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 12
Foundation for
A-6205-1
Defendants
0RCL00034305
Oracle
Senior
Trial Exhibit
Oracle
Director
A-6205-1
organizational
Support
Sales
Foundational Support
chart identifying Richard
Rick Cummins
as
an
Mid-Market
Cummins Sept 16 2008 Depo Tr at 102-11 143-23 1425-1511 276-23 4911-13
Rule 30b6 testimony by Cummins identifying Cummins as Oracles senior director
of support
renewals/sales
discussing
the support
Feb 23 2010 Oracle
Cummins as
Richard
SVI-108747v1
in
North America describing
sales/renewals
Expert
Report
Senior Director
his
responsibilities and
team and reporting structure
of Paul Meyer redacted
Support
Renewals
for
excerpt identifying
North America
Chart
Organization
ORACL.
Page
Aria
People
of
Search
set
..-
Directs
Total
367
an
VP
Suppod
RiewS
Dlrocts
TotaL
taDthaa
Dror Suppod Sas
SdJes
211
thhIt.aLinter
Qacto.
5Mpport
8pIM4-
rotar
TstZg
SSss
ToTaL2
Dy11nS
$LQimcQLwoj
Coordlna
Suoqi
mocd
QCWliQfl
Sublicene
Pru4ecI
Sr
btSCa
Total
19
Sntnic
TotaLs
St
tot43
.._
hghIy
ConfjdentaI
Information
Attornev
Eyes
Ord
0RCL00034305
RICHARD CUMMINS
September 16 2008
ATTORNEYS EYES ONLY
HIGHLY CONFIDENTIAL INFORMATION
Page
UNITED
STATES
DISTRICT
DISTRICT
NORTHERN
SAN
OF
FRANCISCO
COURT
CALIFORNIA
DIVISION
--OOoDelaware
CORPORATION
Corporation
ORACLE
USA INC
and
Colorado
Corporation
ORACLE
INTERNATIONAL
CORPORATION
ORACLE
California
Corporation
Plaintiffs
No
Vs
SAP
AG
SAP
AIVIERICA
German
EDL
07-CV-01658-PJH
Corporation
INC
Delaware
CORPORATION
TOMORROWNOW
and
Texas
Corporation
150 Inclusive
INC
DOES
Defendants
________________/
30b
RULE
VIDEOTAPED
ORACLE
RICHARD
CONFIDENTIAL
Reported
By
Job 412495
CUMMINS
16
September
Volume
HIGHLY
ARLEN
Merrill Legal
800
2008
255
Pages
ATTORNEYS
INFORMATION
WENDY
OF
CORPORATION
Designee
Tuesday
DEPOSITION
CSR
4355
CRR
EYES
ONLY
RNR
Solutions
8699132
e6a0856a-Oee4-4b35.albf-ca2oaf8a26bc
RICHARD
HIGHLY
September
16 2008
INFORMATION
ATTORNEYS
EYES
CUMMINS
CONFIDENTIAL
ONLY
10
Page
Understood
Where
do
Oracle
0913
What
North
Corporation
is
Im
have
long
Edwards
which
acquired
by Oracle
ii
industry
for
ten
MR
McDONELL
12
was
renewals
support
So
years
that
for
by
Ive
the
in
Oracle
have
we
Exhibit
42
with
was
was
in
the
job
since
this
3D
which
Peoplesoft
been
With
Can
position
2005
since
acquired
Defendants
13
2005
marked
marked
for
identification
14
MR
16
marked
17
Im
MCDONELL
42
showing
you
whats
been
record
as
Exhibit
18
19
MS
HOUSE
TUE
Can you
WITNESS
identify
that
for
the
Yes
20
21
22
in
this
morning
MR
So
with
When
25
is
is
various
Its
that
my document
brought
notes
document
you
prepared
Yes
24
what
This
McDONELL
23
0914
of
you had
Oracle
10
0914
director
America
Within
0914
job
your
senior
How
0913
work
you
Yesterday
Merrill
did
you
Legal
800
prepare
it
Solutions
8699132
eaOO5sa.O..4-4b35-afbf.caflafaa2sbc
RICHARD
HIGHLY
September
16 2008
INFORMATION
ATTORNEYS
EYES
CIJMMINS
CONFIDENTIAL
ONLY
Page
those
of
offerings
of
business side
support
When
0918
the
really developed
14
existing
came to
you
separate
did it have
Oracle
kind
renewals
team
Did
support
any
group merge
into
Yes
And what
