Oracle Corporation et al v. SAP AG et al

Filing 1201

Declaration of Tharan Gregory Lanier in Support of 1182 Statement Declaration of Tharan Gregory Lanier iso Joint Statement Regarding Exhibit Objections 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, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59)(Related document(s) 1182 ) (Froyd, Jane) (Filed on 8/2/2012)

EXHIBIT 10

Foundation
A-6042-j

for

0RCL00034303

Jones
for

Oracle

Apr 24

2009

Adams

as an Oracle

Allison

Adams works

and Operations

Practices

Depo Tr 586-10

5812-17

that

indicating

OSSINFO
Tr

2009 Depo

May 13

Rottler

256-14

at

identifying Gary Miller as Oracles

and reports

Jones

Oracles

2009

Oracles

who heads up OSSINFO

4017-416 4120-422

at

Tr

at

318-3317

and

Depo Tr 2912-17

sales

renewal function

at

describing Oracles

senior

2124-225

that

indicating

from

at

process

approval

had responsibility for

Jones

least

2005

that

Jones

indicating

Vice President

Executive

describing Oracles

and OSSII4F0

responsibilities

Depo Tr

Video

operations

head of business

OSS1NFO

OSSINFO

as

2009 Depo

support

Rottler

known

Juan Jones

Apr 24

describing

2516-25

Rottler

2009 Depo Tr

process

including

Jones

Juergen

May 13

Rottler

Jones

to

Apr 24

approval

to

Support

Allison

chart identifying

organizational

Business

Manager

Senior

Foundational

Trial Exhibit A-6042-1

Defendants

to

2009

reported

directly

from

Customer Services

Oracle

to

Juergen

at

least

2005

2009
Apr 24

Jones

decisions

deviate

that

May 13

Rottler

Depo Tr

2009

at

43 7-17

from existing

Tr

2009 Depo

at

Jones

must approve pricing

terms

contract

225-2

that

indicating

describing generally Oracles

approval

process

Blotner

July

runs

Jones

23

Depo Tr 987-993
for North
America

2008

support

Rule

Cummins Sept 16 2008 Depo Tr 345-22
that

support

renewal/sales

representatives

30b6

24-25 Rule

testimony

30b6

report to regional

stating

testimony

managers

that

Juan

indicating

and associated job

responsibilities

Duggan
support

sales

2009

Aug

Feb 23 2010

representatives with

Oracle

Juergen

Rottler

Oracle

Head of

Oracle

Senior

SVI-1 08747v1

Depo Tr 2316-24 Rule

Expert

as Oracle
Global

regard

testimony

communications

Report of Paul Meyer redacted

Executive

Business

Vice President

to

30b6

Vice President

Operations

with Oracle

duties of

customers

excerpt identifying

Customer Services

Oracle

Customer Services

identifying

Customer Support

North America

Gary Miller as
and Juan Jones

Support

as

ORCL0003
Support

9277 Oracle

Services

0RCL00653682
Planning

SVI-108747v1

production

employee

Oracle

Manager

Oracle

in

2005

production
Support

document
located

at

document
Services

in

identifying Betsey

Steelman

as

Oracle

0RCL00039277
identifying Allison

2005

Adams

as Business

organization

Page

Chart

ORACLE

Asia

People

Search

ler

Cry
SVP

Ore

SLtOaI

Otcemaid

Knifi
DIreor

Dkects

Sn

Mea

O.ez

HIgt/

Confldentia

Information

Praclicss

and

Total

Eyes

Bunesa

PTadices

Manager

Manager

Attorneys

Praclices

bans

QJILQnj

Dat
8uness

PcbosandOpw.o

ODefab0r

Antic

Guaineaa
Opera

Bn4

TotatSo

Ofrectsl1

Secia

of

Only

Business

Msi.1d
Pncas

Manager

0RCL00034303

JONES

JUAN
HIGHLY

24

April

2009
EYES

CONFIDENTIAL-ATTORNEYS

ONLY
Page

UNITED
NORTHERN
SAN

COURT

DISTRICT

STATES

DISTRICT

OF

CALIFORNIA

DIVISION

FRANCISCO

---oOo-CORPORATION
Delaware
corporation
Colorado
USA INC
ORACLE

ORACLE

ORACLE
and
corporation
INTERNATIONAL
CORPORATION
California corporation

Plaintiffs

No

vs
SAP

AG

07_CV1658

PJE

Derman

SAP AMERICA
corporation
Delaware
INC
TOMORROWNOW
corporation
Texas corporation
INC
and DOES
15C inclusive

