/1}, please. This is a document in your disclosure, "Tyche Consulting Limited, Employment Contract, Craig Wright, 26th October 2015". Page 2, please {L10/426/2}, I Dr Wright denying, implausibly, that the signature on the Tyche Consulting Appendix B: Schedule of Transcript References 252 REFERENCE QUOTE COMMENT think an introductory page signed apparently by you. Is that your signature? A. Actually, no, it's not. I've said how I sign with "G"s etc. That's actually not my signature. There's no Wright, there's no anything else and there's a big flourish at the end with a "G". There's plenty of fake my signatures and that's definitely one of them. Employment Contract at {L10/426/2} is his. {Day8/8:8 -15} Q. So you say that this contract was not signed you despite the apparent signature, yes? A. At that date, I wasn't living at that address, we had already moved out. A lot of people thought we were still living at 43 Gordon in October, and that's why WIRED and Gizmodo camped out, but actually, in August of that year, we already had the shipping containers come in and we moved, so that's incorrect. Dr Wright denying that the signature in the Tyche Consulting Employment Contract at {L10/426/2} is his. His ev idence here is also inconsistent with Mr Matthews’ witness statement at paragraph 72, in which he states that the family’s belongings were shipped to the UK “in or around October and November 2015”. {Day8/8:16} - {Day8/9:11} Q. So, this employment contrac t, apparently bearing your signature, was not one of the many hundreds of pages of documentation that you signed on that date without reading them? A. Well, it doesn't contain my signature. If you look at my other signatures, where I have them, as I've said, I have a little trick where I do a sort of "C" on the "G". That doesn't really look like a "Craig S Wright". I've never once in my life signed without putting "Craig S Wright" individually, and I can't make out "Craig S Wright" out of that signature at all. Dr Wright discussing his signature - see also his comments at {Day4/129:23} – {Day4/130:16}. {Day8/9:3 -23} Q. Would you accept that this is yet another document in your disclosure which you’ve identified as a fake which was not identified as a fake when disclosure was given? A. No, actually, that’s incorrect. This document comes from one of the ex- staff laptop s. That is in the disclosure platform. It’s listed that it comes from a staff laptop accessing Ramona, my wife’s, email, when that employee had no legal rights to access her email. Dr Wright blaming third parties (his solic itors) for disclosing this document, claiming that he told them that it was from an unauthorised source. Appendix B: Schedule of Transcript References 253 REFERENCE QUOTE COMMENT Q. Pause there, a couple of simple questions. This was a document disclosed by solicitors on your behalf in these proceedings; correct? A. Yes. Q. And when disclosing this document, your solicitors did not identify it in correspondence as a fake, did they? A. I don’t know what they did. I told them that – and it’s in the disclos ure platform, that it’s from an unauthorised source. So in the disclosure platform, it notes it. I can’t say what the solicitors have done after the disclosure platform notes
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table on page 502 of the Manual ) that PDFs could be made to a variety of compatibility levels including compatibility with Acrobat 4, Acrobat 5, Acrobat 6, a nd ( grouped together on the right -hand side of that page) Acrobat 7, Acrobat 8, and Acrobat 9. I observed that t he XMP metadata of Exhibit MS1 (referred to at paragraph 10 below) records the PDF Producer as “Adobe PDF Library 9.0”, which is consistent with theversion of Adobe Acrobat (Acrobat 9) listed in that document . 9.A fter I had conducted the research above, Bird & Bird located and directed me to the archive d w ebsite page at https://web.archive.org/web/20100524220654/http://www.adobe.com/support/downloads/product .jsp?product=31&platform=Windows , a copy of which is at Exhibit PM 5.5, which records the{H/33} {H/34} {D/1} {H/35} {H/35/496} {H/35/502} {D/1} {H/36} Madden Appendix PM 5 “Quill BDO Minutes” / ID_004013 Page 5 of 10 da te of Adobe InDesign 6.0.1 as 2/24/2009 (24 February 2009) and therefore confirmed the view I had reached as a result of my research above. 10.Using the application PDF Stream Dumper , I was able to extract the XMP metadata record from the Exhibit MS1 PDF file, which I have set out in Exhibit PM 5.6 11.The audit logging within this is fairly verbose, in that it has recorded a series of update events that have been applied to the file, providing several timestamps for analysis. In particular, I observe d th at the re was a sequence of 22 records, each indicating an update being saved to the document at intervals between 6 November 2009 at 9:30 (with a time zone of +11 hours) and 9 November 2009 at 14:58 (also with a time zone of +11 hours). Specifically, these saves were groupedtogether in three time groups as follows: a.Several edit s made on the morning of 6 November 2009 from 09:30 to 10:02 with regular saves being made every few minutes throughout that period. This period covers the clear majority of the recorded updates (16 in total). b. There then followed a gap of a few days, and a nother set of four updates is recorded as be ing saved to the file on the afternoon of 9 November 2009 from 12:01 to 12:26. c.There then follows a gap of around two and a half hours, with a final pair of two updates at 14:57:43 on 9 November 2009 sharing the same time stamp . 12.T hese series of updates are in my opinion indicative of a design being worked on in three bouts , w ith regular saves as changes were made. It indicates a period of relatively intensive editi ng on t he morning of 6 November 2009 (with 16 updates being made), followed by relatively few updates on the afternoon of 9 November (4 updates), and a final revision being made at the poin t o f creating the PDF file itself which forms Exhibit MS1. In my opinion , this is consistent with what might be expected of a typical original design process, in which the design was predominantly created in the form of a first draft during the period of intensive editing, wasaltered after some reflection a few days later, and then shortly afterwards the same day, a final version was saved and exported to PDF at the same time . 13.I am informed by Bird & Bird that they understand Hamelin Brands to be based in New Sout h Wal es and I have been shown the webpage at https://hamelinbrands.com.au/contact/ (a copy of which is in Exhibit PM 5.7) which corroborates this to me (at least at the present time). I{H/37} {D/1} {H/38} Madden Appendix PM 5 “Quill BDO Minutes” / ID_004013 Page 6 of 10 obse rved that the +11 hour time zone recorded in the sequence of edits described above is consistent with Australian Eastern Daylight Saving Time (AEDT) Time zone. Having checked the relevant Wikipedia article, exhibited at Exhibit PM 5.8, I understand that from 2007 onwards New South Wales, Australia used the AEDT time zone from the first Sunday in October to the first Sunday in April. This is consistent with AEDT being in use by the creator of Exhibit MS1 during the purported date period (6-9 November 2009). 14.I also observed that the Exhibit MS1 document also contains XMP tags corresponding to colour profiles to be used in the document, which is consistent with the facility described on page 506 ofExhibit PM 5.4 that InDesign is able to create PDFs which “Include All RGB And Tagged Source CMYK Profiles”, and therefore also appears to be consistent with the purported creation software . 15.Beyond these checks, I also reviewed the file structure of Exhibit MS1 in detail by eye, andobserved that the text of Exhibit MS1 was stored as native text within the PDF file and wasclearly visible in embedded, XMP -tagged plain text content corresponding to the text content which is itself visible on the face of the document. This is consistent with the functionality described in various places within Exhibit PM 5.4, including on page 496 of the Manual which indicates that this was a feature of PDFs creat ed with InDesign CS4: “Tagged PDFs contain information on content and structure, which makes them accessible on -screen readers.” 16.Having analysed Exhibit MS1, I have found no irregularities that cause me to doubt its authenticity and in my opinion it is an authentic document dating from 9 November 2009. 17.The only way to investigate this further would be to interrogate the computer systems of HamelinBrands / Quill from which I understand those documents to originate. However, having found noirregularities or cause for concern in the detailed review descri bed above, I do not see any requirement to do so. 18.I have also analysed Exhibit MS2 in a similar way and come to the same conclusion that it too is an authentic document which did not raise questions deserving of further examination of thecomputer systems from which it came .
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 2 of 3 Appendix PM5.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM5.pdf ### File content: table on page 502 of the Manual ) that PDFs could be made to a variety of compatibility levels including compatibility with Acrobat 4, Acrobat 5, Acrobat 6, a nd ( grouped together on the right -hand side of that page) Acrobat 7, Acrobat 8, and Acrobat 9. I observed that t he XMP metadata of Exhibit MS1 (referred to at paragraph 10 below) records the PDF Producer as “Adobe PDF Library 9.0”, which is consistent with theversion of Adobe Acrobat (Acrobat 9) listed in that document . 9.A fter I had conducted the research above, Bird & Bird located and directed me to the archive d w ebsite page at https://web.archive.org/web/20100524220654/http://www.adobe.com/support/downloads/product .jsp?product=31&platform=Windows , a copy of which is at Exhibit PM 5.5, which records the{H/33} {H/34} {D/1} {H/35} {H/35/496} {H/35/502} {D/1} {H/36} Madden Appendix PM 5 “Quill BDO Minutes” / ID_004013 Page 5 of 10 da te of Adobe InDesign 6.0.1 as 2/24/2009 (24 February 2009) and therefore confirmed the view I had reached as a result of my research above. 10.Using the application PDF Stream Dumper , I was able to extract the XMP metadata record from the Exhibit MS1 PDF file, which I have set out in Exhibit PM 5.6 11.The audit logging within this is fairly verbose, in that it has recorded a series of update events that have been applied to the file, providing several timestamps for analysis. In particular, I observe d th at the re was a sequence of 22 records, each indicating an update being saved to the document at intervals between 6 November 2009 at 9:30 (with a time zone of +11 hours) and 9 November 2009 at 14:58 (also with a time zone of +11 hours). Specifically, these saves were groupedtogether in three time groups as follows: a.Several edit s made on the morning of 6 November 2009 from 09:30 to 10:02 with regular saves being made every few minutes throughout that period. This period covers the clear majority of the recorded updates (16 in total). b. There then followed a gap of a few days, and a nother set of four updates is recorded as be ing saved to the file on the afternoon of 9 November 2009 from 12:01 to 12:26. c.There then follows a gap of around two and a half hours, with a final pair of two updates at 14:57:43 on 9 November 2009 sharing the same time stamp . 12.T hese series of updates are in my opinion indicative of a design being worked on in three bouts , w ith regular saves as changes were made. It indicates a period of relatively intensive editi ng on t he morning of 6 November 2009 (with 16 updates being made), followed by relatively few updates on the afternoon of 9 November (4 updates), and a final revision being made at the poin t o f creating the PDF file itself which forms Exhibit MS1. In my opinion , this is consistent with what might be expected of a typical original design process, in which the design was predominantly created in the form of a first draft during the period of intensive editing, wasaltered after some reflection a few days later, and then shortly afterwards the same day, a final version was saved and exported to PDF at the same time . 13.I am informed by Bird & Bird that they understand Hamelin Brands to be based in New Sout h Wal es and I have been shown the webpage at https://hamelinbrands.com.au/contact/ (a copy of which is in Exhibit PM 5.7) which corroborates this to me (at least at the present time). I{H/37} {D/1} {H/38} Madden Appendix PM 5 “Quill BDO Minutes” / ID_004013 Page 6 of 10 obse rved that the +11 hour time zone recorded in the sequence of edits described above is consistent with Australian Eastern Daylight Saving Time (AEDT) Time zone. Having checked the relevant Wikipedia article, exhibited at Exhibit PM 5.8, I understand that from 2007 onwards New South Wales, Australia used the AEDT time zone from the first Sunday in October to the first Sunday in April. This is consistent with AEDT being in use by the creator of Exhibit MS1 during the purported date period (6-9 November 2009). 14.I also observed that the Exhibit MS1 document also contains XMP tags corresponding to colour profiles to be used in the document, which is consistent with the facility described on page 506 ofExhibit PM 5.4 that InDesign is able to create PDFs which “Include All RGB And Tagged Source CMYK Profiles”, and therefore also appears to be consistent with the purported creation software . 15.Beyond these checks, I also reviewed the file structure of Exhibit MS1 in detail by eye, andobserved that the text of Exhibit MS1 was stored as native text within the PDF file and wasclearly visible in embedded, XMP -tagged plain text content corresponding to the text content which is itself visible on the face of the document. This is consistent with the functionality described in various places within Exhibit PM 5.4, including on page 496 of the Manual which indicates that this was a feature of PDFs creat ed with InDesign CS4: “Tagged PDFs contain information on content and structure, which makes them accessible on -screen readers.” 16.Having analysed Exhibit MS1, I have found no irregularities that cause me to doubt its authenticity and in my opinion it is an authentic document dating from 9 November 2009. 17.The only way to investigate this further would be to interrogate the computer systems of HamelinBrands / Quill from which I understand those documents to originate. However, having found noirregularities or cause for concern in the detailed review descri bed above, I do not see any requirement to do so. 18.I have also analysed Exhibit MS2 in a similar way and come to the same conclusion that it too is an authentic document which did not raise questions deserving of further examination of thecomputer systems from which it came .
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f ont’s characters, using the built -in Windows character map tool. I was able to locate the lambda glyph corresponding to the equations in the C ontrol C opies, as follows: {D/91} Madden Appendix PM3 Bitcoin White Paper Page 65 of 80 198. H aving established the location in the Open Symbol font, which was at location U+E0C1 as can be observed in the bottom part of the screenshot above, this still did not allow me t o de termine the source of the glyph showing dots in a circle . 199. H owever, I cons idered whether the replacement might be due to the mistaken use of a default font during conversion, in circumstances where the computer doing the conversion process did not have the Open Symbol font on their computer, such that a different symbol font hadbeen substituted instea d. 200. I therefore refreshed my memory of the default fonts of various iterations of Windows, a nd co nsulted the website https://granneman.com /webdev/coding/css/fonts-and- formatting/default -fonts . As listed there, the default font used in Windows XP was called Tahoma, and the default font used in versions of Windows after that (including WindowsVista, Windows 7 and 8, and Windows 10) was Segoe UI. 201. I investigated the glyph map of the Tahoma font and found that it did not contain a corresponding location to U+E0C1. I then investigated the character map of the Segoe UI font and found that it also did not have a location listed in the character map for U+E0C 1. H owever, I also observed that the glyph location U+E0C1 was listed in the character map named “Segoe UI Symbol” (which I take to be a subset of the same font as displayed in th e Madden Appendix PM3 Bitcoin White Paper Page 66 of 80 character map utility) and that did indeed contain the symbol observed in ID_004010, which can also be entered into this Report appendix by copying from the character map and pasting as follows:  , and again below using size 20 font for clarity:  202. As I have shown in various screenshots towards the beginning of this Appendix in which the Open Symbol font was shown highlighted among the list of embedded fonts within the BWPControl Copies, the PDF files in question contain the font information necessa ry to ensure they display appropriately. Therefore, had the document of which ID_004010 is a scan been created directly from PDF, it should not have resulted in the glyph replacement irregularityseen above, since the font information would have been filled in from the embedded font. 203. It is therefore my conclusion that the document of which ID_004010 i s a scan was created by conversion of a PDF file in an imperfect manner which did not retain the font information, by the use of a computer which did not have the relevant font (Open Symbol) installed, and which substituted its own default symbol font (Segoe UI) in place of Open Symbol. {ID_004010} {ID_004010} {ID_004010} Madden Appendix PM3 Bitcoin White Paper Page 67 of 80 204. It is possible for fonts to receive updates through the course of their lifetime and so I could not initially say when or on which operating system this took place, other than to say it is likely to have been done on a later version of Windows than Windows XP. However, Ichecked as follows: a.On a clean installation of Windows 7, I examined the character map for the version of Segoe UI and Segoe UI Symbol included within that operating system. It did not have any character corresponding to location E0C1. b. I then examined Segoe UI and Segoe UI symbol as presented on a version of Windows 7 which was not a clean installation, but had received updates until 26 March 2020 (which was the date that Windows 7 ceased to be supported). There was no character corresponding to location E0C1. c. I then examined the font as it appeared in a Windows 8 build, which was the next version of Windows after Windows 7. 9 I observed that the Segoe UI and Segoe UI Symbol fonts did contain the E0C1 circle- with-dots character. d. The version of Windows 8 I used was not a clean (non-updated) installation but had received some updates. The version of Segoe UI included was dated with a copyrightnotice to 2013, which is the year after Windows 8 was released . It is possible that earlier versions of Segoe UI shipped with Windows 8 (which was released in August2012) may also have had the character in question. Since I was not able to check the period between August 2012 and the end of 2013, I proceed on the assumption that the character was included from 2012. e.Summarising overall how t hese observations translate into dates: The character was not in the version of Sego e UI which was released in October 2009
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 18 of 22 Appendix PM3.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM3.pdf ### File content: f ont’s characters, using the built -in Windows character map tool. I was able to locate the lambda glyph corresponding to the equations in the C ontrol C opies, as follows: {D/91} Madden Appendix PM3 Bitcoin White Paper Page 65 of 80 198. H aving established the location in the Open Symbol font, which was at location U+E0C1 as can be observed in the bottom part of the screenshot above, this still did not allow me t o de termine the source of the glyph showing dots in a circle . 199. H owever, I cons idered whether the replacement might be due to the mistaken use of a default font during conversion, in circumstances where the computer doing the conversion process did not have the Open Symbol font on their computer, such that a different symbol font hadbeen substituted instea d. 200. I therefore refreshed my memory of the default fonts of various iterations of Windows, a nd co nsulted the website https://granneman.com /webdev/coding/css/fonts-and- formatting/default -fonts . As listed there, the default font used in Windows XP was called Tahoma, and the default font used in versions of Windows after that (including WindowsVista, Windows 7 and 8, and Windows 10) was Segoe UI. 201. I investigated the glyph map of the Tahoma font and found that it did not contain a corresponding location to U+E0C1. I then investigated the character map of the Segoe UI font and found that it also did not have a location listed in the character map for U+E0C 1. H owever, I also observed that the glyph location U+E0C1 was listed in the character map named “Segoe UI Symbol” (which I take to be a subset of the same font as displayed in th e Madden Appendix PM3 Bitcoin White Paper Page 66 of 80 character map utility) and that did indeed contain the symbol observed in ID_004010, which can also be entered into this Report appendix by copying from the character map and pasting as follows:  , and again below using size 20 font for clarity:  202. As I have shown in various screenshots towards the beginning of this Appendix in which the Open Symbol font was shown highlighted among the list of embedded fonts within the BWPControl Copies, the PDF files in question contain the font information necessa ry to ensure they display appropriately. Therefore, had the document of which ID_004010 is a scan been created directly from PDF, it should not have resulted in the glyph replacement irregularityseen above, since the font information would have been filled in from the embedded font. 203. It is therefore my conclusion that the document of which ID_004010 i s a scan was created by conversion of a PDF file in an imperfect manner which did not retain the font information, by the use of a computer which did not have the relevant font (Open Symbol) installed, and which substituted its own default symbol font (Segoe UI) in place of Open Symbol. {ID_004010} {ID_004010} {ID_004010} Madden Appendix PM3 Bitcoin White Paper Page 67 of 80 204. It is possible for fonts to receive updates through the course of their lifetime and so I could not initially say when or on which operating system this took place, other than to say it is likely to have been done on a later version of Windows than Windows XP. However, Ichecked as follows: a.On a clean installation of Windows 7, I examined the character map for the version of Segoe UI and Segoe UI Symbol included within that operating system. It did not have any character corresponding to location E0C1. b. I then examined Segoe UI and Segoe UI symbol as presented on a version of Windows 7 which was not a clean installation, but had received updates until 26 March 2020 (which was the date that Windows 7 ceased to be supported). There was no character corresponding to location E0C1. c. I then examined the font as it appeared in a Windows 8 build, which was the next version of Windows after Windows 7. 9 I observed that the Segoe UI and Segoe UI Symbol fonts did contain the E0C1 circle- with-dots character. d. The version of Windows 8 I used was not a clean (non-updated) installation but had received some updates. The version of Segoe UI included was dated with a copyrightnotice to 2013, which is the year after Windows 8 was released . It is possible that earlier versions of Segoe UI shipped with Windows 8 (which was released in August2012) may also have had the character in question. Since I was not able to check the period between August 2012 and the end of 2013, I proceed on the assumption that the character was included from 2012. e.Summarising overall how t hese observations translate into dates: The character was not in the version of Sego e UI which was released in October 2009
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45 123. He responded to one commenter stating that “WikiLeaks can get payments from other sources. It CAN get money transfers. It can get bit coins it can do many things if it wants. There are MANY options that allow people to send money to WL” (emphasis added). 107 He responded to another commenter as follows (again, emphasis added): 108 “Bit Coin (Bit Coin) is a digital currency. Bit Coin offers a full peer-to-peer currency solution. P2P transfer of funds is available using methods that can even be untraceable. They’re a ways using this technology to transfer funds that cannot be intercepted or stopped. … That said, there are alternatives available in the marketplace such as Bit Coin that offer solutions to the problems that WikiLeaks faces.….” 124. Thus, Dr Wright’s first foray into Bitcoin took a diametrically opposing view to Satoshi Nakamoto. Satoshi was seeking to discourage Wikileaks from adopting Bitcoin. Dr Wright seemed to think this would be a good idea. And, although by late July 2011 Dr Wright was aware of Bitcoin, he was uncertain about how it was spelled (one word or two, 109 capitals or not). 110 Faced with those inconsistencies on Day 8, Dr Wright was unable to explain them: “189:11 Q. Dr Wright, more pertinently, you did not know that 12 Satoshi was keen to discourage WikiLeaks from using 13 Bitcoin, right? 14 A. Again, I wanted people not to use the other. I'd seen 15 all the sites, I'd gone through everything with people 16 multiple times, so, no, I knew what I said. What you're 17 trying to say is because, on a site, it comes up that 18 way, which, "Bitcoin" and then "Bit Coin". It was meant 19 to be cut and paste as a hyperlink and somehow that 20 ended up funky.” 107 {L7/391/13}. 108 {L7/391/17-18}. 109 Dr Wright suggested in cross-examination that the use of two words was a consequence of “auto correct”, but the error appears twice in just 4 words in his post at {L7/391/17} at not at all at {L7/389.1}. 110 The first release of Bitcoin was accompanied by a readme.txt file which referred to BitCoin. However, Satoshi Nakamoto moved the content of that readme file to build-unix.txt on 5 November 2009, see https://sourceforge.net/p/bitcoin/code/32/, in which the equivalent text referred to Bitcoin (without a capital “C”). All further releases of the Bitcoin software referred to Bitcoin without capitalising the “C”. 46 5. Summary 125. Any one of the shortcomings in Dr Wright’s evidence regarding the Bitcoin code and the implementation of the Bitcoin system might reasonably disprove any claim he could make to be Satoshi Nakamoto. Taken together, his lack of basic computer science knowledge, his inexperience with C++, his unawareness of unsigned integers, his ignorance of the CheckBlock function, his erroneous belief about the use of leading zeroes, his misunderstanding of the computing power applied in Bitcoin’s initial mining activities, his ignorance that Satoshi had limited the data element size in script and disabled opcodes, his reliance upon documents with anachronistic content, his lack of awareness of Satoshi’s bitcoin transactions and his misunderstanding of Satoshi’s PGP key lead ineluctably to the conclusion that Dr Wright’s claim to have written the Bitcoin code is a brazen lie. Dr Wright’s first foray into the Bitcoin debate came in late July 2011 and showed that he was not Satoshi. C. The Bitcoin White Paper 126. Dr Wright’s attempt to claim that he authored the Bitcoin White Paper is inescapably linked to his evidence about the so-called White Paper Latex Files. As became clear during Dr Wright’s evidence, those documents are a crude forgery. Accordingly, it is necessary to take the so-called White Paper LaTeX Files at some length in this section of these submissions. There is, however, a preceding indicator that Dr Wright was not involved in production of the Bitcoin White Paper, namely the mess that he made of his dealings with Wei Dai. That point is taken first. 1. Dr Wright’s Wei Dai lies 127. On 20 August 2008 Satoshi Nakamoto shared a link to a then draft of the Bitcoin White Paper with Dr Back {L3/190}. He stated as follows: “I'm getting ready to release a paper that references your Hashcash paper and I wanted to make sure I have the citation right. Here's what I have: [5] A. Back, "Hashcash - a denial of service counter-measure," http://www.hashcash.org/papers/hashcash.pdf, 2002. I think you would find it interesting, since it finds a new use for hash-based proof-of-work as a way to make e-cash work. You can download a pre-release draft at 47 http://www.upload.ae/file/6157/ecash-pdf.html Feel free to forward it to anyone else you think would be interested. I'm also nearly finished with a C++ implementation to release as open source.” 128. Stopping there, Satoshi was clearly envisaging that Dr Back’s Hashcash paper would be the fifth reference in the Bitcoin White Paper. 129. Dr Back responded the following day as follows {L3/194}. “Yes citation looks fine, I'll take a look at your paper. You maybe aware of the "B-money" proposal, I guess google can find it for you, by Wei Dai which sounds to be somewhat related to your paper. (The b-money idea is just described concisely on his web page, he didnt [sic] write up a paper).” 130. Two points emerge from that response. First, it was a perfectly friendly reply from Dr Back. Second, and more importantly he drew Satoshi’s reference to the “B-money” proposal made by Wei Dai (which was set out on a web-page, not in a paper). 131. Satoshi Nakamoto replied to Dr Back on 21 August 2008 as follows {L3/192}: “Thanks, I wasn't aware of the b-money page, but my ideas start from exactly that point. I'll e-mail him to confirm the year of publication so I can credit him. The main thing my system adds is to also use proof-of-work to support a distributed timestamp server. While users are generating proof-of-work to make new coins for themselves, the same proof-of-work is also supporting the network timestamping. This is instead of Usenet.” 132.
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 16 of 59 BTC Core Developers' Closing Submissions.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/BTC Core Developers' Closing Submissions.pdf ### File content: 45 123. He responded to one commenter stating that “WikiLeaks can get payments from other sources. It CAN get money transfers. It can get bit coins it can do many things if it wants. There are MANY options that allow people to send money to WL” (emphasis added). 107 He responded to another commenter as follows (again, emphasis added): 108 “Bit Coin (Bit Coin) is a digital currency. Bit Coin offers a full peer-to-peer currency solution. P2P transfer of funds is available using methods that can even be untraceable. They’re a ways using this technology to transfer funds that cannot be intercepted or stopped. … That said, there are alternatives available in the marketplace such as Bit Coin that offer solutions to the problems that WikiLeaks faces.….” 124. Thus, Dr Wright’s first foray into Bitcoin took a diametrically opposing view to Satoshi Nakamoto. Satoshi was seeking to discourage Wikileaks from adopting Bitcoin. Dr Wright seemed to think this would be a good idea. And, although by late July 2011 Dr Wright was aware of Bitcoin, he was uncertain about how it was spelled (one word or two, 109 capitals or not). 110 Faced with those inconsistencies on Day 8, Dr Wright was unable to explain them: “189:11 Q. Dr Wright, more pertinently, you did not know that 12 Satoshi was keen to discourage WikiLeaks from using 13 Bitcoin, right? 14 A. Again, I wanted people not to use the other. I'd seen 15 all the sites, I'd gone through everything with people 16 multiple times, so, no, I knew what I said. What you're 17 trying to say is because, on a site, it comes up that 18 way, which, "Bitcoin" and then "Bit Coin". It was meant 19 to be cut and paste as a hyperlink and somehow that 20 ended up funky.” 107 {L7/391/13}. 108 {L7/391/17-18}. 109 Dr Wright suggested in cross-examination that the use of two words was a consequence of “auto correct”, but the error appears twice in just 4 words in his post at {L7/391/17} at not at all at {L7/389.1}. 110 The first release of Bitcoin was accompanied by a readme.txt file which referred to BitCoin. However, Satoshi Nakamoto moved the content of that readme file to build-unix.txt on 5 November 2009, see https://sourceforge.net/p/bitcoin/code/32/, in which the equivalent text referred to Bitcoin (without a capital “C”). All further releases of the Bitcoin software referred to Bitcoin without capitalising the “C”. 46 5. Summary 125. Any one of the shortcomings in Dr Wright’s evidence regarding the Bitcoin code and the implementation of the Bitcoin system might reasonably disprove any claim he could make to be Satoshi Nakamoto. Taken together, his lack of basic computer science knowledge, his inexperience with C++, his unawareness of unsigned integers, his ignorance of the CheckBlock function, his erroneous belief about the use of leading zeroes, his misunderstanding of the computing power applied in Bitcoin’s initial mining activities, his ignorance that Satoshi had limited the data element size in script and disabled opcodes, his reliance upon documents with anachronistic content, his lack of awareness of Satoshi’s bitcoin transactions and his misunderstanding of Satoshi’s PGP key lead ineluctably to the conclusion that Dr Wright’s claim to have written the Bitcoin code is a brazen lie. Dr Wright’s first foray into the Bitcoin debate came in late July 2011 and showed that he was not Satoshi. C. The Bitcoin White Paper 126. Dr Wright’s attempt to claim that he authored the Bitcoin White Paper is inescapably linked to his evidence about the so-called White Paper Latex Files. As became clear during Dr Wright’s evidence, those documents are a crude forgery. Accordingly, it is necessary to take the so-called White Paper LaTeX Files at some length in this section of these submissions. There is, however, a preceding indicator that Dr Wright was not involved in production of the Bitcoin White Paper, namely the mess that he made of his dealings with Wei Dai. That point is taken first. 1. Dr Wright’s Wei Dai lies 127. On 20 August 2008 Satoshi Nakamoto shared a link to a then draft of the Bitcoin White Paper with Dr Back {L3/190}. He stated as follows: “I'm getting ready to release a paper that references your Hashcash paper and I wanted to make sure I have the citation right. Here's what I have: [5] A. Back, "Hashcash - a denial of service counter-measure," http://www.hashcash.org/papers/hashcash.pdf, 2002. I think you would find it interesting, since it finds a new use for hash-based proof-of-work as a way to make e-cash work. You can download a pre-release draft at 47 http://www.upload.ae/file/6157/ecash-pdf.html Feel free to forward it to anyone else you think would be interested. I'm also nearly finished with a C++ implementation to release as open source.” 128. Stopping there, Satoshi was clearly envisaging that Dr Back’s Hashcash paper would be the fifth reference in the Bitcoin White Paper. 129. Dr Back responded the following day as follows {L3/194}. “Yes citation looks fine, I'll take a look at your paper. You maybe aware of the "B-money" proposal, I guess google can find it for you, by Wei Dai which sounds to be somewhat related to your paper. (The b-money idea is just described concisely on his web page, he didnt [sic] write up a paper).” 130. Two points emerge from that response. First, it was a perfectly friendly reply from Dr Back. Second, and more importantly he drew Satoshi’s reference to the “B-money” proposal made by Wei Dai (which was set out on a web-page, not in a paper). 131. Satoshi Nakamoto replied to Dr Back on 21 August 2008 as follows {L3/192}: “Thanks, I wasn't aware of the b-money page, but my ideas start from exactly that point. I'll e-mail him to confirm the year of publication so I can credit him. The main thing my system adds is to also use proof-of-work to support a distributed timestamp server. While users are generating proof-of-work to make new coins for themselves, the same proof-of-work is also supporting the network timestamping. This is instead of Usenet.” 132.
