20. In late June 2008, Internet Brands’ CEO Robert Brisco, Technology Director Jennifer Rundell, and Project Manager Michael Anders visited Jelsoft’s offices in England on short notice. The Saturday before Internet Brands’ visit on the following Monday, James Limm sent me an email instructing me to prepare a presentation about the development of vBulletin 4. vBulletin 4, however, was not being developed at that time, because the development team had been diverted by Limm to develop and write the social networking features that would debut in vBulletin 3.7.
21. I was present at and participated in meetings with Internet Brands at the Pangbourne office over three days in June 2008. During the first of these meetings, I discovered that Internet Brands’ corporate representatives believed that Jelsoft had been working on vBulletin 4 since at least 2007. Brisco expressed shock when I told him that we had been working on upgrades to the vBulletin 3 series, that we were just starting to plan the development of vBulletin 4, and that vBulletin 4 was two years away from commercial release.
22. I have since learned that Brisco has testified that, prior to June 2008, Limm had assured him on a regular basis that Jelsoft was working on vBulletin 4 and that progress was good. Contrary to Limm’s assurances to Brisco, vBulletin 4 had only reached its early planning stages, with functional requirements still being defined. With the exception of the decision to make use of MVC and semantic XHTML principles, no technical design or development work for vBulletin 4 had been undertaken at all.