Defendants

____________I
Deposition
JUAN

JONES

Friday

HIGHLY

REPORTED

BY

April

CONFIDENTIAL

WISSENBACH

CLR

CSR

2009

BNR

EYES

CRR

ONLY

CBC

01-418986

6862

Legal

800

24

ATTORNEYS

JOHN

Merrill

of

Solutions

8699132

a6971f9d4392.4642-8f24-97791

aa3377d

JUAN
HIGHLY

JONES

24

April

2009

ATTORNEYS

CONFIDENTIAL

EYES ONLY

Page

102503
10

Well

08

were

sent

102520

and

l02S26

me

to

102534

to

put

that

it
the

up

that

to

approve

102542
360

102559

OSSINFO

term

the

refer
the

email

the

at

sales

very

the

approv1s

organization
request

that

in

see

youll

102601

the

that

process

you

If

102551

approval

in

the

license

the

in

together

that

appears

58

they

were

Caine

to

seeking

transaction

top

to

first page

the

from

of

Exhibit

Allison

at

038

works

in

OSSINFO

Uhhuh

1O2601

10

Is

102606

11

MS HOUSE

102612

12

TILE

102613

13

is

102614

14

BY

102614

15

102620

16

102624

17

102629

10

102631

19

what

10263

20

the

102640

21

102641

22

but

MR

she

10264

25

speculation

dont

know

if

she

currently

w.hats

name

her

names

her

Allison

but

Mains

Im

sure
Can

the

tell

you

actual

exception

MR

effect

from

approval

you

the

review

effect

financial

MS HOUSE

on

of

the

Oracle

email

was

of

granted

Objection

overbroad

McOONELL
In

24

for

did

once

think

BY

Calls

WITNESS

And

not

who

person

McDONELL

102642

02646

Allison

of

other

that

Legal

800

was

it

the

dollar

flatlining

MS HOUSE

Merrill

words

Objection

overbroad

lacks

Solutions

8699132

aeGllfgd-fl9246424fl49n91

aa3377d

Ar1

JUAN
JONES
HIGHLY CONFIDENTIAL

449

24

ATTORNEYS

2009
EYES

ONLY

p.m

declare
foregoing

is

true

under
arid

of

penalty

correct

_______________
_______________

Subscribed
this

California

perjury

1day

that

the

at

of

2009

Snature

of

twitness

10
11

12

13

14

15

16

17

is

J9
20

21
22
23

2J

25

218

erril1 Legal Solutions
800 8699132

Leg2 SeIutkis

Merrill

To

assist

please

them and

Please

make

you

follow

insert
line

the

After

do

any

change

completing

your review

designated 1Signature
Main

Street

of

line

Floor San

the

on

then

errors

you

corrections

on

or

changes

sheet by
wish to

you

wish
the

listing

to

page

make

the face of the transcript

questions

sign

return

the

the

last

Errata

CA 94105

Francisco

ERRATA

Page

any

testimony
please furnish

necessary

sheet

the errata

the change

br

please

and

errata

find

and

changes

any

If

the

you

and

reference

of

DEPOSITION

your deposition
are

pages

corrections

carefully

to

corrections

for

If additional

back

the

and/or

changes

number

NOT

to

transcript

Please do not make

Please

below

the pages

your

and

changes

the directions

attach

read

and the

making

in

YOUR

FOR READINGICORRECTING

INSTRUCTIONS

page

of

the errata

sheets to

or fax

them

Merrill

to

sheet1

Legal

415

above the

Solutions

357.4301

SHEET

Line

Change
Reason_______________________________________

Change
Reason

Change
Reason_______________________________________

at

135

Page

Line

Change

Reason__________________________________________

Change
Reason___________________________________________

Change
Reason__________________________________________

Change

Reason_________________________________________

Change
Reason_______________________________________

Change
Reason____________________________________________

Change_________________________________________

Reason__________________________________________

Subject to the above

_________

No changes

have

been

changes1

certify that

the transcript

is

true

and

correct

made

certify that

the

is

true

and

correct

transcript

dates

iature

OF REPORTER

CERTIFICATE
JOHN

Reporter

hereby

foregoing

deposition

the

truth

truth

in

was

truth

That

said

mc

shorthand

by

and

place

therein

ID

the

said

11

typewriting

12

Shorthand

witness

in

the

duly sworn

by me

to

tell

and

but

nothing

the

cause

within-entitled

the

the

that

certify

whole

the

Certified

WISSENEACH

deposition

taken

down

person

at

was

time

the

supervision

witness
by

That

13
14

review

15

recuested

16

deponent

17

period

of

the

stated
was

and

completion

to

20

said deposition

21

event

22

any

attorney

of

of

for

this

the

either
nor

or

in

reporter

the

by

the

during

hereto
that
any

any

am

of

way

cause and that

parties

made

the

certify

or

and

not

was

changes

appended

further

to

deposition

any

are

19

the

of

of

testimony

my direction

IX was

requested

and provided

the

reduced

under

transcript

allowed

that

thereafter

computer

before

If

18

23

disinterested

in

the

not

counsel

of

parties

interested
am not

to

in

related

the

the
to

thereto

DATED

24

25

JOHN

WISSENBACH

CSR

No

6862
219

JUERGEN ROTTLER
HIGHLY
CONFIDENTIAL

13

May

2009

ATTORNEYS

EYES ONLY
Page

STATES

UNITED
NORTHERN

DISTRICT

DISTRICT

SAN

OF

FRANCISCO

ORACLE
CORPORATION
Delaware
corporation
Colorado
USA

COURT

CALIFORNIA

DIVISION

ORACLE

INC

and

corporation
INTERNATIONAL
California

ORACLE

CORPORATION
corporation
Plaintiffs

No

vs
SAP

AG

German

SAP

AMERICA
corporation

INC
DOES

07CV-1658

PJH

corporation

INC

Delaware

TOMORROWNOW
Texas
corporation
150 inclusive

and

Defendants

VIDEOTAPED

DEPOSITION

JUERGEN

WEDNESDAY

HIGHLY
REPORTED

ROTTLER

MAY

CONFIDENTIAL

BY

HOLLY

OF

13

2009

ATTORNEYS

TRUMAN

CSR

No

EYES

6834

ONLY

RMR

CRR

1-417821

Merrill Legal

800

Solutions

8699132

0e8571cb-5d3f-4935-99b2-2cj67123543ba

JUERGEN ROTTLER
HIGHLY
CONFIDENTIAL

13

May

2009

ATTORNEYS

EYES

ONLY

Page

102214

exist

02218

established

102222

have

102224

related

102227

25

rhat

Lifetime

the

as

had

in

different
to

102228
102229
102232

It

102234

And

102235

10

nature

102237

list

price

knom

what

or

OSSINFO

was

would

it

soniething
like

something

familiar with

you

an

Oracle

within

me yes

to

is

likely

Are

as

reporta

that

of

most

McDOWELL

organization

that

Before

names

support

MR

2002

late

which

policy

Support

of

understanding

your

the

organization

Theyre

the

102240

12

102244

13

102249

14

102250

15

MS

HOUSE

102252

16

THE

WITNESS

102254

11

102258

18

102259

19

102301

20

Gary

102302

21

So

102305

22

102308

23

24

And

102309

25

the

enforcers

of

Yeah

102308

and

keepers

Yeah

our

policies

pricing

there

Is

that

to

reports

MR
business

report

head

my

who

heads

up

OSSINFO

you

to

reports

individual

art

Vague

as

theres

The

of

business

MCDOWELL

time

to

group

operations

whos

And

the

which

yes
head

of

operations

to

Miller

OSSINFO

Gary

Merrill

groiLip

of

individuals

that

Miller

Mr

Miller

Legal

800

is

reports

to

you

Solutions

8699132

OoaSll

cb-5d3f4935-99b2-2d671

2354aba

jrjEp orrr
RIGBLY

182926

The

182928

opposite

direction

other

May 13
ZTTORNEYS

CONFIDENTIAL

to

182929

MR

be

ONLY

EYES

the

going

coxapanies

SAP

Yeah

182931

could

2009

McDONELL

182932

further

182937

this

182940

real document

182942

MS

ROUSE

182945

MR

McDONELL

but

now

am

reserving

concluded

deposition

concerns

10

MS

HOUSE

182947

11

MR

well

12

MS

HOUSE

182949

13

THE

VIDEO

182950

14

Volume

182952

15

Juergen

Rottler

182954

16

time

17

183004

18

183004

19

theres

reserve

have

some

rights

ours

reserve

629

182958

not

Okay

McDONELL

182948

Ill

nothing
to

rights
think

but

1nd

182945

have

Counsel

183004

20

183004

is

This

in

going

the

is

the

end
of

deposition

o-ff

the

of

record

The

p.m

629

---000
declare
the

foregoing

is

under

true

and

penalty

corrct

California

22

flAQ..

this

of

perjury that
Subscribed

____

day

at

of

2009

24

193QO4

qUestions

No
Were

you

questions

OPERATOR

noted

21

183004

No
No

Videotape

Time

thank

Okay

25

_________

RGEN

ROTTLER

296
Merrill

Legal

800

Solutions

869-9132

Errata

of Juergen

Deposition

Page

Line

May 132009

Rotther

Reason

Change
Change

17

Sheet

Ed

Ann

to

Correction

Lew

17

13

Change

Lou

37

20

Change

Oracle

38

21

Delete

Check

Clarification

44

24

Delete

Is

Clarification

to

Correction

Clarification

PeopleSoft

to

lower

70

Change

higher

72

Change

acquisitions

to

to

Clarification

Correction

application

91

10

Change

net

to

list

Clarification

91

15

Change

net

to

list

Clarification

94

23

Change

to

and

Correction

102

Change

conventions

104

Change

consents

to

Change factual

108

Change

infiltration

Change

would

115

21

119

149

Delete

22

18

Correction

Clarification

factually
to

inflation

Correction

had

to

Clarification

will

Clarification

Change

roles

Change

155

182

to

Correction

concerns

to

105

convictions

Louise

Change

settle

rolls

to

Correction

Luiz

to

Correction

set

to

Correction

219

20

Change

that Customer to netCustomer

Correction

246

20

Change

by to

Clarification

248

17

Change

Matson

with
to

Madsen

Correction

area

250

Delete

259

Change

contract

Correction
to

what

our contract

Clarification

284

25

Change

Matson

to

Madsen

Correction

286

14

Change

doesnt

to

didnt

Correction

Change

above

294

to

within

Clarification

is

ecttheaecgesJcetrcrjpt

true

and correct

CERTIFICATE
HOLLY
hereby

foregoing

deposition

the

whole

in

time

and

the
10

by

therein

place
witness

under

computer

That

11

before

12

review

13

If

14

provided

to

15

appended

to

tell

the

that

taken
at

person

the
of

the

testimony

typewriting

supervision
the

of

completion

the

in

to

reduced

direction and

the

truth

deposition was

and

stated

the

requested

transcript
any

the

attorney

18

this

20

parties

by

during

certify

that

cause

the

was
the
the

not

requested

and

deponent

period

allowed

not

of

parties

to

the

are

counsel

am

or

any

of

nor

deposition

19

made

reporter

for either

17

E$

changes

further

16

was

deposition

hereto

of

the

my

but

disinterested

thereafter

was

in

sworn

duly

said

Shorthand

witness

nothing

that

me

by

the

me

by
and

cause

shorthand

said

was

truth

within-entitled
down

that

certify

REPORTER

Certified

THUMAN

Reporter

truth

OF

in any

way

interested

and

that

am not

related

or

said

in

the

event

to

any

of

of

the

thereto

21

DATED

rnt

L4

24

________

25

HOLLY

THUMAN

CSR

No.

6834

JUAN
JONES
HIGHLY CONFIDENTIAL

24

April

ATTORNEYS

2009
EYES ONLY
Page

UNITED

STATES

NORTHERN

DISTRICT

DISTRICT

CALIFORNIA

OF

FRANCISCO

SAN

COURT

DIVISION

ORACLE

CORPORATION
Delaware
ORACLE
corporation
Colorado
USA INC
and
ORACLE
corporation
INTERNATIONAL
CORPORATION
California corporation
Plaintiffs