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want not being accepted, are going to move on and say, well, you know, maybe it will get accepted in the future, and others get, you know, disillusioned, or start their own chains, or start forks, and that is what some people have done, which – and BSV is a fork of a fork at this point. the rules of chess” and set up “their own chess game”. Appendix B: Schedule of Transcript References 468 REFERENCE QUOTE COMMENT DAY 14 CROSS -EXAMINATION OF MICHAEL CHRISTOPHER HEARN BY LORD GRABINER KC {Day14/2:18} – {Day14/3:1} Q. I understand. Would we be right in thinking that R3 is a competitor of nChain? A. Well, I'll be honest, I don't really know what nChain does. I'm not really familiar with nChain at all. I could tell you that Corda is not a competitor to Bitcoin. R3 is presumably -- and I think nChain's a Bitcoin- focused company, that's about all I know. So I think they're not really competitors in my view. Mr Hearn comments that he is not familiar with what nChain does. {Day14/4:1- 13} Q. And you tell us that you refreshed your memory of what happened on that occasion from the email exchanges about the dinner? A. Yes. Q. So, understandably, you couldn’t remember the detail of what happened that far back; is that fair? A. W ell, I think I remember most of it, yeah. Actually, when we talked about the refreshing the detail, it was things like the name of the restaurant, or the exact date on which it happened. So, those details I had forgotten, indeed, but the actual discussions that happened during the dinner, I feel I remember pretty well. Mr Hearn discusses his general recollection of the dinner with Dr Wright in July 2016. {Day14/6:1} – {Day14/8:1} {D/507/2} Email from Jon Matonis to Mike Christopher Hearn Q. So, according to that email, Jon Matonis is saying that it was you – A. Yeah. Q. – who asked if he, Jon, could introduce you to Dr Wright. That’s not really according with your – A. That’s not how I – that’s not how I recall it, no. Q. No, I understand that, but it’s – of course, the way you now recall it is not consistent either with the contemporaneous email, is it? A. Well, he – I didn’t write that, he did. Q. I appreciate that, but did you ever respond to the email? A. No. My understanding is that Jon wanted me to meet Craig Wright and I was like, “Okay, fine, whatever”, and then Jon translated this acquiescence into me wanting to meet him, but I didn’t really care either way, to be honest, so ... Q. Well, I’m assuming you’re being honest, obviously. Mr Hearn discusses the backgroun d to his dinner with Dr Wright. Appendix B: Schedule of Transcript References 469 REFERENCE QUOTE COMMENT A. Well, yeah. Q. You see, when somebody tells a story about events happening eight years earlier and there’s a contemporaneous record which is not consistent with it, it does perhaps – A. Yes, I understand. Q. – suggest that the memory may not be quite accurate. Is tha t a fair point? A. Well, I think the parts I remember are the important parts, which are what happened during the dinner and what Craig Wright said. Q. Well, we’ll come to that. A. Yeah, the exact details of, you know, what Jon said at a conference, or who asked to meet who, I don’t believe I asked to meet him myself. Q. So I – A. I would not have reached out, right? I did not email Craig directly, for example. This has all be done – Q. No, that’s why – A. – through Jon. Q. – you wanted to use – to get to h im through Jon Matonis, didn’t you? A. No. I didn’t particularly want to get to him at all. Q. I see. Anyway, what I suggest is that it was you who wanted to meet Dr Wright. A. Well, I reject that claim. Q. So you didn’t want to meet him at all? A. No, no, no, I didn’t particularly – Q. You were happy to meet him? A. I was happy to meet him because Jon asked me to, yeah, as far as I recall. And I don’t particularly argue with people like that on threads about minor details. {Day14/11:2- 6} Q. Did you sign a non -disclosure agreement before that dinner? A. No, not that I recall. Q. Were you asked to sign one? A. No, I don’t think so. Mr Hearn confirms that he did not sign an NDA before the dinner with Dr Wright and that he was also not asked to sign one. Appendix B: Schedule of Transcript References 470 REFERENCE QUOTE COMMENT {Day14/11:13} - {Day14/12:8} Q. No, I understand. But, I mean, you're saying you know nothing about nChain's business? A. I think -- so I'll tell you what -- everything I know, if that's okay? So I believe nChain is a company that does Bitcoin- related things that Craig Wright is involved in. It's focused exclusively on Bitcoin, as far as I understand, and I believe they've funded Bitcoin- related software. Q. Well, one area of competition bet ween the two entities concerned the scalability of blockchain transactions. Did you know that? A. Well, I know that Craig Wright has been concerned with Bitcoin scalability and scalability is a general concern for all such systems. Q. Including R3? A. Any company that makes software, like database software, has to be concerned with scalability, yeah, that's not something -- Q. That's an area of common interest, so to speak, between those businesses? A. Yeah, I guess. Mr Hearn confirms that scalability i s a concern for many companies, so not a basis for inferring that R3 competes with nChain. {Day14/12:9} - {Day14/13:4} Q. You suggest in your witness statement that Stefan Matthews played -- I mean, it's my word, but you may not disagree with it -- some sort of minder role at the dinner, particularly expressing concern that Dr Wright should not be discussing intellectual property information. Is that a -- that's a fair view of your view of your understanding of what was happening at that dinner? A. Well, I was asking questions that didn't -- didn't appear to me to involve any IP. I was asking questions about the
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 186 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: want not being accepted, are going to move on and say, well, you know, maybe it will get accepted in the future, and others get, you know, disillusioned, or start their own chains, or start forks, and that is what some people have done, which – and BSV is a fork of a fork at this point. the rules of chess” and set up “their own chess game”. Appendix B: Schedule of Transcript References 468 REFERENCE QUOTE COMMENT DAY 14 CROSS -EXAMINATION OF MICHAEL CHRISTOPHER HEARN BY LORD GRABINER KC {Day14/2:18} – {Day14/3:1} Q. I understand. Would we be right in thinking that R3 is a competitor of nChain? A. Well, I'll be honest, I don't really know what nChain does. I'm not really familiar with nChain at all. I could tell you that Corda is not a competitor to Bitcoin. R3 is presumably -- and I think nChain's a Bitcoin- focused company, that's about all I know. So I think they're not really competitors in my view. Mr Hearn comments that he is not familiar with what nChain does. {Day14/4:1- 13} Q. And you tell us that you refreshed your memory of what happened on that occasion from the email exchanges about the dinner? A. Yes. Q. So, understandably, you couldn’t remember the detail of what happened that far back; is that fair? A. W ell, I think I remember most of it, yeah. Actually, when we talked about the refreshing the detail, it was things like the name of the restaurant, or the exact date on which it happened. So, those details I had forgotten, indeed, but the actual discussions that happened during the dinner, I feel I remember pretty well. Mr Hearn discusses his general recollection of the dinner with Dr Wright in July 2016. {Day14/6:1} – {Day14/8:1} {D/507/2} Email from Jon Matonis to Mike Christopher Hearn Q. So, according to that email, Jon Matonis is saying that it was you – A. Yeah. Q. – who asked if he, Jon, could introduce you to Dr Wright. That’s not really according with your – A. That’s not how I – that’s not how I recall it, no. Q. No, I understand that, but it’s – of course, the way you now recall it is not consistent either with the contemporaneous email, is it? A. Well, he – I didn’t write that, he did. Q. I appreciate that, but did you ever respond to the email? A. No. My understanding is that Jon wanted me to meet Craig Wright and I was like, “Okay, fine, whatever”, and then Jon translated this acquiescence into me wanting to meet him, but I didn’t really care either way, to be honest, so ... Q. Well, I’m assuming you’re being honest, obviously. Mr Hearn discusses the backgroun d to his dinner with Dr Wright. Appendix B: Schedule of Transcript References 469 REFERENCE QUOTE COMMENT A. Well, yeah. Q. You see, when somebody tells a story about events happening eight years earlier and there’s a contemporaneous record which is not consistent with it, it does perhaps – A. Yes, I understand. Q. – suggest that the memory may not be quite accurate. Is tha t a fair point? A. Well, I think the parts I remember are the important parts, which are what happened during the dinner and what Craig Wright said. Q. Well, we’ll come to that. A. Yeah, the exact details of, you know, what Jon said at a conference, or who asked to meet who, I don’t believe I asked to meet him myself. Q. So I – A. I would not have reached out, right? I did not email Craig directly, for example. This has all be done – Q. No, that’s why – A. – through Jon. Q. – you wanted to use – to get to h im through Jon Matonis, didn’t you? A. No. I didn’t particularly want to get to him at all. Q. I see. Anyway, what I suggest is that it was you who wanted to meet Dr Wright. A. Well, I reject that claim. Q. So you didn’t want to meet him at all? A. No, no, no, I didn’t particularly – Q. You were happy to meet him? A. I was happy to meet him because Jon asked me to, yeah, as far as I recall. And I don’t particularly argue with people like that on threads about minor details. {Day14/11:2- 6} Q. Did you sign a non -disclosure agreement before that dinner? A. No, not that I recall. Q. Were you asked to sign one? A. No, I don’t think so. Mr Hearn confirms that he did not sign an NDA before the dinner with Dr Wright and that he was also not asked to sign one. Appendix B: Schedule of Transcript References 470 REFERENCE QUOTE COMMENT {Day14/11:13} - {Day14/12:8} Q. No, I understand. But, I mean, you're saying you know nothing about nChain's business? A. I think -- so I'll tell you what -- everything I know, if that's okay? So I believe nChain is a company that does Bitcoin- related things that Craig Wright is involved in. It's focused exclusively on Bitcoin, as far as I understand, and I believe they've funded Bitcoin- related software. Q. Well, one area of competition bet ween the two entities concerned the scalability of blockchain transactions. Did you know that? A. Well, I know that Craig Wright has been concerned with Bitcoin scalability and scalability is a general concern for all such systems. Q. Including R3? A. Any company that makes software, like database software, has to be concerned with scalability, yeah, that's not something -- Q. That's an area of common interest, so to speak, between those businesses? A. Yeah, I guess. Mr Hearn confirms that scalability i s a concern for many companies, so not a basis for inferring that R3 competes with nChain. {Day14/12:9} - {Day14/13:4} Q. You suggest in your witness statement that Stefan Matthews played -- I mean, it's my word, but you may not disagree with it -- some sort of minder role at the dinner, particularly expressing concern that Dr Wright should not be discussing intellectual property information. Is that a -- that's a fair view of your view of your understanding of what was happening at that dinner? A. Well, I was asking questions that didn't -- didn't appear to me to involve any IP. I was asking questions about the
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Patrick Madden
part 11 of 20 Third Expert Report of Patrick Madden.pdf
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the timestamp system. This timestamp server extends the hashing and logging system previously proposed taking a block of items to be timestamp and widely publishing a hash of each block. This block is a binary or Merkle tree of a series of other hashes apart. This data can be published in the same way as the newspaper USENET post used in the reference example to be included.\\par \\par The timestamp proves that each item of data existed at the time that it was posted or pash would not be able to be included in the block. Each timestamp includes the previous timestamp on its cash forming a chain of information where each additional timestamp reinforces the once before at making it more and more secure in\\par } c. The remaining eight are generated with the editor Riched20 10.0.19041 . Dating Riched20 10.0.19041 89. This correspond to the use of Microsoft Rich Text Editor 20, a dll file which is provided with Windows operating systems. The Riched20 DLL updates with successive versions of Windows and the version number, “ 10.0.19041 ” indicates the version of the DLL in use. Version 10.0.19041 of Riched20 corresponds to version 10.0.19041 of the Windows operating system that it formed part of, i.e. it is a version of Windows 10. 90. Specifically, Windows 10 version 10.0.19041 was the May 2020 update of the Windows 10 DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 37 of 69 37 operating system . It had an internal versioning number “2004” (which is not a date) and an internal codename “20H1” as is recorded in, a. The Microsoft release announcement https://learn.microsoft.com/en-us/windows/uwp/whats- new/windows-10-build-19041 (Exhibit PM-R3.13 ) b. The Microsoft Windows 10 Release history list at https://learn.microsoft.com/en- us/windows/release-health/release-information (which is a very long list not exhibited, but which lists the first available date of versio n 19041 as May 2020), and is also corroborated by various third party online resources3, and c. The Microsoft end of support announcement relating of that specific version of Windows (version 2004) is at https://learn.microsoft.com/en-us/lifecycle/announcements/windows-10- version-2004-end-of-servicing (Exhibit PM-R3.14 ) 91. It is therefore my opinion that those eight RTF files could not have been created before May 2020 and therefore that, a. They are not authentic to their purported timestamps (which range between May 2006 and October 2007), b. That their metadata characteristics are consistent with the use of clock manipulation or, based on the findings above in respect of other metadata editing, may also be consistent with the use of direct timestamp metadata editing tools, and c. Since they were obtained from within the BDO Image, are indicative of the BDO Image itself being accessed and manipulated at a time between May 2020 and its imaging on 20 September 2023, to insert data which was not original to October 2007, but was backdated to appear as if it was. DOC files 92. Of the 11 MS Word documents in the drive, a. ID_004649 was created with MS Word version 11.6568 with the author “Craig S Wright” , and with Internal Metadata timestamps of 29-30 July 2006. b. ID_00 4682 is the only Lynn Wright document, and like other “Lynn Wright” documents it has 3 See hƩps://microso Ō.fandom.com/wiki/Windows_10_version_history#Version_2004_(May_2020_Update) ; hƩps://www.lifewire.com/windows-version-numbers-2625171 ; hƩps://endo flife.date/windows DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 38 of 69 38 been created with MS Word version 11.9999. It has a Revision Number of 2 and a Total Edit Time of 1 minute, indicating that it is likely to have been created by the use of a “Save As” operation. The Internal Metadata timestamps date to 16 June 2007 (Created and Last Modified). c. The remaining 7 were created with MS Word version 11.8107. 93. 11.6568, 11.8107, and 11.9999 are all different sub-versions of MS Word 2003 with different release dates: a. I believe the first two software versions are contemporaneous to the timestamps provided. b. However, MS Word version 11.9999 (MS Word 2003 SP3) was not released until September 2007. This is recorded in the following arch ived web page of the Microsoft Release announcement4, a copy of which is at Exhibit PM-R3.15. The screenshot below shows a date- published of 17 September 2007: 94. Since the Internal Created and Last Modified dates of ID_004682 (and the provided external file metadata in the load file) all predate the rele ase of that software, they cannot be accurate.5 95. It is therefore my opinion that: 4 Available at hƩps://web.archive.org/web/20170306034822/h Ʃps://www.microso Ō.com/en- us/download/details.aspx?id=8 5 I note that this also applies to the documents ID_000073, ID_000142, bo th of which are dated as if last modi fied before the release of MS Word 11.9999. These do cuments were both analysed in my Main Report and which I found to be inauthen Ɵc for other reasons. DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 39 of 69 39 a. ID_004682 is not authentic to its purported timestamps, and b. Since ID_004682 was obtained from within the BDO Image, it is also indicative of clock manipulation techniques or metadata editing techniques being used in connection with the BDO Image itself. DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 40 of 69 40 SECTION 3: THE BDO IMAGE AND REPLY TO STROZ FRIEDBERG REPORT 96. In this section of this Report I address the BDO Images and provide my views in response to the Stroz Friedberg report, and the information provided about the
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 11 of 20 Third Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Third Expert Report of Patrick Madden.pdf ### File content: the timestamp system. This timestamp server extends the hashing and logging system previously proposed taking a block of items to be timestamp and widely publishing a hash of each block. This block is a binary or Merkle tree of a series of other hashes apart. This data can be published in the same way as the newspaper USENET post used in the reference example to be included.\\par \\par The timestamp proves that each item of data existed at the time that it was posted or pash would not be able to be included in the block. Each timestamp includes the previous timestamp on its cash forming a chain of information where each additional timestamp reinforces the once before at making it more and more secure in\\par } c. The remaining eight are generated with the editor Riched20 10.0.19041 . Dating Riched20 10.0.19041 89. This correspond to the use of Microsoft Rich Text Editor 20, a dll file which is provided with Windows operating systems. The Riched20 DLL updates with successive versions of Windows and the version number, “ 10.0.19041 ” indicates the version of the DLL in use. Version 10.0.19041 of Riched20 corresponds to version 10.0.19041 of the Windows operating system that it formed part of, i.e. it is a version of Windows 10. 90. Specifically, Windows 10 version 10.0.19041 was the May 2020 update of the Windows 10 DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 37 of 69 37 operating system . It had an internal versioning number “2004” (which is not a date) and an internal codename “20H1” as is recorded in, a. The Microsoft release announcement https://learn.microsoft.com/en-us/windows/uwp/whats- new/windows-10-build-19041 (Exhibit PM-R3.13 ) b. The Microsoft Windows 10 Release history list at https://learn.microsoft.com/en- us/windows/release-health/release-information (which is a very long list not exhibited, but which lists the first available date of versio n 19041 as May 2020), and is also corroborated by various third party online resources3, and c. The Microsoft end of support announcement relating of that specific version of Windows (version 2004) is at https://learn.microsoft.com/en-us/lifecycle/announcements/windows-10- version-2004-end-of-servicing (Exhibit PM-R3.14 ) 91. It is therefore my opinion that those eight RTF files could not have been created before May 2020 and therefore that, a. They are not authentic to their purported timestamps (which range between May 2006 and October 2007), b. That their metadata characteristics are consistent with the use of clock manipulation or, based on the findings above in respect of other metadata editing, may also be consistent with the use of direct timestamp metadata editing tools, and c. Since they were obtained from within the BDO Image, are indicative of the BDO Image itself being accessed and manipulated at a time between May 2020 and its imaging on 20 September 2023, to insert data which was not original to October 2007, but was backdated to appear as if it was. DOC files 92. Of the 11 MS Word documents in the drive, a. ID_004649 was created with MS Word version 11.6568 with the author “Craig S Wright” , and with Internal Metadata timestamps of 29-30 July 2006. b. ID_00 4682 is the only Lynn Wright document, and like other “Lynn Wright” documents it has 3 See hƩps://microso Ō.fandom.com/wiki/Windows_10_version_history#Version_2004_(May_2020_Update) ; hƩps://www.lifewire.com/windows-version-numbers-2625171 ; hƩps://endo flife.date/windows DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 38 of 69 38 been created with MS Word version 11.9999. It has a Revision Number of 2 and a Total Edit Time of 1 minute, indicating that it is likely to have been created by the use of a “Save As” operation. The Internal Metadata timestamps date to 16 June 2007 (Created and Last Modified). c. The remaining 7 were created with MS Word version 11.8107. 93. 11.6568, 11.8107, and 11.9999 are all different sub-versions of MS Word 2003 with different release dates: a. I believe the first two software versions are contemporaneous to the timestamps provided. b. However, MS Word version 11.9999 (MS Word 2003 SP3) was not released until September 2007. This is recorded in the following arch ived web page of the Microsoft Release announcement4, a copy of which is at Exhibit PM-R3.15. The screenshot below shows a date- published of 17 September 2007: 94. Since the Internal Created and Last Modified dates of ID_004682 (and the provided external file metadata in the load file) all predate the rele ase of that software, they cannot be accurate.5 95. It is therefore my opinion that: 4 Available at hƩps://web.archive.org/web/20170306034822/h Ʃps://www.microso Ō.com/en- us/download/details.aspx?id=8 5 I note that this also applies to the documents ID_000073, ID_000142, bo th of which are dated as if last modi fied before the release of MS Word 11.9999. These do cuments were both analysed in my Main Report and which I found to be inauthen Ɵc for other reasons. DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 39 of 69 39 a. ID_004682 is not authentic to its purported timestamps, and b. Since ID_004682 was obtained from within the BDO Image, it is also indicative of clock manipulation techniques or metadata editing techniques being used in connection with the BDO Image itself. DocuSign Envelope ID: 3ABFE9B0-62D6-490A-BB54-AEFA1902AEB7 Third Expert Report of Patrick Madden Page 40 of 69 40 SECTION 3: THE BDO IMAGE AND REPLY TO STROZ FRIEDBERG REPORT 96. In this section of this Report I address the BDO Images and provide my views in response to the Stroz Friedberg report, and the information provided about the
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that if the document was burned to CD -R and the CD-R handled by different custodians, that would not affect the integrity of the document on that CD- R, because CD -R discs are not re- writable , i.e. files on them cannot be directly modified after they are burned. h. The explanation of the technical methods of creation of the document (using OpenO ffice and Latex) is not consistent with my observation of the document or the disclosure dataset. i. The Root Entry and Last Modified timestamps of the file are not consistent with the filehaving been updated at a later time than it was created. They are however consistent with a Madden Appendix PM43 Chain of Custody (“CoC”) Page 15 of 36 35. In my view, the analysis above contradicts what I understand from the CoC Table information in respect of ID_000525. Specifically, there are several technical reasons why I consider the CoC information provided to be inaccurate. I n summary: a. ID_000525 cannot have been sourced from a CD- R or ISO image that was actually created in 2005-2015 or at any time before 16 January 2020 at 13:01:05.702325700. The embedded Grammarly timestamp within the document is not contemporary to 2005- 2015 and could not have been embedded on a file last saved in that period. b. The embedded timestamp is however exactly contemporary to the date (16 January 2020) on which the comparator document from Slack was shared on Slack. c. The embedded timestamp (16 January 2020) is also quite closely contemporary to 23 January 2020, which is the date one week afterwards on which ID_000525 was extracted from the Verbatim CD -R that was analysed for disclosure purposes. d. It is possible that the CD -R in question could appear to have been created at an earlier date than is actually the case . If it was created by using an ISO image created by the use of clock manipulation, the ISO image burned to the disk would carry those timestamps irrespective of the date it was bu rned. e. I consider that the document ID_000525 is properly described as a ‘native document’ . It is possible that this document is not the earliest revision or the original native form of the document. Indeed my conclusion in my First Report is that it was not an original nativedocument, but for different reasons to those set out by Dr Wright. The DOCX comparatordocument from Slack appears to be a good contender for that precursor document. f. In my view, the irregularities with ID_000525 exist in the internal structure of the file and independently of the manner in which it was handled. g. It is also my view that if the document was burned to CD -R and the CD-R handled by different custodians, that would not affect the integrity of the document on that CD- R, because CD -R discs are not re- writable , i.e. files on them cannot be directly modified after they are burned. h. The explanation of the technical methods of creation of the document (using OpenO ffice and Latex) is not consistent with my observation of the document or the disclosure dataset. i. The Root Entry and Last Modified timestamps of the file are not consistent with the filehaving been updated at a later time than it was created. They are however consistent with a 15 - 15 - H/219/15{ID_000525} {ID_000525} Madden Appendix PM43 Chain of Custody (“CoC”) Page 16 of 36 doc ument being created and saved while using clock manipulation techniques. Chain of Custody relating to ID_000217 Chain of custody information provided for ID_000217 36. The CoC Table provides the following information for ID_000217. Originator(s) Drafted by Dr Wright (or by Lynn Wright or former assistants of Dr Wright, using Dr Wright's handwritten notes or dictation software) Any Further Detail (if known)Dr Wright recalls that he was told by Stefan Mathews that the USB was sent to his residence in London from the DeMorgan offices in Australia by Ali Lodhi. It was in a sealed box. Collector(s) Alix Partners Collection Device / Source Toshiba USB Thumb Drive. Device Collection Date 10/01/2020 System Device Serial Number N/A Proceedings Collected In Kleiman; McCormack Collection Device / Document Owner See description in column K. FURTHER COMMENTS This is Dr Wright's LLM proposal. Dr Wright used OpenOffice and converted certain files into Microsoft Word. Lynn Wright would take information provided by Dr Wright and fix the errors produced through the transcription process when Dragon converted voice files into text. Dr Wright is aw are that this document may not the native document but a document which as been handled by a variety of custodians as described in this document. The native document(s) (where available) shall be provided in accordance with the letter from Shoosmiths LLP to Bird and Bird LLP dated 11 October 2023. CoC for ID_000217: Date created 37. The CoC Table does not state the date of this document. However the CoC Table does state that “This is Dr Wright’s LLM proposal”. I have been instructed by Bird & Bird that Dr Wright’s LLM certificate is dated 15 May 2008. I therefore understand the CoC Table to indicate that this document was created before that time. I note that would be consistent with the metadata provided in relation to the document, but not consistent with my findings as set out in my First Report that the document dates from significantly later. Madden Appendix PM43 Chain of Custody (“CoC”) Page 16 of 36 doc ument being created and saved while using clock manipulation techniques. Chain of Custody relating to ID_000217 Chain of custody information provided for ID_000217 36. The CoC Table provides the following information for ID_000217. Originator(s) Drafted by Dr Wright (or by Lynn Wright or former assistants of Dr Wright, using Dr Wright's handwritten notes or dictation software) Any Further Detail (if known)Dr Wright recalls that he was told by Stefan Mathews that the USB was sent to his residence in London from the DeMorgan offices in Australia by Ali Lodhi. It was in a sealed box. Collector(s) Alix Partners Collection Device
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 12 of 24 Appendix PM43.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM43.pdf ### File content: that if the document was burned to CD -R and the CD-R handled by different custodians, that would not affect the integrity of the document on that CD- R, because CD -R discs are not re- writable , i.e. files on them cannot be directly modified after they are burned. h. The explanation of the technical methods of creation of the document (using OpenO ffice and Latex) is not consistent with my observation of the document or the disclosure dataset. i. The Root Entry and Last Modified timestamps of the file are not consistent with the filehaving been updated at a later time than it was created. They are however consistent with a Madden Appendix PM43 Chain of Custody (“CoC”) Page 15 of 36 35. In my view, the analysis above contradicts what I understand from the CoC Table information in respect of ID_000525. Specifically, there are several technical reasons why I consider the CoC information provided to be inaccurate. I n summary: a. ID_000525 cannot have been sourced from a CD- R or ISO image that was actually created in 2005-2015 or at any time before 16 January 2020 at 13:01:05.702325700. The embedded Grammarly timestamp within the document is not contemporary to 2005- 2015 and could not have been embedded on a file last saved in that period. b. The embedded timestamp is however exactly contemporary to the date (16 January 2020) on which the comparator document from Slack was shared on Slack. c. The embedded timestamp (16 January 2020) is also quite closely contemporary to 23 January 2020, which is the date one week afterwards on which ID_000525 was extracted from the Verbatim CD -R that was analysed for disclosure purposes. d. It is possible that the CD -R in question could appear to have been created at an earlier date than is actually the case . If it was created by using an ISO image created by the use of clock manipulation, the ISO image burned to the disk would carry those timestamps irrespective of the date it was bu rned. e. I consider that the document ID_000525 is properly described as a ‘native document’ . It is possible that this document is not the earliest revision or the original native form of the document. Indeed my conclusion in my First Report is that it was not an original nativedocument, but for different reasons to those set out by Dr Wright. The DOCX comparatordocument from Slack appears to be a good contender for that precursor document. f. In my view, the irregularities with ID_000525 exist in the internal structure of the file and independently of the manner in which it was handled. g. It is also my view that if the document was burned to CD -R and the CD-R handled by different custodians, that would not affect the integrity of the document on that CD- R, because CD -R discs are not re- writable , i.e. files on them cannot be directly modified after they are burned. h. The explanation of the technical methods of creation of the document (using OpenO ffice and Latex) is not consistent with my observation of the document or the disclosure dataset. i. The Root Entry and Last Modified timestamps of the file are not consistent with the filehaving been updated at a later time than it was created. They are however consistent with a 15 - 15 - H/219/15{ID_000525} {ID_000525} Madden Appendix PM43 Chain of Custody (“CoC”) Page 16 of 36 doc ument being created and saved while using clock manipulation techniques. Chain of Custody relating to ID_000217 Chain of custody information provided for ID_000217 36. The CoC Table provides the following information for ID_000217. Originator(s) Drafted by Dr Wright (or by Lynn Wright or former assistants of Dr Wright, using Dr Wright's handwritten notes or dictation software) Any Further Detail (if known)Dr Wright recalls that he was told by Stefan Mathews that the USB was sent to his residence in London from the DeMorgan offices in Australia by Ali Lodhi. It was in a sealed box. Collector(s) Alix Partners Collection Device / Source Toshiba USB Thumb Drive. Device Collection Date 10/01/2020 System Device Serial Number N/A Proceedings Collected In Kleiman; McCormack Collection Device / Document Owner See description in column K. FURTHER COMMENTS This is Dr Wright's LLM proposal. Dr Wright used OpenOffice and converted certain files into Microsoft Word. Lynn Wright would take information provided by Dr Wright and fix the errors produced through the transcription process when Dragon converted voice files into text. Dr Wright is aw are that this document may not the native document but a document which as been handled by a variety of custodians as described in this document. The native document(s) (where available) shall be provided in accordance with the letter from Shoosmiths LLP to Bird and Bird LLP dated 11 October 2023. CoC for ID_000217: Date created 37. The CoC Table does not state the date of this document. However the CoC Table does state that “This is Dr Wright’s LLM proposal”. I have been instructed by Bird & Bird that Dr Wright’s LLM certificate is dated 15 May 2008. I therefore understand the CoC Table to indicate that this document was created before that time. I note that would be consistent with the metadata provided in relation to the document, but not consistent with my findings as set out in my First Report that the document dates from significantly later. Madden Appendix PM43 Chain of Custody (“CoC”) Page 16 of 36 doc ument being created and saved while using clock manipulation techniques. Chain of Custody relating to ID_000217 Chain of custody information provided for ID_000217 36. The CoC Table provides the following information for ID_000217. Originator(s) Drafted by Dr Wright (or by Lynn Wright or former assistants of Dr Wright, using Dr Wright's handwritten notes or dictation software) Any Further Detail (if known)Dr Wright recalls that he was told by Stefan Mathews that the USB was sent to his residence in London from the DeMorgan offices in Australia by Ali Lodhi. It was in a sealed box. Collector(s) Alix Partners Collection Device
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that the documents do not date from their purported time period, such as references to post -dating online source materials, or text that appears to have been sourced from later materials, d. The presence of content within the documents which was authored in DOCX format but has been downgraded into DOC format at the point of authoring of the documents, consistent with the use of importing by copying and pasting from a precursor document – but in no cases has that precursor document been disclosed even though multiple copies of many of the Lynn Wright documents ha ve been disclosed , e. T he presence of hidd en text within the redundant portions of the document which do not match the content on the face of the document, and f. E mbedded Grammarly timestamps that indicate that Grammarly was used to interact with a donor document much later than the purported date of the document . 37. Illustrating the presence of these in the form of a table (referring to the 26 unique documents): ID a. Anomalous edit timesb. Post -dating Schemas / Fonts c. post -dating source material d. Downgraded donor content e. Redun dant edit f. Grammarly timestamp ID_000073 ✔ ✔ ID_000142 ✔ ✔ ID_000199 ✔ ✔ ✔ ✔ ✔ ID_000227 ✔ ✔ ✔ ✔ ID_000258 ✔ ✔ ✔ ID_000367 ✔ ✔ ID_000371 ✔ ID_000395 ✔ ✔ ✔ ID_000396 ✔ ✔ ID_000462 ✔ ✔ ID_000504 ✔ ✔ ✔ ID_000505 ✔ ✔ ID_000510 ✔ ✔ 13 - 13 - H/116/13{ID_000073} {ID_000142} {ID_000199} {ID_000227} {ID_000258} {ID_000367} {ID_000371} {ID_000395} {ID_000396} {ID_000462} {ID_000504} {ID_000505} {ID_000510} Madden Appendix PM24 “Lynn Wright overview” / various ID numbers Page 14of 15 ID_000525 ✔ ✔ ✔ ID_000549 ✔ ✔ ✔ ID_000550 ✔ ✔ ✔ ✔ ✔ ID_000551 ✔ ✔ ✔ ID_000568 ✔ ✔ ✔ ID_000569 ✔ ✔ ✔ ID_000570 ✔ ✔ ✔ ✔ ID_000858 ? ID_000859 ✔ ID_001006 ✔ ✔ ID_003935 ✔ ✔ ✔ ✔ ID_004062 ID_004063 38. ID_004062 and ID_004063 do not exhibit any anomalies, and ID_000858 I consider to be inconclusive. All the other Lynn Wright documents exhibit one or more such anomalies. 39. The anomalies pointed out above are all quite different in technical nature and I consider them to arise for the most part independently of each other. T he presence of so many different anomalies in the group, in my opinion, calls into question the authent icity of any member of the group as a whole which exhibits at least one of the characteristics. Further check for distinctive timestamp 40. Earlier in this Appendix I pointed out that many of the Lynn Wright documents contain the same timestamp of 21/12/2008 21:55. 41. Having assessed the Lynn Wright documents as a whole and individually, I later returned to this timestamp and considered whether it might extend to other documents in the dataset and might be indicative of such documents having been manipulated. I therefore conducted a search across the dataset for other occurrences of the same timestamp and found that it is applied to 22 files across the Disclosure dataset in total. T hese are listed in the table below: File Name OS Time stamps Last Author ID_000001 secure -names -bit-strings.pdf 21/12/2008 21:55 ID_000002 10.1.1.71.4891.pdf 21/12/2008 21:55 ID_000227 Node operation.doc 21/12/2008 21:55 Lynn Wright ID_000258 Economic Security.doc 21/12/2008 21:55 Lynn Wright Madden Appendix PM24 “Lynn Wright overview” / various ID numbers Page 14of 15 ID_000525 ✔ ✔ ✔ ID_000549 ✔ ✔ ✔ ID_000550 ✔ ✔ ✔ ✔ ✔ ID_000551 ✔ ✔ ✔ ID_000568 ✔ ✔ ✔ ID_000569 ✔ ✔ ✔ ID_000570 ✔ ✔ ✔ ✔ ID_000858 ? ID_000859 ✔ ID_001006 ✔ ✔ ID_003935 ✔ ✔ ✔ ✔ ID_004062 ID_004063 38. ID_004062 and ID_004063 do not exhibit any anomalies, and ID_000858 I consider to be inconclusive. All the other Lynn Wright documents exhibit one or more such anomalies. 39. The anomalies pointed out above are all quite different in technical nature and I consider them to arise for the most part independently of each other. T he presence of so many different anomalies in the group, in my opinion, calls into question the authent icity of any member of the group as a whole which exhibits at least one of the characteristics. Further check for distinctive timestamp 40. Earlier in this Appendix I pointed out that many of the Lynn Wright documents contain the same timestamp of 21/12/2008 21:55. 41. Having assessed the Lynn Wright documents as a whole and individually, I later returned to this timestamp and considered whether it might extend to other documents in the dataset and might be indicative of such documents having