it
or
it
replace
We
0919
10
At what
11
Well
you
started
14
At
Oracle
the
team
the
highest
level
about
this
you
renewal
JD Edwards
teani
said that
--
Then
right
Right
16
17
of
moved
you
Oracle
to
upon
the
acquisition
Peoplesoft
18
Right
19
And
20
Oracles
at
that
time your group merged
into
similar group
21
Yes
22
was
23
0919
of
talking
support
at
15
0919
it
Uhhuh
13
0919
into
level
Im
the
happened
the head
was
your
What
merged
Who
12
happened
there
head
of
that
support
renewals
team
24
MS HOUSE
25
MR McDONELL
Merrill
Legal
800
At
that
At
time
that
time
Solutions
8699132
oBaOBsea-o.e44b35Ibf.ca2oafssflasc
HIGHLY
RICHARD
CUMMINS
16 2008
September
CONFIDENTIAL
INFORMATION
ATTORNEYS
EYES
ONLY
Page
At
Chris
that
into
reported
reported
in
0919
to
And
worked
time
Chris Madsen
Juan
well
Juergen
Jones
and
who
Rottler
Juergen
has
for
15
that
structure
reporting
changed
then
since
No
You
still report
Chris
to
Madsen
Ido
0920
Has
tO
since
you
Since
13
support
the
renewals
time
14
At
JD
your
job
were
part
of
changed
At
JD
Edwards
forming
the
Peoplesoft
Edwards
16
in
that
19
function
until
MS HOUSE
18
Im sorry
WITNESS
21
MR
MoDONELL
23
24
25
remained
you
vague
You
can
answer
THE
22
Rave
today
Objection
20
O92t
you
at
group
i5
0921
of
No
12
nature
Oracle
joined
11
0920
basic
the
certifications
Im
certification
But
Merrill
or
rigt
or
if
Do
special
sure
there
that
is
essentially
you
have
any
for
training
there is
kind
your
one
you
of
job
special
thats specific
training
Legal
800
Yeah
dont
to
have
that
it
Solutions
8699132
eeaOeS$a4..4.4b35albf.ca2Qaffiaflbc
RICHARD
HIGHLY
September
16 2008
INFORMATION
ATTORNEYS
EYES
CUMMINS
CONFIDENTIAL
ONLY
Page
MR
hasnt
McDONELL
changed
terms ci
in
youve been
since
your
Oracle
at
base
My
responsibilities
mistdken
Am
0935
renewals
about
10
11
Ensuring
in my
for
space
And how
13
that
Theres
14
15
go
looking
do
director
renew
we
of
our customers
whole
but
process
of
the
process
are
do
want
you
or what
are
me
you
for
Give me the
general
outline
17
The
outline
is
general
18
contacted
19
time
frame
20
that
we
21
their contract
22
contracts
23
those
25
that
that
do
16
24
support
renewals
you
details
the
through
base
your
America
support
12
Changed
base
are your
senior
as
North
for
havent
lets talk about
What
responsibilities
ag36
job
responsibilities
responsibilities
Then
Okay
0936
said your
you
that
0935
0936
thought
27
regarding
We
their renewal
then
work
purchase
get
or
and
that
if
questions
with
customers
for
the
order before
please
the
upcoming
customer
the
are
ensure
to
start date
there are any questions
about
the
services
we
of
on
answer
questions
Do
deal
you
directly
with
customers
in
your
job
Merrill
Legal
800
Solutions
8699132
eGaOSSSa-O.e4-4b35.1
bfca2OafB2Obc
RICHARD
HIGHLY
September
16 2008
INFORMATION
ATTORNEYS
EYES
CIJIvIMINS
CONFIDENTIAL
ONLY
49
Page
and
managers
North
then
America
Hes
delivery
So
of
support
support
renewals
support
Mr
Rottler
for
their business offices
our
Redwood
and
here
headquarters
Jones
California
in
City
10
Yes
11
And
whats Mr
12
Hes
vice
13
support
Madsens
job
of
president
North
America
renewals
11
And
15
In