vs
SAP

No

AG

O7CV-1658

PJH

German

SAP
corporation
Delaware
INC

AMERICA

corporation

INC
and

TOMORROMNOW
corporation
l-5D inclusive

Texas

DOES

Defendants

________________/

Deposition
JUAN

JONES

Friday

HIGHLY

REPORTED

BY

April

CONFIDENTIAL

JOHN

WISSENBACH

CLR

CSR

Merrill

of

24

2009

ATTORNEYS1

RMR

6862

Legal

EYES

CRR

ONLY

CBC

01418986

Solutions

800 8699132
a6971f9d.f392-4642-8f24.97791aa3377d

JUAN
HIGHLY

24

2009

ATTORNEYS

EYES

JONES

April

CONFIDENTIAL

ONLY
40

Page

095720

we

095723

how

095726

available

095729

lot

theyre

095732

with

095733

BY

customer

the

and

theyre

issues

that

MR

it

using
and

of

with

share

basically

the

their

systems

if

and

running

then

the

extent

theyre

customers

to

are
not

usually

having
pleased

actually

McDONELL

095733

Does

0957H

multiple

095742

run

the

report

time

at

periods
can

095745

10

the

095748

ii

does

095749

12

095754

13

095757

14

oqc75y

15

fox

D95BO

16

17

095821

18

095823

19

20

Okay

095828

21

095832

22

095035

23

process

095941

24

our

095846

25

time

example

for

when

that

it

or
you

done

be

for

or

how

OSSINFO

095825

So

request

you

of

period

year

095812

cover

report

last

the

the

of

customer

the

work

that

dont
the

life

know

or

year

available

report

for

increTent

time

Are

oSSINFO

How

do

with

refer

you

And

from

tell

for

we

can

run

it

OSSINFO

to

time

you

Typically

familiar

you

of

length

its

But

perspective

history

total

that

example
run

it

for

or

that

us

your

understanding

is

part

of

of

OSSINFO

Its

--

And
our

its

senior

What

Merrill

OSSINFO

is

know
in

approval

it

Legal

800

you

Is

it

our

approval
of

representative
the

approval

group

of

chain

people

Solutions

8699132

a6971f9d4392-4842-8f24-97791

aa

3377d

JUAN
HIGHLY

JONES

24

April

2009
EYES ONLY

ATTORNEYS

CONFIDENTIAL

41

Page

09SB53

OSSINFO

095900

its

its

095905

individual

095908

exception

095913

that

095919

business

that

were

95935

and

standard

know

you

our

ensure

to

business

our

whos

in

currently

of

charge

today

10

Do

11

Ararine

Its

you

know

what

also

0r35944

12

part

09594

13

collection

095950

14

those

095952

15

who

095955

16

D9595

17

THE

095959

18

charge

000O1

13

BY

100001

20

100005

21

100010

22

1000d3

23

lOroOd

24

100017

25

that

HQApps

an

MS HO1SE

of

our

consistency

with

know

you

Kevin

095932

of

an

by

practices
Do

OSSINFO

all

for

complying

led

people

reviews

approvals

095919
095922

of

group

its

believe

includes

approvaloff

of

is
as

theres

process

individuals

believe

And

process

approval

that

work

on

whos

in

approvals

HR

of

is

it

of

charge
Calls

WTTNESS

HQApps

for

Yeah

today

speculation

fm

not

sure

directly

cDQNELL
okay

interact

in

with

To

what

extent

in

your

work

do

you

OSSLNFO

interact

with

OSSINFO

on

fairly

regular

basis
In

what
send

Merrill

ways
approvals

Legal

800

to

OSSINFO

have

Solutions

8699132
aGgllf9d-fa9245424f24-9779l

aaa3l7d

JUAN
JONES
HIGHLY CONFIDENTIAL

24

April

2009

EYES ONLY

ATTORNEYS

42

Page

100022

discussions

100026

process

100031

Pnd
RQApps

in

100039
100042

in

100044

100052

way

the

in

approvals

ways
do

you

inLeract

with

work

your

directly

Youve
part

those

usually

sØ

per

usually

OSSINFO

through

100049

those

what

in

Not

about

them

Mostly

.3

100033

with

between

of

an

approval
two

the

Im

100056

10

1O01Ot

11

to

100104

12

say

100110

13

through

100.117

ii

seniormost

100119

15

100122

16

describe
that

described

and

HQApps

as

is

the

ditfererice

with

enough
in

differences

the

level

the

functions

approval

and

HQApps

even

as

is

would
is

up

the

understand

senior

more

but

OSSINFO

approval

authority
is

tQApps

detail

of

Rottler

Juergen

So

What

process

intimate

not

is

OSSINFO

functions

their

it

both

than

up

it
to

Mr Rattler

C0123

Yes

100124

So

100129

19

management

its
gets

20

21

And

100134

22

100134

23

100136

24

100144

25

involved

at

most

senior

executive

level

that

Yes

100131

the

basically

Ms

thats

Mt

Phillips and

Catz
Well

but

Mr Ellison

its

know

seniormost

the
What

Merrill

dont

governs

Legal

800

if

its

them

directly

approval

when

pricing

decision

gets

Solutions

8699132

aGSTlTOd.f392-442.5124.97791

a3377d

449

24

2009

ATTOBNYS

JUJ1
JONES
LIIGLY CONIDENTIM

EYES

April

ONLY

pm
declare

foregoing

is

true

under
and

of perjury that

penalty

correct

Subscribed

the

at

2i

California

My

this

day

of

2009

nature

of

tjwitness

-10

11

12

13

14

16

17

IS

20
21

22

23

24

25

218
l4errill Legal

800

Solutions

8699132

III

Lg

Solutions

FOR READ1NGICORRECTING YOUR DEPOSITION

INSTRUCTIONS

To

assist

please

you

follow

them and

the

attach

Please

read your

make

insert

and

the

line

making

in

the

pages

transcript

the changes

not make

do

Please

do NOT change

completing your

Street

the back

4th

Floor

any

of

iview
line

then

br

and

your
are

please furnish

or changes

any errors
the errata

change

testimony

deposition

necessary

sheet

you

corrections

on

sheet by
wish to

you

listing

wish to
the page

make

the face of the transcript

questions

please

sign

return

San Francisco1

the

the

last

Errata

CA 94105

ERRATA

Page

errata

on

the

to

pages

find

you

corrections

the

and

of the

If

carefully

and/or

any changes

designated Signature
Main

to

corrections

additional

If

number reference and

Please

After

below

directions

br

and

changes

page

of

the errata

sheets to
or fax

them

sheet above

Merrill Legal
to

415

Solutions

the
at

357A301

SHEET

Line

Change

Reason_____________________________________

Change____________________________________

Reason__________________________________________

Change__________________________________________

Reason_________________________________________

135

Page

Line

Change

Reason__________________________________________

change

Reason__________________________________________

Change

Reason________________________________________

Change

Reason________________________________________

Change.__________________________________
Reason_______________________________________

Change________________________________________
Reason

_________________________________________

Change________________________________________

Reason________________________________________

Subject to the above

_________

ature

No changes

have

been

changes

made

certify that

the transcript

is

true

and

that

the transcript

is

true

and correct

certify

date

correct

CERTIFICATE
JOHN
hereby

foregoing

deposition
the

truLh

truth

in

the

whole

said

me

shorthand

by

and

place

therein

the

said

witness

typewriting

12

the

that

certify
was

by me

truth

the

sworn

to

tell

the

hut

nothing

taken

was

disinterested

was

in

cause

deposition

stated

Shorthand

witness

duly

and

within-entitled

That

11

Certified

WISSENBACH

Reporter

he

OF REPORTER

thereafter

at

person1

that

and

down

the

in

time

the

of

testimony

reduced

to

under

my

direction

completion

of

the

and

supervision
That

13
14

by

review

of

the

requested
lB

deponent

17

period

before

IX was

transcript

If

requested

and provided

allowed

to

are

or

20

said deposition

21

event

22

any

attorney

of
of

for

this

the

either
nor in

or

not

made

the

reporter

by the
the

during

hereto
that
any

any

am not

of

way

cause and that

parties

was

changes

certify

19

deposition

any

appended

further

18

23

computer

the

counsel

of

parties

interested
am not

to

in

related

the

the
to

thereto

DATED

24

25

JOHNWISSENBACH

CER

No

6862
219

JUERGEN ROTTLER
HIGHLY
CONFIDENTIAL

13

May

2009
EYES

ATTORNEYS

ONLY

Page
UNITED

DISTRICT

STATES

NORTHERN

DISTRICT

OF

FRANCISCO

SAN

COURT

CALIFORNIA

DIVISION

ORACLE

CORPORATION
Delaware
ORACLE
corporation
USA INC
Colorado
and ORACLE
corporation
IINTERNATIONAL
CORPORATION
California corporation
Plaintiffs

No

vs
SAP

AG

SAP

AI4ERICA

German

corporation

INC
DOES

PJH

corporation
Delaware

INC

TOMORROWNOW
corporation
inclusive

and

Texas

1-50

07-CV1658

Defendants

VIDEOTAPED

DEPOSITION

JUERGEN

WEDNESDAY

HIGHLY
REPORTED

BY

ROTTLER

NAY

CONFIDENTIAL
HOLLY

OF

13

2009

ATTORNEYS

THUMAN

CSR

No

ONLY

EYES

6834

PNR

CRR

1417821

Merrill Legal

800

Solutions

8699132

0e8571cb-5d3f-4935-99b2-2d67123543ba

ROTTLER

JUERGEN
HIGHLY

13

May

2009

ATTORNEYS

CCNFIDENTIThL

ONLY

EYES

31

Page

No

102924
102927

to

1Q211t

and

20293

that

help
help

our

guide
avoid

102944

narrcm

102947

requests

102949

theyre

to

Can

102954

followed

take

you

when

me

ii

an

103001

11

12

Does

103006

13

Whats

103007

14

An

10t300B

15

Yeah

103010

16

account

103013

17

required

103016

intended

within

which

to

you

know

the

example

for

xequests

that

steps

are
that

year

103002

OSSINFO

consider

through

mastomer

102956

requests

up

come

even

use.d

into

coming

theytre

help

be

make

they

even

boundaries

set

would

not

wculd

they

as

ever

would

we

So

teams

own

requests

would

102940

because

uftimately

uplift

inflationary

be

waived

start

at

the

It

AR

an

start

sales

executive

To

19

to

103021

20

manager

103024

21

22

10302G

23

103026

24

25

And

level

an

would

They

be

case

business

Yes

103027

rep

as

typically

it

103024

level

whom

103017

the

submit

16

coming

please

would

to

the

executive

account
it

AE

for

to

first

typically
even

Okay

see

Md

if

that

thatts

of

manager

to

a.l

their

would

regional

support

sales

manager

Merrill

what

is

Legal

800

the

next

step

Solutions

8699132

foSsil

cb4d3-4935-99b2-2d671

23543ba

ROTTLER

JIJERGEN

HIGHLY

13

May

2009

ATTORNEYS

CONFIDENTIAL

EYES ONLY
32

Page

103028

Then

next

the

103030

deemed

worth

103036

highly

discouraged

103041

OSSINFO

103043

additional

103046

business

review

would

that

and

start

involved

get

able

be

to

questions

to

its

if

is

generally
then

hurdle

makes

it

that

which

OSSINFO

by

if

be

would

step

to

ask

present

case

103048

And

103052

there

relate

103056

like

Rick

how

does

kind

how

of

the

in

does

OSSINFOs
to

hierarchy

role

someone

Cununins

103100

10

103106

11

service/gatekeeper

103110

12

administrative

103115

13

approval

103116

14

103120

15

103122

15

103127

17

103130

18

103132

19

the

103136

20

organization

103137

21

103139

22

103140

23

103142

24

organization

103147

25

specific

they would

So

part

keeper
So

merit

to

become

of

the

lets

say

And

the

an

cant

but

theyre

OSSINFO

final

do

consultant

part

What

of

case
the

example

theres

decides

case-

business
head

has

process

business

regional

is

basically

that

ability

approval

That

Mr

function

they

the

OSSINFO

be

then

custooier

just

next

happens
gets

some

presented

to

services

that

gave

would

be

Curnmins

No

Mr

has

He

part

Merrill

Cummins

of

the

Legal

800

works

within

responsibility
business

as

that

for

sales

one

leader

Solutions

8699132
Oe85flcb5d3f4935-99b2-2d671

23543ba

BOTTLER

JtJERGEN

HIGHLY

2009

13

May

EYES

ATTORNEYS

CONFIDENTIAL

ONLY
33

Page

103149

So

103150

Fir

103151

Juan

103152

Juan

Jones

Mr Jones

Jones

103154

Mr

and

If

me

103202

they

103205

approved

for

final

it

approve
Every
and

approve
then

10

103210

11

103213

12

103215

13

103217

14

operations

103220

15

businesses

103224

16

strict

10t3227

17

processes

103300

18

Deposition

1O33C2

19

20

MR

103307

21

Mr Rottler

103311

22

You

Li

103324

23

you

today

have

1D3317

24

the

lower

righthand

103320

25

to

review

it

single
it

has

would

exception
be

to

that

personally

me

by

to

come

and

identification

103306

it

reviewed

gets

103208

would

Jones

it

review

approval

them

Mr

And

both

personally
by

yes

would

they

to

go

Jones

Miller

103156
103159

would

it

either

And
this

or

approved
why

really is

Mr

does

Mr

for

all

So

the

at

hold

is

that

and

track

kind

of

the

800

440

been
of

of

the

for
to

the

our

processes

was

you

Exhibit

440

will

control
Those

for

marked

documents

during

business

services

as

document

corners

of

showing

marked

if

side

head

pricing

Im

documents

Legal

the

adherence

xhibit

many

involved

support

customer

McDONELL

whats

get

him accountable

particularly

Merrill

the

Miller

implementation

note

Miller
on

request

Because

keep

rejected

are

court

show

numbers
put

cases

on

in

just

like

Solutions

8699132

0.8571

cb.5d314935-99b2-2d171

23543ba

jrjEa

12.92

Q.

182928

The opposite

direction

other

13

May

182929

NR

could be companies

going the

SAP

Yeah

18291

to

2009
ZYES ONLY

3roRNgys

CONPX1ENXAL

BIGHLY

NcDONELL

182932

further

1829

this

deposition concluded

182940

real

document

now

but

have

Counsel

am

concerns

122942

NB.

HOUSE

182945

NR-

to not

reserving rIghts
think

Ifl

but

McDONELL

wl1

And

nothing

theres

reserve

reserve

have

some

rights
ours.

