HT-2021-000363 - [2025] EWHC 532 (TCC)

By DR-10237 dated 23 June 2014, Mr Bond of LzLabs requested Winsopia to provide the layout of the AMDSB data block, the structure of which was mapped in an IMS macro, referred to in an earlier Jira ticket, CORE-96. In response, Mr Payne of Winsopia produced a table describing each field in the data block, including length values, data types and values.

In cross-examination Mr Bond agreed that the information in the Winsopia table was the same as the IBM macro:

“Q. … a plain text table is never going to look like a macro, is it?

A. No.

Q. But that's because a macro definition obviously has to be written in a specific parsable format and it has to conform to the macro language semantics and syntax?

A. Exactly.

Q. But as a matter of substance, as opposed to form, the two are the same, aren't they? This is a translation, in essence, of the macro?

A. Yes, okay.

Q. Well, do you agree with that?

A. Yes.

...

Q. It does rather look, doesn't it, as what Mr Payne has done is got the macro source up on the screen and essentially copied it into the table?

A. It does seem likely.

Q. And so, although you say -- and we looked at it a moment ago at paragraph 92 of your statement – that the Winsopia team used their own words to describe the layout, I mean, really they used IBM's words, didn't they?

A. I certainly did not know that when I did my witness statement because I had not seen the IBM macro.

Q. But looking at it now, do you accept that's the position?

A. Yeah, I can see that, yes.

…

Q. … you say “I recall working on the SDM code, and I accept that the SDM code is based on and incorporates information relating to the fields in the AMDSB data structure from [the file].” That's what you say, isn't it?

A. It was not written from that, but it of course mirrors it exactly.

Q. That's what you meant there, is it?

A. Yes.”