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)

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EXHIBIT 3 PAUL K. MEYER May 14, 2010 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Page 648 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 3; PAGES 648 - 937 FRIDAY, MAY 14, 2010 HIGHLY REPORTED BY: CONFIDENTIAL - ATTORNEYS' EYES ONLY HOLLY THUMAN, CSR No. 6834, RMR, CRR (1-427378) Merrill Legal Solutions (800) 869-9132 c27f64cd-287e-4b3a-a890-1b27136d3d6a PAUL K. MEYER May 14, 2010 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Page 712 TEXT REMOVED - NOT RELEVANT TO MOTION 10:40:53 24 10:40:56 25 Q. As someone who by your background and experience is not an enterprise software industry Merrill Legal Solutions (800) 869-9132 c27f64cd-287e-4b3a-a890-1b27136d3d6a PAUL K. MEYER May 14, 2010 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Page 713 10:41:00 1 expert or an expert on industry enterprise software 10:41:05 2 customer purchasing practices, do you believe 10:41:07 3 you're qualified to respond to Mr. Clarke's report 10:41:10 4 in that regard? 10:41:12 5 MS. HOUSE: 10:41:13 6 THE WITNESS: 10:41:13 7 question, from the issue which I am expert in, 10:41:16 8 which is the high technology area and determining 10:41:19 9 damages and valuation and doing analysis and have 10:41:22 10 looked at hundreds of technology companies, 10:41:24 11 absolutely I'm qualified to do the analysis I've 10:41:26 12 done. 10:41:28 13 that background to do these types of analyses, 10:41:32 14 because these are driven by the facts and 10:41:34 15 circumstances of this case. Objection. Vague. If I understand your And I don't believe it takes someone with TEXT REMOVED - NOT RELEVANT TO MOTION Merrill Legal Solutions (800) 869-9132 c27f64cd-287e-4b3a-a890-1b27136d3d6a TEXT REMOVED - NOT RELEVANT TO MOTION

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