Okay

182945

10

HOUSE

18294

11

NcDoNELL

182948

12

MS HOUSE

182949

13

THE

182950

14

Volume

182952

15

Juergen

Rottir Were

182954

16

time is

629

182958

17

183004

18

VIDEd

declare

183004

20

183004

21

the

No questions

OPERATOR

Videotape

you

No guestions

No

Time noted

183004

thank

Okay

This

in

the

going off

629

and

the

of

correct

California

24

1B30O4

25

end

of

deposition of

record

The

perjury that
Subscribed at

thIs ____

________

183004

the

p.m

under penalty

foregoing is true

is

day

of

_______

_________

RGEN

ROTTLER

296

Merrill Legal

800

Solutio
86-132

Errata Sheet

Deposition

Page

of Juergen

Line

May

Rotther

2009

13

Reason

Change
Change

17

Ed to Ann
Lou

Correction

Lew

Correction

17

13

Change

37

20

Change Oracle

38

21

Delete

Cbedc

Clarification

44

24

Delete

Is

Clarification

to

Clarification

PeopleSoft

to

lower

70

Change higher

72

Change acquisitions

to

Clarification

Correction

to application

91

10

Change

net to

list

Clarification

91

15

Change

net

list

Clarification

94

23

Change

to

to

and

Correction

102

Change conventions

104

Change consents

105

Change factual to factually

Clarification

108

Change infiltration to inflation

Correction

115

21

119
149

Change
Delete

22

would

to

Correction

had

Clarification

will

Change

Clarification

role to roll

Change Louise

182

Change sett1
Change that

246

20

Change

by

248

17

Change

Matson

Correction

set

to

20

Correction

Luiz

to

219

Correction

Customer to netCustomer
to

Correction

with
to

Clarification

Madsen

Correction

area

250

Delete

259

Change contract

to

Correction

284

25

Change

Matson

to

286

14

Change

doesnt

to

Change

above

Subject to the above

Correction

concerns

to

to

155

294

convictions

ges

to

what

our contract

Clarification

Madsen

Correction

didnt

Correction

within

Clarification

certify that

the transcript

is

true

and

correct

/2tU2oo

CERTIFICATE
HOLLY
hereby

foregoing

deposition

truth

whole

the

was

in

time

and place

10

by

shorthand

therein

to

tell the

before

That

12

review

13

Sf

14

provided

to

15

appended

truth in the

th.e

disinterested
and

stated

thereafter

was

hut

said deposition

that

a-nd

completion

of

taken

wa-s

at

person

the

the

testimony

to

reduced

under my direction

coniputer

11

the

nothing

that

by me-

said witness

the

and

truth

in

duly sworn

me

by

witness

the

certify that

within-entitled.cause
down

Certified Shorthand

THOMAN

Reporter

REPORTER

OF

of

typewriting

supervision
the

deposition

hereto

of

the

requested1

any
the

chanqes

reporter

further

16

made by the
during

certify

the

not

requested.

and

deponent
period

that-I am not

of

the parties to

allowed are

counsel
the

said

or

any

of

deposition

nor in any

ay

interested

in

the

event

19

this

and

am not

related

to

any

of

20

parties

CSR

No

17

attorney

18

for

was

was

transcript

cause

-either

-that

of

the

thereto

21
22

25

DATED

rn

M-

HOLLY

THUNAN

6834

or

24

2009

ATTORNEYS

JUAN
JONES
HIGHLY CONFIDENTIAL

EYES

April

ONLY
Page

UNITED

STATES

NORTHERN

DISTRICT

DISTRICT

COURT

CALIFORNIA

OF

FRANCISCO DIVISION

SAN

---oOo-ORACLE

CORPORATION
corporation
Colorado
INC

Delaware

USA

ORACLE

and
ORACLE
corporation
INTERNATIONAL
CORPORATION
California corporation

Plaintiffs

vs
SAP

AG

No

O7CVi655

PJH

German

SAP
corporation
INC
Delaware

AMERICA

corporation
JOMOBROWNOW
Jexas corporation
INC
and

DOES

l5O

inclusive

Defendants

____________/

Deposition
JUAN

JONES

Friday

HIGHLY

REPORTED

BY

AprIl

CONFIDENTIAL

JOHN

WISSENBACH

CLR

CSR

Merrill

of

24

2009

ATTORNEYS

RNR

CRR

ONLY

CBC

01-418986

6862

Legal

EYES

Solutions

800 8699132
a6971i9d-f392-4642-8f24-97791aa3377d

April 24

2009

ATTORNEYS

JUAN
JONES
HIGHLY CONFIDENTIAL

EYES

ONLY

Page

094220

How

094223

have

long

had

you

29

for

responsibility

team

that

094227

team

That

094232

the

C54239

would

fiscal

past

been

has

believe

formed

year

so

maybe

around

that

team

are

year

within

say

094238

As

094241

for

094219

acquisition

responsible

you

slash

Peoplesoft

the

evaluating

094250

of

part

Edwards

JO

results

As

team

of

094252

10

results

094300

11

12

094307

13

094314

14

0943r18

15

094318

16

So

094323

17

Somewhere

094327

lB

Can

relates

look

we

at

those

metrics

094301

that

it

part

094328

For
for

20

094335

22

094351

years

24

0944L0

25

renewal

the

support

you

had

responsibility

services

function

sales

for

for

say

back

you

approximately

four

think

thereafter

or

Do

decisions

you

place

it

something
have

Legal

800

yes

time

in

It

with

sounds

think

right

MS HOUSE

Merrill

there

around

maybe

respect

to

like

was

it

with

six months

that

like

responsibility

connection

in

2005

approximately

time

same

that

to

acquisition

Peoplesoft

about

have

long

to

now

23

091403

how

support

21

094343

the

as

would

the

094332

yes

for

support

Objection

pricing

renewal

sales

vague

Solutions

8699132

a691lf9d-l324642-8f24-97791

a33fld

April 24
ATTOPNEYS

JUAI
JONES
BIGHLY CONFIDENTThL

449

2009
EYES

ONL

pxn
-----o0odeclare

foregoing

is

true

under

penity

correct

and

_______________

California

______________

of perjury that
Subscribed

1day

the

at

2009.

s4gnature

this

of

of

twitness

10

11

12

13

14

15
16

17

18

19
--

20
21

22
23

24

25

218

4erri1l Legal

800

Solutions

8699132

Mrr.II Legal Soluthms

FOR EFADINGICORRECT1NG YOUR DEPOSITION

rNSTRUcTI0NS

To

assist

in

you

please follow

them and

making

the

attach

below

the pages

Please read your transcript

make
and

insert

the

line

the changes

number

Please

do

Please

After

make any

completing

Street

4th

If

line

br

and

on

any

or changes

errors

the errata
you

on

corrections

sign

return

the

the

last

Errata

CA 94105

Francisco

ERRATA

Page

please furnish

sheet by
wish

the

to

you

listing

wish to
the

page

make

face of the transcript

questions

please

and

find

you

testimony

your deposition
are necessary

sheet

then the change

and

of the

to

pages

the errata

of

corrections

changes

any

corrections

additional

back

the

and/or

Floor San

Jot
If

carefully

your review

designated Signature
Main

to

reference

do NOT change

riot

and

changes

directions

page of the
sheets to

or fax

them

errata

Merrill

to

sheet

above

Legal Solutions

415

the
at

357.4301

SHEET

Une

Change

Reason_______________________________________

Change

Reason_________

___________________________

Change________________________________________

Reason_________________________________________

135

Page

Line

Change

Reason__________________________________________

Change

Reason__________________________________________

Change
Reason__________________________________________

Change__________________________________________

Reason_________________________________________

Change_________________________________
Reason____________________________________________

Change_________________________________________

ReasOn__________________________________________

Change_________________________________________
Reason

Subject to the above

_________

No changes

have

been

changes1

certify that

the transcript

made

certify that

the

transcript

is

true

and

correct

is

true

and

correct

datØ

iature

OF REPORTER

CERTIFICATE
JOHN

Reporter

hereby

foregoing

deposition

truth the whole

the

truth in

that

certify
was

That

me

by

and

place

therein

ID

the

said witness

11

typewriting

12

the

sworn

to

tell

but

nothinq

the

cause

said deposition

shorthand

in

duly

and

truth

witness

the

by me

within--entitled

the

Shorthand

Certified

WISSENB7ACH

taken

down

person

at

was

supervision
That

13

14

review

15

requested

16

deponent

17

period

the

of

and

stated
was

under

1X

requested

and provided

to

or

20

said

21

event

22

any

attorney

deposition

of

of

this

the

either
nor

or

in

was

of

and

deposition

was

not

made

the

reporter

by the
the

during

hereto
that
any

any

am

of

way

cause and that

parties

the

of

time

to

my direction

changes

certify

for

the

testimony

any

appended

further

19

are

the

reduced

completion

transcript

allowed

that

thereafter

computer

before

If

18

23

by

disinterested

in

the

not

counsel

of

parties

interested
am not

to

in

related

the

the
to

thereto

DATED

24

25

JOHN

-WISSENEACH

CER

No

6862
219

Jones DA PC
Jones DA PC on

Sotne

11-14

Designation

203-206

Ix Duration

Source
Jones

Juan

what

Today

206

president

Jones Juan

That

cuslomer

223

Mr

224

Juan

you

your

My

Okay

North

America

2416

predorninanUy

2417

group

2418

Can

you

with

259

gel

our

of

involved

for

also

2513

customeit

2514

Ihe

2515

that

2516

theyre

value

we

tasking

to

have

In

nay have
those

ensure

flour
that

customers
working
or

my
do

woricing

wilh

contracts

You know

customers

when

so

lot

support

realizing

base
with

learn

to

spend

of

connection

in

Im responsible or

of

me

004501

sales function

conversatIons

In

appropriate

2512

you do

our customer

support

in

makes

000108

our supporl maintenance

across

--

small

success

more

bit

ensure we

renewal

directly

for

little

are

well

going

what

support renewal

the

258

me

tell

then

Okay

hove

also

servJces

Those

customer

for

learn

customer

America

Functions

are

today

sales

000107

specilically

he

are

he

load

to

acquisition

things

004541

detail

renewal

North

for

000028

responsibdities

2009-04-24

257

22t39PM

more

support

also

my

does

that

maybe

yeats

little

job

team

sure those

253

1111512010

to

reported

you

responsibilities

the

and

manaemonl

2519

half

in

job

lead

to

2415

2518

and

current

today

2517

004558

Rower

Juergen

me

tell

2414

Pnntod

to

four

current

am

2511

support

000011

000040

2413

Juan

have

long

2009-04-24

what

2412

2510

America

Juergen

to

directly

reporl

how

long

Can

2411

256

North

Rotiler

approximately

24

255

services

000017

Ive reported

225

254

vice

coliect

Is

How

222

Jones

senior

is

Rotteii

221

253-2520

title

job

So today you

2125

Jones

my

2009-04-24

2124

-2418

precisely

004609

tulle

today

205

2410

000000

job

your

is

Remains

Elapsed

000011

2009-04-24

Whal

204

-225

FINAL

FINAL

203

2124

on 11-14

of

that

all

of

time

service

about

on

and

also

issues

ptans
plans

to

to

of

all

elements
ensure

spend

time

or Incidents

provide

be

to

receiving

service

offer

value

on

tatking

they are
Ihe

ills

they

remedialion

proactive

to

of

22

24

2009

ATTORNEYS

JUAN
JONES
HIGHLY CONFIDENTIAL

EYES

April

ONLY

Page
UNITED

STATES

NORTHERN

DISTRICT

CALIFORNIA

OF

FRANCISCO

SAN

COURT

DISTRICT

DIVISION

---oUo-ORACLE

CORPORATION
Delaware
corporation
ORACLE
Colorado
USA INC
and
ORACLE
corporation
INTERNATIONAL
CORPORATION
California corporation
Plaintiffs

