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 6

STEPHEN CLARKE
June 9, 2010
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 324
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND 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
STEPHEN CLARKE
_________________________________
VOLUME 2; PAGES 324 - 651
WEDNESDAY, JUNE 9, 2010

HIGHLY

REPORTED BY:

CONFIDENTIAL - ATTORNEYS' EYES ONLY

HOLLY THUMAN, CSR No. 6834, RMR, CRR
(1-427119)

Merrill Legal Solutions
[phone]

16af1716-9ceb-4114-9498-37fa06417026

STEPHEN CLARKE
June 9, 2010
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
Page 550
TEXT REMOVED - NOT RELEVANT TO MOTION

16:12:42

4

16:12:47

5

service vendors available to a potential customer

16:12:51

6

at the time serviced all versions of all products

16:12:57

7

within the either PeopleSoft, JD Edwards, or Siebel

16:13:02

8

families?

16:13:03

9

16:13:04

10

16:13:10

11

16:13:12

12

I didn't think it was necessary.

16:13:17

13

TomorrowNow didn't even support all of the

16:13:20

14

different elements, as a matter of fact.

16:13:24

15

16:13:25

16

which particular elements, to use your word, each

16:13:31

17

of the third-party alternative vendors offered.

16:13:36

18

that correct?

16:13:37

19

MR. McDONELL:

16:13:37

20

THE WITNESS:

16:13:39

21

Q.

Did you make sure that the third-party

MR. McDONELL:
question.

Object to the form of the

Compound, overly broad.
THE WITNESS:

MR. PICKETT:

Incomplete.

I didn't do that analysis.

Q.

And as we know,

So you haven't looked at

Is

Same objections.
I think that's what I just

said.

TEXT REMOVED - NOT RELEVANT TO MOTION

Merrill Legal Solutions
[phone]

16af1716-9ceb-4114-9498-37fa06417026

TEXT REMOVED - NOT RELEVANT TO MOTION