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 13 of 14 Appendix PM24.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM24.pdf ### File content: that the documents do not date from their purported time period, such as references to post -dating online source materials, or text that appears to have been sourced from later materials, d. The presence of content within the documents which was authored in DOCX format but has been downgraded into DOC format at the point of authoring of the documents, consistent with the use of importing by copying and pasting from a precursor document – but in no cases has that precursor document been disclosed even though multiple copies of many of the Lynn Wright documents ha ve been disclosed , e. T he presence of hidd en text within the redundant portions of the document which do not match the content on the face of the document, and f. E mbedded Grammarly timestamps that indicate that Grammarly was used to interact with a donor document much later than the purported date of the document . 37. Illustrating the presence of these in the form of a table (referring to the 26 unique documents): ID a. Anomalous edit timesb. Post -dating Schemas / Fonts c. post -dating source material d. Downgraded donor content e. Redun dant edit f. Grammarly timestamp ID_000073 ✔ ✔ ID_000142 ✔ ✔ ID_000199 ✔ ✔ ✔ ✔ ✔ ID_000227 ✔ ✔ ✔ ✔ ID_000258 ✔ ✔ ✔ ID_000367 ✔ ✔ ID_000371 ✔ ID_000395 ✔ ✔ ✔ ID_000396 ✔ ✔ ID_000462 ✔ ✔ ID_000504 ✔ ✔ ✔ ID_000505 ✔ ✔ ID_000510 ✔ ✔ 13 - 13 - H/116/13{ID_000073} {ID_000142} {ID_000199} {ID_000227} {ID_000258} {ID_000367} {ID_000371} {ID_000395} {ID_000396} {ID_000462} {ID_000504} {ID_000505} {ID_000510} Madden Appendix PM24 “Lynn Wright overview” / various ID numbers Page 14of 15 ID_000525 ✔ ✔ ✔ ID_000549 ✔ ✔ ✔ ID_000550 ✔ ✔ ✔ ✔ ✔ ID_000551 ✔ ✔ ✔ ID_000568 ✔ ✔ ✔ ID_000569 ✔ ✔ ✔ ID_000570 ✔ ✔ ✔ ✔ ID_000858 ? ID_000859 ✔ ID_001006 ✔ ✔ ID_003935 ✔ ✔ ✔ ✔ ID_004062 ID_004063 38. ID_004062 and ID_004063 do not exhibit any anomalies, and ID_000858 I consider to be inconclusive. All the other Lynn Wright documents exhibit one or more such anomalies. 39. The anomalies pointed out above are all quite different in technical nature and I consider them to arise for the most part independently of each other. T he presence of so many different anomalies in the group, in my opinion, calls into question the authent icity of any member of the group as a whole which exhibits at least one of the characteristics. Further check for distinctive timestamp 40. Earlier in this Appendix I pointed out that many of the Lynn Wright documents contain the same timestamp of 21/12/2008 21:55. 41. Having assessed the Lynn Wright documents as a whole and individually, I later returned to this timestamp and considered whether it might extend to other documents in the dataset and might be indicative of such documents having been manipulated. I therefore conducted a search across the dataset for other occurrences of the same timestamp and found that it is applied to 22 files across the Disclosure dataset in total. T hese are listed in the table below: File Name OS Time stamps Last Author ID_000001 secure -names -bit-strings.pdf 21/12/2008 21:55 ID_000002 10.1.1.71.4891.pdf 21/12/2008 21:55 ID_000227 Node operation.doc 21/12/2008 21:55 Lynn Wright ID_000258 Economic Security.doc 21/12/2008 21:55 Lynn Wright Madden Appendix PM24 “Lynn Wright overview” / various ID numbers Page 14of 15 ID_000525 ✔ ✔ ✔ ID_000549 ✔ ✔ ✔ ID_000550 ✔ ✔ ✔ ✔ ✔ ID_000551 ✔ ✔ ✔ ID_000568 ✔ ✔ ✔ ID_000569 ✔ ✔ ✔ ID_000570 ✔ ✔ ✔ ✔ ID_000858 ? ID_000859 ✔ ID_001006 ✔ ✔ ID_003935 ✔ ✔ ✔ ✔ ID_004062 ID_004063 38. ID_004062 and ID_004063 do not exhibit any anomalies, and ID_000858 I consider to be inconclusive. All the other Lynn Wright documents exhibit one or more such anomalies. 39. The anomalies pointed out above are all quite different in technical nature and I consider them to arise for the most part independently of each other. T he presence of so many different anomalies in the group, in my opinion, calls into question the authent icity of any member of the group as a whole which exhibits at least one of the characteristics. Further check for distinctive timestamp 40. Earlier in this Appendix I pointed out that many of the Lynn Wright documents contain the same timestamp of 21/12/2008 21:55. 41. Having assessed the Lynn Wright documents as a whole and individually, I later returned to this timestamp and considered whether it might extend to other documents in the dataset and might be indicative of such documents having
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prayer for relief in the Amended Particulars of Claim in the BTC Core Claim {A1/2/32}. 69 See para. 3 of the prayer for relief in the Amended Particulars of Claim in (a) Wright v McCormack {L16/46/35} and (b) Wright v Granath {L17/121/8}. 40 ensuring that Dr Wright paid into court a sum of £6 million, thus securing the bulk of COPA’s costs. At minimum, the costs of the WFO application were reasonably incurred in the course of this litigation and ought to follow the event . Indemnity basis 96. The costs to be paid by Dr Wright and the other Claimants in the BTC Core Claim should be assessed on the indemnity basis. The well-known test for whether costs should be ordered on the indemnity basis is whether there are circumstances taking the case “out of the norm ” – see the discussion in Whaleys (Bradford) Ltd v Bennett [2017] EWCA Civ 2143 at [19]-[22], Newey LJ, and that in Excalibur Ventures LLC v Texas Keystone Inc [2013] EWHC 4278 (Comm), Christopher Clarke LJ . 97. Where a party’s case is fundamentally dishonest, an indemnity basis order ought to follow. As Longmore LJ put it in Esure Services Ltd v Quarcoo [2009] EWCA Civ 595 at [31]: “A fraudulent claim is, in my judgment, indeed out of the norm and it would be a sad day if this court were to give the impression that fraudulent claims being brought at first instance were in any way within the norm .” 98. It is difficult to imagine a case which better justifies the indemnity basis than the present one. Dr Wright’s persistent perjury in the service of a fundamentally dishonest set of claims, together with his prolific forgery, take this case a very long way out of the norm. Interest on costs 99. The jurisdiction to order interest on costs from the dates on which the receiving party paid the relevant fee invoices is under CPR 44.2(6)(g). The power in that rule is “now routinely exercised when an order for costs is made following trial to award interest at a commercial rate from the dates when the costs were incurred until the date when interest becomes payable under the Judgments Act”: Involnert Management Ltd v Aprilgrange Ltd [2015] EWHC 2834 (Comm) at [7], Leggatt J. See generally White Book Notes at [44.2.29]. 100. In this case, COPA should not be left out of pocket as a result of having paid its lawyers from time to time during the litigation . The amount sought in the draft order is 8%, which reflects a commercial rate of base plus 2-3%. The Bank of England base rate having been at or above 5% for the last 12 months (when most costs were incurred) and the US Prime 41 rate being at 8.5% for the last year and above 5% since July 2022. The US Prime rate being most relevant for COPA. For simplicity COPA seeks 8% as a mid-point between these two. Interim payment s on account of costs 101. CPR 44.2(8), provides that a payment on account of costs is the default position: “Where the court orders a party to pay costs subject to detailed assessment, it will order that party to pay a reasonable sum on account of costs, unless there is good reason not to do so.” The amount of the “reasonable sum” which is to be ordered takes account of (a) the likely level of recovery and (b) an appropriate margin of error for the circumstances of the case. The sum is not to be limited to the “irreducible minimum” of what the receiving party may recover70. The Court makes a “reasonable assessment of what is likely to be awarded”71. As explained in the White Book Notes,72 the trial judge who has the advantage of a good understanding of the evidence may not need to allow as much of a margin of error. 102. It is in the interests of justice for interim payments on account of costs to be ordered . Having pursued its case over three years against a fundamentally dishonest opponent, COPA should not be denied a substantial proportion of its costs for longer than is absolutely necessary. That is all the more so given that it is a non-profit organisation. Dr Wright has drained resources which otherwise would have been used to further its aims directly. COPA wishes to get on with its valuable work, and the interim payment will allow it to do so. 103. The reasons why the interim payment s requested are at the level of 85% are as follows: 103.1. 85% would be a reasonable estimated recovery , given that the overall costs figure is not excessive and that costs ought to be assessed on the inde mnity basis. 103.2. The figure of 85% mirrors the amount of the security for costs ordered in favour of the Developers at the PTR (which at that point was prospective; time has not affected the balance of factors in a way that would tend to reduce what is fair). 103.3. As explained in Sherrell 21, the profit costs of Bird & Bird (the largest element of the costs claimed) are based on hourly rates significantly lower than those usually 70 Excalibur Ventures (cited above) at [22]-[23], Christopher Clarke LJ. 71 Otkritie International Investment Management Ltd v Urumov [2014] EWHC 755 (Comm) at [20], Eder J (following United Airways Inc v United Airways Ltd [2011] EWHC 2411 (Ch), Vos J). 72 White Book 2023, Vol 1, p1365 [44.2.12]. 42 seen in a case of this significance, and in almost every case are well below the Solicitors’ Guideline Hourly Rates of HMCTS. 104. COPA’s total costs figure for the COPA Claim is £6,974,572.33, so COPA seeks an
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 18 of 20 Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf ### Folder name: Skeletons ### File path: /content/Copa v Wright - Trial Documents/Relief Hearing/Skeletons/Skeleton Argument of COPA for the Form of Order hearing on 7 June 2024.pdf ### File content: prayer for relief in the Amended Particulars of Claim in the BTC Core Claim {A1/2/32}. 69 See para. 3 of the prayer for relief in the Amended Particulars of Claim in (a) Wright v McCormack {L16/46/35} and (b) Wright v Granath {L17/121/8}. 40 ensuring that Dr Wright paid into court a sum of £6 million, thus securing the bulk of COPA’s costs. At minimum, the costs of the WFO application were reasonably incurred in the course of this litigation and ought to follow the event . Indemnity basis 96. The costs to be paid by Dr Wright and the other Claimants in the BTC Core Claim should be assessed on the indemnity basis. The well-known test for whether costs should be ordered on the indemnity basis is whether there are circumstances taking the case “out of the norm ” – see the discussion in Whaleys (Bradford) Ltd v Bennett [2017] EWCA Civ 2143 at [19]-[22], Newey LJ, and that in Excalibur Ventures LLC v Texas Keystone Inc [2013] EWHC 4278 (Comm), Christopher Clarke LJ . 97. Where a party’s case is fundamentally dishonest, an indemnity basis order ought to follow. As Longmore LJ put it in Esure Services Ltd v Quarcoo [2009] EWCA Civ 595 at [31]: “A fraudulent claim is, in my judgment, indeed out of the norm and it would be a sad day if this court were to give the impression that fraudulent claims being brought at first instance were in any way within the norm .” 98. It is difficult to imagine a case which better justifies the indemnity basis than the present one. Dr Wright’s persistent perjury in the service of a fundamentally dishonest set of claims, together with his prolific forgery, take this case a very long way out of the norm. Interest on costs 99. The jurisdiction to order interest on costs from the dates on which the receiving party paid the relevant fee invoices is under CPR 44.2(6)(g). The power in that rule is “now routinely exercised when an order for costs is made following trial to award interest at a commercial rate from the dates when the costs were incurred until the date when interest becomes payable under the Judgments Act”: Involnert Management Ltd v Aprilgrange Ltd [2015] EWHC 2834 (Comm) at [7], Leggatt J. See generally White Book Notes at [44.2.29]. 100. In this case, COPA should not be left out of pocket as a result of having paid its lawyers from time to time during the litigation . The amount sought in the draft order is 8%, which reflects a commercial rate of base plus 2-3%. The Bank of England base rate having been at or above 5% for the last 12 months (when most costs were incurred) and the US Prime 41 rate being at 8.5% for the last year and above 5% since July 2022. The US Prime rate being most relevant for COPA. For simplicity COPA seeks 8% as a mid-point between these two. Interim payment s on account of costs 101. CPR 44.2(8), provides that a payment on account of costs is the default position: “Where the court orders a party to pay costs subject to detailed assessment, it will order that party to pay a reasonable sum on account of costs, unless there is good reason not to do so.” The amount of the “reasonable sum” which is to be ordered takes account of (a) the likely level of recovery and (b) an appropriate margin of error for the circumstances of the case. The sum is not to be limited to the “irreducible minimum” of what the receiving party may recover70. The Court makes a “reasonable assessment of what is likely to be awarded”71. As explained in the White Book Notes,72 the trial judge who has the advantage of a good understanding of the evidence may not need to allow as much of a margin of error. 102. It is in the interests of justice for interim payments on account of costs to be ordered . Having pursued its case over three years against a fundamentally dishonest opponent, COPA should not be denied a substantial proportion of its costs for longer than is absolutely necessary. That is all the more so given that it is a non-profit organisation. Dr Wright has drained resources which otherwise would have been used to further its aims directly. COPA wishes to get on with its valuable work, and the interim payment will allow it to do so. 103. The reasons why the interim payment s requested are at the level of 85% are as follows: 103.1. 85% would be a reasonable estimated recovery , given that the overall costs figure is not excessive and that costs ought to be assessed on the inde mnity basis. 103.2. The figure of 85% mirrors the amount of the security for costs ordered in favour of the Developers at the PTR (which at that point was prospective; time has not affected the balance of factors in a way that would tend to reduce what is fair). 103.3. As explained in Sherrell 21, the profit costs of Bird & Bird (the largest element of the costs claimed) are based on hourly rates significantly lower than those usually 70 Excalibur Ventures (cited above) at [22]-[23], Christopher Clarke LJ. 71 Otkritie International Investment Management Ltd v Urumov [2014] EWHC 755 (Comm) at [20], Eder J (following United Airways Inc v United Airways Ltd [2011] EWHC 2411 (Ch), Vos J). 72 White Book 2023, Vol 1, p1365 [44.2.12]. 42 seen in a case of this significance, and in almost every case are well below the Solicitors’ Guideline Hourly Rates of HMCTS. 104. COPA’s total costs figure for the COPA Claim is £6,974,572.33, so COPA seeks an
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References 283 REFERENCE QUOTE COMMENT {Day8/93:23} - {Day8/95:10} Q. Page 13 {S2/2.1/13}. Mr Ayre's tweet of 13 April 2019: "Judge only needs one troll to pass judgment ... no need to sue everyone ... just waiting for a volunteer to bankrupt themselves trying to prove a negative and then letting Craig show the proof. Who will be this moron?" That's Mr Ayre positively tweeting about you taking defamation claims and bankrupting people who dispute your claims to be Satoshi, right? A. I don't actually know. I'm not reading Mr Ayre's Twitter. I don't read much Twitter at all these days, but I know Mr Ayre supports me. Q. Do you follow Mr Ayre on Twitter? A. I don't actually know. I don't run my Twitter account. I have posted things there myself, but -- Q. To your knowledge, are you a follower of Mr Ayre on Twitter? A. To m y knowledge, no. NChain runs the account. Q. Mr Ayre has a controlling interest in nChain, doesn't he? A. Not directly. I'm not sure what his percentage is. Mr Ayre owns companies that own companies, so -- Q. Well, I'm going to put to you, and I'll deal with the documents with Mr Matthews, I'm going to put to you that the Ayre Group has a majority of nChain, the parent entity, and the Ayre Group lists nChain amongst its investments. Would you deny either of those things? A. Oh, I know he's an investor. Q. But that nChain is one of its companies, one of the companies it controls? A. Let me be more specific. I know that he invests in nChain. Q. And nChain, and Ayre Group company, of which Mr Ayre has the majority stake, h as provided funding for your litigation, hasn't it? A. No, not at all. I have never received any funding from any part of nChain, either here or overseas. The only money I've received, which I get from them, is now a consulting fee, and before, a salary. Dr Wright is claiming that nChain runs his Twitter account, even though he no longer works for nChain. This is also inconsistent with {Day8/91:17} – {Day8/93:3} above, where he states that “I’ve threatened people who are criminals” (referring to Twitter po sts). Mock Trial Exercise {M1/1/707} Letter from Clyde & Co dated 10 November 2023 Appendix B: Schedule of Transcript References 284 REFERENCE QUOTE COMMENT {Day8/95:11} - {Day8/96:13} Q. {M1/1/707}, please, a letter from Clyde & Co on behalf of Zafar Ali and Ted Loveday answering concerns raised about the mock trial exercise, written by a partner at Clyde & Co. At paragraph 2: “In relation to the events you mention, our clients were instructed by nChain UK Limited, the funder and supporter of litigation involving Dr Wright ...” Were they wrong about that? A. In this, what they're doing is taking action now against Mr Ager -Hanssen, so they're funding that. So the litigation, they have an injunction against Mr Ager -Hanssen, a preliminary one -- Q. No, this is talking about the -- what Mr Ali and Mr Loveday were doing before the bust up with Mr Ager -Hanssen. A. No, it's not. This is 10 November. This is post. That is when the litigation started against Mr Ager -Hanssen and there is a filing going to be done with the Bar against Mr Ali Zafar. So this is post al l of that. This is litigation that, any day now, will be going into criminal matters. Q. Dr Wright, this is nothing to do with that litigation, it is a firm of solicitors writing on behalf of Mr Ali and Mr Loveday to explain what was happening at the time of the mock trial? A. Not by nChain. I don't know who the solicitors, etc, are, but what I can tell you is, in the 10 November, Mr Ali Zafar had nothing to do with nChain. Dr Wright is stating that Zafar Ali KC had “nothing to do with nChain”. On day 11 , Mr Matthews also stated that Mr Ali was not instructed by nChain. Zafar Ali KC’s lawyers, Clyde & Co, state that he was instructed by nChain {M1/1/707}. Calvin Ayre - financial gain from BSV trading {Day8/96:14- 17} Q. Another question about Mr Ayre. A re you aware that he's seeking to gain financially from your claim through trading in BSV? A. Not really. He actually loses a lot of money. Dr Wright is denying that Calvin Ayre is seeking to gain financially from his claim through BSV trading, claiming that Mr Ayre “loses a lot of money.” {Day8/96:18} - {Day8/97:14} {L20/252.3/1} {L20/252.4/1} Capture of Calvin Ayre X Posts Q. {L20/252.3/1}. Could we maximise the top? A tweet from Mr Ayre on 28 December 2023. “So I tell my guy to tell one of our banks in Europe yesterday to start to buy slow as I am all in on Craig winning and the market roars today ... they were just waiting for me to put my money where my mouth is.” Are you aware of Mr Ayre making those sorts of communications, Dr Wright? Dr Wright is asked about Mr Ayre’s Twitter posts regarding BSV trading, he d enies having read any of these posts. Appendix B: Schedule of Transcript References 285 REFERENCE QUOTE COMMENT A. No, I'm not, but what you're missing is, that's not in cryptocurrency trading. BSV has been de -listed by all of your clients and people related to them. Q. So he’s not talking about trading in tokens, is he? A. I doubt it. He would be looking at the companies. Q. {L20/252.4/1}. A tweet from Mr Ayre on the same day: “I never talk tokens but BSV is for sure over 1000 in the run up to the COPA case ... they were watching my money and I said buy but do not move the market [yesterday] and this happens ... watch what happens when I start to buy for real in Jan.” He’s talking about BSV, isn’t he, Dr Wright? A. Looks like it, but I don't know. As I said, I haven't read any of his stuff. {L19/212} Email from Calvin Ayre to Dr Wright -23 September 2023 {Day8/97:15} – {Day8/98:17) {S1/1.35/614} Capture of Calvin Ayre X Post Q. Aftermath of the mock trial {L19/212/6}. This is an email ostensibly from Calvin Ayre to you, 23 September 2023, immediately after the mock trial exercise, or the
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 114 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: References 283 REFERENCE QUOTE COMMENT {Day8/93:23} - {Day8/95:10} Q. Page 13 {S2/2.1/13}. Mr Ayre's tweet of 13 April 2019: "Judge only needs one troll to pass judgment ... no need to sue everyone ... just waiting for a volunteer to bankrupt themselves trying to prove a negative and then letting Craig show the proof. Who will be this moron?" That's Mr Ayre positively tweeting about you taking defamation claims and bankrupting people who dispute your claims to be Satoshi, right? A. I don't actually know. I'm not reading Mr Ayre's Twitter. I don't read much Twitter at all these days, but I know Mr Ayre supports me. Q. Do you follow Mr Ayre on Twitter? A. I don't actually know. I don't run my Twitter account. I have posted things there myself, but -- Q. To your knowledge, are you a follower of Mr Ayre on Twitter? A. To m y knowledge, no. NChain runs the account. Q. Mr Ayre has a controlling interest in nChain, doesn't he? A. Not directly. I'm not sure what his percentage is. Mr Ayre owns companies that own companies, so -- Q. Well, I'm going to put to you, and I'll deal with the documents with Mr Matthews, I'm going to put to you that the Ayre Group has a majority of nChain, the parent entity, and the Ayre Group lists nChain amongst its investments. Would you deny either of those things? A. Oh, I know he's an investor. Q. But that nChain is one of its companies, one of the companies it controls? A. Let me be more specific. I know that he invests in nChain. Q. And nChain, and Ayre Group company, of which Mr Ayre has the majority stake, h as provided funding for your litigation, hasn't it? A. No, not at all. I have never received any funding from any part of nChain, either here or overseas. The only money I've received, which I get from them, is now a consulting fee, and before, a salary. Dr Wright is claiming that nChain runs his Twitter account, even though he no longer works for nChain. This is also inconsistent with {Day8/91:17} – {Day8/93:3} above, where he states that “I’ve threatened people who are criminals” (referring to Twitter po sts). Mock Trial Exercise {M1/1/707} Letter from Clyde & Co dated 10 November 2023 Appendix B: Schedule of Transcript References 284 REFERENCE QUOTE COMMENT {Day8/95:11} - {Day8/96:13} Q. {M1/1/707}, please, a letter from Clyde & Co on behalf of Zafar Ali and Ted Loveday answering concerns raised about the mock trial exercise, written by a partner at Clyde & Co. At paragraph 2: “In relation to the events you mention, our clients were instructed by nChain UK Limited, the funder and supporter of litigation involving Dr Wright ...” Were they wrong about that? A. In this, what they're doing is taking action now against Mr Ager -Hanssen, so they're funding that. So the litigation, they have an injunction against Mr Ager -Hanssen, a preliminary one -- Q. No, this is talking about the -- what Mr Ali and Mr Loveday were doing before the bust up with Mr Ager -Hanssen. A. No, it's not. This is 10 November. This is post. That is when the litigation started against Mr Ager -Hanssen and there is a filing going to be done with the Bar against Mr Ali Zafar. So this is post al l of that. This is litigation that, any day now, will be going into criminal matters. Q. Dr Wright, this is nothing to do with that litigation, it is a firm of solicitors writing on behalf of Mr Ali and Mr Loveday to explain what was happening at the time of the mock trial? A. Not by nChain. I don't know who the solicitors, etc, are, but what I can tell you is, in the 10 November, Mr Ali Zafar had nothing to do with nChain. Dr Wright is stating that Zafar Ali KC had “nothing to do with nChain”. On day 11 , Mr Matthews also stated that Mr Ali was not instructed by nChain. Zafar Ali KC’s lawyers, Clyde & Co, state that he was instructed by nChain {M1/1/707}. Calvin Ayre - financial gain from BSV trading {Day8/96:14- 17} Q. Another question about Mr Ayre. A re you aware that he's seeking to gain financially from your claim through trading in BSV? A. Not really. He actually loses a lot of money. Dr Wright is denying that Calvin Ayre is seeking to gain financially from his claim through BSV trading, claiming that Mr Ayre “loses a lot of money.” {Day8/96:18} - {Day8/97:14} {L20/252.3/1} {L20/252.4/1} Capture of Calvin Ayre X Posts Q. {L20/252.3/1}. Could we maximise the top? A tweet from Mr Ayre on 28 December 2023. “So I tell my guy to tell one of our banks in Europe yesterday to start to buy slow as I am all in on Craig winning and the market roars today ... they were just waiting for me to put my money where my mouth is.” Are you aware of Mr Ayre making those sorts of communications, Dr Wright? Dr Wright is asked about Mr Ayre’s Twitter posts regarding BSV trading, he d enies having read any of these posts. Appendix B: Schedule of Transcript References 285 REFERENCE QUOTE COMMENT A. No, I'm not, but what you're missing is, that's not in cryptocurrency trading. BSV has been de -listed by all of your clients and people related to them. Q. So he’s not talking about trading in tokens, is he? A. I doubt it. He would be looking at the companies. Q. {L20/252.4/1}. A tweet from Mr Ayre on the same day: “I never talk tokens but BSV is for sure over 1000 in the run up to the COPA case ... they were watching my money and I said buy but do not move the market [yesterday] and this happens ... watch what happens when I start to buy for real in Jan.” He’s talking about BSV, isn’t he, Dr Wright? A. Looks like it, but I don't know. As I said, I haven't read any of his stuff. {L19/212} Email from Calvin Ayre to Dr Wright -23 September 2023 {Day8/97:15} – {Day8/98:17) {S1/1.35/614} Capture of Calvin Ayre X Post Q. Aftermath of the mock trial {L19/212/6}. This is an email ostensibly from Calvin Ayre to you, 23 September 2023, immediately after the mock trial exercise, or the
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that document that's referred to as ID_004531. So you showing me on the screen today is the first time I've seen that. Q. So that's the first time you've seen the transcript? A. Correct. Q. I should point out, there are a number of versions of the transcript. Were you shown any version of the transcript? A. I've not received any version of the transcript, no. Mr Jenkin s states that he was never sent one of the PD57AC documents listed in his witness statement (ID_004531, the transcript of his evidence in Granath) and this is the first time he has seen it and that he was never sent any version of his Granath transcripts. {Day9/61:15} - {Day9/62:13} Q. Now, if we can go back to your statement, page 5 {E/6/5}, paragraph 16, the very last sentence of paragraph 16, you say: "We didn't have ongoing conversations around other digital currencies, but the concept of trust was a r elatively consistent feature of what we talked about over the next few years." So your evidence there is it wasn't something you were regularly talking about, digital currencies, it was something that was one of many topics that you touched upon over the years with Dr Wright; is that fair? A. I think it's fair to say that, during that time, we were talking more about the trust side of things rather than digital currencies per se. It was more to do with - I think it was in relation to - to paying for - for a lunch at one stage, but essentially, the trust that's placed in a piece of paper, a piece of paper being a,you know, £5 note, £10 note, whatever it is, and it was conversations around why you trust a piece of paper that you hold in your wallet rather tha n something else that could be proven to be something more than just a promissory note. But essentially, the conversations were on the trust rather than actual digital currencies at that time. Mr Jenkins agrees that his discussions with Dr Wright were not about digital currencies, but about trust in the context of banking systems. Appendix B: Schedule of Transcript References 330 REFERENCE QUOTE COMMENT {Day9/63:8} - {Day9/64:2} Q. And it was you that was interested in E - Gold, not Dr Wright; is that correct? You were the one that was actually invested in E - Gold? A. So when I say invested in E - Gold, don't misinterpret that. I was the one that initially used E - Gold in order to make an online purchase, so I wasn't an investor in E - Gold. I'm not an investor in anything. But in terms of E - Gold, that was a mean s to - in order to purchase something online and that was the mechanism available and that was the escrow service available in Australia at the time. Q. So you were the one at the time using E - Gold. There doesn’t appear to be any record of Dr Wright using E - Gold. Do you know if Dr Wright was also using E - Gold or was it just yourself? A. I’m unsure. I know that Craig knew about E - Gold and knew, you know, about escrow services. E - Gold, I think, probably at the time had several other competitors as w ell, but E - Gold was the one that was quite prevalent in Australia. Mr Jenkins admits that he was the one that initially used E -Gold to make an online purchase, and was unsure whether Dr Wright used E -Gold. {Day9/64:11} - {Day9/65:24} Q. But can you nam e - can you remember the details - I appreciate it's a long time ago, but can you remember the details or the specific names of any other providers at that time? A. Off the top of my head right now, no, I can't. Could I refer to them in my emails, as I - you know, for the previous court case, and refer to other such services that I was looking at at the time? Yes, I probably have that information. Do I have it right now and has it been refreshed in the last couple of years? No, it hasn't. Q. I do apprecia te it is a long time ago, Mr Jenkins, and I make no criticism of that. So just to clarify - A. Yeah, but - but just to clarify that as well, if I - if I may. There were certain - from the court case in Norway, I was given permission and was asked to spec ifically search for information in my emails and SMSs and anything else. If there was nothing there, I was asked to look for in terms of alternative means of - of escrow services back then and I wouldn't have looked for it. So it's disappeared into the annals of time. Where my more recent knowledge and memory prevails is based on the fact that, you know, 18 months ago, I was searching through these emails and it refreshed my memory. So I wasn't asked specifically what other escrow - like services were avail able back then, so it's not as fresh in my memory as it was for other things. Q. Perfectly understandable, Mr Jenkins. Do you think then that you might have been able to give a more accurate reflection, or recollection, I should say, of what was happening Mr Je nkins disclosing that in Granath, he was specifically asked to search for information in his emails and text messages, etc. Discloses later that he was specifically asked not to conduct such searches in these proceedings {Day9/69:19- 22}. Appendix B: Schedule of Transcript References 331 REFERENCE QUOTE COMMENT back in this time had you undertaken such searches in advance of giving this evidence in these proceedings? A. Absolutely. And it wouldn't just be recollection, it would be factual. Q. It would be backed up by contemporaneous documents? A. Correct {Day9/66:9- 13} Q. And in your statement you mention conversations with Dr Wright about topics you discussed that could relate, or may relate to some of the broad concepts relating to Bitcoin; correct? A. That's correct, yes. Mr Jenkins agrees that he had conversations with Dr Wright about topics that “could” or “may” relate to some of the broad concepts relating to Bitcoin. {Day9/66:14} - {Day9/67:7} Q. But you say
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 132 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: that document that's referred to as ID_004531. So you showing me on the screen today is the first time I've seen that. Q. So that's the first time you've seen the transcript? A. Correct. Q. I should point out, there are a number of versions of the transcript. Were you shown any version of the transcript? A. I've not received any version of the transcript, no. Mr Jenkin s states that he was never sent one of the PD57AC documents listed in his witness statement (ID_004531, the transcript of his evidence in Granath) and this is the first time he has seen it and that he was never sent any version of his Granath transcripts. {Day9/61:15} - {Day9/62:13} Q. Now, if we can go back to your statement, page 5 {E/6/5}, paragraph 16, the very last sentence of paragraph 16, you say: "We didn't have ongoing conversations around other digital currencies, but the concept of trust was a r elatively consistent feature of what we talked about over the next few years." So your evidence there is it wasn't something you were regularly talking about, digital currencies, it was something that was one of many topics that you touched upon over the years with Dr Wright; is that fair? A. I think it's fair to say that, during that time, we were talking more about the trust side of things rather than digital currencies per se. It was more to do with - I think it was in relation to - to paying for - for a lunch at one stage, but essentially, the trust that's placed in a piece of paper, a piece of paper being a,you know, £5 note, £10 note, whatever it is, and it was conversations around why you trust a piece of paper that you hold in your wallet rather tha n something else that could be proven to be something more than just a promissory note. But essentially, the conversations were on the trust rather than actual digital currencies at that time. Mr Jenkins agrees that his discussions with Dr Wright were not about digital currencies, but about trust in the context of banking systems. Appendix B: Schedule of Transcript References 330 REFERENCE QUOTE COMMENT {Day9/63:8} - {Day9/64:2} Q. And it was you that was interested in E - Gold, not Dr Wright; is that correct? You were the one that was actually invested in E - Gold? A. So when I say invested in E - Gold, don't misinterpret that. I was the one that initially used E - Gold in order to make an online purchase, so I wasn't an investor in E - Gold. I'm not an investor in anything. But in terms of E - Gold, that was a mean s to - in order to purchase something online and that was the mechanism available and that was the escrow service available in Australia at the time. Q. So you were the one at the time using E - Gold. There doesn’t appear to be any record of Dr Wright using E - Gold. Do you know if Dr Wright was also using E - Gold or was it just yourself? A. I’m unsure. I know that Craig knew about E - Gold and knew, you know, about escrow services. E - Gold, I think, probably at the time had several other competitors as w ell, but E - Gold was the one that was quite prevalent in Australia. Mr Jenkins admits that he was the one that initially used E -Gold to make an online purchase, and was unsure whether Dr Wright used E -Gold. {Day9/64:11} - {Day9/65:24} Q. But can you nam e - can you remember the details - I appreciate it's a long time ago, but can you remember the details or the specific names of any other providers at that time? A. Off the top of my head right now, no, I can't. Could I refer to them in my emails, as I - you know, for the previous court case, and refer to other such services that I was looking at at the time? Yes, I probably have that information. Do I have it right now and has it been refreshed in the last couple of years? No, it hasn't. Q. I do apprecia te it is a long time ago, Mr Jenkins, and I make no criticism of that. So just to clarify - A. Yeah, but - but just to clarify that as well, if I - if I may. There were certain - from the court case in Norway, I was given permission and was asked to spec ifically search for information in my emails and SMSs and anything else. If there was nothing there, I was asked to look for in terms of alternative means of - of escrow services back then and I wouldn't have looked for it. So it's disappeared into the annals of time. Where my more recent knowledge and memory prevails is based on the fact that, you know, 18 months ago, I was searching through these emails and it refreshed my memory. So I wasn't asked specifically what other escrow - like services were avail able back then, so it's not as fresh in my memory as it was for other things. Q. Perfectly understandable, Mr Jenkins. Do you think then that you might have been able to give a more accurate reflection, or recollection, I should say, of what was happening Mr Je nkins disclosing that in Granath, he was specifically asked to search for information in his emails and text messages, etc. Discloses later that he was specifically asked not to conduct such searches in these proceedings {Day9/69:19- 22}. Appendix B: Schedule of Transcript References 331 REFERENCE QUOTE COMMENT back in this time had you undertaken such searches in advance of giving this evidence in these proceedings? A. Absolutely. And it wouldn't just be recollection, it would be factual. Q. It would be backed up by contemporaneous documents? A. Correct {Day9/66:9- 13} Q. And in your statement you mention conversations with Dr Wright about topics you discussed that could relate, or may relate to some of the broad concepts relating to Bitcoin; correct? A. That's correct, yes. Mr Jenkins agrees that he had conversations with Dr Wright about topics that “could” or “may” relate to some of the broad concepts relating to Bitcoin. {Day9/66:14} - {Day9/67:7} Q. But you say
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project into that ZIP file, hadn't you? Dr Wright blaming third parties - KLD - for disclosure failures. Appendix B: Schedule of Transcript References 521 REFERENCE QUOTE COMMENT A. No. I downloaded that with the KLD people, clicked the link at one stage and things got sent. {AB-A/5/58} Letter from Macfarlanes to Court Paragraph 15 {Day15/193:3} - {Day15/194:15} Q. Dr Wright, we have established, because we did it right at the very beginning of the cross -examination, that you copied the BitcoinSN.tex file into the main.tex file as described there, right? A. Yes. Q. Right. And the BitcoinSN.tex file was from th e Maths (OLD) project, right? A. As this says -- Q. Yes. A. -- it comes from -- no, as it says, it comes from another project. That was copied, like 20 existing files, into a similar structure. So -- Q. Dr Wright, the content of the first full version of main.tex in the Bitcoin folder is identical, it's not just hash identical, it's identical to the final version of the BitcoinSN.tex file in the Maths (OLD) project. A. That's because that's where I started. You're getting it, again, the wrong way round. I downloaded these, I removed some of the stuff; the download stayed the same, that was in my R drive. That was then loaded up for the demonstrations where I compiled basically multiple versions to show the differences, and then I loaded the original one that I'd downloaded, which is talking here about the existing files of similar structure. Q. Dr Wright, the inference that was drawn by us when we saw this was that you had copied material from the Maths (OLD) project into the new Bitcoin project, and that was true, right? A. No, it's actually the other way round. I copied down. That's where these files are. I then copied those into the demonstration drive and then I copied later back into the other. Q. No, the Bitcoin project didn't exist until 19 November. A. No, but I had other folders, and like it says here, "20 existing files". The problem is that it doesn't have any information from previous -- Dr Wright not accepting the obvious truth regarding copying the BitcoinSN.tex file into the Maths (OLD) project. Appendix B: Schedule of Transcript References 522 REFERENCE QUOTE COMMENT {E/33/5} - Fourteenth Witness St atement (on Chain of Custody) {Day15/196:13} - {Day15/196:25} Q. Dr Wright, I have been now through each of the witness statements in which you purported to touch on the White Paper LaTeX files and you did not describe in any of those witness statements the changes that we saw in the animations, right? A. Because none of those were actually part of the files we're talking about. The files we're talking about are the ones that I demonstrated in October, that I downloaded to make sure they didn't change, that I re -uploaded afterwards, hence why, in the evidence, it says "existing files". Q. Can we -- A. Existing files were loaded to create this. Dr Wright claiming that he did not talk about the changes in the LaTeX files in his witness statement as those were different files, which is completely implausible. {M/3/15}, para 8 - Letter from Shoosmiths to B&B/Macfarlanes {Day15/199:25} - {Day15/201:5} Q. Can we go to {M/3/16}, paragraph 14. Let's just read that. It says this: "Importantly, Dr Wright's case in relation to the White Paper LaTeX Files does not depend on the proposition that he has not edited the ... code in those files since publicatio n of the Bitcoin White Paper, or that the files are a time capsule that can be dated to any particular point in time. Our instructions are that Dr Wright did edit the code in the intervening years for personal experimentation and to make corrections and improvements, and for the purposes of the demonstrations referred to above, and that Dr Wright then sought to undo the changes to the LaTeX code he had made since publication of the Bitcoin White Paper in order to put the code into the form that wo uld compile [to] the Bitcoin White Paper." Right? A. No, because that's the other changes. You're, again, confusing the maths folder and what I did in October. There were some changes I made in October when I was demonstrating to Matt and others, and t hose were basically -- I demonstrated these were changes and I undid some of those changes. Q. They were producing two us at this point the unredacted versions of both the Maths (OLD) project and the Bitcoin project, Dr Wright, so they're talking about both of them. Dr Wright giving an evasive answer where he again refers to different material used in the demonstrations to Shoosmiths to that which was then disclosed in these proceedings. Appendix B: Schedule of Transcript References 523 REFERENCE QUOTE COMMENT A. This is before that. As you demonstrated already, the Maths (OLD) was loaded from existing files. So those existing files were loaded into that structure. {L21/18.1} - Blob file that existed in the Maths (OLD) project on 17 November 2023 {L21/22.2/3} - image2.tex from Dr Wright’s White Paper LaTeX files (earliest on e in disclosure) {Day15/211:18} - {Day15/214:2} Q. But you have remembered that you needed to convert the individual placing of letters into a full word, right? A. No. Q. Because if you had placed each letter individually, it would have screamed out that it was a forgery, right? A. Again, it would show that an automated tool had created it. But, no, I didn't do that. Q. If we then go to page 3 {L21/22.2/3} and go to {L21/18.1/64} on the left -hand side and let's go to the word "item". You forgot to change the word "item" from its Aspose encoding, didn't you, Dr Wright? A. I did not. Q. Every letter of that word has been positioned in exactly the same position as your Aspose output, right? A. Where is this document from? Q. The document on the right is image 2.tex from your White Paper LaTeX fil es. A. Which particular? Q. All of them, actually. A. That's not -- Q. It doesn't change from 17 November, the earliest one that we've got. A. That's not how mine was, so ... Q. This is down to 0.035 of a micron, right? A. Possibly. Q. Which is a bout the length of a short segment of DNA, Dr