vs
SAP

No

AG

07CV-1658

PJB

German

SAP
corporation
INC
Delaware

ANERICA

corporation

INC
and

TOMORROWNOW
corporation
1-50 inclusive

Texas

DOES

Defendants

______________/

Deposition
JUAN

JONES

Friday

HIGHLY

REPORTED

RY

of

April

CONFIDENTIAL

JOHN

WISSENBACH

CLR

CSR

6862

24

2009

ATTORNEYS

RMR

EYES

CRR

ONLY

CRC

01418996

Merrill Legal Solutions
800 869-9132

a6971f9d-f392-4642-8f24-97791aa3377d

24

2009

ATTORNEYS

JUAN
JONES
HIGHLY CONFIDENTIAL

EYES

April

ONLY

-r

Page

10014

escalated

to

HQAP2s

100154

Ms

HOUSE

100156

THE

WITNESS

100158

Im

100201

Calls

for

speculation

Im

not

really

because

sure

process

100202

BY

not

MR

intimate

with

does

Does

100207

an

100211

renewed

that

every

of

piece

the

approval

McDONELL

100202

from

exception
have

to

the

get

pricing

10

100232

11

100235

12

100238

13

My

approvals

100242

14

So

the

100244

15

typically

100247

16

communicated

100248

17

18

Do

10oa0S

t9

thats

being

documenting

your

you

by

Yes

10O25

thats

decision

contract

existing

approved

100230

II

43

10030

20

100319

22

lnd

100326

with

every

24

1011343

25

answer

there

is

yes

is

for

process

and

conie

you

by

decisions

on

the

requests

decision

yoii

email
are

well

as

interact

you

account

email

to

email

by

my

come

requests
your

through

with
make

OSSINFO

in

connection

on

an

exception

do

it

on

request

dont
because

things

10131

the

approvals

21

100322

believe

advance

do
in

know

have

terms
So

What

authority
of

cant

like

for

every

approval

billing

billing

request

ofThome
in

every

say

decisions

Merrill Legal

800

that

do

you

have

authority

to

Solutions

8699132

a6911f9d.f392.4S424f24g779

saSSfld

Ju1
HIGHLY

449

pri1 24

JoNEs
CONFIDENTThL

ATTORNEYS

2009
EYES

ONLY

p.m
--aDo-declare

foregoing

is

Lao\_

My

true

under
and

of perjury that

penalty

correct

Subscribed at
this

California

the

I5day

of

2009

sgnature

of

t1witness

Iii

12
13

14

1.5

15

18
19

20
21
22

23

24

25

218

4errii1 Legal Solutions
800 869-9j32

Merrill

Lei Soiutofts

To assit you
please

follow

them and

in

making

below

the pages

Please read your transcript

make
and

insert

the

line

the changes

number

do not make

Please

do NOT change

completing

designated
Main

Street

any

your

reviews

Signature
4th

Floor San

you

br

any

errors

on the errata
you

on

corrections

return

the

last

the Errata

CA 94105

Francisco1

ERRATA

Page

testimony

your deposition

please furnish

are necessary

or

changes

sheet by
wish to

you

listing

wish to
the

page

make

the face of the transcript

questions

please sign
and

find

DEPOSITION

sheet

then the change

and

of the

pages

the errata

corrections

and

changes

line

If

carefully

and/or

any

of

to

corrections

additional

If

back

the

reference

Please

After

to

br

and

changes

the directions

attach

YOUR

FOR READING/CORRECTiNG

INSTRUCTIONS

or

page

of

the errata

sheets to
fax

them

Merrill

to

sheet above

Legal

415

Solutions

the
at

357A301

SHEET

Line

Change

Reason._______________________________________

Change
Reason_____________________________________

Change
Reason_________________________________________

135

Page

Line

Change__________________________________________

Reason__________________________________________

Change

Reason____________________________________________

Change

Reason__________________________________________

Change_______________________________________

Reason__________________________________________

Change__________________________________
Reason.________________________________________

Change________________________________________

Reason__________________________________________

Change__________________________________________

Reason____________________________________________

Subject to the above

No changes

ature

have

7/

changes

been

made

certify that

the transcript

certi

the

that

transcript

is

is

true

and

true

and correct

correct

_____
dates

JOHN
hereby

foregoing

deposition

truth

truth in

that

certify

whole

the

Certified

WISSENBACH

Reporter

the

was

That

said

me

shorthand

by

and

place

therein

10

the

said witness

11

typewriting

12

in

the

sworn

to

tell

duly

truth and

Shorthand

witness

the

by me

the

but

nothing

cause

within-entitled

the

REPORTER

OF

CERTIFICATE

deposition

taken

down

person

at

was

in

supervision

by

That

13

14

review

15

requested

16

deponent
period

of

the

stated

and

under

computer

further

20

said deposition

21

event

22

any

attorney

of

of

for

this

the

reporter

either
nor

cause

parties

or

in

that
any

any

and

the

by

the

during

hereto

certify

or

and

not

made

changes

appended

19

was

the

are

to

deposition

any

to

of

testimony

the

of

time

the

my direction

was

requested

and provided

the

reduced

completion

transcript

allowed

that

chereafter

was

before

If

18

23

disinterested

of

way

that

am
the

not

counsel

of

parties

interested
am not

to

in

related

the

the
to

thereto

DATED

24

25

JOHNWISSENBACH

CER

No

6862
219

May 13
ATTORNEYS

JUERGEN ROTTLER
HIGHLY
CONFIDENTIAL

2009
EYES

ONLY

Page
UNITED

DISTRICT

STATES

NORTHERN

DISTRICT

OF

COURT

CALIFORNIA

FRANCISCO DIVISION

SAN

ORACLE CORPORATION
Delaware
corporation
Colorado
USA INC

ORACLE

and
ORACLE
corporation
INTERNATIONAL
CORPORATION
California corporation

Plaintiffs

No

vs
SAP

AG

German

INC
DOES

corporation
Delaware

TOMORROWNOW
corporation
inclusive

Texas

l50

PJH

INC

SAP

AMERICA
corporation

07CV-1658

and

Defendants

VIDEOTAPED

DEPOSITION

IUERGEN

WEDNESDAY

HIGHLY
REPORTED

BY

BOTTLER

MAY

CONFIDENTIAL
HOLLY

OF

THUMAN

13

2009

ATTORNEYS
CSR

No

EYES

6834

ONLY

RMR

CRR

1-4l821

Merrill

Legal

Solutions

800 8699132
Oe85llcb-Sd3f-4935-99b2-2c167123543ba

JUERGEN ROTTLER
CONFIDENTIAL
HIGHLY

13

May

2009

EYES ONLY

ATTORNEYS

Page

L01S7

like

101824
101426

During

1018t45

have

1O1O5

about

101856

had

existing

you

be

so

believe

1QIB41

would

group

be

that

for

responsible

to

companies

target

that

Peoplesoft

like

acquired

of

valuations

performing

22

time

your

for

responsibility
on

pricing

changing

Mr Rattler

Oracle

at

decisions

making

services

support

fot

customers

Yes

101058

Md

101859

10

101902

11

about

101906

12

customer

thats

101908

13

customer

wants

101913

14

contract

101915

15

lets

is

to

just

say

to

Do

Oracle

also

what

clear

be

has

software

existing

the

and

their

service

that

in

involved

get

talking

support

getting

renegotiate

you

an

Urn

Yes

101911

how

Procedurally

10d919

11

101921

19

101924

19

it

101927

20

services

101932

21

to

101938

22

101941

23

101942

24

25

Can

work

what

At

Yes

1D1944

that

does

level

do

involved

get
goes

to

the

as

the

the

as

final

After

business

process

final

approval

that

it

before

approver
within
goes

to

the
approval

Larry/Safra
Does

go

in

involved

get

you

through

Merrill

all

repricing

of

that

nature

have

to

you

you

Legal

800

Solutions

8699132

CoO

511 cb-Sd

3f4935-99b2-Zd

671

23543ba

182926

The

182928

13

JDERGEt R0TLBt
CONFXDENTIAL

BIG

other

Yeah

MR

going the

to SAP

direction

182931

OIILY

be companies

could

opposite

182929

2009
EYES

rnOPNEYS

McDONELL

no

182932

further

182937

this

deposition

182940

real

document

but

concluded

concerns

MS HOUSE

182945

.MR
10

11

IMR

182948

12

MS HOUSE

18249

VIDEO

182950

14

29

15

Juergen

Rottler

182954

16

time

17

183004

19

183004

20

the

183004

21

_______________

questions

islo

No

you

questions

OPERATOR

This

is

the

end

of

18

183004

ours.

