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 16

Foundation for
A-5995

Defendants
0RCL00034305
Vice President

and Kathleen

ORCLOO1

60564

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group

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support

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had previously

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203-6 2410-18

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North America

his job responsibilities

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sales renewal

from

function

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for North America

least

at

Jones

2005

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Tr 49124-4928

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that

indicating

2008

Jones runs support

at

Vice President Customer Services

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as Oracles

2009

Apr 24

Oracles

she

after

title

Senior

Acquisitions

president

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Jones

this

chart identifying

organizational

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Jones

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that

renewal/sales

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Juan Jones as Oracle

Director Support Sales

as Senior

Lindsey

below shows

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chart identifying

organizational

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managed

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Trial

to

had responsibility for

2009

testimony

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Lindseys

responsibilities

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that

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23

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Central Applications

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production document

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testimony indicating

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acquisitions

1184-5

Vice President

A-5997 Oracle

11

11
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Rule

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at

president

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Page

of

22

JONES
JUAN
HIGHLY CONFIDENTIAL

24

April

2009
EYES

ATTORNEYS

ONLY
Page

UNITED
NORTHERN

DISTRICT

OF

CALIFORNIA

DIVISION

FRANCISCO

SAN

COURT

DISTRICT

STATES

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

ORACLE

Delaware

INTERNATIONAL
CORPORATION
California corporation
PlaIntIffs

No

vs
SAP

AG

O-CV-l658

PJE

German

SAP AMERICA
corporation
Delaware
INC
TOMORROWNOW
corporation
INC
Texas corporation
and

DOES

IO

incusie

Defendants
____________________________/

Deposition

of

JONES

JUAN

Friday April 24

HIGHLY

REPORTED

HI

CONFIDENTIAL

ATTORNEYS

JOHN

WISSENBACH

CLR

CSR

Merrill

RMR

EYES

CRR

ONLY

CBC

01-418986

6862

Legal

800

2009

Solutions

8699132
a6971f9d4392-46428f24-97791aa3377d

24

2009

ATTORNEYS

JONES
JUAN
HIGHLY CONFIDENTIAL

EYES

April

ONLY
29

Page

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for

support

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Solutions

8699132
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April 24
ATTORNEYS

JONES
JUAN
IUGHLY CONFIDENTIAL

449

2009
EYES ONLY

prn

declare
foregoing

is

true

under
and

correct

California

My

of perjury that

penalty

the

Subscribed at
this

day

of

2009

Lnature

of

1witness

10

12

113

14

15
16

17

118

19
20

21
22

23

24

25

218

erril1 Legal Solutions
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DEPOSITION

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CERTIFICATE
JOHN
hereby

foregoing

deposition

truth

truth

in

Certified

that

certify
was

whole

the

truth

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me

by

and

place

therein

10

the

said

11

typewriting

12

the

sworn

to

tell

but

nothing

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cause

said deposition

shorthand

in

duly

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witness

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by me

within-entitled

the

REPORTER

WISSENBACH

Reporter

the

OF

was

taken

down

person

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in

supervision

review

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deponent

17

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are

19

or

23

said

21

event

22

any

attorney

for

deposition
of
of

this

to

was

the

deposition

was

IJ

not

made

any

changes

the

to

and

reporter

the

by

the

during

appendedheeto
that

certify

either
nor

or

in

cause and

the parties

of

of

testimony

reduced

completion

provided

the

time

the

under my direction

computer

further

18

thereafter

was

requested

allowed

that

and

transcript

If
hand

stated

before

the

15

23

by

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13

14

witness

disinterested

any

any

of

way

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parties

interested
am

counsel

of

not

to

in

related

the

the
to

thereto

DATED

24

25

JOHN

WISSENBACH

CSR

No

6862
219

RICHARD

UNITED
NORTHERN

BLOTNER
July
HIGHLY CONFIDENTIAL

STATES

DISTRICT

DISTRICT

SAN

OF

FRANCISCO

23

2008

COURT

CALIFORNIA

DIVISION

-000-ORACLE
Delaware

CORPORATION
corporation

INC

USA

ORACLE

Colorado

and ORACLE
INTERNATIONAL
CORPORATION
California
corporation

corporation

Plaintiffs

No 07CV1658PJH

vs
SAP

AG

German

SAP

ANERICA
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

01411414

Merrill Legal

800

Solutions

8699132

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July 23
CONFIDENTIAL

BLOTNER

RICHARD

HIGHLY

2008

98

Page

them

wont

ask

Technology

group

him then

doesnt

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matter

through 262

group went

through 266

going

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about

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267

Charles Phillips
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12

is

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69

34268

pages

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organizations

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17

sales

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who

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we

our president

Charles

have

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globally for Oracle

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19

34270

on

organizations

18

internal

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related

20

Jones

21

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22

earlier

23

Oracle

24

North

25

labeled Latin America

report
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is

the

Juergen Rottler

271

then

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our

title that

Oracle customer

support before
America and

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Merrill

other

Jones

talked

about

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saying

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individuals

EMEA

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Juan

organization

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800

support

and

dont

for

support
who

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know

if

Solutions

8699132

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BLOTNER
July 23
HIGHLY CONFIDENTIAL