Mr Madsen
Ido
16
17
this
lB
19
have
Peoplesoft
you
the
other individuals
Exhibit
43
which
of
page
which
and
At
22
of
23
24
some
this
JD
this
individuals
25
these
of
responsibility for
21
to
report
terms of
0RCL00087625
20
1007
all
Mr
At
1006
for
job
located
physically
1006
support
are
Where
1005
as
of
renewals
support
EVP of
the
well
as
side
whats Mr Rottlers
And
1005
business
the
all
responsibility
For
Merrill
Legal
if
renewals
for
Lindsey
but
no
is
the
any
legacy
Peoplesoft
and
longer
part
other
other individuals
for
support
800
chart
the
number
products
Kathy
organizational
Bates
individuals
support
Edwards
point
is
listed on
here have
JO
Edwards
renewals
Solutions
8699132
eSatBGSa.0004.4b35..1
bt.ca2oafB82Bbc
C4INS
RICRARD
Septeer 16
2008
CONFIDENTIAL
MR
break
for
McDONELL
the
day
Im
Counsel
See
you
then
Thank
week
next
to
you
going
sir
VIDEOGRAPHER
1701
videotape
number
Cummins
Going
four
off
marks
This
in
the
the
the
end
of
deposiLion
record
the
of
time
Richard
is
502
-oOoWhereupon
502
the
adjourned
at
p.m
--eDo--
iO
declare
12
13
the
14
/VeJi-
15
was
deposition
foregoing
under
is
and
true
_____
.C1ifornia
penalty
perjury
Subscribed
correct
this
of
IS
day
that
at
of
2008
19
Signature
of
Witness
20
21
22
23
24
25
253
Merrill
Legal
800
Solutions
8699132
Errata Sheet
Deposition
Page
Rick
of
Line
41
1-22
Cummins September 16
2008
Change
Reason
Change Juans
manager
to
responsibility
Juan
is
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
174
Change
23
less
welcome
to
176
Change Hutton
207
Change
219
to
to
the
above
Correction
Murquia
Correction
renew
Correction
to
or doesnt
Change
14
Correction
Hunt
to
new
Correction
Oracle
to
Change
245
A72687826
McGee
Change were
22
232
Subject
more
Change
151
IP to IT
changes
1er
that
to
does
or
doesnt
Correction
Correction
the transcript
is
true
and correct
CERTIFICATE
WFNDY
certify that
hereby
foregoing
deposition
the
whole
by
and
therein
said
11
computer
me
witness
13
review
14
under
requested
15
deponent
16
period
of
the
stated
before
to
tell
but
the
are
reduced
in
the
to
further
either
19
deposition nor
in
20
this
that
21
parties
and
any
thereto
DATED
of
any
way
of
the
by
deposition
was
not
made
the
reporter
the
by
during
the
hereto
that
of
the
am
not
parties
interested
am not
related
Cgk
of
counsel
to
the
said
of
in
the
event
to
any
of
nc
2008
23
24
WENDY
time
typewriting
the
changes
certify
or
the
supervision
any
to
at
in
testimony
was
appended
attorney for
25
the
truth
down
person
the
completion
requested
allowed
taken
that
transcript
18
22
and
direction and
and provided
cause
sworn
nothtng
thereafter
my
If
17
the
duly
disinterested
was
That
12
and
in
said deposition was
shorthand
10
me
by
witness
the
cause
That
place
was
truth
within-entitled
Certified Shorthand
ARLEN
Reporter
truth
REPORTER
OF
ARLdN
CSR
No
4355
the
or
ORACLE
USA INC
SAP
CASE
SUPPLEMENTAL
AG
No
Ft AL
Ft AL
07-CV-01658
EXPERT REPORT
IM FINANCW
FEBRuARY
OP PAUL
FORENSICS
23
MEYER
LLC
2010
IALJ
MEYER
Rick
Cunimins
Senior Director
America
Page
SuijecI
Highly
Prolectiw
CozfidnitiilI
Order
Lnftrmition
AtWrneIJ5
Eyn Ony
of
Th1
Support Renewals
or North