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 206 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: project into that ZIP file, hadn't you? Dr Wright blaming third parties - KLD - for disclosure failures. Appendix B: Schedule of Transcript References 521 REFERENCE QUOTE COMMENT A. No. I downloaded that with the KLD people, clicked the link at one stage and things got sent. {AB-A/5/58} Letter from Macfarlanes to Court Paragraph 15 {Day15/193:3} - {Day15/194:15} Q. Dr Wright, we have established, because we did it right at the very beginning of the cross -examination, that you copied the BitcoinSN.tex file into the main.tex file as described there, right? A. Yes. Q. Right. And the BitcoinSN.tex file was from th e Maths (OLD) project, right? A. As this says -- Q. Yes. A. -- it comes from -- no, as it says, it comes from another project. That was copied, like 20 existing files, into a similar structure. So -- Q. Dr Wright, the content of the first full version of main.tex in the Bitcoin folder is identical, it's not just hash identical, it's identical to the final version of the BitcoinSN.tex file in the Maths (OLD) project. A. That's because that's where I started. You're getting it, again, the wrong way round. I downloaded these, I removed some of the stuff; the download stayed the same, that was in my R drive. That was then loaded up for the demonstrations where I compiled basically multiple versions to show the differences, and then I loaded the original one that I'd downloaded, which is talking here about the existing files of similar structure. Q. Dr Wright, the inference that was drawn by us when we saw this was that you had copied material from the Maths (OLD) project into the new Bitcoin project, and that was true, right? A. No, it's actually the other way round. I copied down. That's where these files are. I then copied those into the demonstration drive and then I copied later back into the other. Q. No, the Bitcoin project didn't exist until 19 November. A. No, but I had other folders, and like it says here, "20 existing files". The problem is that it doesn't have any information from previous -- Dr Wright not accepting the obvious truth regarding copying the BitcoinSN.tex file into the Maths (OLD) project. Appendix B: Schedule of Transcript References 522 REFERENCE QUOTE COMMENT {E/33/5} - Fourteenth Witness St atement (on Chain of Custody) {Day15/196:13} - {Day15/196:25} Q. Dr Wright, I have been now through each of the witness statements in which you purported to touch on the White Paper LaTeX files and you did not describe in any of those witness statements the changes that we saw in the animations, right? A. Because none of those were actually part of the files we're talking about. The files we're talking about are the ones that I demonstrated in October, that I downloaded to make sure they didn't change, that I re -uploaded afterwards, hence why, in the evidence, it says "existing files". Q. Can we -- A. Existing files were loaded to create this. Dr Wright claiming that he did not talk about the changes in the LaTeX files in his witness statement as those were different files, which is completely implausible. {M/3/15}, para 8 - Letter from Shoosmiths to B&B/Macfarlanes {Day15/199:25} - {Day15/201:5} Q. Can we go to {M/3/16}, paragraph 14. Let's just read that. It says this: "Importantly, Dr Wright's case in relation to the White Paper LaTeX Files does not depend on the proposition that he has not edited the ... code in those files since publicatio n of the Bitcoin White Paper, or that the files are a time capsule that can be dated to any particular point in time. Our instructions are that Dr Wright did edit the code in the intervening years for personal experimentation and to make corrections and improvements, and for the purposes of the demonstrations referred to above, and that Dr Wright then sought to undo the changes to the LaTeX code he had made since publication of the Bitcoin White Paper in order to put the code into the form that wo uld compile [to] the Bitcoin White Paper." Right? A. No, because that's the other changes. You're, again, confusing the maths folder and what I did in October. There were some changes I made in October when I was demonstrating to Matt and others, and t hose were basically -- I demonstrated these were changes and I undid some of those changes. Q. They were producing two us at this point the unredacted versions of both the Maths (OLD) project and the Bitcoin project, Dr Wright, so they're talking about both of them. Dr Wright giving an evasive answer where he again refers to different material used in the demonstrations to Shoosmiths to that which was then disclosed in these proceedings. Appendix B: Schedule of Transcript References 523 REFERENCE QUOTE COMMENT A. This is before that. As you demonstrated already, the Maths (OLD) was loaded from existing files. So those existing files were loaded into that structure. {L21/18.1} - Blob file that existed in the Maths (OLD) project on 17 November 2023 {L21/22.2/3} - image2.tex from Dr Wright’s White Paper LaTeX files (earliest on e in disclosure) {Day15/211:18} - {Day15/214:2} Q. But you have remembered that you needed to convert the individual placing of letters into a full word, right? A. No. Q. Because if you had placed each letter individually, it would have screamed out that it was a forgery, right? A. Again, it would show that an automated tool had created it. But, no, I didn't do that. Q. If we then go to page 3 {L21/22.2/3} and go to {L21/18.1/64} on the left -hand side and let's go to the word "item". You forgot to change the word "item" from its Aspose encoding, didn't you, Dr Wright? A. I did not. Q. Every letter of that word has been positioned in exactly the same position as your Aspose output, right? A. Where is this document from? Q. The document on the right is image 2.tex from your White Paper LaTeX fil es. A. Which particular? Q. All of them, actually. A. That's not -- Q. It doesn't change from 17 November, the earliest one that we've got. A. That's not how mine was, so ... Q. This is down to 0.035 of a micron, right? A. Possibly. Q. Which is a bout the length of a short segment of DNA, Dr
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as a backed-up version of the other . The Edit Time percentage was 46% and the documents were authored over the course of 12 days. A 46% Edit Time is considerably lower than any of the anomalous near-100% Edit Times of the Lynn Wright documents, and while higher than might normally be expected, it presents as a draft of a book, which could be understood to require dedicated authoring over a long period of time.2 d. ID_000165 has a recorded Edit Time of 1,602 minutes (1 day 2 hours and 42 minutes) that equates to 84% of the time difference between created and last modified timestamps for the document. This is somewhat anomalous, but can be explained in view of its content, as an intensive drafting exercise to create a 56 -page document on “International Cyberlaw”. 26. The cross -check confirms my opin ion that the presence of long Edit Times approaching 100% of the difference between Created and Modified dates is not typical even within the disclosuredataset. Similar characteristics were observed on only two occasions above, and in both c ases the percentage of Edit Time was lower than observed in the Lynn Wright documents and related to documents that are consistent with a short period of intensive drafting. Revision count s 27. In addition to the anomalous Edit Times, many of the Lynn Wright documents display unusual Revision Counts. 28. Many of the documents with 100% Edit Times over long periods display low Revision counts, indicating they were saved very little. For example, ID_000462 presents as having 2I did consider whether the period of �me (12 days) was rela�vely short for the dra�ing of a whole book. However, in the course of reviewing the document I Googl ed various passages from it and found hits online for iden�cal content from other sources. For example, I found the phrase "Now change to the root account, install to a temporary directory, and create a tarball" from the dra� was also published at the web site htp://www.boran.com/security/sp/chroo�ng_bind.html and that was archived significantly earlier in 2001, at the URL htps://web.archive.org/web/20010420155352/htp://www.boran.com/security/sp/chroo�ng_bind.html . This led me to the preliminary view that elements of the text of the book may be copied from online sources, whi ch might speed up authorship and so explain the �me . This therefore resolves th at considera�on at least by providing me with a plausible reason for it, which I set out here for complet eness. It is not my aim to come to an opinion on whether or not the content was copied, only to assess this document as a compara�ve source for the documents otherwise under scru�ny for their authen�city and so I have not inves�gated furtherbeyond what was helpful to my main analysis . I form no conclusion about whether the content was copi ed. Madden Appendix PM24 “Lynn Wright overview” / various ID numbers Page 9 of 15 c. ID_0001 15, ID_000116 were very long documents which present as being drafts of a “Security Administrators Handbook” , one of which presented as a backed-up version of the other . The Edit Time percentage was 46% and the documents were authored over the course of 12 days. A 46% Edit Time is considerably lower than any of the anomalous near-100% Edit Times of the Lynn Wright documents, and while higher than might normally be expected, it presents as a draft of a book, which could be understood to require dedicated authoring over a long period of time.2 d. ID_000165 has a recorded Edit Time of 1,602 minutes (1 day 2 hours and 42 minutes) that equates to 84% of the time difference between created and last modified timestamps for the document. This is somewhat anomalous, but can be explained in view of its content, as an intensive drafting exercise to create a 56 -page document on “International Cyberlaw”. 26. The cross -check confirms my opin ion that the presence of long Edit Times approaching 100% of the difference between Created and Modified dates is not typical even within the disclosuredataset. Similar characteristics were observed on only two occasions above, and in both c ases the percentage of Edit Time was lower than observed in the Lynn Wright documents and related to documents that are consistent with a short period of intensive drafting. Revision count s 27. In addition to the anomalous Edit Times, many of the Lynn Wright documents display unusual Revision Counts. 28. Many of the documents with 100% Edit Times over long periods display low Revision counts, indicating they were saved very little. For example, ID_000462 presents as
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 9 of 14 Appendix PM24.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM24.pdf ### File content: as a backed-up version of the other . The Edit Time percentage was 46% and the documents were authored over the course of 12 days. A 46% Edit Time is considerably lower than any of the anomalous near-100% Edit Times of the Lynn Wright documents, and while higher than might normally be expected, it presents as a draft of a book, which could be understood to require dedicated authoring over a long period of time.2 d. ID_000165 has a recorded Edit Time of 1,602 minutes (1 day 2 hours and 42 minutes) that equates to 84% of the time difference between created and last modified timestamps for the document. This is somewhat anomalous, but can be explained in view of its content, as an intensive drafting exercise to create a 56 -page document on “International Cyberlaw”. 26. The cross -check confirms my opin ion that the presence of long Edit Times approaching 100% of the difference between Created and Modified dates is not typical even within the disclosuredataset. Similar characteristics were observed on only two occasions above, and in both c ases the percentage of Edit Time was lower than observed in the Lynn Wright documents and related to documents that are consistent with a short period of intensive drafting. Revision count s 27. In addition to the anomalous Edit Times, many of the Lynn Wright documents display unusual Revision Counts. 28. Many of the documents with 100% Edit Times over long periods display low Revision counts, indicating they were saved very little. For example, ID_000462 presents as having 2I did consider whether the period of �me (12 days) was rela�vely short for the dra�ing of a whole book. However, in the course of reviewing the document I Googl ed various passages from it and found hits online for iden�cal content from other sources. For example, I found the phrase "Now change to the root account, install to a temporary directory, and create a tarball" from the dra� was also published at the web site htp://www.boran.com/security/sp/chroo�ng_bind.html and that was archived significantly earlier in 2001, at the URL htps://web.archive.org/web/20010420155352/htp://www.boran.com/security/sp/chroo�ng_bind.html . This led me to the preliminary view that elements of the text of the book may be copied from online sources, whi ch might speed up authorship and so explain the �me . This therefore resolves th at considera�on at least by providing me with a plausible reason for it, which I set out here for complet eness. It is not my aim to come to an opinion on whether or not the content was copied, only to assess this document as a compara�ve source for the documents otherwise under scru�ny for their authen�city and so I have not inves�gated furtherbeyond what was helpful to my main analysis . I form no conclusion about whether the content was copi ed. Madden Appendix PM24 “Lynn Wright overview” / various ID numbers Page 9 of 15 c. ID_0001 15, ID_000116 were very long documents which present as being drafts of a “Security Administrators Handbook” , one of which presented as a backed-up version of the other . The Edit Time percentage was 46% and the documents were authored over the course of 12 days. A 46% Edit Time is considerably lower than any of the anomalous near-100% Edit Times of the Lynn Wright documents, and while higher than might normally be expected, it presents as a draft of a book, which could be understood to require dedicated authoring over a long period of time.2 d. ID_000165 has a recorded Edit Time of 1,602 minutes (1 day 2 hours and 42 minutes) that equates to 84% of the time difference between created and last modified timestamps for the document. This is somewhat anomalous, but can be explained in view of its content, as an intensive drafting exercise to create a 56 -page document on “International Cyberlaw”. 26. The cross -check confirms my opin ion that the presence of long Edit Times approaching 100% of the difference between Created and Modified dates is not typical even within the disclosuredataset. Similar characteristics were observed on only two occasions above, and in both c ases the percentage of Edit Time was lower than observed in the Lynn Wright documents and related to documents that are consistent with a short period of intensive drafting. Revision count s 27. In addition to the anomalous Edit Times, many of the Lynn Wright documents display unusual Revision Counts. 28. Many of the documents with 100% Edit Times over long periods display low Revision counts, indicating they were saved very little. For example, ID_000462 presents as
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PM 22 “InterofficeMemoTemplates ” / ID_00 0856 Page 29of 30 66. The only place I identified where ID_001006 was inconsistent with the current Office template was the text for the Address field “Cc:”. In ID_001006 it is listed as “cc:” which matches more closely the two older samples (which are in lowercase), while the current Office template features “Cc:”. This can however be easily adjusted simply by typing the letter “c” in lowercase. 67. Document ID_001006 also carries a metadata tag for the template filename that matches that downloaded from the MS Office Online res ource , “Interoffice Memo (Professional design).dotx”, which is consistent with the c urrent O ffice template file but not the other older templates that I was able to obtain. C omparative review with ID_000856 68. Turning to ID_000856, a similar analysis can be conduct ed – although it is more difficult to compare as it has been resized and has suffered some degradation. 69. Comparing the template files shown above to ID_000856, it can be observed that aside from the text in the dark box not needing to be wrapped (because the company name ‘Information Defense’ in shorter) , all of the similarities/ differences between the c urrent Office template and the two previous templates correlate with ID_000856 in the same manner as ID_001007. 70. Again , therefore, t his indicates that the general layout and structure of ID_000856 is more consistent with the current Office template tha n the sample templates dated 2012 and 2014. 29 - 29 - H/106/29{ID_001006} {ID_000856} {ID_001007} Madden Appendix PM 22 “InterofficeMemoTemplates ” / ID_00 0856 Page 30of 30 C onclusion 71. In conclusion : a. I D_000856 and ID_001006 are both sourced from simi lar MS Word templates. b. Although they are dated to 2009 and 2011 respectively, I have not been able to find any instance of the template in question being available at any time before October 2012, when it was described by Microsoft as being “ New! ”. c. S imilar but slightly different templates have been produced since then and I was able to identify multiple versions for comparative review. In my opinion, based on a visual inspection ID_000856 and ID_001006 are both more consistent with the most recent version of the template than they are with the oldest version of the template. 72. The two PDF documents have been created in different ways: ID_001006 has been exported directly from MS Word, while ID_000856 has been printed, re- scanned to picture format, and then re -converted to PDF, leading to a loss of useful metadata for analysis, however: a. Wh at metadata does exist in the file is easily manipulable as I have demonstrated, and there are possible (although not conclusive) indications that the PDF may have be en edited after it was created . b. Viewed in the context of several other documents within the dataset having similar characteristics, ID_000856 is unique in that it is the only document which records “Lynn Wright” as its author, whereas the other documents (before and after it in time ) record “Admin” as their author . 73. This leads me to the conclusion that ID_001006, ID_001007, and ID_000856 are likely not authentic to the dates that they bear on their face and in their metadata. H owever due to the lack of information I have referred to above, I am not able to be as confident in my findings as I have been in relation to other documents. Madden Appendix PM 22 “InterofficeMemoTemplates ” / ID_00 0856 Page 30of 30 C onclusion 71. In conclusion : a. I D_000856 and ID_001006 are both sourced from simi lar MS Word templates. b. Although they are dated to 2009 and 2011 respectively, I have not been able to find any instance of the template in question being available at any time before October 2012, when it was described by Microsoft as being “ New! ”. c. S imilar but slightly different templates have been produced since then and I was able to identify multiple versions for comparative review. In my opinion, based on a visual inspection ID_000856 and ID_001006 are both more consistent with the most recent version of the template than they are with the oldest version of the template. 72. The two PDF documents have been created in different ways: ID_001006 has been exported directly from MS Word, while ID_000856 has been printed, re- scanned to picture format, and then re -converted to PDF, leading to a loss of useful metadata for analysis, however: a. Wh at metadata does exist in the file is easily manipulable as I have demonstrated, and there are possible (although not conclusive) indications that the PDF may have be en edited after it was created . b. Viewed in the context of several other documents within the dataset having similar characteristics, ID_000856 is unique in that it is the only document which records “Lynn Wright” as its author, whereas the other documents (before and after it in time ) record “Admin” as their author . 73. This leads me to the conclusion that ID_001006, ID_001007, and ID_000856 are likely not authentic to the dates that they bear on their face and in their metadata. H owever due to the lack of information I have referred to above, I am not able to be as confident in my findings as I have been in relation to other documents. 30 - 30 - H/106/30{ID_000856} {ID_001006} {ID_000856} {ID_001006} {ID_001007} {ID_001006} {ID_000856}
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 13 of 13 Appendix PM22.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM22.pdf ### File content: PM 22 “InterofficeMemoTemplates ” / ID_00 0856 Page 29of 30 66. The only place I identified where ID_001006 was inconsistent with the current Office template was the text for the Address field “Cc:”. In ID_001006 it is listed as “cc:” which matches more closely the two older samples (which are in lowercase), while the current Office template features “Cc:”. This can however be easily adjusted simply by typing the letter “c” in lowercase. 67. Document ID_001006 also carries a metadata tag for the template filename that matches that downloaded from the MS Office Online res ource , “Interoffice Memo (Professional design).dotx”, which is consistent with the c urrent O ffice template file but not the other older templates that I was able to obtain. C omparative review with ID_000856 68. Turning to ID_000856, a similar analysis can be conduct ed – although it is more difficult to compare as it has been resized and has suffered some degradation. 69. Comparing the template files shown above to ID_000856, it can be observed that aside from the text in the dark box not needing to be wrapped (because the company name ‘Information Defense’ in shorter) , all of the similarities/ differences between the c urrent Office template and the two previous templates correlate with ID_000856 in the same manner as ID_001007. 70. Again , therefore, t his indicates that the general layout and structure of ID_000856 is more consistent with the current Office template tha n the sample templates dated 2012 and 2014. 29 - 29 - H/106/29{ID_001006} {ID_000856} {ID_001007} Madden Appendix PM 22 “InterofficeMemoTemplates ” / ID_00 0856 Page 30of 30 C onclusion 71. In conclusion : a. I D_000856 and ID_001006 are both sourced from simi lar MS Word templates. b. Although they are dated to 2009 and 2011 respectively, I have not been able to find any instance of the template in question being available at any time before October 2012, when it was described by Microsoft as being “ New! ”. c. S imilar but slightly different templates have been produced since then and I was able to identify multiple versions for comparative review. In my opinion, based on a visual inspection ID_000856 and ID_001006 are both more consistent with the most recent version of the template than they are with the oldest version of the template. 72. The two PDF documents have been created in different ways: ID_001006 has been exported directly from MS Word, while ID_000856 has been printed, re- scanned to picture format, and then re -converted to PDF, leading to a loss of useful metadata for analysis, however: a. Wh at metadata does exist in the file is easily manipulable as I have demonstrated, and there are possible (although not conclusive) indications that the PDF may have be en edited after it was created . b. Viewed in the context of several other documents within the dataset having similar characteristics, ID_000856 is unique in that it is the only document which records “Lynn Wright” as its author, whereas the other documents (before and after it in time ) record “Admin” as their author . 73. This leads me to the conclusion that ID_001006, ID_001007, and ID_000856 are likely not authentic to the dates that they bear on their face and in their metadata. H owever due to the lack of information I have referred to above, I am not able to be as confident in my findings as I have been in relation to other documents. Madden Appendix PM 22 “InterofficeMemoTemplates ” / ID_00 0856 Page 30of 30 C onclusion 71. In conclusion : a. I D_000856 and ID_001006 are both sourced from simi lar MS Word templates. b. Although they are dated to 2009 and 2011 respectively, I have not been able to find any instance of the template in question being available at any time before October 2012, when it was described by Microsoft as being “ New! ”. c. S imilar but slightly different templates have been produced since then and I was able to identify multiple versions for comparative review. In my opinion, based on a visual inspection ID_000856 and ID_001006 are both more consistent with the most recent version of the template than they are with the oldest version of the template. 72. The two PDF documents have been created in different ways: ID_001006 has been exported directly from MS Word, while ID_000856 has been printed, re- scanned to picture format, and then re -converted to PDF, leading to a loss of useful metadata for analysis, however: a. Wh at metadata does exist in the file is easily manipulable as I have demonstrated, and there are possible (although not conclusive) indications that the PDF may have be en edited after it was created . b. Viewed in the context of several other documents within the dataset having similar characteristics, ID_000856 is unique in that it is the only document which records “Lynn Wright” as its author, whereas the other documents (before and after it in time ) record “Admin” as their author . 73. This leads me to the conclusion that ID_001006, ID_001007, and ID_000856 are likely not authentic to the dates that they bear on their face and in their metadata. H owever due to the lack of information I have referred to above, I am not able to be as confident in my findings as I have been in relation to other documents. 30 - 30 - H/106/30{ID_000856} {ID_001006} {ID_000856} {ID_001006} {ID_001007} {ID_001006} {ID_000856}
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/content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf
Martti Malmi - Exhibits
part 17 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf
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load bitmaps from xpm instead of resources. There are debian packages available for some of the dependencies instead of having to compile them ourselves: apt-get install build-essential apt-get install libgtk2.0-dev apt-get install libssl-dev I need to see if Berkeley DB or Boost have packages. We'll shared-link OpenSSL, I'm pretty sure it's always preinstalled on Linux. GTK has to be shared linked. I'm not completely sure if it's preinstalled by default. SUBJECT : Re: Linux build FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 05/11/2009 05:31 I merged the linux changes into the main trunk on SVN. It compiles and runs now. I think all the problems are in the UI. The menus quickly quit working and it doesn't repaint when it's supposed to unless I resize it, and the UI is getting some segfaults. Shouldn't be too hard to debug with gdb. I haven't tested if it plays nice with other nodes yet so keep it off-net. build-unix.txt and makefile.unix added SUBJECT : Re: Proxy FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 05/11/2009 15:25 [email protected] wrote: > Enabling the proxy setting and restarting Bitcoin I got the first > connections in less than a minute and ultimately even 8 connections. I > wonder if they're all really through TOR. Netstat shows only 2 > connections to localhost:9050 and 7 connections from local port 8333 to > elsewhere. (Some of the shown connections may be already disconnected > ones.) For some reason there's no debug.log in the folder where I'm > running it. debug.log moved to the data directory "%appdata%/bitcoin/debug.log" 7 inbound and 2 outbound sounds about as expected. My last SVN commit included an overhaul of the code that selects the order of addresses to connect to, trying them in the order of most recently seen online, so it should get connected in a more reasonable amount of time if IRC is unavailable. IRC is really only needed to seed the first connection, but we've been using it as a crutch to get connected faster. >> If some nodes that accept incoming connects were willing to have their >> IP coded into the program, it could seed automatically. Or some IP >> seed addresses posted on a Wiki page with the instructions. > > The wiki page sounds like a good and quickly applicable solution. I > could keep my ip updated there and we could ask others to do the same. > When the Linux build works, it's easier to set up nodes on servers that > are online most of the time and have a static IP. A static ip list > shipped with Bitcoin and a peer exchange protocol would be cool. That > way there'd be no need for an IRC server. That would be great. It's only TOR users that need it, so in the instructions saying "bitcoin -proxy=127.0.0.1:9050 -addnode=<someip>", someip could be an actual static IP, with the wiki free-for-all add-your-ip list nearby or a link to it. There should be a link to that optional step, add your IP to this list now that you can accept incoming if you're static. Do you think anonymous people are looking to be completely stealth, as in never connect once without TOR so nobody knows they use bitcoin, or just want to switch to TOR before doing any transactions? It's just if you want to be completely stealth that you'd have to go through the -proxy -addnode manual seeding. It would be very easy to fumble that up; if you run bitcoin normally to begin with it immediately automatically starts connecting. SUBJECT : Forum FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 05/11/2009 17:33 Now that the forum on bitcoin.sourceforge.net is catching on, we really should look for somewhere that freehosts full blown forum software. The bitweaver forum feature is just too lightweight. I assume the "Forum" tab on the homepage can link out to wherever the forum is hosted. I've seen projects that have major following just from forum talk and pie-in-the-sky planning without even having any code yet. Having a lot of forum talk gives a project more presence on the net, more search hits, makes it look big, draws new users in, helps solve support questions, hashes out what features are most of wanted. It would be a big plus if it could support SSL, at least for the login page if not sitewide. Multiple people on the forum have expressed interest in TOR/I2P, and those users need SSL because a lot of TOR exit nodes are probably password scrapers run by identity thieves. A lot of the core interest in Bitcoin is going to be from the privacy crowd. Any ideas where we can get a free forum? Maybe we should look at where some other projects have their forums hosted for ideas where to look. SUBJECT : Re: Linux build FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 06/11/2009 06:20 It works reliably on Linux now, except if it uses wxMessageBox() outside the GUI thread, it'll crash because non-GUI threads can't open a window on Linux. I haven't got to fixing that yet. I've been running my stress test on it and it's functioning normally. Most of wxWidgets is not thread-safe to use in threads other than the UI thread, but as a rule of thumb on Windows anything not UI related is OK. It turns out its more thread-unsafe on GTK. I replaced a bunch of stuff at once so I don't know if it was just one thing (probably Repaint), but I have to assume even any wx function that uses wxString is not safe to use outside the UI thread. So dang, there goes all the nice wxWidgets portability support functions. I left a few simple things like wxThread::GetCPUCount() that I checked the source and it's all numerical, and wxMutex has to be safe or it'd be useless. There's an issue that if you exit and run it again right away, it can't bind port 8333. The port frees
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 17 of 44 Martti Malmi - Exhibit MM1 - SN to MM.pdf ### Folder name: Martti Malmi - Exhibits ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Martti Malmi - Exhibits/Martti Malmi - Exhibit MM1 - SN to MM.pdf ### File content: load bitmaps from xpm instead of resources. There are debian packages available for some of the dependencies instead of having to compile them ourselves: apt-get install build-essential apt-get install libgtk2.0-dev apt-get install libssl-dev I need to see if Berkeley DB or Boost have packages. We'll shared-link OpenSSL, I'm pretty sure it's always preinstalled on Linux. GTK has to be shared linked. I'm not completely sure if it's preinstalled by default. SUBJECT : Re: Linux build FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 05/11/2009 05:31 I merged the linux changes into the main trunk on SVN. It compiles and runs now. I think all the problems are in the UI. The menus quickly quit working and it doesn't repaint when it's supposed to unless I resize it, and the UI is getting some segfaults. Shouldn't be too hard to debug with gdb. I haven't tested if it plays nice with other nodes yet so keep it off-net. build-unix.txt and makefile.unix added SUBJECT : Re: Proxy FROM: Satoshi Nakamoto <[email protected]> TO: [email protected] DATE: 05/11/2009 15:25 [email protected] wrote: > Enabling the proxy setting and restarting Bitcoin I got the first > connections in less than a minute and ultimately even 8 connections. I > wonder if they're all really through TOR. Netstat shows only 2 > connections to localhost:9050 and 7 connections from local port 8333 to > elsewhere. (Some of the shown connections may be already disconnected > ones.) For some reason there's no debug.log in the folder where I'm > running it. debug.log moved to the data directory "%appdata%/bitcoin/debug.log" 7 inbound and 2 outbound sounds about as expected. My last SVN commit included an overhaul of the code that selects the order of addresses to connect to, trying them in the order of most recently seen online, so it should get connected in a more reasonable amount of time if IRC is unavailable. IRC is really only needed to seed the first connection, but we've been using it as a crutch to get connected faster. >> If some nodes that accept incoming connects were willing to have their >> IP coded into the program, it could seed automatically. Or some IP >> seed addresses posted on a Wiki page with the instructions. > > The wiki page sounds like a good and quickly applicable solution. I > could keep my ip updated there and we could ask others to do the same. > When the Linux build works, it's easier to set up nodes on servers that > are online most of the time and have a static IP. A static ip list > shipped with Bitcoin and a peer exchange protocol would be cool. That > way there'd be no need for an IRC server. That would be great. It's only TOR users that need it, so in the instructions saying "bitcoin -proxy=127.0.0.1:9050 -addnode=<someip>", someip could be an actual static IP, with the wiki free-for-all add-your-ip list nearby or a link to it. There should be a link to that optional step, add your IP to this list now that you can accept incoming if you're static. Do you think anonymous people are looking to be completely stealth, as in never connect once without TOR so nobody knows they use bitcoin, or just want to switch to TOR before doing any transactions? It's just if you want to be completely stealth that you'd have to go through the -proxy -addnode manual seeding. It would be very easy to fumble that up; if you run bitcoin normally to begin with it immediately automatically starts connecting. SUBJECT : Forum FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 05/11/2009 17:33 Now that the forum on bitcoin.sourceforge.net is catching on, we really should look for somewhere that freehosts full blown forum software. The bitweaver forum feature is just too lightweight. I assume the "Forum" tab on the homepage can link out to wherever the forum is hosted. I've seen projects that have major following just from forum talk and pie-in-the-sky planning without even having any code yet. Having a lot of forum talk gives a project more presence on the net, more search hits, makes it look big, draws new users in, helps solve support questions, hashes out what features are most of wanted. It would be a big plus if it could support SSL, at least for the login page if not sitewide. Multiple people on the forum have expressed interest in TOR/I2P, and those users need SSL because a lot of TOR exit nodes are probably password scrapers run by identity thieves. A lot of the core interest in Bitcoin is going to be from the privacy crowd. Any ideas where we can get a free forum? Maybe we should look at where some other projects have their forums hosted for ideas where to look. SUBJECT : Re: Linux build FROM: Satoshi Nakamoto <[email protected]> TO: Martti Malmi <[email protected]> DATE: 06/11/2009 06:20 It works reliably on Linux now, except if it uses wxMessageBox() outside the GUI thread, it'll crash because non-GUI threads can't open a window on Linux. I haven't got to fixing that yet. I've been running my stress test on it and it's functioning normally. Most of wxWidgets is not thread-safe to use in threads other than the UI thread, but as a rule of thumb on Windows anything not UI related is OK. It turns out its more thread-unsafe on GTK. I replaced a bunch of stuff at once so I don't know if it was just one thing (probably Repaint), but I have to assume even any wx function that uses wxString is not safe to use outside the UI thread. So dang, there goes all the nice wxWidgets portability support functions. I left a few simple things like wxThread::GetCPUCount() that I checked the source and it's all numerical, and wxMutex has to be safe or it'd be useless. There's an issue that if you exit and run it again right away, it can't bind port 8333. The port frees
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Openings
part 47 of 51 COPA v Wright - Opening Skeleton of COPA.pdf
