Oracle Corporation et al v. SAP AG et al

Filing 1157

Declaration of Tharan Gregory Lanier in Support of 1156 Opposition/Response to Motion Declaration of Tharan Gregory Lanier in Support of Defendants' Oppositions to Oracle's Motions in Limine filed bySAP AG, SAP America Inc, Tomorrownow Inc. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23)(Related document(s) 1156 ) (Froyd, Jane) (Filed on 5/10/2012)

EXHIBIT 2

PAUL K. MEYER
May 13, 2010
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 332
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
ORACLE CORPORATION, a
Delaware corporation,
ORACLE USA, INC., a
Colorado corporation, and
ORACLE INTERNATIONAL
CORPORATION, a California
corporation,

)
)
)
)
)
)
)
)
Plaintiffs,
)
)
vs.
) No. 07-CV-1658 (PJH)
)
SAP AG, a German
)
corporation, SAP AMERICA,
)
INC., a Delaware
)
corporation, TOMORROWNOW,
)
INC., a Texas corporation,
)
and DOES 1-50, inclusive,
)
)
Defendants.
)
________________________________)

VIDEOTAPED DEPOSITION OF
PAUL K. MEYER
_________________________________
VOLUME 2; PAGES 332 - 647
THURSDAY, MAY 13, 2010

HIGHLY
REPORTED BY:

CONFIDENTIAL - ATTORNEYS' EYES ONLY
HOLLY THUMAN, CSR No. 6834, RMR, CRR
(1-427374)

Merrill Legal Solutions
[phone]

3ae7549b-c0d5-4963-b773-f83ce7edfbe0

PAUL K. MEYER
May 13, 2010
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 574

TEXT REMOVED - NOT RELEVANT TO MOTION

16:07:44

14

16:07:44

15

created for rebuttal purposes since you've read

16:07:47

16

Mr. Clarke's report?

16:07:48

17

16:07:49

18

had an understanding that there was no

16:07:51

19

alternatives.

16:07:54

20

time analyzing the alternatives and took the

16:07:57

21

position that there were alternatives, I spent some

16:07:59

22

time going back and looking at those groups.

16:08:02

23

on a preliminary basis, I've pulled together a

16:08:04

24

schedule, which you now have, and all the backup

16:08:06

25

that basically says, as you scan through this,

MR. McDONELL:

A.

Q.

Is this a binder you

Well, there's two levels.

I had already

And when Mr. Clarke spent a lot of

And

Merrill Legal Solutions
[phone]

3ae7549b-c0d5-4963-b773-f83ce7edfbe0

PAUL K. MEYER
May 13, 2010
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 575
16:08:08

1

these companies are not acceptable non-infringing

16:08:13

2

alternatives on any kind of scale.

16:08:15

3

16:08:17

4

don't have a little business, but a scaling

16:08:19

5

business.

I'm not saying they don't exist and they

TEXT REMOVED - NOT RELEVANT TO MOTION

Merrill Legal Solutions
[phone]

3ae7549b-c0d5-4963-b773-f83ce7edfbe0

TEXT REMOVED - NOT RELEVANT TO MOTION