629

182958

thank

Okay

McDONELL

THE

reserve

Okay

MS HOUSE

182347

soiae

Ill reserve rights

welJ

And

theres

think

but

McDONELL

182945

nothing

resering rights to not have

am

182942

have

Counsel

18

52

Volume

No

in

Were

going

Videotape

is

Time noted

declare

the
off

deposition

of

the record

The

629 p.nL

under

penalty

foregoing is true and

correct

California

of

perjury that
Subscribed at

this ____

day of

___2009.
183004

24

183004

25

RGEN

ROTTLER

296

Merrill Legal Solutions

800

8699132

rrata

Deposition

of

Sheet

Jneren Rottber May i3 2009
Reason

Change
change

17

Ed to Ann
Lou

Correction

Lew

Correction

17

13

Change

37

20

Change Oracle

38

21

Delete

Check

Clarification

44

24

Delete

Is

Clarification

to

Clarification

PeopleSoft

to

lower

Clarification

to

Correction

70

Change higher to

72

Change acquisitions

application

91

10

Change

net

to list

Clarification

91

15

Change

net

to

list

Clarification

94

23

Change

to

and

Correction
to convictions

102

Change conventions

104

Change consents

105

Change factual

108

Correction

Change infiltration to inflation

115

21

Change

119
149

Delete

22

to

would

Correction
Clarification

factually

Correction

had

to

Clarification

will

Clarification

Change roles

rolls

to

Change Louise

155

concerns

to

Luiz

to

182

18

20

Change that

246

20

Change

by

248

17

Change

Matson

Correction

set

Change settle to

219

Correction

Correction

Customer to netCustomer
to

Correction

with
to

Clarification

Madsen

Correction

area

250

Delete

259

Change contract

Correction

what

to

our contract

Clarification

284

25

Change

Matson

to

Madsen

Correction

286

14

Change

doesnt

to

didnt

Correction

Change

above

294

Subject to the above

ges

to

within

certify that

the transcript

___________________________
Ignature

Clarification

is

true

and

correct

/2f2oO
date

CERTIFICATE
ROLLY

certify that

hereby

foregoing

depo5ition

truth

whole

the

was

shorthand

the
10

place

witness

said

in

the

duly sworn

me

to

tell the

that

That

before

12

review

13

Sf

14

provided

to

15

appended

truth

the

disinterested
and

stated

that

the

and

completion

the

in

taken

was

at

person

reduced

thereafter

was

but

said deposition

under my directioxi

by computer

11

witness

the

and nothing

me

by

therein

time and

by

truth

withinentitledcause
down in

Certified Shorthand

THIJI4AN

Reporter1

REPORTER

OF

the

testimony

of

typewriting

t-o

supervision

of

deposition

the

hereto

of

the

requested

any
the

changes

reporter

further

16
for

was

transcript

17

attorney

18

deposition

nor in

19

this cause

and

20

parties

made

by

during

certify that

was
the
the

allowed

are

counsel

parties

to

the

of

ny

way

interested

am not

period

of

any

that

and

deponent

not

am

either or

the

requested

not

related

or

said

in

the

event

to

any

of

of

the

thereto

21

DATED

24

________

25

HOLLY

TWJMAN

CSR

t1o

6834

BLOTNER
July 23
HIGHLY CONFIDENTIAL

RICHARD

UNITED

DISTRICT

STATES

NORTHERN

OF

DISTRICT

SAN

FRANCISCO

2008

COURT

CALIFORNIA

DIVISION

--000ORACLE
CORPORATION
Delaware
corporation

INC

USA

corporation

ORACLE

Colorado
and ORACLE

INTERNATIONAL
CORPORATION
California
corporation

Plaintiffs

No 07CV1658PJH

vs
SAP
SAP

AG

German

AMERICA
corporation

INC
DOES

corporation

INC

Delaware

TOMORROWNOW
Texas
corporation
150 inclusive

and

Defendants

DEPOSITION
RICHARD

Wednesday
CONTAINS

REPORTED

BY

HIGHLY

CYNTHIA

OF

BLOTNER

July

23

2008

CONFIDENTIAL

PACINI

MATERIAL

CSR

6117

RMR

CRR

01-411414

Merrill Legal

800

Solutions

8699132

fa6333c2-5247-4156-8fef-c02a2d623366

RICHARD

23

BLOTNER
July
HIGHLY CONFIDENTIAL

2008

98

Page

them

wont

ask

group

went

going

through 266

group keeps

him then

doesnt matter

so

his

So

about

questions

anyway

Technology

Screvens

any

it

262

through

actually

34266
okay
And

Charles
the

12

Catzs
Shes

next

page

CFO

our

14

Arid

direct

corporate

to

reports

Various internal

him

69

34268

pages

So

reports

And

Safra

related

support

organizations

15

our

they are nonsales

organization
also

two

of

part

for example

Phillips

next

is

Larry Ellisons

organization
to

this

267

16

Phillips

11

sales

who

then
is

our

And

globally for

Charles

have

manages

all

the

Oracle

Okay

19

we

president and

organizations

lB

34270

on

271

then

Juergen Rottler

20

Jones

21

So

22

earlier is Oracle customer services

23

Oracle support

24

North America

25

this

report
guess

labeled

the

is

official

before
and

the

Latin America

Merrill

our

title

Juan

that

Jones

EMEA

and

Juan

organization
we

talked about
was

runs

other individuals

Legal

800

support

and

dont

saying
for

support
who

are

know

if

Solutions

8699132

fa6333c2-5247-4l

56-SIGI-c02a20623366

RICHARD

BLOTNER
HIGHLY

23

July
CONFIDENTIAL

2008

99

Page

theres
the

one

here

on

for

renewals

support

Pacific

Asia

organization

not

or

to

reports

But

Juan

Jones
For

America

For
he

North
North

America

have

might

global

to

Edwards

Jones

Screven

yeah

who

12

out

of
we

have

page

275

is

organization

Ed

16

people

all

They

following
works

Ed

t9

20

21

page

22

Is

as

that

is

John

There

me just

Wookey

titles

salesrelated

23

in

What

25

These

can

breakout

277
stop

Rozwat

see

of

6211

And

Doris

of

the

Wong

who

278

first of

people

relating

has

he

page

further
you

The

development

the

on

technology

all

at

listed

on

to

product

is

this

that

strategy

function

No

24

the

Charles

you

fit

number

are

with

As

is

and

hit

we

applications

didnt

Abbo

Let

34276

our

276

page

for

back

goes

34273

274

Abbo

15

IS

page

more

organization with

development
next

next

Oracle

Then

transition

The

already discussed

we

and

developmentoriented
11

fact

Jones

Juan

in

renewals

support

Juan

have

Might

kind

of

function

are

in

the

Merrill

Legal

800

development

organization

Solutions

8699132

a

6333c252474l

SGfef-c

O2fld 523366

RICHMD

BLOTNER
HIGHLY

declare
the

foregoing

is

under

true

and

23

July
CONFIDENTThL

penalty

correct

of

perjury

___________

that

Subscribed

California
of

2008

thisa3

at
day

2008

RICHARD

BLOTNER

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

149
Merrill

Legal

800

Solutions

8699132

Merrill Legal Solutions

FOR READING/CORRECTING YOUR DEPOSITION

INSTRUCTIONS

To

you

assist

making corrections

in

below

directions

pages to the back

This

is

Please
insert

the

If
directly

of the errata

the

final

read

it

you are

version

carefully

pages
sheet

deposition

If

find

you

in

of the

possession

testimony

please

follow

please

furnish

transcript

any errors or changes you wish
beside

original

change

After completing

the

page

transcript

and

do

line

to

make

numbers

NOT make

any changes

the designated

any of the questions

your

review please

Signature

line

sign the

and return

the

last

page

transcript

of the

errata

to your

sheet

attorney

ERRATA SHEET

Page

the

them and attach the

the transcript

Do NOT

above

your deposition
are necessary

on the errata sheet

corrections

on

to

of your

If additional

Line

Change
Reason________________________________________

Change_________________________________
Reason________________________________________

Change
Reason

Page

Line

Change

/1

Reason

//

Change
Reason

Change
Reason

11

Change
Reason

Change
Reason____________________________________________

Change
Reason_________________________________________

Change
Reason

________

Subject

to

the

above

changes

_______ No changes have been

signature

made

the

transcript

cefti that the

transcript

certify

that

is

is

true

and correct

true

and

date

correct

CERTIFICATE
CYNTHIA

OF

hereby certify that

foregoing

deposition was

the

withinentitled

therein

place
10

witness

11

computer

was

said

me

by

the

the

sworn

to

tell

but

nothing

the

and

before

review

14

If

15

provided

to

16

appended

that

taken

the

truth

down

in

the

to
and

at

the
of

typewriting

time
the

and
said

by

supervision
of

completion

in

testimony

the

reduced

direction

my

13

was

disinterested person

thereafter

That
of

in

duly

deposition

stated

under

12

and

witness

cause

That
shorthand

truth

whole

the

me

by

Shorthand

Certified

PACINI

Reporter

truth

REPORTER

the

deposition

hereto

requested

17

for

attorney

19

deposition

20

this

21

parties

25

any
the

changes

reporter

further

18

22

transcript

cause

either

was
made

by

during

certify that

the
the

am

or

any

of

nor

in any

way

interested

and

that

am

not

the

was

requested

and

deponent

allowed

period

not

parties

related

not

of

counsel

to

the

are

or

said

in

the

event

to

any

of

CSR

No

of

the

thereto
DATED

CYNT

IA

PACINI

6117

RICHARD CUMMINS
September 16 2008
HIGHLY CONFIDENTIAL INFORMATION
ATTORNEYS EYES

ONLY

Page
UNITED
NORTHERN

STATES

DISTRICT

DISTRICT

SAN

OF

FRANCISCO

COURT

CALIFORNIA

DIVISION

000
ORACLE

Delaware
CORPORATION
Corporation
ORACLE
USA INC
Colorado
and
Corporation
ORACLE
INTERNATIONAL
CORPORATION
California
Corporation

Plaintiffs

Vs
SAP
SAP

No

EDL

07-CV-0l658-PJH

AG

German
Corporation
AMERICA
Delaware
INC
CORPORATION
TOMORROWNOW
INC
Texas
and
DOES
Corporation
150 Inclusive