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in disclosure (e.g. {L1/101/1} ). 105 each other. The detailed budget cites the third phase as final and includes no costing for the supposed fourth phase. Supposed C ollaboration with Prof Wrightson and Dr Furche 267. Dr Wright’s false account of collaboration with Prof Wrightson and Dr Furche during his MStat course at Newcastle University (NSW) is another striking example. In his “Fully Peer-to-Peer ” blogpost of June 2019,442 he said that studying at this university gave him access to people deeply versed in monetary systems, notably Prof Wrightson and Dr Furche. He says that Prof Wrightson knew about Wei Dai’s work, while Dr Furche put him onto Hal Finney and Adam Back. He claims that their research group had a lot of resources and that he read their patents and papers on transfer instruments (hyperlinking a 1988 patent paper). 268. This account is riddled with falsehoods. Based on the evidence of Prof Wrightson and Dr (now Prof) Furche, they had both left the University and the research group cited had ceased working some years before Dr Wright’s arrival and his claimed dealings with them.443 Prof Wrightson does not know of Wei Dai, while Prof Furche has never heard of Adam Back .444 Their research group at the University did not have the suggested resources, had never lodged a patent application and had no connection to the paper hyperlinked to Dr Wright’s post.445 In addition, neither has any recollection of coming across Dr Wright at the University. Finally, the real Satoshi cannot have had these rewarding discussions about Wei Dai with Prof Wrightson in 2005 -2009 because (as pointed out above) Satoshi did not know about Wei Dai’s work until directed to it by Adam Back in August 2008. Early Events in the History of Bitcoin 269. Patch Tuesday : In a blog post of 6 April 2019446 (and in other public statements447), Dr Wright has claimed that Microsoft Patch Tuesday (the monthly issuing of software patches) caused a shut-down of the Bitcoin network directly after the creation of the 442 {L15/88/2} . 443 Furche 1, §§4-8 {C/13/2} and §§27 -31 {C/13/6} ; Wrightson email at {C/18/11} . 444 Furche 1, §§36- 38 {C/13/7} ; Wrightson email at {C/18/11} . 445 Furche 1, §§40-42 {C/13/8} ; Wrightson email at {C/18/11} . 446 “Two steps forward, one step back ” 6 April 2019 {L14/420/2} . 447 “Dr Craig Wright explains the origins of Bitcoin ” 24 April 2019 {O4/25/25} ; “Coingeek Toronto Fireside Chat ” 19 June 2019 {O4/12/14} ; “Satoshi’s Vision” (June 2019 book) {L15/96/14} . 106 Genesis block (which was on 3 January 2009) . He has claimed that he addressed this by building a domain in the week between 3 and 10 January 2009. The problem with this story is that, in January 2009, Microsoft Patch Tuesday was on 13 January .448 270. Upload.ae : In an email from Satoshi to Wei Dai on 22 August 2008 which has long been public ,449 Satoshi told him that he could download a pre-release draft from an “upload.ae ” address. Dr Wright has tried to appropriate this detail as part of his narrative, by saying repeatedly that this was a site he had and operated in Melbourne.450 In Wright 4, answering RFI questions, he says: “I also operated a secondary server in Melbourne, known as upload.ae, to mirror some of the directories. ” In fact, upload.ae was a free file hosting service451 that was owned in 2009 by one Faisal Al Khaja.452 271. Satoshi’s Bitcoin transactions : In his interview with GQ in late April 2019, Dr Wright was asked if he had moved any bitcoins from the early blocks linked to Satoshi. He replied: “I haven’t moved them. I have sent them to Hal Finney and Zooko [Wilcox O’Hearn], and that was it. Full stop.”453 It is well-known that Satoshi sent Bitcoin to Mr Finney, but the statement was otherwise wrong. First, Mr Wilcox -O’Hearn , who is credited with having written the first blog post about Bitcoin, did not receive any Bitcoin from Satoshi . He points out that even though he had blogged about Bitcoin, he did not actually use it until years later.454 Secondly, Satoshi sent 100 bitcoin, unsolicited, to Nicholas Bohm .455 That was not a matter of public knowledge before exchange of evidence in these proceedings, which explains Dr Wright’s omission. Satoshi also sent 32.51 and 50 Bitcoin to Mike Hearn on 18 April 2009.456 272. Bitcoin described as a cryptocurrency : Dr Wright insists that Bitcoin is not a cryptocurrency and that it is wrong to describe it as such. He pleads that point in his Defence457 and he makes it in his first statement in the BTC Core Claim.458 He insisted 448 See for instance the following articles: {L4/60/1} ; {L4/262/1} ; {L18/316/1} . 449 {L3/195/1 }. 450 See “Coingeek Toronto Fireside Chat ” 19 June 2019 {O4/12/6} ; Dr Wright’s Kleiman trial evidence on 22 November 2021, internal p99-100 {P/10/99} . 451 {L3/191/1} . 452 {L17/379/21} . 453 See transcript at {O4/23/5} . 454 Wilcox -O’Hearn §§7-8 {C/6/3} . 455 Bohm §15 {C/10/4} . 456 {D/505/08} . 457 Defence at §78 {A/3/23} . 458 Wright 1 in BTC Core at §49(6) {E1/1/13} . 107 upon it in his evidence in Granath459 and McCormack,460 and has made the point in postings repeatedly and with vehemence.461 This is part of his effort to challenge features of Bitcoin Core and promote BSV. However, since taking this line in public, he
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 47 of 51 COPA v Wright - Opening Skeleton of COPA.pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/COPA v Wright - Opening Skeleton of COPA.pdf ### File content: in disclosure (e.g. {L1/101/1} ). 105 each other. The detailed budget cites the third phase as final and includes no costing for the supposed fourth phase. Supposed C ollaboration with Prof Wrightson and Dr Furche 267. Dr Wright’s false account of collaboration with Prof Wrightson and Dr Furche during his MStat course at Newcastle University (NSW) is another striking example. In his “Fully Peer-to-Peer ” blogpost of June 2019,442 he said that studying at this university gave him access to people deeply versed in monetary systems, notably Prof Wrightson and Dr Furche. He says that Prof Wrightson knew about Wei Dai’s work, while Dr Furche put him onto Hal Finney and Adam Back. He claims that their research group had a lot of resources and that he read their patents and papers on transfer instruments (hyperlinking a 1988 patent paper). 268. This account is riddled with falsehoods. Based on the evidence of Prof Wrightson and Dr (now Prof) Furche, they had both left the University and the research group cited had ceased working some years before Dr Wright’s arrival and his claimed dealings with them.443 Prof Wrightson does not know of Wei Dai, while Prof Furche has never heard of Adam Back .444 Their research group at the University did not have the suggested resources, had never lodged a patent application and had no connection to the paper hyperlinked to Dr Wright’s post.445 In addition, neither has any recollection of coming across Dr Wright at the University. Finally, the real Satoshi cannot have had these rewarding discussions about Wei Dai with Prof Wrightson in 2005 -2009 because (as pointed out above) Satoshi did not know about Wei Dai’s work until directed to it by Adam Back in August 2008. Early Events in the History of Bitcoin 269. Patch Tuesday : In a blog post of 6 April 2019446 (and in other public statements447), Dr Wright has claimed that Microsoft Patch Tuesday (the monthly issuing of software patches) caused a shut-down of the Bitcoin network directly after the creation of the 442 {L15/88/2} . 443 Furche 1, §§4-8 {C/13/2} and §§27 -31 {C/13/6} ; Wrightson email at {C/18/11} . 444 Furche 1, §§36- 38 {C/13/7} ; Wrightson email at {C/18/11} . 445 Furche 1, §§40-42 {C/13/8} ; Wrightson email at {C/18/11} . 446 “Two steps forward, one step back ” 6 April 2019 {L14/420/2} . 447 “Dr Craig Wright explains the origins of Bitcoin ” 24 April 2019 {O4/25/25} ; “Coingeek Toronto Fireside Chat ” 19 June 2019 {O4/12/14} ; “Satoshi’s Vision” (June 2019 book) {L15/96/14} . 106 Genesis block (which was on 3 January 2009) . He has claimed that he addressed this by building a domain in the week between 3 and 10 January 2009. The problem with this story is that, in January 2009, Microsoft Patch Tuesday was on 13 January .448 270. Upload.ae : In an email from Satoshi to Wei Dai on 22 August 2008 which has long been public ,449 Satoshi told him that he could download a pre-release draft from an “upload.ae ” address. Dr Wright has tried to appropriate this detail as part of his narrative, by saying repeatedly that this was a site he had and operated in Melbourne.450 In Wright 4, answering RFI questions, he says: “I also operated a secondary server in Melbourne, known as upload.ae, to mirror some of the directories. ” In fact, upload.ae was a free file hosting service451 that was owned in 2009 by one Faisal Al Khaja.452 271. Satoshi’s Bitcoin transactions : In his interview with GQ in late April 2019, Dr Wright was asked if he had moved any bitcoins from the early blocks linked to Satoshi. He replied: “I haven’t moved them. I have sent them to Hal Finney and Zooko [Wilcox O’Hearn], and that was it. Full stop.”453 It is well-known that Satoshi sent Bitcoin to Mr Finney, but the statement was otherwise wrong. First, Mr Wilcox -O’Hearn , who is credited with having written the first blog post about Bitcoin, did not receive any Bitcoin from Satoshi . He points out that even though he had blogged about Bitcoin, he did not actually use it until years later.454 Secondly, Satoshi sent 100 bitcoin, unsolicited, to Nicholas Bohm .455 That was not a matter of public knowledge before exchange of evidence in these proceedings, which explains Dr Wright’s omission. Satoshi also sent 32.51 and 50 Bitcoin to Mike Hearn on 18 April 2009.456 272. Bitcoin described as a cryptocurrency : Dr Wright insists that Bitcoin is not a cryptocurrency and that it is wrong to describe it as such. He pleads that point in his Defence457 and he makes it in his first statement in the BTC Core Claim.458 He insisted 448 See for instance the following articles: {L4/60/1} ; {L4/262/1} ; {L18/316/1} . 449 {L3/195/1 }. 450 See “Coingeek Toronto Fireside Chat ” 19 June 2019 {O4/12/6} ; Dr Wright’s Kleiman trial evidence on 22 November 2021, internal p99-100 {P/10/99} . 451 {L3/191/1} . 452 {L17/379/21} . 453 See transcript at {O4/23/5} . 454 Wilcox -O’Hearn §§7-8 {C/6/3} . 455 Bohm §15 {C/10/4} . 456 {D/505/08} . 457 Defence at §78 {A/3/23} . 458 Wright 1 in BTC Core at §49(6) {E1/1/13} . 107 upon it in his evidence in Granath459 and McCormack,460 and has made the point in postings repeatedly and with vehemence.461 This is part of his effort to challenge features of Bitcoin Core and promote BSV. However, since taking this line in public, he
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does not appear in the L bundles. 255 Wright v McCormack [2023] EWHC 1030 at [5]. 75 a) On 22 January 2022, Bird & Bird were named and criticised on Dr Wright’s same Slack Channel: “Basically, one lying scumbag defendant has made a statement and it must be true because the other lying scumbaag [sic] defendant and others in the other cases that are being represented by totally dishonest and disingenuous law firm Bird & Bird have stated that they are honest because dishonest people lie about other dishonest people that makes sense doesn’t it?”256 b) Subsequently, on 27 January 2022, Dr Wright personally attacked a Partner at Bird & Bird: “9:00 Daily reminder, Ms Sophie Eyre of Bird & Bird is a promoter and supporter of fraud who used lies created by her own clients to support lies and fraud created and propagated by her criminal clients.” “9:01 She misleads the court and should be struck off as a solicitor. She holds the law, judges and court in utter contempt.” “9:03 Bird & Bird active in the deception and take money to lie, defraud and promote bold statements in court.”257 c) Whilst the above comments were all posted on Dr Wright’s private Slack Channel, he had no qualms about their further reach, and asked his followers to share his posts, but making clear that they were Dr Wright’s own opinion, presumably in light of his knowledge of defamation law: “9:16 Feel free to post on Twitter the statement I made, reporting, not your opinion. “9:17 Just because Ms Eyre is a lying scumbag does not mean you need to be an easy target for this bully and contemnor”.258 154. Steve Lee has set out his understanding that multiple developers, including Greg Maxwell, have stopped contributing to Bitcoin entirely following Dr Wright’s lawsuits.259 Dr Wright has personally targeted Greg Maxwell on numerous occasions; a selection of which are below: a) On 26 August 2019, Dr Wright published ‘Satoshi’s Vision’, in which he wrote:260 “Let’s have a look at some of the key detractors. Greg Maxwell [D12] was involved in anti-sec and helped with the theft of thousands of copyrighted documents and other intellectual property. He broke into computer systems and altered records and released this stolen information to the world….” 256 {L/17/53/1798}. 257 {L17/53/1798}. 258 {L/17/53/1800}. 259 Lee1¶20.c. {C/12/9}. 260 {L15/200/153}. 76 b) 13 August 2021:261 On his Slack Channel, Dr Wright posted: “How do you think Gregory Maxwell will handle all of the things our private investigators already know about him? Then, when this goes to court, if he opposes anything, it all goes out.” … “even what I know about Mr Greggles now, though it would be so interesting to release it all – but these things are only done after people don’t comply with court orders…. c) On 4 January 2022:262 “Yes, BTC will learn, adding Greg’s plagiarism of my work (irony on his claims) has grave consequences” d) On 21 July 2023, Dr Wright posted on his Slack Channel: “I don’t want to go after Greg Maxwell for defamation. I want to go up to misrepresentation and fraud. I want to push criminal charges with Mr Maxwell. Greg needs to face criminal charges like his deceased scumbag friend from Reddit, the one he helped steal material from JSTOR. I don’t want to see Mr Maxwell charged with mere civil charges. I want to him in prison, and when I’m done with him, he will be.”263 155. Mr Lee has explained the impact this has on ongoing work with Bitcoin; when software developers no longer contribute, it inevitably impacts the development of that software.264 He cites former Core Maintainers who have stepped down by reason of the ongoing and continued threat of litigation, which CoinGeek, a prominent supporter of Dr Wright, has cited as a reason in their own reporting on the developers stepping back. 265 It is not a stretch to say that Dr Wright intends his threats to be taken seriously. 156. Further, Dr Wright has publicly threatened graphic and extreme violence against his critics. These are no laughing matter. a) On 22 November 2018,266 Dr Wright crashed a ‘Hash Wars Live’ Live Stream hosted by KeyPort Live, a YouTuber with a channel called ‘Decentralised Live’. Dr Wright joined the stream and engaged in a 261 {L17/53/1290}. 262 {L17/53/1668}. 263 {L18/482/15}. 264 Lee1¶¶21,22{C/12/9}. 265 Lee1¶¶20.a, 20.b., 20.d {C/12/7-9}. 266 {L20/131/1}. 77 discussion about ABC and BSV. During this conversation, Dr Wright was asked about various different Bitcoin forks, and said inter alia as follows. In the passages below, “them” is understood to be a reference to those working on non BSV Bitcoin systems: 16:10: “We don’t want a quick war…. I want to burn them to fucking shit” 16:24 “I want them fucking broke.” 16:28 “I want them to burn everything they own” 17:17 “9/10 exchanges are illegal. They’re criminal activities that should be fucking burnt to the ground” 29:35 DC: [In a discussion about historic thoughts on the debate] “Before that, it was just like “slit their throats” CSW: “Oh we’re going to. You seem to think that means I have to do it now. … I’ve actually said 2 months ago I wanted to bleed Jihan [Understood to be a reference to Jihan Wu, the then CTO of Blockmain]. Do you understand what that means? I want to string him up and rip him out”. 32:07 “I want to bleed people… I want to cause him pain” b) On 6 October 2022, Dr Wright posted a photograph of someone falling from a high tower, with the caption: “Defenestrated. This word details what is about to happen to those who sought to grab power and
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 29 of 37 Developers' Skeleton Argument IL-2022-000069 (Trial commencing 5 February 2024).pdf ### Folder name: Openings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Openings/Developers' Skeleton Argument IL-2022-000069 (Trial commencing 5 February 2024).pdf ### File content: does not appear in the L bundles. 255 Wright v McCormack [2023] EWHC 1030 at [5]. 75 a) On 22 January 2022, Bird & Bird were named and criticised on Dr Wright’s same Slack Channel: “Basically, one lying scumbag defendant has made a statement and it must be true because the other lying scumbaag [sic] defendant and others in the other cases that are being represented by totally dishonest and disingenuous law firm Bird & Bird have stated that they are honest because dishonest people lie about other dishonest people that makes sense doesn’t it?”256 b) Subsequently, on 27 January 2022, Dr Wright personally attacked a Partner at Bird & Bird: “9:00 Daily reminder, Ms Sophie Eyre of Bird & Bird is a promoter and supporter of fraud who used lies created by her own clients to support lies and fraud created and propagated by her criminal clients.” “9:01 She misleads the court and should be struck off as a solicitor. She holds the law, judges and court in utter contempt.” “9:03 Bird & Bird active in the deception and take money to lie, defraud and promote bold statements in court.”257 c) Whilst the above comments were all posted on Dr Wright’s private Slack Channel, he had no qualms about their further reach, and asked his followers to share his posts, but making clear that they were Dr Wright’s own opinion, presumably in light of his knowledge of defamation law: “9:16 Feel free to post on Twitter the statement I made, reporting, not your opinion. “9:17 Just because Ms Eyre is a lying scumbag does not mean you need to be an easy target for this bully and contemnor”.258 154. Steve Lee has set out his understanding that multiple developers, including Greg Maxwell, have stopped contributing to Bitcoin entirely following Dr Wright’s lawsuits.259 Dr Wright has personally targeted Greg Maxwell on numerous occasions; a selection of which are below: a) On 26 August 2019, Dr Wright published ‘Satoshi’s Vision’, in which he wrote:260 “Let’s have a look at some of the key detractors. Greg Maxwell [D12] was involved in anti-sec and helped with the theft of thousands of copyrighted documents and other intellectual property. He broke into computer systems and altered records and released this stolen information to the world….” 256 {L/17/53/1798}. 257 {L17/53/1798}. 258 {L/17/53/1800}. 259 Lee1¶20.c. {C/12/9}. 260 {L15/200/153}. 76 b) 13 August 2021:261 On his Slack Channel, Dr Wright posted: “How do you think Gregory Maxwell will handle all of the things our private investigators already know about him? Then, when this goes to court, if he opposes anything, it all goes out.” … “even what I know about Mr Greggles now, though it would be so interesting to release it all – but these things are only done after people don’t comply with court orders…. c) On 4 January 2022:262 “Yes, BTC will learn, adding Greg’s plagiarism of my work (irony on his claims) has grave consequences” d) On 21 July 2023, Dr Wright posted on his Slack Channel: “I don’t want to go after Greg Maxwell for defamation. I want to go up to misrepresentation and fraud. I want to push criminal charges with Mr Maxwell. Greg needs to face criminal charges like his deceased scumbag friend from Reddit, the one he helped steal material from JSTOR. I don’t want to see Mr Maxwell charged with mere civil charges. I want to him in prison, and when I’m done with him, he will be.”263 155. Mr Lee has explained the impact this has on ongoing work with Bitcoin; when software developers no longer contribute, it inevitably impacts the development of that software.264 He cites former Core Maintainers who have stepped down by reason of the ongoing and continued threat of litigation, which CoinGeek, a prominent supporter of Dr Wright, has cited as a reason in their own reporting on the developers stepping back. 265 It is not a stretch to say that Dr Wright intends his threats to be taken seriously. 156. Further, Dr Wright has publicly threatened graphic and extreme violence against his critics. These are no laughing matter. a) On 22 November 2018,266 Dr Wright crashed a ‘Hash Wars Live’ Live Stream hosted by KeyPort Live, a YouTuber with a channel called ‘Decentralised Live’. Dr Wright joined the stream and engaged in a 261 {L17/53/1290}. 262 {L17/53/1668}. 263 {L18/482/15}. 264 Lee1¶¶21,22{C/12/9}. 265 Lee1¶¶20.a, 20.b., 20.d {C/12/7-9}. 266 {L20/131/1}. 77 discussion about ABC and BSV. During this conversation, Dr Wright was asked about various different Bitcoin forks, and said inter alia as follows. In the passages below, “them” is understood to be a reference to those working on non BSV Bitcoin systems: 16:10: “We don’t want a quick war…. I want to burn them to fucking shit” 16:24 “I want them fucking broke.” 16:28 “I want them to burn everything they own” 17:17 “9/10 exchanges are illegal. They’re criminal activities that should be fucking burnt to the ground” 29:35 DC: [In a discussion about historic thoughts on the debate] “Before that, it was just like “slit their throats” CSW: “Oh we’re going to. You seem to think that means I have to do it now. … I’ve actually said 2 months ago I wanted to bleed Jihan [Understood to be a reference to Jihan Wu, the then CTO of Blockmain]. Do you understand what that means? I want to string him up and rip him out”. 32:07 “I want to bleed people… I want to cause him pain” b) On 6 October 2022, Dr Wright posted a photograph of someone falling from a high tower, with the caption: “Defenestrated. This word details what is about to happen to those who sought to grab power and
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Closings
part 54 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf
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where I had to breach and work out how to get into the WiFi. We were given a red team/blue team scenario and this was my paper done during that examination, which I subsequently passed. Q. You're aware, aren't you, that Mr Madden has found that this file was created with a version of Windows which was the May 2020 update? A. I've seen his notification of the versioning, yes. Q. Is that a finding you accept? A. I'm saying now it could be possible. It's actually feasible that people could have been on that drive. Q. Ah, so the fact that this was shown as created with a version of Windows which was the 2020 update is down to Mr Ager - Hanssen's hack? A. That's the only explanation I can give you. What I do know is he accessed that drive. I led myself to believe that he wouldn't be able to, and obviously, if there are files on a computer displayed on the internet that are mine, I have to accept it. Dr Wright blaming third parties (Christen Ager -Hanssen) for hacking his drive and forging The King2.rtf document. {ID_004715} NG3.tex {Day5/81:17} - {Day5/82:6} Q. You could look at the documents, couldn't you? A. Yes. Q. So, looking at the documents, you didn't notice anything wrong with any of them? A. No, I didn't. Q. Back to {L1/175/1} {PTR -F/72/1}, which is the document. Now, Mr Madden made a finding that there was a previous version of this document on InfoDef09. raw which showed various changes. You're aware of that, aren't you? Dr Wright disagreeing with both experts as to the order in which InfoDef09.raw and the BDO image were created. Appendix B: Schedule of Transcript References 135 REFERENCE QUOTE COMMENT A. Again, I would say it's the other way round. I would say that there is a changed version of this document on InfoDef09.raw. If you actually look at it - - and if I had the drive, I'd a nalyse it properly - - I think you'll find that InfoDef09.raw is copied after the BDO Drive. {Day5/82:20} - {Day5/84:17} Q. So what I suggest to you is that these are very clear indications of a document which refers to Bitcoin as an existing system being modified to look like something looking at a Hashcoin system to support your case. A. No, I'd actually say it's the othe r way round. What it is is someone trying to ensure that there is manipulated evidence on these drives because of my own hubris not believing it. Even having, on an external drive, a 2008 copy of a file would support my claim. So, your argument on being a deleted version, etc, if that hadn't been manipulated more, that would be supportive itself. Now, the BDO Drive would be updated the other way, effectively, which could be easily checked, and the problem is neither expert has actually checked this, they've made a presumption without validation. Q. So you say that Mr Ager - Hanssen - - we'll come back to what the experts did in a moment, but you say that Mr Ager - Hanssen and his team of hackers, whoever they were, manipulated documents in order to seed the m onto InfoDef09.raw with the hope that COPA and the developers would gain access to the drive, find them and finger you as a forger, yes? A. I think -- Q. That's your hypothesis? A. No, actually, it isn't a hypothesis. One of the things I disclosed to my lawyers was, some of the files that I'd given to Christen Ager - Hanssen, including PDF files, had a web cookie, my Lord. A web cookie calls a web server or IP address when logged. I have a web server running that these files log from. I can't say how, but they recorded, in 2016 - - sorry, September last year, Bird & Bird's IP address. I notified both Travers Smith and other solicitors of this. Q. I'm sorry, what are you suggesting this indicates, Dr Wright? A. I don't actually know, because they've go t an open WiFi, so it can't say that it's them. Someone could have stood outside their office, Mr Ager - Hanssen could likely have actually done that to try and implicate them some way. What I do know is Mr Ager - Hanssen is playing a game that I don't understand. Q. I'm going to put to you, first of all, Dr Wright, that Bird & Bird don't have an open WiFi, do they? I'm putting that on pretty clear instructions. Dr Wright blaming third parties (Bird & Bird, Travers Smith, Ager - Hanssen) for conspiring to compromise the BDO Drive. Appendix B: Schedule of Transcript References 136 REFERENCE QUOTE COMMENT A. I haven't checked their WiFi. Q. And this is yet another, and may I suggest somewhat scand alous, embellishment to your tale. A. No, it's not. It actually happened, and I did report it. {L1/183} - ID_004719 - LaTeX Timecoin fragment {Day5/86:3} - {Day5/86:9} Q. And that's a clear sign that you forged this document, isn't it? A. No, actually, it's not. Even if there was an alternative document with that information, that wouldn't show any forgery, or anything like this. None of that demonstrates what you're saying. What it does say is that someone was trying to access my drive. Dr Wright blaming third parties, saying that “someone” tried to access his drive. {Day5/88:19} - {Day5/88:22} Q. But Dr Wright, it’s odd, i sn’t it, when you’re writing an academic piece, to give a reference to a paper but then not include the date, or a citation and put a question mark? That’s unusual, isn’t it? A. No, actually, generally, now, because I use APA more than anything else, at 7, I do “N.D” for “no date”, but when writing, until I’ve actually figured out what the date is, I will put something in there. Dr Wright is evasive regarding the acronyms used on a document and his writing style. {Day5/89:2} - {Day5/89:15} Q. Dr Wright, it isn't the case, is it, that Mr Ager - Hanssen got strikingly lucky here, this is another sign of forgery by you, isn't it? A. No, he didn't get lucky. It turns out that he'd been actually monitoring my computer for months, including all of my emails, all of my communications, all of my WhatsApp. He had basically been screenshotting
1,077
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 54 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: where I had to breach and work out how to get into the WiFi. We were given a red team/blue team scenario and this was my paper done during that examination, which I subsequently passed. Q. You're aware, aren't you, that Mr Madden has found that this file was created with a version of Windows which was the May 2020 update? A. I've seen his notification of the versioning, yes. Q. Is that a finding you accept? A. I'm saying now it could be possible. It's actually feasible that people could have been on that drive. Q. Ah, so the fact that this was shown as created with a version of Windows which was the 2020 update is down to Mr Ager - Hanssen's hack? A. That's the only explanation I can give you. What I do know is he accessed that drive. I led myself to believe that he wouldn't be able to, and obviously, if there are files on a computer displayed on the internet that are mine, I have to accept it. Dr Wright blaming third parties (Christen Ager -Hanssen) for hacking his drive and forging The King2.rtf document. {ID_004715} NG3.tex {Day5/81:17} - {Day5/82:6} Q. You could look at the documents, couldn't you? A. Yes. Q. So, looking at the documents, you didn't notice anything wrong with any of them? A. No, I didn't. Q. Back to {L1/175/1} {PTR -F/72/1}, which is the document. Now, Mr Madden made a finding that there was a previous version of this document on InfoDef09. raw which showed various changes. You're aware of that, aren't you? Dr Wright disagreeing with both experts as to the order in which InfoDef09.raw and the BDO image were created. Appendix B: Schedule of Transcript References 135 REFERENCE QUOTE COMMENT A. Again, I would say it's the other way round. I would say that there is a changed version of this document on InfoDef09.raw. If you actually look at it - - and if I had the drive, I'd a nalyse it properly - - I think you'll find that InfoDef09.raw is copied after the BDO Drive. {Day5/82:20} - {Day5/84:17} Q. So what I suggest to you is that these are very clear indications of a document which refers to Bitcoin as an existing system being modified to look like something looking at a Hashcoin system to support your case. A. No, I'd actually say it's the othe r way round. What it is is someone trying to ensure that there is manipulated evidence on these drives because of my own hubris not believing it. Even having, on an external drive, a 2008 copy of a file would support my claim. So, your argument on being a deleted version, etc, if that hadn't been manipulated more, that would be supportive itself. Now, the BDO Drive would be updated the other way, effectively, which could be easily checked, and the problem is neither expert has actually checked this, they've made a presumption without validation. Q. So you say that Mr Ager - Hanssen - - we'll come back to what the experts did in a moment, but you say that Mr Ager - Hanssen and his team of hackers, whoever they were, manipulated documents in order to seed the m onto InfoDef09.raw with the hope that COPA and the developers would gain access to the drive, find them and finger you as a forger, yes? A. I think -- Q. That's your hypothesis? A. No, actually, it isn't a hypothesis. One of the things I disclosed to my lawyers was, some of the files that I'd given to Christen Ager - Hanssen, including PDF files, had a web cookie, my Lord. A web cookie calls a web server or IP address when logged. I have a web server running that these files log from. I can't say how, but they recorded, in 2016 - - sorry, September last year, Bird & Bird's IP address. I notified both Travers Smith and other solicitors of this. Q. I'm sorry, what are you suggesting this indicates, Dr Wright? A. I don't actually know, because they've go t an open WiFi, so it can't say that it's them. Someone could have stood outside their office, Mr Ager - Hanssen could likely have actually done that to try and implicate them some way. What I do know is Mr Ager - Hanssen is playing a game that I don't understand. Q. I'm going to put to you, first of all, Dr Wright, that Bird & Bird don't have an open WiFi, do they? I'm putting that on pretty clear instructions. Dr Wright blaming third parties (Bird & Bird, Travers Smith, Ager - Hanssen) for conspiring to compromise the BDO Drive. Appendix B: Schedule of Transcript References 136 REFERENCE QUOTE COMMENT A. I haven't checked their WiFi. Q. And this is yet another, and may I suggest somewhat scand alous, embellishment to your tale. A. No, it's not. It actually happened, and I did report it. {L1/183} - ID_004719 - LaTeX Timecoin fragment {Day5/86:3} - {Day5/86:9} Q. And that's a clear sign that you forged this document, isn't it? A. No, actually, it's not. Even if there was an alternative document with that information, that wouldn't show any forgery, or anything like this. None of that demonstrates what you're saying. What it does say is that someone was trying to access my drive. Dr Wright blaming third parties, saying that “someone” tried to access his drive. {Day5/88:19} - {Day5/88:22} Q. But Dr Wright, it’s odd, i sn’t it, when you’re writing an academic piece, to give a reference to a paper but then not include the date, or a citation and put a question mark? That’s unusual, isn’t it? A. No, actually, generally, now, because I use APA more than anything else, at 7, I do “N.D” for “no date”, but when writing, until I’ve actually figured out what the date is, I will put something in there. Dr Wright is evasive regarding the acronyms used on a document and his writing style. {Day5/89:2} - {Day5/89:15} Q. Dr Wright, it isn't the case, is it, that Mr Ager - Hanssen got strikingly lucky here, this is another sign of forgery by you, isn't it? A. No, he didn't get lucky. It turns out that he'd been actually monitoring my computer for months, including all of my emails, all of my communications, all of my WhatsApp. He had basically been screenshotting
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Nicholas Bohm Witness Statement - Exhibit
part 1 of 1 20090202-All's well-131923(75057002.1).pdf
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Subject: All's well From: Nicholas Bohm <[email protected]> Date: 02/02/2009, 11:27 To: [email protected] No further trouble; but whereas the UI at first showed your transfer as: 35 blocks 01/02/2009 16:25 Received with: !Me 1CHE5JRfc5mr8ZtVUP7nnsS5HC4bWcXoc6 +100.00 it now (the morning after) shows: 98 blocks 01/02/2009 16:25 Received with: Satoshi Nakamoto 1CHE5JRfc5mr8ZtVUP7nnsS5HC4bWcXoc6 +100.00 Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFAll's well mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:10
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090202-All's well-131923(75057002.1).pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090202-All's well-131923(75057002.1).pdf ### File content: Subject: All's well From: Nicholas Bohm <[email protected]> Date: 02/02/2009, 11:27 To: [email protected] No further trouble; but whereas the UI at first showed your transfer as: 35 blocks 01/02/2009 16:25 Received with: !Me 1CHE5JRfc5mr8ZtVUP7nnsS5HC4bWcXoc6 +100.00 it now (the morning after) shows: 98 blocks 01/02/2009 16:25 Received with: Satoshi Nakamoto 1CHE5JRfc5mr8ZtVUP7nnsS5HC4bWcXoc6 +100.00 Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFAll's well mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:10
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Closings
part 28 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf
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It bears Dr Wright’s name and contact details at Charles Sturt University, in a manner identical to {ID_000536}, {ID_000537}, and {ID_000538}, and those details in those other documents are otherwise identical to thi s document’s face -value content [PM3 at 10: Style 4 in relation to ID_00536 to ID_00538, and Style 8 in relation to {ID_004011}]. 6. The Coffee Stained Printout is a printout of a digital document. When imaged (whether as {ID_003330} or as {ID_004011}), it c arries no internal metadata for forensic examination of its original content. [PM15 at 1, 8; PM3 at 245]. 7. No underlying digital document has been identified by Dr Wright. However, the title of the Coffee -Stained Printout contains the same hyphenation error as present in the title of {ID_000537} (a native PDF), which reads “Peer -toPeer” [PM3 at 138 -139]. That hyphenation error does not appear in any other versions of the Bitcoin White Paper, or Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 93 of 167 any other documents, in Dr Wright’s disclosure. It is to be inferred that the Coffee Stained Printout is a printout of an edited version of {ID_000537}. 8. The Reasons for Allegation of Forgery relating to {ID_000537} (above) are therefore repeated. 9. As explained above in relation to {ID_000537}, that document could not have been created before 22 August 2019. On that basis, the Coffee -Stained Printout could not have been created before that date. 10. {ID_003330} has been disclosed with external metadata indicating that it was created and/or sent by WhatsApp on 4 Septembe r 2019 [P15 at 6- 10]. Taking this point with those above, Dr Wright’s handwritten annotations visible on the face of {ID_003330} (the “Initial Handwritten Annotations ”) date from the period 22 August 2019 to 4 September 2019. 11. {ID_004011} was created by scanning using a Canon Multifunction Scanner/Printer device on 10 September 2019 [PM3 at 245]. Dr Wright’s further handwritten annotations, visible on the face of {ID_004011} (the “Further Handwritten Annotations ”), do not appear on the face of {ID_003330}. The Further Handwritten Annotations therefore date from the period between 4 September 2019 and 10 September 2019. 12. In each case, the Initial Handwritten Annotations and the Further Handwritten Annotations are of a nature tending to present the document and the annotations as if it was a printout of a draft of the Bitcoin White Paper containing annotations from 2008, contrary to fact. 13. In addition to the handwritten annotati ons, the Coffee -Stained Printout (as seen in {ID_003330}) contains physical characteristics including tears, marks, warped paper, and the prominent presence of a coffee stain. These characteristics are of a nature tending to present the document as if it w as an aged document, contrary to fact. In fact, for the aforesaid reasons, the Coffee -Stained Printout was not two weeks old by the date that the photograph {ID_003330} was taken. It is to be inferred that these indicia of age were added during that period, in an attempt to make the document to appear to be older than it was. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 94 of 167 14. Following receipt of the Madden Report, Dr Wright has accepted in his Chain of Custody information that {ID_003330} was taken using his Samsung Galaxy S10 Plus Mobile Phone, a device t hat was not released until 2019, and he has said that some annotations in red ink were added between 2017 and 2020. This account is implausible. COPA contends that the document itself, including all the annotations, are inauthentic to their purported date in 2008. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 15. Dr Wright has positively asserted that both of these documents are documents on which he primarily relies as supporting his claim to be Satoshi Nakamoto. 16. Dr Wright has chosen to rely in these proceedings on two copies of the Coffee -Stained Printout ({ID_004011} and {ID_003330}) both of which are stripped of metadata by reason of their creation process, but he has not relied on or disclosed any underlying digital document that contains relevant metadata. 17. The documents both contain notes in Dr Wright’s own handwriting. 18. Dr Wright accepts that he deliberately altered the Coffee- Stained Printout in his own handwriting at some time during 2017- 2020. 19. Dr Wright accepts that the photograph {ID_003330} was taken on his own mobile phone. 20. The effect of the creation of Coffee- Stained Printout in the way described is to make the document appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto (i.e. as a predecessor version of the Bitcoin White Paper, recorded for posterity), contrary to fact. 21. Dr Wright refused to provide information about the dating of his Reliance Documents, including these, when requested. Only following service of the Madden Report did he provide an alternative acco unt of the origin of these documents. As noted above, his account is implausible. 22. The effect of the alterations has been to introduce annotations referring to matters on which Dr Wright relies in his evidence in these proceedings. 23. The document bears Dr Wr ight’s name and contact details. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 95 of 167 24. The contact details included refer to Charles Sturt University. In his evidence in these proceedings, Dr Wright has claimed to have drafted and shared versions of the Bitcoin White Paper while studying at Charles Sturt Uni versity, and to have discussed the concepts with teaching staff at Charles Sturt University. [Wright 1 at 87; Wright 4 at 52] 25. Dr Wright claims, in his Chain of Custody information, to have drafted this document. Dr Wright’s Explanations and COPA’s Rebutta l 26. In Appendix B to Wright 11, Dr Wright accepted that this document {ID_004011} was created by scanning a hard copy document on 10 September 2019. He claimed that some of the annotations in the document had been made between August and September 2019, while others had been made earlier. He denied that the document at {ID_000537} was the source for this document, despite the two having the same irregular hyphenation in the title and there being no other document in disclosure with that feature (other than {ID_003330}, which is a photograph of the first page of the document later scanned as {ID_004011}). He claimed that both documents had been originally created in L ATEX but that the prior versions had not been retained. See: {CSW/2/64} to {CSW/2/65}. 27. This document is a forgery, plainly created to give the appearance of a