RICHARD

2008

99

Page

theres
the

one

here

on

renewals

support

Asia

for

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organization

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Jones
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34276

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page

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CYNT

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PACINI

CSR

No

6117

THE

IN

UNITED

22

2009

ATTORNEYS

RICHARD CUMMINS
HIGHLY CONFIDENTIAL

EYES

April

STATES

DISTRICT

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NORTHERN
SAN

OF

FRANCISCO

ONLY

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DIVISION

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CORPORATION
Delaware
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INC

USA

ORACLE

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corporation

and
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INTERNATIONAL
CORPORATION
California
corporation

Plaintiffs

vs
SAP
SAP

AG

German

AMERICA
corporation

INC
DOES

07CV1658

PJH

corporation

INC

Delaware

TOMORROWNOW
Texas
corporation
150 inclusive

and

Defendants

VIDEOTAPED

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APRIL

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DATED

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SARAH

LUCIA

BRANN

CSR

No

3887

HIGHLY

RICHARD CUMMINS
Septeer 16 2008
CONFIDENTIAL INFORMATION
ATTORNEYS EYES

ONLY

Page
UNITED

STATES

DISTRICT

DISTRICT

NORTHERN
SAN

OF

FRANCISCO

COURT

CALIFORNIA

DIVISION

--O0o-ORACLE

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

Plaintiffs

Vs
SAP

No

07CV0l658PJH

EDL

AG

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

Defendants

____________________/

VIDEOTAPED

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CONFIDENTIAL

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September

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July 23
HIGHLY CONFIDENTIAL

RICHARD

UNITED

STATES

DISTRICT

DISTRICT

NORTHERN
SAN

OF

FRANCISCO

2008

COURT

CALIFORNIA

DIVISION

--oDe-ORACLE
Delaware

CORPORATION
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SAP

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INC
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07CV-l658PJH

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Delaware

TOMORROWNOW
Texas
corporation
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DEPOSITION
RICHARD

Wednesday
CONTAINS

REPORTED

BY

HIGHLY

CYNTHIA

OF

BLOTNER

July

23

2008

CONFIDENTIAL

PACINI

MATERIAL

CSR

6117

RMR

CRR

01411414

Merrill Legal

800

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8699132

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RICHARD

23

BLOTNER
July
HIGHLY CONFIDENTIAL

2008

118

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RICHARD

BLOTNER

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Keith

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359 PM

2006

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30

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232

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Message

Original

From Donna Walderzak
Sent Friday June 30

To

RE

Subject

2006

155

PM

Tate

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Phone

conversation

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Donna

Walderzak
Executive
Admin
One

Haworth

Holland
Direct

Fax

MI

49423

616.393.1959

616.393.1033

Donna

walderzak@haworth

Original

From

Craig

Sent

Donna

Subject

coin

Message
Tate

Friday

To

Assistant

Center

June

Walderzak
RE Phone

30

2006

132

conversation

PM
between

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and

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you

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Craig

From
Sent

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Message
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Donna
Walderzak

Subject

Highly

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June

Friday
Craig

30

2006

128

PM

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Franco

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you

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Donna
Donna

Walderzak

Executive
One

Admin

Haworth

Holland
Direct

Assistant

Center
49423

MI

616.393.1959

Fax

616.393.1033

Donna

.waiderzak@haworth

Original

From

corn

Message
Tate

[e-mail]
Friday June 30 2006 126 PM
To Donna Walderzak Ann Harten
RE Phone conversation
Subject
between
Franco
Craig

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and

Keith

Block

Haworth

is

Donna
Thanks

for

the

response

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only

concern

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Regards
Craig

From

Message
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Donna
Walderzak

Sent

To

Friday

Ann

correct

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10

July

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Franco
he

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after 200
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PM EST

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Donna

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Executive
One

Admin

Haworth

Holland
Direct

Fax

Information

PM

advise

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Confidential

1216

[e-mail]
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conversation
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Highly

2006

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30

June

MI

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49423

616.393.1959

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mke.schlrmcenJcracIeco

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Sent

Jun

30

115233

2006

ton- conversation between

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Franco

and

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Block

Ann
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has

between

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30pn

EST

and

500pm

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today

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Craici

Group

Vice

North

Central

USA

Oracle
Elm

312

Suite

President

pp1scattons
Inc

Street

1525

incinnati

OR

15202

Phone

Highly

Confidential

Information

5136292229

Clobile

5137034529

Fax

5l36514E3

Email

[e-mail]

Attorneys

Eyes Only

0RCL00747255