Defendants
________________________________________________/

VIDEOTAPED

RULE
ORACLE

RICHARD

Tuesday

Reported
Job 412495

By

16

ARLEN

Merrill Legal

800

2008
255

Pages

INFORMATION

WENDY

OF

CUMMINS

September

Volume
CONFIDENTIAL

DEPOSITION

CORPORATION

Designee

HIGHLY

30b

ATTORNEYS

CSR

4355

CRR

EYES

ONLY

RMR

Solutions

8699132

e6a0856a-Oee4-4b35-albf-ca2oaf8a26bc

September 16 2008
CUMMINS
ATTORNEYS EYES
INFORMATION
CONFIDENTIAL
RICHARD

HIGHLY

ONLY
34

Page
likely

is

TomorrowNow
either

through

license

how

Then
in

get

license

manager

regional

does

you

How

me

through

the

to

license

do

you

reps

and

did

so

to

up

report

say

rep

0944

did

You

1O

meant

II

12

support

13

And

14

support

15

onto
back

or

17

thats

19

they

so

reps
the

it

out

19

the

theyre
of
then
there

than

21

be

responsible

22

to

returning

group

are

issues

is

that
for

will

there

reports
trythg

get

make

new

then

something
of

what

involved

other

through

me

back

bringing

parameters

any

up

to

with

the

back

customer

bring

their

of

come

structure

to

then

group
you

other

that

would

license

sales

stuff

already

customers

23

MS

HOUSE

24

TIlE

WITNESS

mentioned

to

outside

do

to

trying

to

manager

regional

trying

So

apologize

how

there

If

20

25

to
is

customer

Is

can

up

understands

rep

if

reps

support

report

support

16

0945

relate

that

loop

the

The

0945

correct

Correct

09LI1

094S

with

relationship

rep

support

from

Oracle

to

of

kind

sortie

or

rep

return

to

customers

for

ways

dont

Objection

believe

Merrill Legal

800

Other

vague

than

the

so

Solutions

8699132
s6.Oa56a-0a4-4b35-al

bf-ca2OQa26bc

RIChARD

CUMMINS

16

September

2008

CONFIDENTIAL

MR
break

McDONELL

the

for

day

Im

Counsel

See

then

Thank

week

next

you

to

you

going

sir
This

VIDEOGRPPHER

i70

videotape

number

Cuminins

Going

four
off

in

the

marks

end

deposition

the

the

of

record

the

time

of

Richard

is

502

-o0o
Whereupon

502

the

was

deposition

adjourned

at

p.m
-o0o--

10

12

declare

13

the

14

______________

foregoing

15

____________

under

is

and

Cal

ue

fo

penalty

of

perjury

correct

Subscribed

this

day

that
at

of

2008

19

Signature

of

Witness

20

21

22

23

24

25

253
Merrill

Legal

800

Solutions

8699132

Errata

of Rick

Deposition

Pa2e

Line

41

1-22

Cummins September 16

Sheet

2008

Change

Reason

Change Juans

manager

is

responsibility

Juan

to

is

responsible

service

Clarification

delivery

for service

delivery

managers
Change

14

No

havent

havent

124

talked

to

talked

hundreds

to

customers

to

No

Clarification

of customers about

TomorrowNow
151

Change

174

less to

more

Change welcome

23

to

Change Hutton

207

Change

McGee

Change

were new

to

Change or doesnt

to

219

22

232

245

Subject

14

to

the

_v

A72687826j

Change

above

changes

IP

to

Oracle

Correction

Hunt

176

to

Correction

Correction

Murquia

to

Correction

renew

Correction

does

or

doesnt

Correction

IT

I9erttfy

that

Correction

the transcript

is

true

and

correct

CERTIFICATE
WENDY
hereby

foregoing

deposition

the

REPORTER

Certified Shorthand

ARLEN

Reporter

truth

OF

certify that
was

by

truth and

whole

witness

the

me

but

the

to

sworn

duly

nothing

in

tell

the

the
in

truth

the

withinentitled cause
said deposition

That

shorthand

by

and

therein

place

10

said

11

computer

review

14

requested

15

deponent

16

period

the

of

before

reduced

to

and

allowed

are

either

18

attorney for

19

deposition

nor

in

20

this

and

that

21

22

way
am

during

the

hereto

of

the

of

parties to

interested
not

not

am

related

counsel
the

said
of

in

the

event

to

any

of

rc4

DATED

2008

24

WENDY

by

the

by

23

25

the

not

made

reporter

parties thereto

cause

any

of

deposition
was

the

any

time

typewriting

the

of

changes

certify that
or

the

at

supervision

any

appended

further

in

testimony

was

to

down

person
the

completion

requested

and provided

taken

that

transcript

If

17

and

direction

my

That

13

stated

thereafter

was

under

12

disinterested

me

witness

was

ARN

CSR No

4355

the

or

PAUL

DUGGAN
HIGHLY CONFIDENTIAL

2009

August

ATTORNEYS

EYES

ONLY
Page

THE

IN

UNITED

STATES

DISTRICT

DISTRICT

NORTHERN
SAN

OF

FRANCISCO

COURT

CALIFORNIA

DIVISION

--aDo-ORACLE
Delaware

CORPORATION
corporation

INC

USA

ORACLE

Colorado
and
ORACLE

corporation

INTERNATIONAL
CORPORATION
California
corporation

Plaintiffs

vs
SAP

AG

German

SAP

AMERICA
corporation

INC
DOES

07CV1658

PJH

corporation

INC

Delaware

TOMORROWNOW
Texas
corporation
150 inclusive

and

Defendants

VIDEOTAPED

DEPOSITION

REPORTED

BY

CONFIDENTIAL

SARAH

ATTORNEYS

LUCIA

BRANN

Merrill Legal

800

PAUL

DUGGAN

2009

August

HIGHLY

OF

CSR

EYES

3887

ONLY

421893

Solutions

8699132

f2f312ff-3d87.4268-a7b3-2b05efa96663

HIGHLY

PAUL DUGGAN
CONFIDENTIAL

2009

August

ATTORNEYS

ONLY

EYES

23

Page
094J405

Can

09494E

one

creating

describe

you

MR

ALINDER

Objection

0949i5

THE

WITNESS

Can

099d6

MR

DELAHtJNTY

09490/
094913

in

methodology

forecasts

those

of

the

and

Vague

ambiguous

094920

and

094925

these

service

support

forecasts

094929

The

094934

10

forecasting

U9493

ii

percentage

094945

12

use

094947

13

typically

094950

to

How

in

track

date
OKS

the
our

and

verbal

renewals

conversations

directors

numbers

in

our

standard

do

those

15

095004

16

095006

17

responsible

095009

18

forecasts

095012

19

20

095019

21

some

cases

095021

22

with

that

095025

23

from

quotation

095031

24

to

is

the

And

based

terms

we

system

there
the

on

of

are

reps

and

rollup

of

sale

095014

in

between

the

095003

of

the

track

which

and

managers

one

likelihood

How

the

managers

dreate

will

system

support

the

to

refer

you

representatives
close

do

representatives

that

that

clarify

you

25

those

for

those

determine

The
the

manager

customer
to

and

getting

Is

record

Legal

800

forecasts

who

or

sales

the

of

closing

and

representative

would

be

in
the

tracking

purchase
created

are

creating

likelihood

communications

eventually

Merrill

individuals

the

support

reporting

of

constant
sales

with

in

contact

cycle

the

customer

order
those

Solutions

8699132

tZf3l

2ff-3d

SI-I

268-a

7b3-2b0

Sofa

96663

PAUL
HIGHLY

DUGGAN

2009
August
ATTORNEYS
EYES ONLY

CONFIDENTIAL

113457

the

Whereupon

113457

concluded

at

was

deposition

a.m

1124

oOo

113457
113457

declare

113457

foregoing

S-

113457

is

true

under

and

penalty

correct

2pp.JCCO

of perjury

Subscribed

California

the

at

this

day

2oo9
______

Paul

Duggan

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

80
Merrill

Legal

800

Solutions

8699132

Merrill

Legal Solutions

INSTRUCTIONS

To

assist

please

them

making

below

and

in

attach

Please

read

your

make

insert

the

and

the

line

br

changes and

the directions

you

follow

FOR READING/CORRECTING

the

number

reference

do not make any changes and

Please

do NOT change

designated
Main

Street

br

you wish

to

on the face

make

of the transcript

any of the questions

your review please sign the last page of the errata sheet above
line and
return the Errata sheets
to Merrill Legal Solutions

Signature
4th

Floor

CA 94105

San Frandsco

or fax

them to

415

the
at

135

357.4301

SHEET

Line

1E1

Change
Reason

2Cr

furnish

any errors or changes you wish to
on the errata sheet by listing the page

corrections

ERRATA
Page

testimony

find

then the change

Please

After completing

you

corrections

and

your deposition

pages are necessary please
of the errata sheet

If

transcript carefully

to

DEPOSITION

additional

If

pages to the back

changes and/or

corrections

YOUR

CFrU-

liftS

Clange

I---

Reason

JiZi
IN

rE

V1

r1FC

Change

5U

Reason_ii

1-CCJ

gLS

s4-

zaa

Page

Line

-r R4Sk

Change
Reason

Change

Ei Jk

Ti
J22L

Reason

1tPo

Change
Reason_________________________________________

Change
Reason_______________________________________

Change
Reason_________________________________________

Change
Reason_______________________________________

Change
Reason

Subject

_______

to

the

above

changes

certify

that the transcript

is

true

and

correct

made

certify

that the transcript

is

true

and

correct

No changes have been

ill
signature

date

CERTIFICATE
LUCIA

SARAH

OF

REPORTER

BRANN

Reporter

hereby certify

that

foregoing

deposition

Certified

by me

the

truth

whole

was

and

truth

the

Shorthand

witness

in

the

sworn

to

tell

duly

but

nothing

the

the

truth

in

the

time

and

within-entitled cause
That
shorthand

place

me

by

therein

10

witness

11

computer

was

said

of

and

thereafter

That

12

disinterested

stated

under

review

the

14

If

15

provided

to

16

appended

that

taken

down

to

and

the

testimony

of

typewriting

the

said

by

supervision
of the

completion

in

at

person
the

reduced

direction

my

before

13

was

deposition

deposition

hereto

requested

17

any
the

changes

reporter

further

attorney

19

deposition

nor

in

20

this

and

that

21

parties

cause

made

either

by

during

certify

18

for

was

transcript

that

the
the

am

or

any

of

any

way

interested

am

not

the

was

requested

and

deponent

period allowed

not

parties

related

not

of

counsel

to

the

are

or

said

iii

the

event

to

any

of

of

the

thereto

_____

DATED

24

25

SARAH

LUCIA

BRANN

CSR

No

3887

ORACLE

USA INC

SAP

CASE

SUPPLEMENTAL

TM

AC

No

ET AL

07-CV-01658

EXPERT REPORT

FINANCIAL
FEBRUARy

Fr AL

OF PAUL

FORENSICS

MEYtR

LLC

232010

PAUL

MEYER

Juwgi RoUeg Orade Exulive
Gazy

Miller

Orade

Head

of

Vice

CktaI

Page
Subject
Highly

to

Protective

Confidential

Order
Information

AtorncyF

Oniig

Cusic.w

Servic

Opendixa

Ond

President
Busaness

242

o1281

Customer

Senic

OPACLC
25-Oct-OS

Canon

Margaret
FedEx
60

Corporation

FedEx

2nd

Paitway

Floor-V

COLLIERVILLE

TN 38017
States

United

Re
Dear

Please

are

you

conditions

renewal

your

order

service

15-Nov-OS

before

nan-cancelable

Once
and

loss prepayment
for
these
accepted
referred
of

copy

as

to

order

purchase

Oracles

Reinstatement

current

then

technical

Oracle

and

notices

would

like

information

found

to

be

is

the

no

USA

sales

of

below

service

OST

teduiical

Details

is

be

itmst

or

not

are

VAT

or

or

$2000

Is

odeis

yr cnnpany

on

is

renewal

This

PwrJase
tax

If

your

to

delmed

as vendixi

Inc.