1,111
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 28 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### File content: It bears Dr Wright’s name and contact details at Charles Sturt University, in a manner identical to {ID_000536}, {ID_000537}, and {ID_000538}, and those details in those other documents are otherwise identical to thi s document’s face -value content [PM3 at 10: Style 4 in relation to ID_00536 to ID_00538, and Style 8 in relation to {ID_004011}]. 6. The Coffee Stained Printout is a printout of a digital document. When imaged (whether as {ID_003330} or as {ID_004011}), it c arries no internal metadata for forensic examination of its original content. [PM15 at 1, 8; PM3 at 245]. 7. No underlying digital document has been identified by Dr Wright. However, the title of the Coffee -Stained Printout contains the same hyphenation error as present in the title of {ID_000537} (a native PDF), which reads “Peer -toPeer” [PM3 at 138 -139]. That hyphenation error does not appear in any other versions of the Bitcoin White Paper, or Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 93 of 167 any other documents, in Dr Wright’s disclosure. It is to be inferred that the Coffee Stained Printout is a printout of an edited version of {ID_000537}. 8. The Reasons for Allegation of Forgery relating to {ID_000537} (above) are therefore repeated. 9. As explained above in relation to {ID_000537}, that document could not have been created before 22 August 2019. On that basis, the Coffee -Stained Printout could not have been created before that date. 10. {ID_003330} has been disclosed with external metadata indicating that it was created and/or sent by WhatsApp on 4 Septembe r 2019 [P15 at 6- 10]. Taking this point with those above, Dr Wright’s handwritten annotations visible on the face of {ID_003330} (the “Initial Handwritten Annotations ”) date from the period 22 August 2019 to 4 September 2019. 11. {ID_004011} was created by scanning using a Canon Multifunction Scanner/Printer device on 10 September 2019 [PM3 at 245]. Dr Wright’s further handwritten annotations, visible on the face of {ID_004011} (the “Further Handwritten Annotations ”), do not appear on the face of {ID_003330}. The Further Handwritten Annotations therefore date from the period between 4 September 2019 and 10 September 2019. 12. In each case, the Initial Handwritten Annotations and the Further Handwritten Annotations are of a nature tending to present the document and the annotations as if it was a printout of a draft of the Bitcoin White Paper containing annotations from 2008, contrary to fact. 13. In addition to the handwritten annotati ons, the Coffee -Stained Printout (as seen in {ID_003330}) contains physical characteristics including tears, marks, warped paper, and the prominent presence of a coffee stain. These characteristics are of a nature tending to present the document as if it w as an aged document, contrary to fact. In fact, for the aforesaid reasons, the Coffee -Stained Printout was not two weeks old by the date that the photograph {ID_003330} was taken. It is to be inferred that these indicia of age were added during that period, in an attempt to make the document to appear to be older than it was. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 94 of 167 14. Following receipt of the Madden Report, Dr Wright has accepted in his Chain of Custody information that {ID_003330} was taken using his Samsung Galaxy S10 Plus Mobile Phone, a device t hat was not released until 2019, and he has said that some annotations in red ink were added between 2017 and 2020. This account is implausible. COPA contends that the document itself, including all the annotations, are inauthentic to their purported date in 2008. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 15. Dr Wright has positively asserted that both of these documents are documents on which he primarily relies as supporting his claim to be Satoshi Nakamoto. 16. Dr Wright has chosen to rely in these proceedings on two copies of the Coffee -Stained Printout ({ID_004011} and {ID_003330}) both of which are stripped of metadata by reason of their creation process, but he has not relied on or disclosed any underlying digital document that contains relevant metadata. 17. The documents both contain notes in Dr Wright’s own handwriting. 18. Dr Wright accepts that he deliberately altered the Coffee- Stained Printout in his own handwriting at some time during 2017- 2020. 19. Dr Wright accepts that the photograph {ID_003330} was taken on his own mobile phone. 20. The effect of the creation of Coffee- Stained Printout in the way described is to make the document appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto (i.e. as a predecessor version of the Bitcoin White Paper, recorded for posterity), contrary to fact. 21. Dr Wright refused to provide information about the dating of his Reliance Documents, including these, when requested. Only following service of the Madden Report did he provide an alternative acco unt of the origin of these documents. As noted above, his account is implausible. 22. The effect of the alterations has been to introduce annotations referring to matters on which Dr Wright relies in his evidence in these proceedings. 23. The document bears Dr Wr ight’s name and contact details. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 95 of 167 24. The contact details included refer to Charles Sturt University. In his evidence in these proceedings, Dr Wright has claimed to have drafted and shared versions of the Bitcoin White Paper while studying at Charles Sturt Uni versity, and to have discussed the concepts with teaching staff at Charles Sturt University. [Wright 1 at 87; Wright 4 at 52] 25. Dr Wright claims, in his Chain of Custody information, to have drafted this document. Dr Wright’s Explanations and COPA’s Rebutta l 26. In Appendix B to Wright 11, Dr Wright accepted that this document {ID_004011} was created by scanning a hard copy document on 10 September 2019. He claimed that some of the annotations in the document had been made between August and September 2019, while others had been made earlier. He denied that the document at {ID_000537} was the source for this document, despite the two having the same irregular hyphenation in the title and there being no other document in disclosure with that feature (other than {ID_003330}, which is a photograph of the first page of the document later scanned as {ID_004011}). He claimed that both documents had been originally created in L ATEX but that the prior versions had not been retained. See: {CSW/2/64} to {CSW/2/65}. 27. This document is a forgery, plainly created to give the appearance of a
2,039
/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Fourth Expert Report of Patrick Madden.pdf
Patrick Madden
part 17 of 40 Fourth Expert Report of Patrick Madden.pdf
38,640
79,485
mounting BDOPC.raw , it is possible to explore the file’s data as if it was a hard drive. This allowed me to inspect : a. information relating to the image itself and how it came to be created and modified. My observations about the drive itself are set out in this section of my report; and b. details of individual files within the drive. My observations about those individual files are separate, in Appendix PM 46. Single partition – content of an operating system 62. A computer disk can be ‘partitioned’ or segmented into different spaces or sectors, which can then be used for different purposes. As well as storage of user files, different partitions can be used for different reasons, e.g. it is common for the first portion of a hard disk to contain information which instructs the computer about where to locate the operating system files in order t o initially boot up before the operating system is loaded (referred to as a ‘boot sector’). 63. As shown below, the BDOPC.raw image is an image of a single partition of a computer hard disk. It does not contain a boot sector: 8I have also considered the possibility that these �mestamps were inherited when the file was copied from another storage device but have discounted that possibility also because it would not explain the observa�ons I have made in rela�on to those �mest amps, which I explain in further detail throughout this report. Fourth expert report of Patrick Madden Page 22 of 57 a bove and further discussed in detail below and in Appendix PM46 , and in particular I note that the date is before the existence of the Samsung Drive, which was manufactured in 2015. I made this observation before the other analysis described above (but mention it here as this is not a chronologica l report), and formed the preliminary view that it was probable that these timestamps did not therefore correlate to the creation and modification timestamps of the disk image file, buthave been attributed to the file by some other means or activity. This preliminary view was later informed and became more concrete by reason of the other analysis described in this report. 8 Overview of the BDOPC.raw Image contents 61. By mounting BDOPC.raw , it is possible to explore the file’s data as if it was a hard drive. This allowed me to inspect : a. information relating to the image itself and how it came to be created and modified. My observations about the drive itself are set out in this section of my report; and b. details of individual files within the drive. My observations about those individual files are separate, in Appendix PM 46. Single partition – content of an operating system 62. A computer disk can be ‘partitioned’ or segmented into different spaces or sectors, which can then be used for different purposes. As well as storage of user files, different partitions can be used for different reasons, e.g. it is common for the first portion of a hard disk to contain information which instructs the computer about where to locate the operating system files in order t o initially boot up before the operating system is loaded (referred to as a ‘boot sector’). 63. As shown below, the BDOPC.raw image is an image of a single partition of a computer hard disk. It does not contain a boot sector: 8I have also considered the possibility that these �mestamps were inherited when the file was copied from another storage device but have discounted that possibility also because it would not explain the observa�ons I have made in rela�on to those �mest amps, which I explain in further detail throughout this report. 22 - 22 - G/6/22{H/278} {H/278} Fourth expert report of Patrick Madden Page 23 of 57 Figure 5: overview diagram of the BDOPC.raw 64. Other format data of the partitioned hard drive is shown below : Volume Serial Number E859 -F3AF Full Volume Serial Number 62E85A21E859F3AF Driver Informa�on NTFS 3.1 Dirty (301) File System NTFS Total Sectors 78,124,032 Total Capacity 39,999,500,288 Bytes (37.3GB) Total Clusters 9,765,503 Unallocated 1,676,435,456 Bytes (1.6GB) Free Clusters 409,286 Allocated 38,323,064,832 Bytes (35.7GB) BDOPC.raw data partition information Files on BDOPC.raw 65. Including system files, files associated with installed programs, and user files, there are 165,243{BDO} files within BDOPC.raw, including the 97 New Reliance Documents. 66. Based on my analysis below, the files on BDOPC fall into two groups: a. 165,102 appear to be files which were present on the BDO PC at the time the Original BDO PC Image was captured. b. 141 files display markedly different characteristics, including being added by a different user at a date after the Original 2007 BDO Image was captured. c. Of those , 71 documents are part of the 97 New Reliance Documents. How BDO PC was used Activity information on the BDO PC 67. It is possible to establish details about how the BDO PC was used and what its software set upwas, as follows : a. The image is a clone of the content of the hard disk of a computer that was using a Windows XP operating system with Service Pack 2 installed: The operating system files are included on the drive. b. The Windows XP installation date{BDO} is recorded as 18 April 2006. c. The computer name is recorded as being “BDO -SYD- NB-439”. Fourth expert report of Patrick Madden Page 23 of 57 Figure 5: overview diagram of the BDOPC.raw 64. Other format data of the partitioned hard drive is shown below : Volume Serial Number E859 -F3AF Full Volume Serial Number 62E85A21E859F3AF Driver Informa�on NTFS 3.1 Dirty (301) File System NTFS Total Sectors 78,124,032 Total Capacity 39,999,500,288 Bytes (37.3GB) Total Clusters 9,765,503 Unallocated 1,676,435,456 Bytes (1.6GB) Free
966
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 17 of 40 Fourth Expert Report of Patrick Madden.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Fourth Expert Report of Patrick Madden.pdf ### File content: mounting BDOPC.raw , it is possible to explore the file’s data as if it was a hard drive. This allowed me to inspect : a. information relating to the image itself and how it came to be created and modified. My observations about the drive itself are set out in this section of my report; and b. details of individual files within the drive. My observations about those individual files are separate, in Appendix PM 46. Single partition – content of an operating system 62. A computer disk can be ‘partitioned’ or segmented into different spaces or sectors, which can then be used for different purposes. As well as storage of user files, different partitions can be used for different reasons, e.g. it is common for the first portion of a hard disk to contain information which instructs the computer about where to locate the operating system files in order t o initially boot up before the operating system is loaded (referred to as a ‘boot sector’). 63. As shown below, the BDOPC.raw image is an image of a single partition of a computer hard disk. It does not contain a boot sector: 8I have also considered the possibility that these �mestamps were inherited when the file was copied from another storage device but have discounted that possibility also because it would not explain the observa�ons I have made in rela�on to those �mest amps, which I explain in further detail throughout this report. Fourth expert report of Patrick Madden Page 22 of 57 a bove and further discussed in detail below and in Appendix PM46 , and in particular I note that the date is before the existence of the Samsung Drive, which was manufactured in 2015. I made this observation before the other analysis described above (but mention it here as this is not a chronologica l report), and formed the preliminary view that it was probable that these timestamps did not therefore correlate to the creation and modification timestamps of the disk image file, buthave been attributed to the file by some other means or activity. This preliminary view was later informed and became more concrete by reason of the other analysis described in this report. 8 Overview of the BDOPC.raw Image contents 61. By mounting BDOPC.raw , it is possible to explore the file’s data as if it was a hard drive. This allowed me to inspect : a. information relating to the image itself and how it came to be created and modified. My observations about the drive itself are set out in this section of my report; and b. details of individual files within the drive. My observations about those individual files are separate, in Appendix PM 46. Single partition – content of an operating system 62. A computer disk can be ‘partitioned’ or segmented into different spaces or sectors, which can then be used for different purposes. As well as storage of user files, different partitions can be used for different reasons, e.g. it is common for the first portion of a hard disk to contain information which instructs the computer about where to locate the operating system files in order t o initially boot up before the operating system is loaded (referred to as a ‘boot sector’). 63. As shown below, the BDOPC.raw image is an image of a single partition of a computer hard disk. It does not contain a boot sector: 8I have also considered the possibility that these �mestamps were inherited when the file was copied from another storage device but have discounted that possibility also because it would not explain the observa�ons I have made in rela�on to those �mest amps, which I explain in further detail throughout this report. 22 - 22 - G/6/22{H/278} {H/278} Fourth expert report of Patrick Madden Page 23 of 57 Figure 5: overview diagram of the BDOPC.raw 64. Other format data of the partitioned hard drive is shown below : Volume Serial Number E859 -F3AF Full Volume Serial Number 62E85A21E859F3AF Driver Informa�on NTFS 3.1 Dirty (301) File System NTFS Total Sectors 78,124,032 Total Capacity 39,999,500,288 Bytes (37.3GB) Total Clusters 9,765,503 Unallocated 1,676,435,456 Bytes (1.6GB) Free Clusters 409,286 Allocated 38,323,064,832 Bytes (35.7GB) BDOPC.raw data partition information Files on BDOPC.raw 65. Including system files, files associated with installed programs, and user files, there are 165,243{BDO} files within BDOPC.raw, including the 97 New Reliance Documents. 66. Based on my analysis below, the files on BDOPC fall into two groups: a. 165,102 appear to be files which were present on the BDO PC at the time the Original BDO PC Image was captured. b. 141 files display markedly different characteristics, including being added by a different user at a date after the Original 2007 BDO Image was captured. c. Of those , 71 documents are part of the 97 New Reliance Documents. How BDO PC was used Activity information on the BDO PC 67. It is possible to establish details about how the BDO PC was used and what its software set upwas, as follows : a. The image is a clone of the content of the hard disk of a computer that was using a Windows XP operating system with Service Pack 2 installed: The operating system files are included on the drive. b. The Windows XP installation date{BDO} is recorded as 18 April 2006. c. The computer name is recorded as being “BDO -SYD- NB-439”. Fourth expert report of Patrick Madden Page 23 of 57 Figure 5: overview diagram of the BDOPC.raw 64. Other format data of the partitioned hard drive is shown below : Volume Serial Number E859 -F3AF Full Volume Serial Number 62E85A21E859F3AF Driver Informa�on NTFS 3.1 Dirty (301) File System NTFS Total Sectors 78,124,032 Total Capacity 39,999,500,288 Bytes (37.3GB) Total Clusters 9,765,503 Unallocated 1,676,435,456 Bytes (1.6GB) Free
1,685
/content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf
Closings
part 38 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf
55,528
99,982
(InfoDef09.raw) contains 17 of the 97 new reliance documents, but with the documents in slightly different form. This was recovered by Mr Madden, and it shows Dr Wright creating the forgeries. Madden 4 {G/6/41}. The deleted files contain evidence of changes being made to documents t o create potential precursors to the Bitcoin White Paper, by removing what would otherwise be anachronisms For example, where a precursor document contained a reference to a paper published in 2016, the disclosed version by Dr Wright had that reference date removed and replaced by a question mark: see PM46 at 112b {H/278/39}. This course of editing is set out more fully in subsequently pleaded forgeries set out later in this Part 3. f. The edits made to documents between InfoDef.raw (the deleted version) and BDOPC.raw were also changes specifically in support of Dr Wright’s case that he is Satoshi, such as changing the words “the original Bitcoin White Paper” on InfoDef.raw to “the proposed Timecoin system” on BDOPC.raw. g. Dr Wright accepted that many of the file s appeared to be modified, but claimed that this had been done by Mr Ager -Hanssen or someone associated with him. There is simply no evidence that such hacking occurred, and it is a fantastical excuse. For the avoidance of doubt, the fact that Mr Ager -Hanssen posted in October 2023 some pictures of a computer screen showing Dr Wright’s BDO drive files does not prove that he gained access through hacking. These are files which Dr Wright presented to Mr Ager -Hanssen and others in September 2023 to encourage their continued support of him. h. It is also implausible that Dr Wright also did not appear to notice this alleged hack at the time, even though Mr Ager -Hanssen had published in October the pictures of a computer screen containing Dr Wright’s BDO drive fi les which Dr Wright now (wrongly) claims are conclusive evidence of the supposed hack. Dr Wright never mentioned this hack by Mr Ager -Hanssen in his statements, even though he says he worked out that it had happened some time in December. His ninth statem ent was served on 21 December 2023, so he had the opportunity to address the issue squarely in that and later statements. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 124 of 167 {ID_004648} {PTR -F/5/1} and {ID_004687} {L1/236/1} Conversions to LaTeX using the 2022 version of Pandoc 1. These are two LaTeX source documents presented by Dr Wright as if they are precursor work to the Bitcoin White Paper. {ID_004648} is presented as a draft or paper produced in his work on the MNSA programme at Charles Sturt University in 2004/5 P4/10/4, and it appears to be a paper on hash chains and security of voting. {ID_004687} is presented as an article on IT security with a face dating of June 2006 which refers to hash chains and Merkle trees (features of the Bitcoin system). Reasons for Allegation of Forgery 2. These are documents which were among the 71 New Reliance Documents that were inserted into the BDO Drive by the editing process and which the parties’ experts agree were manipulated [Madden / Lynch Joint Report 1 at 12 Q/6/5]. 3. These d ocuments have been backdated. They refer to LaTeX packages which were not released in 2007. In particular: a. They specify code (‘ \\usepackage’) to use the package “selnolig ”. Selnolig was not conceived of until 2011. It was not created until 2012- 2013. It was not posted to the internet until May 2013 [Loretan 1 at 5, C/20/2]. They also refer to the package “xurl”, which had not been released at the stated dates of these documents [Madden 3 at 30 G/5/16]. b. Selnolig requires a then- recent (2012- 2013) version of L uaTeX to be used. [Loretan 1 at 6, C/20/2] c. There was no previous package called ‘selnolig’. [Loretan 1 at 7, C/20/2] 4. These documents have been created with the Pandoc document conversion software. Pandoc is an open- source piece of software that can convert documents between different formats. It can generate LaTeX documents automatically [Macfarlane 1 at 3 C/19/1]. In particular: a. {ID_004687} contains a line which states that it was created as LaTeX via Pandoc, which is characteristic of the use of Pandoc. [ Macfarlane 1 at 5 C/19/1]. Although Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 125 of 167 {ID_004648} does not include that line “ LaTeX via Pandoc ”, it includes the other code from the same October template. b. The template for conversion to LaTeX was not introduced into Pandoc at all until 2010 [Macfarlane 1 at 5 C/19/1]. 5. The documents have been created during the course of these proceedings: a. Inspection of the (open- source) source code of Pandoc allows for more precise dating. The document was created after October 2022. The version of Pandoc used for creation of this document uses code that was not committed to Pandoc until October 2022. [Macfarlane 1 at 9 C/19/2]. b. October 2022 is after the commencement of these proceedings. 6. The documents were sourced from BDOPC.raw. The section “BDOPC.raw” above is repeated. These documents were added by the Manipulation User. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 7. The effect of the tampering is to create documents which appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto, contrary to fact. 8. These documents were added to BDOPC.raw by the Manipulation User. The Manipulation User is Dr Wright, as explained in the section “BDOPC.raw” above. 9. The further effect of tampering is to lend support to Dr Wright’s new position that the Bitcoin Wh ite Paper was created in LaTeX, by providing other LaTeX documents alongside it. That story is a recent product of Dr Wright’s invention. 10. Dr Wright has attached particular importance to these documents: a. Both are said to be important to Dr Wright’s case because they are “Notes, drafts and articles addressing technical concepts that underpin the concepts developed in the Bitcoin White Paper” [Wright 6 E/21/3; Schedule 1 to Field 1, L20/223/4]. b. {ID_004648} is said to be one of Dr Wright’s “ drafts and papers written by Dr Wright during his Masters of Network and System Administration (MNSA) programme at Charles Sturt University, which he pursued between 2004 and 2005. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 126 of 167 These papers show an interest in the problems in distributed in distributed computing syste ms and considers solutions that are precursors to the consensus
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 38 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### File content: (InfoDef09.raw) contains 17 of the 97 new reliance documents, but with the documents in slightly different form. This was recovered by Mr Madden, and it shows Dr Wright creating the forgeries. Madden 4 {G/6/41}. The deleted files contain evidence of changes being made to documents t o create potential precursors to the Bitcoin White Paper, by removing what would otherwise be anachronisms For example, where a precursor document contained a reference to a paper published in 2016, the disclosed version by Dr Wright had that reference date removed and replaced by a question mark: see PM46 at 112b {H/278/39}. This course of editing is set out more fully in subsequently pleaded forgeries set out later in this Part 3. f. The edits made to documents between InfoDef.raw (the deleted version) and BDOPC.raw were also changes specifically in support of Dr Wright’s case that he is Satoshi, such as changing the words “the original Bitcoin White Paper” on InfoDef.raw to “the proposed Timecoin system” on BDOPC.raw. g. Dr Wright accepted that many of the file s appeared to be modified, but claimed that this had been done by Mr Ager -Hanssen or someone associated with him. There is simply no evidence that such hacking occurred, and it is a fantastical excuse. For the avoidance of doubt, the fact that Mr Ager -Hanssen posted in October 2023 some pictures of a computer screen showing Dr Wright’s BDO drive files does not prove that he gained access through hacking. These are files which Dr Wright presented to Mr Ager -Hanssen and others in September 2023 to encourage their continued support of him. h. It is also implausible that Dr Wright also did not appear to notice this alleged hack at the time, even though Mr Ager -Hanssen had published in October the pictures of a computer screen containing Dr Wright’s BDO drive fi les which Dr Wright now (wrongly) claims are conclusive evidence of the supposed hack. Dr Wright never mentioned this hack by Mr Ager -Hanssen in his statements, even though he says he worked out that it had happened some time in December. His ninth statem ent was served on 21 December 2023, so he had the opportunity to address the issue squarely in that and later statements. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 124 of 167 {ID_004648} {PTR -F/5/1} and {ID_004687} {L1/236/1} Conversions to LaTeX using the 2022 version of Pandoc 1. These are two LaTeX source documents presented by Dr Wright as if they are precursor work to the Bitcoin White Paper. {ID_004648} is presented as a draft or paper produced in his work on the MNSA programme at Charles Sturt University in 2004/5 P4/10/4, and it appears to be a paper on hash chains and security of voting. {ID_004687} is presented as an article on IT security with a face dating of June 2006 which refers to hash chains and Merkle trees (features of the Bitcoin system). Reasons for Allegation of Forgery 2. These are documents which were among the 71 New Reliance Documents that were inserted into the BDO Drive by the editing process and which the parties’ experts agree were manipulated [Madden / Lynch Joint Report 1 at 12 Q/6/5]. 3. These d ocuments have been backdated. They refer to LaTeX packages which were not released in 2007. In particular: a. They specify code (‘ \\usepackage’) to use the package “selnolig ”. Selnolig was not conceived of until 2011. It was not created until 2012- 2013. It was not posted to the internet until May 2013 [Loretan 1 at 5, C/20/2]. They also refer to the package “xurl”, which had not been released at the stated dates of these documents [Madden 3 at 30 G/5/16]. b. Selnolig requires a then- recent (2012- 2013) version of L uaTeX to be used. [Loretan 1 at 6, C/20/2] c. There was no previous package called ‘selnolig’. [Loretan 1 at 7, C/20/2] 4. These documents have been created with the Pandoc document conversion software. Pandoc is an open- source piece of software that can convert documents between different formats. It can generate LaTeX documents automatically [Macfarlane 1 at 3 C/19/1]. In particular: a. {ID_004687} contains a line which states that it was created as LaTeX via Pandoc, which is characteristic of the use of Pandoc. [ Macfarlane 1 at 5 C/19/1]. Although Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 125 of 167 {ID_004648} does not include that line “ LaTeX via Pandoc ”, it includes the other code from the same October template. b. The template for conversion to LaTeX was not introduced into Pandoc at all until 2010 [Macfarlane 1 at 5 C/19/1]. 5. The documents have been created during the course of these proceedings: a. Inspection of the (open- source) source code of Pandoc allows for more precise dating. The document was created after October 2022. The version of Pandoc used for creation of this document uses code that was not committed to Pandoc until October 2022. [Macfarlane 1 at 9 C/19/2]. b. October 2022 is after the commencement of these proceedings. 6. The documents were sourced from BDOPC.raw. The section “BDOPC.raw” above is repeated. These documents were added by the Manipulation User. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 7. The effect of the tampering is to create documents which appear to be supportive of Dr Wright’s claim to be Satoshi Nakamoto, contrary to fact. 8. These documents were added to BDOPC.raw by the Manipulation User. The Manipulation User is Dr Wright, as explained in the section “BDOPC.raw” above. 9. The further effect of tampering is to lend support to Dr Wright’s new position that the Bitcoin Wh ite Paper was created in LaTeX, by providing other LaTeX documents alongside it. That story is a recent product of Dr Wright’s invention. 10. Dr Wright has attached particular importance to these documents: a. Both are said to be important to Dr Wright’s case because they are “Notes, drafts and articles addressing technical concepts that underpin the concepts developed in the Bitcoin White Paper” [Wright 6 E/21/3; Schedule 1 to Field 1, L20/223/4]. b. {ID_004648} is said to be one of Dr Wright’s “ drafts and papers written by Dr Wright during his Masters of Network and System Administration (MNSA) programme at Charles Sturt University, which he pursued between 2004 and 2005. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 126 of 167 These papers show an interest in the problems in distributed in distributed computing syste ms and considers solutions that are precursors to the consensus
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/content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090130-Re_Resent-102984(75056991.1).pdf
Nicholas Bohm Witness Statement - Exhibit
part 1 of 1 20090130-Re_Resent-102984(75056991.1).pdf
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Subject: Re: Resent From: Nicholas Bohm <[email protected]> Date: 30/01/2009, 21:54 To: Satoshi Nakamoto <[email protected]> Satoshi Nakamoto wrote: I resent the 0.1.4 file in the previous e-mail. It also contained a bugfix for a bug that was dormant but I thought by process of elimination might have been what you had, but after you told me about Eraser I think it's more likely to have been Eraser/disk space related. I guess we are simultaneously trying to debug my e-mail. We seem to be, as I can only find two messages from you, the one above and the one from vistomail, and neither has any attachments. (I have also again checked the spam quarantine.) So something odd is happening. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFRe: Resent mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:09
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090130-Re_Resent-102984(75056991.1).pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090130-Re_Resent-102984(75056991.1).pdf ### File content: Subject: Re: Resent From: Nicholas Bohm <[email protected]> Date: 30/01/2009, 21:54 To: Satoshi Nakamoto <[email protected]> Satoshi Nakamoto wrote: I resent the 0.1.4 file in the previous e-mail. It also contained a bugfix for a bug that was dormant but I thought by process of elimination might have been what you had, but after you told me about Eraser I think it's more likely to have been Eraser/disk space related. I guess we are simultaneously trying to debug my e-mail. We seem to be, as I can only find two messages from you, the one above and the one from vistomail, and neither has any attachments. (I have also again checked the spam quarantine.) So something odd is happening. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FFRe: Resent mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:09
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/content/Copa v Wright - Trial Documents/Witness Statements/Witness Statement of Zooko Wilcox-O'Hearn.pdf
Witness Statements
part 1 of 2 Witness Statement of Zooko Wilcox-O'Hearn.pdf
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1 On behalf of the Claimant Witness: Wilcox -OHearn Exhibit s: Z-1 to Z-3 July 2023 IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES INTELLECTUAL PROPERTY LIST (ChD) Claim No: IL -202 1-000 019 BETWEEN: (1) CRYPTO OPEN PATENT ALLIANCE Claimant -and- (1) DR CRAIG STEVEN WRIGHT Defendant WITNESS STATEMENT OF ZOOKO WILCOX -O'HEARN I, Bryce Wilcox -O'Hearn , known as Zooko Wilcox -O’Hearn, of will say as follows: 1. I am computer s cientist and developer in the field of cryptography and cryptocurrency. I am the CEO of the Electric Coin Company, although I do not make this statement in that capacity. This written statemen t has been prepared by Bird & Bird to record my own evidence and answers given to Bird & Bird during a n interview, though I am informed by Bird & Bird that our exchanges are privileged . The evidence given in this statement is written in my own words as far as practicable . The facts and matters set out in this statement are within my own knowledge unless otherwise stated. Where I refer to facts within my own knowledge, I believe them to be true. Where I refer to information from other sources , those facts and matters are true to the best of my knowledge and belief and I have identified my sources . On points that I understand to be important in the case, I have stated honestly (a) how well I recall matters and (b) whether my memory has been refreshed by considering documents, and if so how and when. 2. I am happy to provide what evidence I can to bring out the truth in court. But, I lack a lot of context about the story of Craig Wright : I do remember several years ago someone approached me on Twitter to ask me if I wanted to have the honor of DocuSign Envelope ID: 227BCF3A-49F6-40C5-A4EE-90764B7A8BB0 2 meeting him, and that he was someone very important in the history of Bitcoin , though I don’t remember any more detail about that. At the time I said ‘no t hanks’, as I could smell it didn’t feel right, and I was pretty sure I knew of everyone who fit that description and he wasn’t part of it. Since then I have seen some videos and tweets about him and know he claims to be Satoshi Nakamoto. I don’t have any i nside information about Satoshi’s identity. 3.I was involved in cryptography for many years before the development of Bitcoin , i ncluding working on DigiCash in the 1990s . I was good friends with others like Ha l F inney , Nick Szabo, Adam Back and Greg Maxwell, and w e used to hang out on IRC (Internet Relay Chat) channels and chat about open source projects, cryptograph y, and similar things . Later on, I also met others who were involved with Bitcoin afte r S atoshi such as Gavin Andres en and Peter Todd, and I was active with those folks for years. 4.I first became aware of Bitcoin when it was announced by Satoshi in 2008 . I remember being interested in it at the time, and one day on IRC talking to Greg and saying he should stop working on his project at that time (an open source audio codec) and start working on Bitcoin, which was much more important! 5.I can’t recall any occasion when I had any private discussions with Satoshi. I don’t have records and may not remember perfectly but a t most , it’s possible tha t he might have notified me of the publication of the original Bitcoin white paper . I don’t think he even did that . 6.On 26 January
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 2 Witness Statement of Zooko Wilcox-O'Hearn.pdf ### Folder name: Witness Statements ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Witness Statement of Zooko Wilcox-O'Hearn.pdf ### File content: 1 On behalf of the Claimant Witness: Wilcox -OHearn Exhibit s: Z-1 to Z-3 July 2023 IN THE HIGH COURT OF JUSTICE BUSINESS AND PROPERTY COURTS OF ENGLAND & WALES INTELLECTUAL PROPERTY LIST (ChD) Claim No: IL -202 1-000 019 BETWEEN: (1) CRYPTO OPEN PATENT ALLIANCE Claimant -and- (1) DR CRAIG STEVEN WRIGHT Defendant WITNESS STATEMENT OF ZOOKO WILCOX -O'HEARN I, Bryce Wilcox -O'Hearn , known as Zooko Wilcox -O’Hearn, of will say as follows: 1. I am computer s cientist and developer in the field of cryptography and cryptocurrency. I am the CEO of the Electric Coin Company, although I do not make this statement in that capacity. This written statemen t has been prepared by Bird & Bird to record my own evidence and answers given to Bird & Bird during a n interview, though I am informed by Bird & Bird that our exchanges are privileged . The evidence given in this statement is written in my own words as far as practicable . The facts and matters set out in this statement are within my own knowledge unless otherwise stated. Where I refer to facts within my own knowledge, I believe them to be true. Where I refer to information from other sources , those facts and matters are true to the best of my knowledge and belief and I have identified my sources . On points that I understand to be important in the case, I have stated honestly (a) how well I recall matters and (b) whether my memory has been refreshed by considering documents, and if so how and when. 2. I am happy to provide what evidence I can to bring out the truth in court. But, I lack a lot of context about the story of Craig Wright : I do remember several years ago someone approached me on Twitter to ask me if I wanted to have the honor of DocuSign Envelope ID: 227BCF3A-49F6-40C5-A4EE-90764B7A8BB0 2 meeting him, and that he was someone very important in the history of Bitcoin , though I don’t remember any more detail about that. At the time I said ‘no t hanks’, as I could smell it didn’t feel right, and I was pretty sure I knew of everyone who fit that description and he wasn’t part of it. Since then I have seen some videos and tweets about him and know he claims to be Satoshi Nakamoto. I don’t have any i nside information about Satoshi’s identity. 3.I was involved in cryptography for many years before the development of Bitcoin , i ncluding working on DigiCash in the 1990s . I was good friends with others like Ha l F inney , Nick Szabo, Adam Back and Greg Maxwell, and w e used to hang out on IRC (Internet Relay Chat) channels and chat about open source projects, cryptograph y, and similar things . Later on, I also met others who were involved with Bitcoin afte r S atoshi such as Gavin Andres en and Peter Todd, and I was active with those folks for years. 4.I first became aware of Bitcoin when it was announced by Satoshi in 2008 . I remember being interested in it at the time, and one day on IRC talking to Greg and saying he should stop working on his project at that time (an open source audio codec) and start working on Bitcoin, which was much more important! 5.I can’t recall any occasion when I had any private discussions with Satoshi. I don’t have records and may not remember perfectly but a t most , it’s possible tha t he might have notified me of the publication of the original Bitcoin white paper . I don’t think he even did that . 6.On 26 January
