Oracle Corporation et al v. SAP AG et al

Filing 1206

Declaration of Nargues Motamed in Support of 1202 Statement Joint Statement in Support of Evidentiary Issues filed byOracle International Corporation. (Attachments: # 1 Exhibit A-0059, # 2 Exhibit A-6329-1, # 3 Exhibit A-0367, # 4 Exhibit A-5042, # 5 Exhibit A-5997, # 6 Exhibit A-6042-1, # 7 Exhibit A-6205-1, # 8 Exhibit A-5193, # 9 Exhibit A-5995, # 10 Exhibit A-5058, # 11 Exhibit A-5002-1, # 12 Exhibit A, # 13 Exhibit B, # 14 Exhibit C, # 15 Exhibit D, # 16 Exhibit E, # 17 Exhibit F, # 18 Exhibit G, # 19 Exhibit H, # 20 Exhibit I, # 21 Exhibit J, # 22 Exhibit K, # 23 Exhibit L, # 24 Exhibit M, # 25 Exhibit N, # 26 Exhibit PTX 0008, # 27 Exhibit PTX 0014, # 28 Exhibit PTX 0161, # 29 Exhibit O, # 30 Exhibit P, # 31 Exhibit Q, # 32 Exhibit R, # 33 Exhibit PTX 4809, # 34 Exhibit PTX 4819, # 35 Exhibit PTX 0012, # 36 Exhibit PTX 0024, # 37 Exhibit PTX 0960, # 38 Exhibit PTX 7028, # 39 Exhibit S, # 40 Exhibit T, # 41 Exhibit U, # 42 Exhibit V, # 43 Exhibit W, # 44 Exhibit PTX 8040, # 45 Exhibit PTX 2582, # 46 Exhibit X, # 47 Exhibit Y, # 48 Exhibit PTX 8112, # 49 Exhibit PTX 8111, # 50 Exhibit PTX 8108)(Related document(s) 1202 ) (Howard, Geoffrey) (Filed on 8/2/2012)

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Redacted Merck & Company Incorporated 2007 E1 & World 1,394,529.00 1,394,529.00 1/8 Merck JDE Renewal is losft in excess of $1 million. all interested parties are aware of the situation. 12/12 Conference call will take place next week with customer (Martha Love and Cindy House), Chris Madsen, Jason Taylor, Barbara Sharp-Moore, and myself. It's a last ditch effort. A little over a year ago, Merck signed a deal with SAP for 27M. This is a multi-year migration over the next several years to one instance (Merck refers to it as Project Comet). At this point the PSoft HR applications are not part of this migration. But the JDE products are. We are looking at a $1.4M loss in January. It is also important to point out that Merck is currently facing 5.5B in back taxes owed and about 650M in litigation around VIOX. They are not in good financial shape and things could change. The SAP deal was about relationships and Oracle did not even bid on the deal. Merck did not provide information in the discovery stage to allow our involvement. Keith Block went out and met with Merck but they were intent on SAP. Keith Block has subsequently tried to get a meeting with Merck to salvage any apps business but they won’t even take a call from him. We are going to try and get a meeting to do what we can on salvaging the JDE business, but I am not hopeful P-JDPS3118-US M04713001--5 17-Nov-06 1/8/2007 Lost AMER 1/1/2007 Redacted PSFT-JDE 3rd party risk analysis 1-25-08REDACTED.xls ORCL00079745 DATA 1 Redacted PSFT-JDE 3rd party risk analysis 1-25-08REDACTED.xls ORCL00079745 DATA 6 Redacted PSFT-JDE 3rd party risk analysis 1-25-08REDACTED.xls ORCL00079745 DATA 19 Redacted PSFT-JDE 3rd party risk analysis 1-25-08REDACTED.xls ORCL00079745 DATA 38 Redacted PSFT-JDE 3rd party risk analysis 1-25-08REDACTED.xls ORCL00079745 DATA 2 Redacted PSFT-JDE 3rd party risk analysis 1-25-08REDACTED.xls ORCL00079745 AMER-Lost 17

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