tethnical

above

the

on

Aegtacce

vabe

receivS

accearice

Oracle

pursuant

acquired

fltecnjption

pei

pe-tax

applicable
of

receipt

provied

acceptance

attathod

the

support

must be

including

upon

govern

can

collectively

tax

exempt

included

wtth

your

most
on

support

Policy

the

terms

the
to

of

web

support polices

and

wish

later

reinstatement

Applicable

nchidflg

10

subject

change

Oracles

Iitto-j/mmoda.wnt.Et/wJ1t14

at

lapse

we

your tectmlcÆ support and

technical

aJrrellt

reactivate

to

wil

it

may apply

fees

be

to

sttjact

addition

fri

to

the

Oracles
annual

tees

information

updated

from

policIes

technical

If

card

credit

there

with

the

for

Oracles

is

ycu

when

refwced

and

services

support

qootS

payment

The

Roinstalement

provide

of

or

specifying

twms

its

allow

provides

you

issued

certificate

lonn

support

An Invoice

be

only

support

support

hat

lI

that

accordance

non-refundable

are

check

transactions

Policy

who

Customers

form ala

or other

with

technical

This

licenses
to

subject

ensure

to

in

tedoica

you exeojted

that

the

for

is

and

renewal

foes

related

the

exemption

technical

accordance

in

renewal

sene

orderad

the

in

TaC

tac

your

this

quotation

this

seMce

this

accept

please

undoq

aider

agreement

as Peoplesoft

Tho

22-Dec-OS

expired on

license

valid

known

formedy

completo

to

support

of the

renewal

service

have

or

expire

will

above

the

for

qiotation

recoMng

from Oracle

support

In

attached

find

terms and

the

P-04-11888-000--l1

Canon

Margaret

benefits
to

Renewal

Service

and
e-mail

notices

about

information

technical

with

your

via

to

that

Axtdhgty

e-mal

ensure

support
order

receive

you

It

is

important

cwimunication

us

take

please

this

do

opportinity
not

hesitate

to

thank you

to

contact

me

for

at

your continued
your

earliesl

busbess

II

you

require

lurther

nvenience

Regards

Betsy

Steehuan

Oracle

Support

Sarvices

E-mail

[e-mail]

Tel.

303-3342641

Fax

119-7574279

Page

Highly

Confidential

Cotxacf

of

nfomiation

Attorneys

Eyes Oniy

ttwiber

P-04-I 1888-000--Il

ORCL000392TT

ORACLE
Oracle

Margaret

Renewal

Date 25-Oct-05

Quotation

FedEx

Service

Canon

Corporation

60 FedEx

Parkway

2nd

Floor-V

COLLIERVILLE
TN 38017
United

States

Tel

901 263-5174

Fax
E-mail

[e-mail]

QUOTATION

THIS

IS

THROUGH

VALID

15-Nov-05

PLEASE DO NOT CHANGE

ANY OF THE INFORMATION BELOW WHEN SUBMITTING YOUR
RENEWAL
ORDERS IN WHICH THE SERVICE DETAILS HAVE BEEN CHANGED ARE
NOT VALID AND YOUR ORDER WILL NOT BE PROCESSED
to the information
change
provided
below is required
contact
me and an updated service renewal quote will be provided to you in
please
SERVICE

If

accordance

Service

Product

Oracles

with

Level

technical

Software

eBill

Enterprise

14CM

PeopleSoft

Enterprise

Financials

PeopleSoft

Enterprise

Billing

Planning

PeopleSoft

Enterprise

Business

PeopleSoft

Enterprise

Catalog

HCM

Frns

Expansion

Perpetual

Budgeting

Employees

Employees

Planning

Management

Perpetual

Perpetual

Employees

Perpetual

Perpetual

260000

23-Dec-05

14482452

260000

23-Dec-05

260000

23-Dec-05

14482452

260000

23-Dec-05

14482452

260000

23-Dec-05

14482452

260000

23-Dec-05

14482452

Perpetual

23-Dec-05

14482452

Employees

Start

260000

14482452

Perpetual

Oty

14482452

260000

23-Dec-05

Date

Employees

Perpetual

14482452

260000

23-Dec-05

Expansion

Employees

Perpetual

14482452

260000

23-Dec-05

14482462

260000

23-Dec05

Peoplesoft

Confidential

End Date 22-Dec-06

Expansion

Scm

Page

Employees

httollwww.oracle.comfsuooort/policies.html

Support

Perpetual

Employees

Warehouse

And

at

CSI

Employees

Enterprise

License

Employees

Warehouse

PeopleSoft

located

policies

Metric

Payment

Enterprise

PeopleSoft

Highly

Update

License

Description

PeopleSofl

support

Enterprise

EPM

Portal

Pack

Employees

Perpetual

of

Information

Contract

Attorneys

Eyes Only

Number

P-04-11888-000--i1

0RCL00039278

QRACL
Total

Amount USD
Plus

Page

Highly

Confidential

of

Information

Contract

Attorneys

Eyes

Only

Number

P-04-1

270000.00

Applicable

Tax

1888-000--il

0RCL00039279

QRACLE
Details

Acceptance
Oracle

processes
such

payment

PURCHASE
Purchase
If

renewal

orders

check

or credit

card

ORDER

CHECK

renewal

service

your

by Purchase

P-04-i

Service

23-Dec-05

Term

of

Local

Tax
terms

terms

if

purchase

fees

total

specified

on

order

or other

Oracle

the

form

acceptable

of

Renewal

Service

Order

your Purchase

Order

must

include

the

following

1888-000--il
to

22-Dec-06

applicable

of your

agreement

Purchase

of

Please

of

receipt

CARD CONFIRMATION

CREDIT

Renewal

Service

after
for the

Order

accepting

The

service

as

e-mail

or-fax

Attn

Oracle

with

formerly

known

as Peoplesoft and

this

order

supersede

the

Order

Purchase

your

Betsy

Support

to

Steelman

Oracle

Order

Fax

Services

719-757-4279

E-mail

betsysteelmancoraclecom

Customer

FedEx

From

Margaret

Canon

service

renewal

Corporation

Check
If

accepting

by

Check

Renewal

Service

23-Dec-05

of

Local

Tax

Credit

include

the

following

complete

the

information

if

to

22-Dec-06

applicable

Card

accepting

information

Attn

service

your

renewal

by

Credit

Card

please

sections

below and

fax

this

to

Betsy

Steelman

Oracle

Support

Fax

Services

719-757-4279

E-mail

[e-mail]

Customer

FedEx

From

Margaret

Page

Highly

please

P-04-11888-000l1

Service

Term

If

your

Confidential

Corporation

Canon

of

Information

Contract

Attorneys

Eyes

Only

Number

P-04-1

1888-000il

0RCL00039280

ORACLE
Number

Card

Credit

Expiration

Date

Authorized

Signature

Name

Print

PAYMENT

TERMS

Terms

Payment

ADDITIONAL
There

Page

Highly

Confidential

are

no

for

all

fees

payable

to

Oracle

are

30

NET and

will

be

invoiced

annually

in

advance

ORACLE TERMS
additional

terms

of

Information

Contract

Attorneys

Eyes

Only

Number

P-04-1

1888-000--Il

0RCL00039281

ORACLE
Customer

Details

Please

verify

and

to

company

your

update
If

the

following
are

changes

information

required

please

to

enable

us

e-mail or fax

to

the

provide

an

updated

efficient

information

and

timely

service

to

Betsy Steelman

Attention

Oracle

Support

Services

E-mail

betsy.steelmanloracle.com

Fax

719-757-4279

Tel

303-334-2647

Company

Name

Renewal

Service

FedEx
it

Corporation

P-04-i

1888-000--li

For Quotation
Contact

Margaret

Company

FedEx

Address

60 FedEx

Canon

Corporation

Parkway

2nd

Floor-V

COLLIERVILLE
TN 38017
United

TeL

States

263-5174

901

Fax
E-mail

For

[e-mail]

Invoice

Contact

Scott

Company

FedEx

Address

60

Struminger
Corporation

FedEx

Parkway

COLLIER VILLE
TN 3801 7-9647
United

Tel

States

-901/486-0905

Fax
E-mail

Page

Highly

Confidential

of

Information

Contract

Attorneys

Eyes

Only

Number

P-04-l

1888-00011

0RCL00039282

O$$W4FO-

From

Allison

LoSno_uS_aPcc00k.000u1

131 PM
23.2005
Fettuary
Wednetfl
Chris Madsen
TaylorJason
NASUPPINFQ..US

Sent

To

HutchinsDebra

RogersGretdlefl

AmbreEileefl

Subject

Executive

Summary

for

Honeywell

itachmonts

Executive

Summaty

for

Honeywell

Fxtive Swmary
HoneyweL

far

Tkrn

attached

request

for

bill

are

quoting

to

and

ship

to

in

Canada

is

approved

by

OSSINFO
As

noted

Re ga

below

please

ensure

we

in

US

and

apply

iS

adjustmentsitaxiflg/etc

rds

.lltson

Businas
Oracj.o

Adams
Flanatng
Support

phonefax

Confidenbel

Manager

Services

132262429

lnkrmation

0RCL00853682