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/content/Copa v Wright - Trial Documents/Hearsay Statements/Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf
Hearsay Statements
part 31 of 52 Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf
36,046
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the date of it is just Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 83 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2511:22:49 11:22:53 11:23:00 11:23:04 11:23:04 11:23:0711:23:10 11:23:14 11:23:20 11:23:23 11:23:2411:23:26 11:23:28 11:23:3111:23:34 11:23:38 11:23:40 11:23:44 11:23:46 11:23:50 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 84 not going to work. We wanted you to get a normal time of the day. So -- MS McGOVERN: Talking to Lynn about the personal -- MR BRENNER: We've got seven hours to take the depo, hopefully it will take less. MS McGOVERN: That's just not going to work. Stop there right now. MR BRENNER: What are you telling me right now? What are you talking about? MS McGOVERN: What is not going to work is some of these deposition exhibits that go into the personal circumstances surrounding the divorce between Lynn and Craig Wright that have zero to do with bitcoin and IP and are clearly meant to harass the witness. That is not going to work. MR BRENNER: That we'll take up as it happens. But the time is - the time is what it is. It's not good for anyone, but we will power through. MR ROCHE: All right. Ms Wright --MS McGOVERN: Okay, Mr Brenner, let's go. MR ROCHE: -- I believe it's 23 minutes past the hour. Let's plan on reconvening at 50 minutes past the hour and I will try to move the deposition along as quickly as I can. THE VIDEOGRAPHER: Okay. Going off the record at Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 84 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2511:23:54 11:53:1511:53:19 11:53:21 11:53:28 11:53:32 11:53:34 11:53:39 11:53:42 11:53:51 11:53:54 11:53:5611:54:00 11:54:23 11:54:24 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 85 11.23. End of tape 2. (11.23am) (A short break) (11.53am) THE VIDEOGRAPHER: Going back on the record at 11.53am. Commencement of tape 3. Proceed. MR ROCHE: Sati, if you could introduce tab 38. BY MR ROCHE: Q.Ms Wright, let me know when you have the document that Sati is about to hand you in front of you. A.Yes. MR ROCHE: For the record, this is document with Bates stamp ending in 640897. THE VIDEOGRAPHER: USA, this is the videographer. You are introducing documents. Are you giving them exhibit numbers for our court reporter? MR ROCHE: Yes. Are you - what exhibit number are we on? THE COURT REPORTER: You didn't tender the document that was the subpoena, you just produced it. Do you want that marked as exhibit 4? MR ROCHE: Yes. Please mark that as exhibit 4, and, for the record, exhibit 4 is the subpoena served by plaintiffs to Miss Lynn Wright. (Exhibit 4 marked for identification)Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 85 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2511:54:32 11:54:33 11:54:45 11:54:45 11:54:4911:54:51 11:54:54 11:54:5511:54:59 11:55:04 11:55:0811:55:14 11:55:17 11:55:22 11:55:28 11:55:2911:55:30 11:55:33 11:55:36 11:55:37 11:55:42 11:55:47 11:55:48 11:55:51 11:55:5111:55:53 11:55:58 11:55:59 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 86 MR ROCHE: And exhibit 5 is the document ending in Bates stamp 640897. (Exhibit 5 marked for identification) BY MR ROCHE: Q.Ms Wright do you recognize this document? A.No, I don't remember it. Q.Okay. So I'm just going to read - it is an email, it looks - it is an email chain between craig.wright@ - do you recognize that email address? A.No. I - I - very vaguely. I have some vague memory of the - of the - not the email address so much as the " " name. Q.Okay. And is Lynn - "lynnbw14@ " - is that you? A.Yes, it is. Q.Okay. And in this email, it's dated April 20th, 2015, Craig writes,
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 31 of 52 Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf ### Folder name: Hearsay Statements ### File path: /content/Copa v Wright - Trial Documents/Hearsay Statements/Transcript of the deposition of Ms Lynn Carroll Wright during the Kleiman v Wright proceedings.pdf ### File content: the date of it is just Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 83 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2511:22:49 11:22:53 11:23:00 11:23:04 11:23:04 11:23:0711:23:10 11:23:14 11:23:20 11:23:23 11:23:2411:23:26 11:23:28 11:23:3111:23:34 11:23:38 11:23:40 11:23:44 11:23:46 11:23:50 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 84 not going to work. We wanted you to get a normal time of the day. So -- MS McGOVERN: Talking to Lynn about the personal -- MR BRENNER: We've got seven hours to take the depo, hopefully it will take less. MS McGOVERN: That's just not going to work. Stop there right now. MR BRENNER: What are you telling me right now? What are you talking about? MS McGOVERN: What is not going to work is some of these deposition exhibits that go into the personal circumstances surrounding the divorce between Lynn and Craig Wright that have zero to do with bitcoin and IP and are clearly meant to harass the witness. That is not going to work. MR BRENNER: That we'll take up as it happens. But the time is - the time is what it is. It's not good for anyone, but we will power through. MR ROCHE: All right. Ms Wright --MS McGOVERN: Okay, Mr Brenner, let's go. MR ROCHE: -- I believe it's 23 minutes past the hour. Let's plan on reconvening at 50 minutes past the hour and I will try to move the deposition along as quickly as I can. THE VIDEOGRAPHER: Okay. Going off the record at Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 84 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2511:23:54 11:53:1511:53:19 11:53:21 11:53:28 11:53:32 11:53:34 11:53:39 11:53:42 11:53:51 11:53:54 11:53:5611:54:00 11:54:23 11:54:24 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 85 11.23. End of tape 2. (11.23am) (A short break) (11.53am) THE VIDEOGRAPHER: Going back on the record at 11.53am. Commencement of tape 3. Proceed. MR ROCHE: Sati, if you could introduce tab 38. BY MR ROCHE: Q.Ms Wright, let me know when you have the document that Sati is about to hand you in front of you. A.Yes. MR ROCHE: For the record, this is document with Bates stamp ending in 640897. THE VIDEOGRAPHER: USA, this is the videographer. You are introducing documents. Are you giving them exhibit numbers for our court reporter? MR ROCHE: Yes. Are you - what exhibit number are we on? THE COURT REPORTER: You didn't tender the document that was the subpoena, you just produced it. Do you want that marked as exhibit 4? MR ROCHE: Yes. Please mark that as exhibit 4, and, for the record, exhibit 4 is the subpoena served by plaintiffs to Miss Lynn Wright. (Exhibit 4 marked for identification)Case 9:18-cv-80176-BB Document 488-17 Entered on FLSD Docket 05/08/2020 Page 85 of 202 1 2 3 4 56 7 89 10 1112 13 14 15 1617 18 1920 21 2223 24 2511:54:32 11:54:33 11:54:45 11:54:45 11:54:4911:54:51 11:54:54 11:54:5511:54:59 11:55:04 11:55:0811:55:14 11:55:17 11:55:22 11:55:28 11:55:2911:55:30 11:55:33 11:55:36 11:55:37 11:55:42 11:55:47 11:55:48 11:55:51 11:55:5111:55:53 11:55:58 11:55:59 Epiq Suite 204, Level 2, 105 Pitt Street, Sydney, NSW 2000 Phone: Int + 61-2-92253500LYNN CARROLL WRIGHT January 13, 2020 86 MR ROCHE: And exhibit 5 is the document ending in Bates stamp 640897. (Exhibit 5 marked for identification) BY MR ROCHE: Q.Ms Wright do you recognize this document? A.No, I don't remember it. Q.Okay. So I'm just going to read - it is an email, it looks - it is an email chain between craig.wright@ - do you recognize that email address? A.No. I - I - very vaguely. I have some vague memory of the - of the - not the email address so much as the " " name. Q.Okay. And is Lynn - "lynnbw14@ " - is that you? A.Yes, it is. Q.Okay. And in this email, it's dated April 20th, 2015, Craig writes,
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/content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090127-Re__bitcoin-list_ Problems-87111(75056979.1).pdf
Nicholas Bohm Witness Statement - Exhibit
part 1 of 1 20090127-Re__bitcoin-list_ Problems-87111(75056979.1).pdf
120
447
Subject: Re: [bitcoin-list] Problems From: Nicholas Bohm <[email protected]> Date: 27/01/2009, 13:03 To: [email protected] Two further crashes yesterday at 21:16 and 23:59 (GMT). They seem to follow exactly the same pattern, and I don't know if there is likely to be anything informative in the log, but I attach it in case. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FF Deleted:debug.rar The original MIME headers for this a�achment are: Content-Type: applica�on/octet-stream; name="debug.rar" Content-Transfer-Encoding: base64 Content-Disposi�on: a�achment; filename="debug.rar" Attachments: Deleted:debug.rar 206 bytesRe: [bitcoin-list] Problems mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:09
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 1 of 1 20090127-Re__bitcoin-list_ Problems-87111(75056979.1).pdf ### Folder name: Nicholas Bohm Witness Statement - Exhibit ### File path: /content/Copa v Wright - Trial Documents/Witness Statements/Nicholas Bohm Witness Statement - Exhibit/20090127-Re__bitcoin-list_ Problems-87111(75056979.1).pdf ### File content: Subject: Re: [bitcoin-list] Problems From: Nicholas Bohm <[email protected]> Date: 27/01/2009, 13:03 To: [email protected] Two further crashes yesterday at 21:16 and 23:59 (GMT). They seem to follow exactly the same pattern, and I don't know if there is likely to be anything informative in the log, but I attach it in case. Regards, Nicholas -- Salkyns, Great Canfield, Takeley, Bishop's Stortford CM22 6SX, UK Phone 01279 870285 (+44 1279 870285) Mobile 07715 419728 (+44 7715 419728) PGP public key ID: 0x899DD7FF. Fingerprint: 5248 1320 B42E 84FC 1E8B A9E6 0912 AE66 899D D7FF Deleted:debug.rar The original MIME headers for this a�achment are: Content-Type: applica�on/octet-stream; name="debug.rar" Content-Transfer-Encoding: base64 Content-Disposi�on: a�achment; filename="debug.rar" Attachments: Deleted:debug.rar 206 bytesRe: [bitcoin-list] Problems mailbox:///Q:/Admin/Mail/Profiles/erj82dii.default/Mail/... 1 of 1 21/07/2023, 17:09
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/content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM26.pdf
Patrick Madden
part 9 of 9 Appendix PM26.pdf
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timestamps for this file are also contrary to normal operating conditions, in that the file has a recorded OS Created timestamp in 2020, but a last accessed date and Last Modified date significantly before then, in 2011 and 2008 respectively. I have highl ighted this document in blue text in the table above and set out the relevant metadata separately below. Original File name OS Created – Date and Time OS Last Modified – Date and Time OS Last Accessed - Date and Time Document retention.doc16/01/2020 02:54:00 01/01/2008 16:40:00 25/03/2011 20:17:00 36. I also note that the OS Created date and time, which is 16/01/2020, is only shortly before the date of the email to which it is attached, which was 18 January 2020. 37. I consider this to be irregular and that it may be indicative of the use of clock manipulati on techniques. A lthough I cannot be certain that this is the only way it could arise, I take this into account in the context of my conclusion below . Conclusion on ID_003927 and its attachment, and the documents within it. 38. ID_003927 is therefore an email which appears to have authentically been sent in January 2020. However, the ZIP file attached to the email features irregular metadata and the 2M ore specifically, with an NTFS -formated file system volume ID Original File Name OS Created – Date and Time OS Last Modified – Date and Time OS Last Accessed – Date and Time Author Application CreatedApplication Modified ID_003943 Microsoft Word – WKID Memo 26.03.11.pdf 25/03/2011 20:14:00 25/03/2011 20:14:00 25/03/2011 20:15:00 Admin 25/03/2011 21:14:52 25/03/2011 21:14:52 33. I observe that a ll but two of the user documents indicate “Lynn Wright” as the Last Author. I also observe that many of these documents are analysed separately in different Appendices to my report and I do not discuss them further here save to say that in many cases I have found the documents not to be authentic to their purported dates. 34. It can be seen that for several of these files, the L ast Accessed timestamp has been updated independently of the Last M odified timestamp, and matches the File C reated timestamp : this behaviour is typical of a File copy/paste operation on a standard Windows computer and is to be expected .I also observe that t he Last Accessed timestamp for the PDF file ID_003943 is 1 minute later than both the Created and L ast M odified timestamps . This is typical of a Standard Windows OS interacting with a standard storage device2. 35. Another document, “Document retention.doc” (ID_003933) however has “Craig S Wright” recorded as the author and last author. It can be observed that the file date and timestamps for this file are also contrary to normal operating conditions, in that the file has a recorded OS Created timestamp in 2020, but a last accessed date and Last Modified date significantly before then, in 2011 and 2008 respectively. I have highl ighted this document in blue text in the table above and set out the relevant metadata separately below. Original File name OS Created – Date and Time OS Last Modified – Date and Time OS Last Accessed - Date and Time Document retention.doc16/01/2020 02:54:00 01/01/2008 16:40:00 25/03/2011 20:17:00 36. I also note that the OS Created date and time, which is 16/01/2020, is only shortly before the date of the email to which it is attached, which was 18 January 2020. 37. I consider this to be irregular and that it may be indicative of the use of clock manipulati on techniques. A lthough I cannot be certain that this is the only way it could arise, I take this into account in the context of my conclusion below . Conclusion on ID_003927 and its attachment, and the documents within it. 38. ID_003927 is therefore an email which appears to have authentically been sent in January 2020. However, the ZIP file attached to the email features irregular metadata and the 2M ore specifically, with an NTFS -formated file system volume 11 - 11 - H/121/11{ID_003943} {ID_003933} {ID_003927} documents in the ZIP file include many of questionable authenticity, and for the reasons set out in this A ppendix (in the case of ID_003937 and ID_003933) and Appendix PM24 I do not consider it or the documents within it (listed above) it can be relied up on as an authentic. documents in the ZIP file include many of questionable authenticity, and for the reasons set out in this A ppendix (in the case of ID_003937 and ID_003933) and Appendix PM24 I do not consider it or the documents within it (listed above) it can be relied up on as an authentic. 12 - 12 - H/121/12{ID_003937} {ID_003933} {H/116}
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 9 of 9 Appendix PM26.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM26.pdf ### File content: timestamps for this file are also contrary to normal operating conditions, in that the file has a recorded OS Created timestamp in 2020, but a last accessed date and Last Modified date significantly before then, in 2011 and 2008 respectively. I have highl ighted this document in blue text in the table above and set out the relevant metadata separately below. Original File name OS Created – Date and Time OS Last Modified – Date and Time OS Last Accessed - Date and Time Document retention.doc16/01/2020 02:54:00 01/01/2008 16:40:00 25/03/2011 20:17:00 36. I also note that the OS Created date and time, which is 16/01/2020, is only shortly before the date of the email to which it is attached, which was 18 January 2020. 37. I consider this to be irregular and that it may be indicative of the use of clock manipulati on techniques. A lthough I cannot be certain that this is the only way it could arise, I take this into account in the context of my conclusion below . Conclusion on ID_003927 and its attachment, and the documents within it. 38. ID_003927 is therefore an email which appears to have authentically been sent in January 2020. However, the ZIP file attached to the email features irregular metadata and the 2M ore specifically, with an NTFS -formated file system volume ID Original File Name OS Created – Date and Time OS Last Modified – Date and Time OS Last Accessed – Date and Time Author Application CreatedApplication Modified ID_003943 Microsoft Word – WKID Memo 26.03.11.pdf 25/03/2011 20:14:00 25/03/2011 20:14:00 25/03/2011 20:15:00 Admin 25/03/2011 21:14:52 25/03/2011 21:14:52 33. I observe that a ll but two of the user documents indicate “Lynn Wright” as the Last Author. I also observe that many of these documents are analysed separately in different Appendices to my report and I do not discuss them further here save to say that in many cases I have found the documents not to be authentic to their purported dates. 34. It can be seen that for several of these files, the L ast Accessed timestamp has been updated independently of the Last M odified timestamp, and matches the File C reated timestamp : this behaviour is typical of a File copy/paste operation on a standard Windows computer and is to be expected .I also observe that t he Last Accessed timestamp for the PDF file ID_003943 is 1 minute later than both the Created and L ast M odified timestamps . This is typical of a Standard Windows OS interacting with a standard storage device2. 35. Another document, “Document retention.doc” (ID_003933) however has “Craig S Wright” recorded as the author and last author. It can be observed that the file date and timestamps for this file are also contrary to normal operating conditions, in that the file has a recorded OS Created timestamp in 2020, but a last accessed date and Last Modified date significantly before then, in 2011 and 2008 respectively. I have highl ighted this document in blue text in the table above and set out the relevant metadata separately below. Original File name OS Created – Date and Time OS Last Modified – Date and Time OS Last Accessed - Date and Time Document retention.doc16/01/2020 02:54:00 01/01/2008 16:40:00 25/03/2011 20:17:00 36. I also note that the OS Created date and time, which is 16/01/2020, is only shortly before the date of the email to which it is attached, which was 18 January 2020. 37. I consider this to be irregular and that it may be indicative of the use of clock manipulati on techniques. A lthough I cannot be certain that this is the only way it could arise, I take this into account in the context of my conclusion below . Conclusion on ID_003927 and its attachment, and the documents within it. 38. ID_003927 is therefore an email which appears to have authentically been sent in January 2020. However, the ZIP file attached to the email features irregular metadata and the 2M ore specifically, with an NTFS -formated file system volume 11 - 11 - H/121/11{ID_003943} {ID_003933} {ID_003927} documents in the ZIP file include many of questionable authenticity, and for the reasons set out in this A ppendix (in the case of ID_003937 and ID_003933) and Appendix PM24 I do not consider it or the documents within it (listed above) it can be relied up on as an authentic. documents in the ZIP file include many of questionable authenticity, and for the reasons set out in this A ppendix (in the case of ID_003937 and ID_003933) and Appendix PM24 I do not consider it or the documents within it (listed above) it can be relied up on as an authentic. 12 - 12 - H/121/12{ID_003937} {ID_003933} {H/116}
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font of the letter λ (with unicode -math); and the drawing of diagrams (with the package TikZ, coded to load the TikZ library arrows.meta ). They include the use of Lua code (requiring the package luacode with LuaLaTeX ). [Rosendahl 1 at section 3.7, G/7/43- 50]. 13. As well as the textual content of the output PDF from Dr Wright’s LaTeX files, also the location of elements on the pages cannot be reproduced without modern code. The code calls again on software packages and options which did not yet exist in 2009, including to set the geometry of the page and margins (in the case of main.tex, the command \\newgeometry ), the location of images on the page (with the command \\AddToShipoutPictureBG* ), the location display of margins. [Rosendahl 1 at section 3.7, G/7/43- 50]. 14. In each case, those packages and o ptions provide the very functionality which causes Dr Wright’s LaTeX files to output something resembling the original Bitcoin White Paper. If they were not used, the output PDF from Dr Wright’s LaTeX files would not resemble the original Bitcoin White Pap er at all. [Rosendahl 1 at 158, G/7/50] [Rosendahl / Lynch 1 at 5 Q/5/2]. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 112 of 167 15. In each case, by contrast, each of the observed characteristics of the Bitcoin White Paper were supported natively by OpenOffice in 2008 -2009 [Rosendahl 1 at 160, G/7/50] [Lynch 1 a t 116- 120 I/5/33]. 16. In respect of E -Cash -main.tex (file C), the file cannot be compiled at all on a 2008- 2009 version of LaTeX software, even with concerted effort to make the file compatible. [Rosendahl 1 at 106- 109 G/7/38]. 17. Dr Wright has stated that the se files should be compiled on Overleaf, a modern system which did not exist in 2008- 2009. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 18. The effect of creating these documents is to support Dr Wright’s story that the Bitcoin White Paper was created in LaTeX. The story is untrue, and is designed to be supportive of Dr Wright’s claim to be Satoshi Nakamoto (suggesting both special knowledge of the production of the paper and possession of material which only Satoshi could supposedly possess), contrary to fact. 19. E-Cash -main.tex (file C) is created by copying from Satoshi Nakamoto’s draft abstract (sent by email to Adam Back and Wei Dai in a for m available to Dr Wright) in reference to a document that was never published. The effect of creating this document is to support Dr Wright’s claim to be Satoshi Nakamoto by suggesting that he is in sole possession of the source of that unpublished document, contrary to fact. 20. Dr Wright has admitted to having created these files and being in sole possession of these files since they were created. Further, Dr Wright has averred that he has created and been in sole possession of these files since their creat ion, claiming that the “mere possession of these files is evidence of authorship of the White Paper” [Wright 6 E/21/3; Field 1 at 33, P3/13/11], and that they are “unique”. It is true only that the files are unique to Dr Wright. His possession and deployme nt of these files is indicative of a willingness to forge documents to be used as evidence before this Court. 21. On 30 September 2023, Christen Ager -Hanssen tweeted a screenshot indicating that Dr Wright’s browsing history showed that he had searched Google leading to the web page “Was anything in Satoshi Nakamoto’s original Bitcoin paper compiled in LaTeX?” L20/195/1 [Sherrell 19 at 65- 66 P1/18/24]. Dr Wright has stated that the screenshots of Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 113 of 167 his browsing history posted in tweets by Mr Ager -Hanssen were obt ained from his (Dr Wright’s) laptop computer [Wright 3 at 18- 19 E/3/6]. 22. These documents were then created during the course of the present proceedings using current technology: paragraphs 8, 9, 9 and 14 above are repeated. Dr Wright has created numerous other documents during the course of proceedings, as is a matter of agreement between all four forensic experts (including Dr Wright’s own instructed experts). 23. Dr Wright has stated in clear terms that “all graphical images in the White Paper were produced using LaTeX code” [Wright 4 at 6.c.i E/4/5]. However, the graphical images in the White Paper were not produced by LaTeX code. Par agraphs 7 to 9 above are repeated. 24. When ordered by this Court to descr ibe the software environment required to compile the document, Dr Wright did not simply state what the software is required. Instead, he provided a statement (Wright 8) that was verbose and vague. It is to be inferred that the purpose of the statement was to obscure relevant technical detail and supply irrelevant, technical -sounding information in its place and/or to provide scope for Dr Wright to give excuses for failures of his LaTeX files to compile into a true replica of the Bitcoin White Paper. 25. The fi les were taken from Dr Wright’s own LaTeX editing account, hosted on Overleaf. Dr Wright claimed that no metadata existed in relation to the files hosted on that account, but the claim was untrue and metadata does exist and had been accessible to Dr Wright prior to the time that he made that claim. Further, when ordered to provide access to the metadata, account history, and history of editing those files on Overleaf, Dr Wright did not disclose that data until compelled by further application to the Court. Yet further, while refusing to provide the metadata associated with his Overleaf account, Dr Wright has sought to alter and embellish his story in respect of the number and type of accounts hosted on Overleaf and the supposed method of transmission of the LaTeX files. 26. The metadata, as summarised in paragraph 9.3 above, directly implicate Dr Wright as being responsible for the recent creation of the Overleaf LaTeX files as forgeries. 27. Dr Wright has sought falsely to blame his former advisors for his failure to disclose these supposedly important documents at an earlier stage: Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 114 of 167 a. The story provided by Dr Wright in respect of failings by Dr Wright’s former solicitors, Ontier, is false. Paragraph 9.5 above is repeated. b. The story provided by Dr Wright in respect of failings by Dr Wright’s former e - disclosure providers, Alix Partners, is unsubstantiated
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 34 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### File content: font of the letter λ (with unicode -math); and the drawing of diagrams (with the package TikZ, coded to load the TikZ library arrows.meta ). They include the use of Lua code (requiring the package luacode with LuaLaTeX ). [Rosendahl 1 at section 3.7, G/7/43- 50]. 13. As well as the textual content of the output PDF from Dr Wright’s LaTeX files, also the location of elements on the pages cannot be reproduced without modern code. The code calls again on software packages and options which did not yet exist in 2009, including to set the geometry of the page and margins (in the case of main.tex, the command \\newgeometry ), the location of images on the page (with the command \\AddToShipoutPictureBG* ), the location display of margins. [Rosendahl 1 at section 3.7, G/7/43- 50]. 14. In each case, those packages and o ptions provide the very functionality which causes Dr Wright’s LaTeX files to output something resembling the original Bitcoin White Paper. If they were not used, the output PDF from Dr Wright’s LaTeX files would not resemble the original Bitcoin White Pap er at all. [Rosendahl 1 at 158, G/7/50] [Rosendahl / Lynch 1 at 5 Q/5/2]. Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 112 of 167 15. In each case, by contrast, each of the observed characteristics of the Bitcoin White Paper were supported natively by OpenOffice in 2008 -2009 [Rosendahl 1 at 160, G/7/50] [Lynch 1 a t 116- 120 I/5/33]. 16. In respect of E -Cash -main.tex (file C), the file cannot be compiled at all on a 2008- 2009 version of LaTeX software, even with concerted effort to make the file compatible. [Rosendahl 1 at 106- 109 G/7/38]. 17. Dr Wright has stated that the se files should be compiled on Overleaf, a modern system which did not exist in 2008- 2009. Reasons for Inference of Dr Wright’s Knowledge / Responsibility 18. The effect of creating these documents is to support Dr Wright’s story that the Bitcoin White Paper was created in LaTeX. The story is untrue, and is designed to be supportive of Dr Wright’s claim to be Satoshi Nakamoto (suggesting both special knowledge of the production of the paper and possession of material which only Satoshi could supposedly possess), contrary to fact. 19. E-Cash -main.tex (file C) is created by copying from Satoshi Nakamoto’s draft abstract (sent by email to Adam Back and Wei Dai in a for m available to Dr Wright) in reference to a document that was never published. The effect of creating this document is to support Dr Wright’s claim to be Satoshi Nakamoto by suggesting that he is in sole possession of the source of that unpublished document, contrary to fact. 20. Dr Wright has admitted to having created these files and being in sole possession of these files since they were created. Further, Dr Wright has averred that he has created and been in sole possession of these files since their creat ion, claiming that the “mere possession of these files is evidence of authorship of the White Paper” [Wright 6 E/21/3; Field 1 at 33, P3/13/11], and that they are “unique”. It is true only that the files are unique to Dr Wright. His possession and deployme nt of these files is indicative of a willingness to forge documents to be used as evidence before this Court. 21. On 30 September 2023, Christen Ager -Hanssen tweeted a screenshot indicating that Dr Wright’s browsing history showed that he had searched Google leading to the web page “Was anything in Satoshi Nakamoto’s original Bitcoin paper compiled in LaTeX?” L20/195/1 [Sherrell 19 at 65- 66 P1/18/24]. Dr Wright has stated that the screenshots of Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 113 of 167 his browsing history posted in tweets by Mr Ager -Hanssen were obt ained from his (Dr Wright’s) laptop computer [Wright 3 at 18- 19 E/3/6]. 22. These documents were then created during the course of the present proceedings using current technology: paragraphs 8, 9, 9 and 14 above are repeated. Dr Wright has created numerous other documents during the course of proceedings, as is a matter of agreement between all four forensic experts (including Dr Wright’s own instructed experts). 23. Dr Wright has stated in clear terms that “all graphical images in the White Paper were produced using LaTeX code” [Wright 4 at 6.c.i E/4/5]. However, the graphical images in the White Paper were not produced by LaTeX code. Par agraphs 7 to 9 above are repeated. 24. When ordered by this Court to descr ibe the software environment required to compile the document, Dr Wright did not simply state what the software is required. Instead, he provided a statement (Wright 8) that was verbose and vague. It is to be inferred that the purpose of the statement was to obscure relevant technical detail and supply irrelevant, technical -sounding information in its place and/or to provide scope for Dr Wright to give excuses for failures of his LaTeX files to compile into a true replica of the Bitcoin White Paper. 25. The fi les were taken from Dr Wright’s own LaTeX editing account, hosted on Overleaf. Dr Wright claimed that no metadata existed in relation to the files hosted on that account, but the claim was untrue and metadata does exist and had been accessible to Dr Wright prior to the time that he made that claim. Further, when ordered to provide access to the metadata, account history, and history of editing those files on Overleaf, Dr Wright did not disclose that data until compelled by further application to the Court. Yet further, while refusing to provide the metadata associated with his Overleaf account, Dr Wright has sought to alter and embellish his story in respect of the number and type of accounts hosted on Overleaf and the supposed method of transmission of the LaTeX files. 26. The metadata, as summarised in paragraph 9.3 above, directly implicate Dr Wright as being responsible for the recent creation of the Overleaf LaTeX files as forgeries. 27. Dr Wright has sought falsely to blame his former advisors for his failure to disclose these supposedly important documents at an earlier stage: Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 114 of 167 a. The story provided by Dr Wright in respect of failings by Dr Wright’s former solicitors, Ontier, is false. Paragraph 9.5 above is repeated. b. The story provided by Dr Wright in respect of failings by Dr Wright’s former e - disclosure providers, Alix Partners, is unsubstantiated
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the private signing sessions) . Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 12 of 167 The Second Pleaded Example The BlackNet Abstract (Particulars of Claim at [26] -[27] {A/2/9}) 1. On 10 February 2019, Wright published a picture of an abstract on Twitter regarding a project entitled ‘BlackNet’ which he asserts is an early iteration of the Bitcoin White Paper (the “BlackNet Abstract”). This abstract published by Wright appears to describe a Peer -to-Peer transaction system for sending “online consideration” without the use of a central intermediary. Wright asserts that the BlackNet Abstra ct was written in 2001 and submitted to the Australian Government. 2. The BlackNet Abstract is copied from the abstract of the Bitcoin White Paper. The abstract in the Draft Bitcoin White Paper from August 2008 was corrected and amended before it was finally published as the Bitcoin White Paper in October 2008. The BlackNet Abstract, despite Wright’s assertions that it was written in 2001, contains the corrections made between August 2008 and October 2008 and entered into the Bitcoin White Paper. In the premi ses, it is averred that the BlackNet Abstract is a copy of the abstract of the Bitcoin White Paper (i.e. the one published in October 2008 which contains the corrections made between August 2008 and October 2008) and is therefore not a document which preda tes either the Draft Bitcoin White Paper or the Bitcoin White Paper. Dr Wright’s Explanations and COPA’s Rebuttal 3. Dr Wright has accepted that the BlackNet Abstract was not taken from a document written in 2001. He claims that (a) he first submitted his BlackNet paper to AusIndustry in 2001 in applications for a research grant and tax rebate; (b) he successfully obtained rebates from 2001 to 2009; (c) he later made unsuccessful applications for grants and rebates in 2009 and 2010; (d) he updated the BlackNet paper on each occasion; and (e) the image of the BlackNet Abstract which he posted on Twitter in February 2019 was that used for one of the later applications. He claims that his Twitter post did not represent that the BlackNet Abstract was something he had written in 2001. See Defence at paras. 44 -46 {A/3/16} and Appendix C to Wright 11 {CSW/3/5}. 4. Dr Wright’s explanation should be rejected, for the following reasons: Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 13 of 167 a. The Twitter post {L14/294/1} stated: “My stupidest mistake was going t o the Australian Government in 2001 and filing this shit”. Below the message were images of the front page of the BlackNet paper and the BlackNet Abstract. The plain meaning of the post was that Dr Wright had filed the paper below, including the abstract shown, with the Australian Government in 2001 (not that he had filed a paper without that abstract in 2001 and a paper with that abstract in 2009 and 2010). In his evidence at trial, Dr Wright could only answer this point by saying: “I’m better with code than with words. So if you think that, that’s the problem” {Day2/92:6}. b. Other images in the Tweet (those headed “Approval by the company…” and “R&D Project Plan”) were plainly intended to show parts of the filing. Each prominently includes a date of 23 October 2001, thus reinforcing the message that the filing was made in 2001 and that all the images in the Tweet relate to the filing. c. The clear implication of the message was that Dr Wright had revealed his supposed involvement in creating Bitcoin to the Australian authorities in 2001 (a role which the abstract would have made clear) and that he now regretted having done so. d. Dr Wright’s account in his Defence on this point is at odds with accounts he has given elsewhere about the versions of the BlackNet paper which he filed with the Australian authorities at different times. In the Kleiman proceedings, he claimed that his filings with AusIndustry in 2002 (not only those in 2009/10) contained reference to elements of the Bitcoin system {L17/327/93}. In these proceedings, Dr Wright told the Court in his oral evidence that the versions of his BlackNet paper which contained reference to e lements of the Bitcoin system (i.e. the supposed Stage 4 of the project) were first filed in 2002 and 2003 {Day2/72:24}. All versions of the paper in disclosure which included reference to elements of the Bitcoin system contained the BlackNet Abstract. A ccordingly, there is a stark contrast between (i) his repeated evidence that he first filed versions of the paper including reference to elements of the Bitcoin system in 2002; and (ii) his account in the Defence that he first did this in 2009/10 (an account given in an effort to answer the issue raised in the Particulars of Claim about the content of the BlackNet Abstract). Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 14 of 167 e. The cover page of the supposed BlackNet Paper in the Tweet, pictured directly above the abstract is identified as Version 1.0, thus undermining Dr Wright’s suggestion that the abstract related to a late version of the paper. Furthermore, the cover page is identical to a version of the document which Dr Wright now claims was written in 2002 ({ID_001379} – addressed in Part 2 of this Sche dule). Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 15 of 167 The Third Pleaded Example The 12 March 2008 Kleiman email (Particulars of Claim at [28] – [29] {A/2/10}) 1. There are ongoing proceedings in the United States involving Wright, in which it is alleged that Wright stole a substantial amount of Bitcoin and related intellectual property assets from a company named W&K Info Defence Research, LLC, after the death of its founder, David Kleiman, by forging documents (the “Kleiman Litigation”). In those proceedings Wright asserts that he sent an email to Dav id Kleiman on 12 March 2008 which shows him to be the originator of the idea of Bitcoin. The email he claims to have sent is as follows: 2. The domain used by the sender of this email is ‘information- defense.com’, which was not created until 23 January 2009. In the premises, the email could not have been sent in 2008 as claimed from the “craig.wright@information- defense.com” email address. Dr Wright’s Explanations and COPA’s Rebuttal 3. In his Defence, Dr Wright claimed that he sent an email to Mr Kleiman on 12 March 2008 and that “the body of the email [cited in COPA’s Particulars of Claim] is
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 4 of 50 Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix A to COPA's Closing Submissions - Consolidated Forgery Schedule.pdf ### File content: the private signing sessions) . Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 12 of 167 The Second Pleaded Example The BlackNet Abstract (Particulars of Claim at [26] -[27] {A/2/9}) 1. On 10 February 2019, Wright published a picture of an abstract on Twitter regarding a project entitled ‘BlackNet’ which he asserts is an early iteration of the Bitcoin White Paper (the “BlackNet Abstract”). This abstract published by Wright appears to describe a Peer -to-Peer transaction system for sending “online consideration” without the use of a central intermediary. Wright asserts that the BlackNet Abstra ct was written in 2001 and submitted to the Australian Government. 2. The BlackNet Abstract is copied from the abstract of the Bitcoin White Paper. The abstract in the Draft Bitcoin White Paper from August 2008 was corrected and amended before it was finally published as the Bitcoin White Paper in October 2008. The BlackNet Abstract, despite Wright’s assertions that it was written in 2001, contains the corrections made between August 2008 and October 2008 and entered into the Bitcoin White Paper. In the premi ses, it is averred that the BlackNet Abstract is a copy of the abstract of the Bitcoin White Paper (i.e. the one published in October 2008 which contains the corrections made between August 2008 and October 2008) and is therefore not a document which preda tes either the Draft Bitcoin White Paper or the Bitcoin White Paper. Dr Wright’s Explanations and COPA’s Rebuttal 3. Dr Wright has accepted that the BlackNet Abstract was not taken from a document written in 2001. He claims that (a) he first submitted his BlackNet paper to AusIndustry in 2001 in applications for a research grant and tax rebate; (b) he successfully obtained rebates from 2001 to 2009; (c) he later made unsuccessful applications for grants and rebates in 2009 and 2010; (d) he updated the BlackNet paper on each occasion; and (e) the image of the BlackNet Abstract which he posted on Twitter in February 2019 was that used for one of the later applications. He claims that his Twitter post did not represent that the BlackNet Abstract was something he had written in 2001. See Defence at paras. 44 -46 {A/3/16} and Appendix C to Wright 11 {CSW/3/5}. 4. Dr Wright’s explanation should be rejected, for the following reasons: Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 13 of 167 a. The Twitter post {L14/294/1} stated: “My stupidest mistake was going t o the Australian Government in 2001 and filing this shit”. Below the message were images of the front page of the BlackNet paper and the BlackNet Abstract. The plain meaning of the post was that Dr Wright had filed the paper below, including the abstract shown, with the Australian Government in 2001 (not that he had filed a paper without that abstract in 2001 and a paper with that abstract in 2009 and 2010). In his evidence at trial, Dr Wright could only answer this point by saying: “I’m better with code than with words. So if you think that, that’s the problem” {Day2/92:6}. b. Other images in the Tweet (those headed “Approval by the company…” and “R&D Project Plan”) were plainly intended to show parts of the filing. Each prominently includes a date of 23 October 2001, thus reinforcing the message that the filing was made in 2001 and that all the images in the Tweet relate to the filing. c. The clear implication of the message was that Dr Wright had revealed his supposed involvement in creating Bitcoin to the Australian authorities in 2001 (a role which the abstract would have made clear) and that he now regretted having done so. d. Dr Wright’s account in his Defence on this point is at odds with accounts he has given elsewhere about the versions of the BlackNet paper which he filed with the Australian authorities at different times. In the Kleiman proceedings, he claimed that his filings with AusIndustry in 2002 (not only those in 2009/10) contained reference to elements of the Bitcoin system {L17/327/93}. In these proceedings, Dr Wright told the Court in his oral evidence that the versions of his BlackNet paper which contained reference to e lements of the Bitcoin system (i.e. the supposed Stage 4 of the project) were first filed in 2002 and 2003 {Day2/72:24}. All versions of the paper in disclosure which included reference to elements of the Bitcoin system contained the BlackNet Abstract. A ccordingly, there is a stark contrast between (i) his repeated evidence that he first filed versions of the paper including reference to elements of the Bitcoin system in 2002; and (ii) his account in the Defence that he first did this in 2009/10 (an account given in an effort to answer the issue raised in the Particulars of Claim about the content of the BlackNet Abstract). Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 14 of 167 e. The cover page of the supposed BlackNet Paper in the Tweet, pictured directly above the abstract is identified as Version 1.0, thus undermining Dr Wright’s suggestion that the abstract related to a late version of the paper. Furthermore, the cover page is identical to a version of the document which Dr Wright now claims was written in 2002 ({ID_001379} – addressed in Part 2 of this Sche dule). Appendix A to COPA’s Closing Skeleton Argument Consolidated Schedule of Dr Wright’s Forgeries Page 15 of 167 The Third Pleaded Example The 12 March 2008 Kleiman email (Particulars of Claim at [28] – [29] {A/2/10}) 1. There are ongoing proceedings in the United States involving Wright, in which it is alleged that Wright stole a substantial amount of Bitcoin and related intellectual property assets from a company named W&K Info Defence Research, LLC, after the death of its founder, David Kleiman, by forging documents (the “Kleiman Litigation”). In those proceedings Wright asserts that he sent an email to Dav id Kleiman on 12 March 2008 which shows him to be the originator of the idea of Bitcoin. The email he claims to have sent is as follows: 2. The domain used by the sender of this email is ‘information- defense.com’, which was not created until 23 January 2009. In the premises, the email could not have been sent in 2008 as claimed from the “craig.wright@information- defense.com” email address. Dr Wright’s Explanations and COPA’s Rebuttal 3. In his Defence, Dr Wright claimed that he sent an email to Mr Kleiman on 12 March 2008 and that “the body of the email [cited in COPA’s Particulars of Claim] is
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people in person. Q. So is Mr Wilcox- O'Hearn overstating the connection between you? A. I mean, I wouldn't put a strong kind of feeling on that. You know, maybe some people feel differently about online conversations to in- person friendships, for example. Q. And are you still friendly with Mr Wilcox- O'Hearn? Mr Orr KC questioning Dr Back on the statements about him in Mr Wilcox- O’Hearn’s witness statement. Dr Back confirming that he is not on good terms with Mr Wilcox -O’Hearn, thereby reinforcing the independence of COPA’s witnesses of fact. Appendix B: Schedule of Transcript References 459 REFERENCE QUOTE COMMENT A. Actually, he blocked me on Twitter some time ago, so evidently not. Q. And what was the cause of that? A. Well, he s tarted Milk(?) Coin and I had some things to say about that which he didn't like. {H/182/6} -{H/182/7} – Exhibit SM -10 – Bitcoin’s Academic Pedigree by Arvind Narayanan & Jeremy Clark {Day13/43:8} – {{Day13/44:24} Q. Is that a fair description of the kind of research that was being undertaken on proof -of-work in the late 1990s and early 2000s? A. Yes, I mean, there seemed to be multiple people inventing similar things over time. For example, Juels and Brainard's client puzzles, they were unaware of Hashcash and their system is superficially similar. Like, in hindsight, being aware of Hashcash, you could see how to modify Juels and Brainard's later proposal to be as -- to work as Hashcash does, but they do it in an interactive setting, so -- and there are multiple threads like this. The -- I think, one thing to be aware of is the -- even though I have a PhD academic background, I was operating in a more applied sphere here where I was trying to -- interested in designing things that would be secure in practice and there's a bit of a kind of two silos in this kind of research, where the academic silos were interested in publication track records and the sort of applied people are interested in building things, and in th is part of my career I was more interested in building things. So there are certainly cases where the academics were unaware of the applied and also where the applied, ie myself, aren't fully aware of the publication records stretching back years. Q. Now, at the beginning of that answer, you said, "there seemed to be multiple people inventing similar things over time"? A. Yes. Q. And it's fair to say that, by the early 2000s, there was a rich source of academic materials on proof -of-work systems? A. Yes , I mean, there was a track on memory hard proof -of- work, which proved to create a lot of papers, and when you get a new idea that enters people's consciousness, sort of the buzz at the moment, you get a lot of sort of derivative papers that think of appli cations of it or ways to incorporate it into other systems, so there's quite a bit of activity arising from that. And I think there were many more applied people familiar with Mr Orr KC asking about the research being undertaken on proof -of-work in the late 1990s -early 2000s. Appendix B: Schedule of Transcript References 460 REFERENCE QUOTE COMMENT Hashcash than would have been familiar with the academic history as well. {CSW/169/5} – DOS - Resistant Authentication with Client Puzzles by Pekka Nikander & Tuomas Aura {L3/231/3} – Bitcoin White Paper Section 4 – Proof of Work {Day13/47:16} – {Day13/50:24} Q. Now, in Bitcoin, the proof -of-work involves scanning for a value that, when hashed, the hash begins with a specified number of zero bits; that's right, isn't it? A. It's a simplification. It's because the -- this paper and the Hashcash paper is concern ing itself with a very coarse -grained type of work where the difficulty can only adjust by a factor of two, then it's leading zeros, but in the Bitcoin case, the precision is much higher, so that it's technically to find a hash which is less than a target. Now, because that is a small – small number relatively, it will have a lot of leading zeros, but technically it's a little more than that, which is, you know, the first digit of the -- that isn't zero has to be below the target and so on, as a kind of flo ating point number. Q. Now -- well -- so I'm not quite sure what you're saying in that answer, because what I've put to you is precisely how the proof -of-work is described in the Bitcoin White Paper; do you follow? A. Yeah. I'm saying that the -- the way that Bitcoin uses the proof -of-work is a little different. So, when I designed Hashcash, I was -- I considered the case for that difficulty to vary by smaller increments than a factor of two. This paper appears to also use the factor of two simplification , but Bitcoin doesn't, and so Bitcoin is not just looking for leading zeros; it's looking for, you know, one number treated as a floating point to be less than another. And so leading zeros could result -- you know, the specification is not a number of lea ding zeros in Bitcoin, the specification is a difficulty which is the floating point number. But, you know, still at high level, you can see that there's a lot of work done and you're within a factor of, you know, a small distance of it having the right am ount of work, but just in the fine detail, there could be, and there frequently are, Bitcoin proofs of work that have, you know, superficially the right number of zeros, but they're incorrect in the first digit or something. So really it's less than a targ et. Now I would say this is a fairly obvious optimisation and something I considered in the original Hashcash paper. This paper seems to take the same simplification that I did for the email use case. Q. Can I try to deal with this this way. Can we go to the Bitcoin White Paper in {L3/231/3}. Under the heading "Proof -of-Dr Back explaining why the proof -of-work in the Bitcoin White Paper is similar to that in Hashcash, rather than that in the Tuomas Aura paper as asserted by Dr Wright. Appendix B: Schedule of Transcript References 461
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 182 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: people in person. Q. So is Mr Wilcox- O'Hearn overstating the connection between you? A. I mean, I wouldn't put a strong kind of feeling on that. You know, maybe some people feel differently about online conversations to in- person friendships, for example. Q. And are you still friendly with Mr Wilcox- O'Hearn? Mr Orr KC questioning Dr Back on the statements about him in Mr Wilcox- O’Hearn’s witness statement. Dr Back confirming that he is not on good terms with Mr Wilcox -O’Hearn, thereby reinforcing the independence of COPA’s witnesses of fact. Appendix B: Schedule of Transcript References 459 REFERENCE QUOTE COMMENT A. Actually, he blocked me on Twitter some time ago, so evidently not. Q. And what was the cause of that? A. Well, he s tarted Milk(?) Coin and I had some things to say about that which he didn't like. {H/182/6} -{H/182/7} – Exhibit SM -10 – Bitcoin’s Academic Pedigree by Arvind Narayanan & Jeremy Clark {Day13/43:8} – {{Day13/44:24} Q. Is that a fair description of the kind of research that was being undertaken on proof -of-work in the late 1990s and early 2000s? A. Yes, I mean, there seemed to be multiple people inventing similar things over time. For example, Juels and Brainard's client puzzles, they were unaware of Hashcash and their system is superficially similar. Like, in hindsight, being aware of Hashcash, you could see how to modify Juels and Brainard's later proposal to be as -- to work as Hashcash does, but they do it in an interactive setting, so -- and there are multiple threads like this. The -- I think, one thing to be aware of is the -- even though I have a PhD academic background, I was operating in a more applied sphere here where I was trying to -- interested in designing things that would be secure in practice and there's a bit of a kind of two silos in this kind of research, where the academic silos were interested in publication track records and the sort of applied people are interested in building things, and in th is part of my career I was more interested in building things. So there are certainly cases where the academics were unaware of the applied and also where the applied, ie myself, aren't fully aware of the publication records stretching back years. Q. Now, at the beginning of that answer, you said, "there seemed to be multiple people inventing similar things over time"? A. Yes. Q. And it's fair to say that, by the early 2000s, there was a rich source of academic materials on proof -of-work systems? A. Yes , I mean, there was a track on memory hard proof -of- work, which proved to create a lot of papers, and when you get a new idea that enters people's consciousness, sort of the buzz at the moment, you get a lot of sort of derivative papers that think of appli cations of it or ways to incorporate it into other systems, so there's quite a bit of activity arising from that. And I think there were many more applied people familiar with Mr Orr KC asking about the research being undertaken on proof -of-work in the late 1990s -early 2000s. Appendix B: Schedule of Transcript References 460 REFERENCE QUOTE COMMENT Hashcash than would have been familiar with the academic history as well. {CSW/169/5} – DOS - Resistant Authentication with Client Puzzles by Pekka Nikander & Tuomas Aura {L3/231/3} – Bitcoin White Paper Section 4 – Proof of Work {Day13/47:16} – {Day13/50:24} Q. Now, in Bitcoin, the proof -of-work involves scanning for a value that, when hashed, the hash begins with a specified number of zero bits; that's right, isn't it? A. It's a simplification. It's because the -- this paper and the Hashcash paper is concern ing itself with a very coarse -grained type of work where the difficulty can only adjust by a factor of two, then it's leading zeros, but in the Bitcoin case, the precision is much higher, so that it's technically to find a hash which is less than a target. Now, because that is a small – small number relatively, it will have a lot of leading zeros, but technically it's a little more than that, which is, you know, the first digit of the -- that isn't zero has to be below the target and so on, as a kind of flo ating point number. Q. Now -- well -- so I'm not quite sure what you're saying in that answer, because what I've put to you is precisely how the proof -of-work is described in the Bitcoin White Paper; do you follow? A. Yeah. I'm saying that the -- the way that Bitcoin uses the proof -of-work is a little different. So, when I designed Hashcash, I was -- I considered the case for that difficulty to vary by smaller increments than a factor of two. This paper appears to also use the factor of two simplification , but Bitcoin doesn't, and so Bitcoin is not just looking for leading zeros; it's looking for, you know, one number treated as a floating point to be less than another. And so leading zeros could result -- you know, the specification is not a number of lea ding zeros in Bitcoin, the specification is a difficulty which is the floating point number. But, you know, still at high level, you can see that there's a lot of work done and you're within a factor of, you know, a small distance of it having the right am ount of work, but just in the fine detail, there could be, and there frequently are, Bitcoin proofs of work that have, you know, superficially the right number of zeros, but they're incorrect in the first digit or something. So really it's less than a targ et. Now I would say this is a fairly obvious optimisation and something I considered in the original Hashcash paper. This paper seems to take the same simplification that I did for the email use case. Q. Can I try to deal with this this way. Can we go to the Bitcoin White Paper in {L3/231/3}. Under the heading "Proof -of-Dr Back explaining why the proof -of-work in the Bitcoin White Paper is similar to that in Hashcash, rather than that in the Tuomas Aura paper as asserted by Dr Wright. Appendix B: Schedule of Transcript References 461
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the work of Dr Wright, the company Squire Mining, haven't you? A. Craig Wright had nothing to do with Squire Mining -- oh, sorry, he did take a shareholding position in a -- a capital raise that occurred at one stage, yes, you are right. Mr Matth ews admits that Dr Wright took a shareholding position in Squire Mining, another company seeking to profit from his work. {M1/1/707} Letter from Clyde & Co on behalf of Zafar Ali KC & Ted Loveday dated 10 November 2023 Appendix B: Schedule of Transcript References 377 REFERENCE QUOTE COMMENT {Day11/61:9- 19} Q. -- their professional conduct, and then they instructed solicitors, Clyde & Co, who wrote this letter on their behalf. Is the context now clear? A. Yes. Q. And paragraph 2, they say -- Clyde & Co say on behalf of Mr Ali and Mr Loveday: ".. our clients were instruct ed by nChain UK Limited .." Pausing there, is it right that they were instructed by nChain UK Limited? A. No. Mr Matthews refutes information provided by Clyde & Co, who would have no interest in providing false information, denying that Mr Ali and Mr Love day were instructed by nChain UK Limited. {Day11/61:20} – {Day11/62:9} Q. It then says that -- it then describes nChain UK Limited as: ".. the funder and supporter of litigation involving Dr Wright .." Is that right or wrong? A. That is incorrect. Q. So, is it right or wrong that nChain has provided funding for Dr Wright's litigation, directly or indirectly? A. That is incorrect. Q. You're saying that nChain has never provided funding, even indirectly through loans or transfer of shares, or anything li ke that, to support Dr Wright in his litigation? A. Correct. Mr Matthews’ denying that nChain is providing funding for Dr Wright’s litigation, either directly or indirectly, contrary to the letter from Clyde & Co. {Day11/62:13- 18} Q. How do you say, to y our knowledge, Dr Wright's litigation has been funded, including his costs in these proceedings? A. I've never been involved in -- in details of how Dr Wright has funded these proceedings. Anything I may have read would only be hearsay. When asked about how Dr Wright’s litigation has been funded, Mr Matthews does not answer the question. {Day11/63:3} – {Day11/64:9} Q. That document featured Dr Wright's claim to be Satoshi because it was thought to improve the appeal of the company in the market, right? A. No, I would disagree with that. Q. Why -- A. We weren't going to market. Q. Why do you say that Dr Wright's claim to be Satoshi was prominently featured in the company's IM? A. Just for reference, because it's true. Q. And it's because nChain stands to be nefit from Craig Wright being Satoshi that it went to the trouble and cost of retaining lawyers to work on this case; that's right, isn't it? A. NChain haven't retained lawyers to work on this case. Q. Would you accept this at least, that nChain, a company whose whole business is crypto technology, would benefit, or Mr Matthews is asked about whether Dr Wright’s claim to be Satoshi improved the appeal of nChain. Mr Matthews is evasive in response, failing to directly answer the question bei ng put to him and answering a different question to that asked. Appendix B: Schedule of Transcript References 378 REFERENCE QUOTE COMMENT stand to benefit if Dr Wright was found to be the founder of cryptocurrencies? A. NChain is not a crypto company. NChain is a blockchain software research company. It doesn't trade in cry ptos, it doesn't create cryptos, it doesn't -- it doesn't have any connection with cryptos. Q. Would you accept that nChain, giving it the description you've given it, would stand to benefit if Dr Wright were found to be Satoshi Nakamoto, the creator of the Bitcoin technology and the blockchain? A. NChain's value is in its intellectual property and its products. Just because Dr Wright's name appears on a number of patent filings doesn't make those patent filings any more or less valuable. The patents are va lued on their -- on their ability to be able to generate meaningful solutions. {Day11/64:10- 18} Q. So you don't think nChain, despite prominently touting Dr Wright's claim in its IM, would stand to benefit if that claim were found to be right? A. I don't think the value of nChain's patents change at all; it's the technology which is the value. The fact that it was created or partially created by Dr Wright and others within the research team I don't think adds any -- any -- or detracts any value one way or the other. Mr Matthews is evasive, failing to directly answer the question being put to him. He refuses to accept the obvious truth that the value of nChain’s assets will be impacted by the outcome of these proceedings. There are tweets by Calvin Ayre which contradict t his at {L20/252.5/1}, {L20/252.7/1}, {L20/252.11/1}, {L20/252.4/1}, {L20/252.3/1 {Day11/64:19} – {Day11/65:2} Q. You don't think it would have any effect on nChain's value or its profitability as a business? A. Well, we've never -- we've never relied on that, despite what you've been asserting. Q. Well, it's a simple question, and I think you still haven't answered. You're saying, are you, that you don't think nChain's value or profitability would be improved by Dr Wright being found to be Satoshi? A. Not by any material value, no. Mr Matthews continues to be evasive when pressed for an answer to the original question (whether Dr Wright’s claim to be Satoshi would affect nChain’s value/profitability), failing to directly answer the question being put to hi m. Mr Matthews finally Appendix B: Schedule of Transcript References 379 REFERENCE QUOTE COMMENT answers by stating, implausibly, that nChain’s value/profitability would not be improved “by any material value”. {E/5/25} First Witness Statement of Stefan Matthews {Day11/65:8- 10} Q. Does Mr Ayre also have substantial holdings in BSV, either directly or indirectly? A. I have no idea. I'm not involved in Mr Ayre's business. Mr Matthews’s answer is implausible. As Co- founder and Executive Chairman of nChain he would be expected to have knowledge of the majorit y shareholder’s business interests. Calvin Ayre has been a vocal supporter of BSV for years, and it lacks credibility for Mr Matthews to state that he would have no knowledge of this. {L20/252.3/1} Capture of Calvin Ayre X
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Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 151 of 220 Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### Folder name: Closings ### File path: /content/Copa v Wright - Trial Documents/Skeletons/Closings/Appendix B to COPA's Closing Submissions - Schedule of Transcript References.pdf ### File content: the work of Dr Wright, the company Squire Mining, haven't you? A. Craig Wright had nothing to do with Squire Mining -- oh, sorry, he did take a shareholding position in a -- a capital raise that occurred at one stage, yes, you are right. Mr Matth ews admits that Dr Wright took a shareholding position in Squire Mining, another company seeking to profit from his work. {M1/1/707} Letter from Clyde & Co on behalf of Zafar Ali KC & Ted Loveday dated 10 November 2023 Appendix B: Schedule of Transcript References 377 REFERENCE QUOTE COMMENT {Day11/61:9- 19} Q. -- their professional conduct, and then they instructed solicitors, Clyde & Co, who wrote this letter on their behalf. Is the context now clear? A. Yes. Q. And paragraph 2, they say -- Clyde & Co say on behalf of Mr Ali and Mr Loveday: ".. our clients were instruct ed by nChain UK Limited .." Pausing there, is it right that they were instructed by nChain UK Limited? A. No. Mr Matthews refutes information provided by Clyde & Co, who would have no interest in providing false information, denying that Mr Ali and Mr Love day were instructed by nChain UK Limited. {Day11/61:20} – {Day11/62:9} Q. It then says that -- it then describes nChain UK Limited as: ".. the funder and supporter of litigation involving Dr Wright .." Is that right or wrong? A. That is incorrect. Q. So, is it right or wrong that nChain has provided funding for Dr Wright's litigation, directly or indirectly? A. That is incorrect. Q. You're saying that nChain has never provided funding, even indirectly through loans or transfer of shares, or anything li ke that, to support Dr Wright in his litigation? A. Correct. Mr Matthews’ denying that nChain is providing funding for Dr Wright’s litigation, either directly or indirectly, contrary to the letter from Clyde & Co. {Day11/62:13- 18} Q. How do you say, to y our knowledge, Dr Wright's litigation has been funded, including his costs in these proceedings? A. I've never been involved in -- in details of how Dr Wright has funded these proceedings. Anything I may have read would only be hearsay. When asked about how Dr Wright’s litigation has been funded, Mr Matthews does not answer the question. {Day11/63:3} – {Day11/64:9} Q. That document featured Dr Wright's claim to be Satoshi because it was thought to improve the appeal of the company in the market, right? A. No, I would disagree with that. Q. Why -- A. We weren't going to market. Q. Why do you say that Dr Wright's claim to be Satoshi was prominently featured in the company's IM? A. Just for reference, because it's true. Q. And it's because nChain stands to be nefit from Craig Wright being Satoshi that it went to the trouble and cost of retaining lawyers to work on this case; that's right, isn't it? A. NChain haven't retained lawyers to work on this case. Q. Would you accept this at least, that nChain, a company whose whole business is crypto technology, would benefit, or Mr Matthews is asked about whether Dr Wright’s claim to be Satoshi improved the appeal of nChain. Mr Matthews is evasive in response, failing to directly answer the question bei ng put to him and answering a different question to that asked. Appendix B: Schedule of Transcript References 378 REFERENCE QUOTE COMMENT stand to benefit if Dr Wright was found to be the founder of cryptocurrencies? A. NChain is not a crypto company. NChain is a blockchain software research company. It doesn't trade in cry ptos, it doesn't create cryptos, it doesn't -- it doesn't have any connection with cryptos. Q. Would you accept that nChain, giving it the description you've given it, would stand to benefit if Dr Wright were found to be Satoshi Nakamoto, the creator of the Bitcoin technology and the blockchain? A. NChain's value is in its intellectual property and its products. Just because Dr Wright's name appears on a number of patent filings doesn't make those patent filings any more or less valuable. The patents are va lued on their -- on their ability to be able to generate meaningful solutions. {Day11/64:10- 18} Q. So you don't think nChain, despite prominently touting Dr Wright's claim in its IM, would stand to benefit if that claim were found to be right? A. I don't think the value of nChain's patents change at all; it's the technology which is the value. The fact that it was created or partially created by Dr Wright and others within the research team I don't think adds any -- any -- or detracts any value one way or the other. Mr Matthews is evasive, failing to directly answer the question being put to him. He refuses to accept the obvious truth that the value of nChain’s assets will be impacted by the outcome of these proceedings. There are tweets by Calvin Ayre which contradict t his at {L20/252.5/1}, {L20/252.7/1}, {L20/252.11/1}, {L20/252.4/1}, {L20/252.3/1 {Day11/64:19} – {Day11/65:2} Q. You don't think it would have any effect on nChain's value or its profitability as a business? A. Well, we've never -- we've never relied on that, despite what you've been asserting. Q. Well, it's a simple question, and I think you still haven't answered. You're saying, are you, that you don't think nChain's value or profitability would be improved by Dr Wright being found to be Satoshi? A. Not by any material value, no. Mr Matthews continues to be evasive when pressed for an answer to the original question (whether Dr Wright’s claim to be Satoshi would affect nChain’s value/profitability), failing to directly answer the question being put to hi m. Mr Matthews finally Appendix B: Schedule of Transcript References 379 REFERENCE QUOTE COMMENT answers by stating, implausibly, that nChain’s value/profitability would not be improved “by any material value”. {E/5/25} First Witness Statement of Stefan Matthews {Day11/65:8- 10} Q. Does Mr Ayre also have substantial holdings in BSV, either directly or indirectly? A. I have no idea. I'm not involved in Mr Ayre's business. Mr Matthews’s answer is implausible. As Co- founder and Executive Chairman of nChain he would be expected to have knowledge of the majorit y shareholder’s business interests. Calvin Ayre has been a vocal supporter of BSV for years, and it lacks credibility for Mr Matthews to state that he would have no knowledge of this. {L20/252.3/1} Capture of Calvin Ayre X
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14 Openoffice.org software version 24. Within the metadata ,there is also a field identifying the “generator”. This contains the text “<meta:generator>OpenOffice.org/2.4$Win32 OpenOffice.org_project/680m12$Build- 9286</meta:generator> ”. This relates to the specific build of the Open Office.org software that was used to create the document, indicating that: a. The software was OpenOffice.org for Windows (“Win32”). b. The version of the software was version 2.4. c. There is also a build number specified. 25. I am not as immediately familiar with the versions of OpenOffice.org as I am with Microsoft Office, and so I checked the release dates for the software. On the website for OpenOffice .org itself1, it lists the various product release dates. Version 2.4 of the software is listed as only having been released on 27 March 2008 as per the screenshot below (the relevant link is underlined because my mouse cursor was hovering over it at the time of creating the screenshot): 1h tps://wiki.openoffice.org/wiki/Product_Release9 - 9 - H/107/9 Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 10of 14 26. The installation file for Open Office 2.4 is still available for download from a mirror listed on the OpenOffice website, 2which is where I obtained a copy of the software used as I de scribed above. 27. The mi rror website from which I sourced the file had an associated timestamp for the Installation file of 16 March 2008 at 12:52, which I note is earlier than the listed Release date in the screenshot above (March 27th, 2008) : 2A “mirror” in this context is a different server hos�ng a copy of the content referred to, allowing for it to be downloaded from more than one place. The URL of the mirror listed was htp://�p5.gwdg.de/pub/openoffice/archive/stable/2.4.0/ Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 10of 14 26. The installation file for Open Office 2.4 is still available for download from a mirror listed on the OpenOffice website, 2which is where I obtained a copy of the software used as I de scribed above. 27. The mi rror website from which I sourced the file had an associated timestamp for the Installation file of 16 March 2008 at 12:52, which I note is earlier than the listed Release date in the screenshot above (March 27th, 2008) : 2A “mirror” in this context is a different server hos�ng a copy of the content referred to, allowing for it to be downloaded from more than one place. The URL of the mirror listed was htp://�p5.gwdg.de/pub/openoffice/archive/stable/2.4.0/ 10 - 10 - H/107/10 Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 11 of 14 28. Having installed this version, I created a test document and saved it . Doing so produced a metadata generator tag within that document identical to that observed in ID_000260: “OpenOffice.org/2.4$Win32 OpenOffice.org_project/680m12$Build- 9286” 29. I observed that not only the version but also the “build” number were the same. 30. This therefore confirmed my view that OpenOffice.org software had been used to author ID_000260. However, the apparent upload date of that software was 16 March 2008 and its release date was 27 March 2008, both of which were after the “C reated” and “L ast Saved” date of ID_000260 (8 -9 March 2008). 31. The dates were therefore contradictory. In my view, it should not have been possible to generate the observed metadata tags within ID_000260 before the creation of OpenOffice.org 2.4, without the use of clock manipulation techniques. Even if the document was opened in an earlier version of OpenOffice.org W riter and later edited after the software was upgraded to v2.4, no changes would have been committed to the file without a Save operation having been performed. However, doing so would have updated the “Last Saved” and “Last Modified” timestamps to match the date of that save, which necessarily would have needed to be afterthe release of OpenOffice.org 2.4. 32. This led me to doubt the authenticity of ID_000260 and to the initial conclusion that it could not be relied upon as authentic to its purported creation date. Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 11 of 14 28. Having installed this version, I created a test document and saved it . Doing so produced a metadata generator tag within that document identical to that observed in ID_000260: “OpenOffice.org/2.4$Win32 OpenOffice.org_project/680m12$Build- 9286” 29. I observed that not only the version but also the “build” number were the same. 30. This therefore confirmed my view that OpenOffice.org software had been used to author ID_000260. However, the apparent upload date of that software was 16 March 2008 and its release date was 27 March 2008, both of which were after the “C reated” and “L ast Saved” date of ID_000260 (8 -9 March 2008). 31. The dates were therefore contradictory. In my view, it should not have been possible to generate the observed metadata tags within ID_000260 before the creation of OpenOffice.org 2.4, without the use of clock manipulation techniques. Even if the document was opened in an earlier version of OpenOffice.org W riter and later edited after the software was upgraded to v2.4, no changes would have been committed to the file without a Save operation having been performed. However, doing so would have updated the “Last Saved” and “Last Modified” timestamps to match the date of that save, which necessarily would have needed to be afterthe release of OpenOffice.org 2.4. 32. This led me to doubt the authenticity of ID_000260 and to the initial conclusion that it could not be relied upon as authentic to its purported creation date. 11 - 11 - H/107/11{ID_000260} {ID_000260} {ID_000260} {ID_000260} Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page
948
Trial document files for the COPA v Wright case. The claimant is CRYPTO OPEN PATENT ALLIANCE (COPA). The defendant is DR CRAIG STEVEN WRIGHT (Craig Wright). ### File name: part 5 of 7 Appendix PM23.pdf ### Folder name: Patrick Madden ### File path: /content/Copa v Wright - Trial Documents/Expert Reports/Patrick Madden/Appendix PM23.pdf ### File content: 14 Openoffice.org software version 24. Within the metadata ,there is also a field identifying the “generator”. This contains the text “<meta:generator>OpenOffice.org/2.4$Win32 OpenOffice.org_project/680m12$Build- 9286</meta:generator> ”. This relates to the specific build of the Open Office.org software that was used to create the document, indicating that: a. The software was OpenOffice.org for Windows (“Win32”). b. The version of the software was version 2.4. c. There is also a build number specified. 25. I am not as immediately familiar with the versions of OpenOffice.org as I am with Microsoft Office, and so I checked the release dates for the software. On the website for OpenOffice .org itself1, it lists the various product release dates. Version 2.4 of the software is listed as only having been released on 27 March 2008 as per the screenshot below (the relevant link is underlined because my mouse cursor was hovering over it at the time of creating the screenshot): 1h tps://wiki.openoffice.org/wiki/Product_Release9 - 9 - H/107/9 Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 10of 14 26. The installation file for Open Office 2.4 is still available for download from a mirror listed on the OpenOffice website, 2which is where I obtained a copy of the software used as I de scribed above. 27. The mi rror website from which I sourced the file had an associated timestamp for the Installation file of 16 March 2008 at 12:52, which I note is earlier than the listed Release date in the screenshot above (March 27th, 2008) : 2A “mirror” in this context is a different server hos�ng a copy of the content referred to, allowing for it to be downloaded from more than one place. The URL of the mirror listed was htp://�p5.gwdg.de/pub/openoffice/archive/stable/2.4.0/ Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 10of 14 26. The installation file for Open Office 2.4 is still available for download from a mirror listed on the OpenOffice website, 2which is where I obtained a copy of the software used as I de scribed above. 27. The mi rror website from which I sourced the file had an associated timestamp for the Installation file of 16 March 2008 at 12:52, which I note is earlier than the listed Release date in the screenshot above (March 27th, 2008) : 2A “mirror” in this context is a different server hos�ng a copy of the content referred to, allowing for it to be downloaded from more than one place. The URL of the mirror listed was htp://�p5.gwdg.de/pub/openoffice/archive/stable/2.4.0/ 10 - 10 - H/107/10 Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 11 of 14 28. Having installed this version, I created a test document and saved it . Doing so produced a metadata generator tag within that document identical to that observed in ID_000260: “OpenOffice.org/2.4$Win32 OpenOffice.org_project/680m12$Build- 9286” 29. I observed that not only the version but also the “build” number were the same. 30. This therefore confirmed my view that OpenOffice.org software had been used to author ID_000260. However, the apparent upload date of that software was 16 March 2008 and its release date was 27 March 2008, both of which were after the “C reated” and “L ast Saved” date of ID_000260 (8 -9 March 2008). 31. The dates were therefore contradictory. In my view, it should not have been possible to generate the observed metadata tags within ID_000260 before the creation of OpenOffice.org 2.4, without the use of clock manipulation techniques. Even if the document was opened in an earlier version of OpenOffice.org W riter and later edited after the software was upgraded to v2.4, no changes would have been committed to the file without a Save operation having been performed. However, doing so would have updated the “Last Saved” and “Last Modified” timestamps to match the date of that save, which necessarily would have needed to be afterthe release of OpenOffice.org 2.4. 32. This led me to doubt the authenticity of ID_000260 and to the initial conclusion that it could not be relied upon as authentic to its purported creation date. Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page 11 of 14 28. Having installed this version, I created a test document and saved it . Doing so produced a metadata generator tag within that document identical to that observed in ID_000260: “OpenOffice.org/2.4$Win32 OpenOffice.org_project/680m12$Build- 9286” 29. I observed that not only the version but also the “build” number were the same. 30. This therefore confirmed my view that OpenOffice.org software had been used to author ID_000260. However, the apparent upload date of that software was 16 March 2008 and its release date was 27 March 2008, both of which were after the “C reated” and “L ast Saved” date of ID_000260 (8 -9 March 2008). 31. The dates were therefore contradictory. In my view, it should not have been possible to generate the observed metadata tags within ID_000260 before the creation of OpenOffice.org 2.4, without the use of clock manipulation techniques. Even if the document was opened in an earlier version of OpenOffice.org W riter and later edited after the software was upgraded to v2.4, no changes would have been committed to the file without a Save operation having been performed. However, doing so would have updated the “Last Saved” and “Last Modified” timestamps to match the date of that save, which necessarily would have needed to be afterthe release of OpenOffice.org 2.4. 32. This led me to doubt the authenticity of ID_000260 and to the initial conclusion that it could not be relied upon as authentic to its purported creation date. 11 - 11 - H/107/11{ID_000260} {ID_000260} {ID_000260} {ID_000260} Appendix PM 23 Openoffice 2.4 document/ ID_000260 and ID _000374 Page
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