Oracle Corporation et al v. SAP AG et al

Filing 362

Declaration of Robert Schwentker in Support of 358 Reply Memorandum, re Motion to Compel Production of Documents Related to Damages Model and Interrogatory Responses Related to Use of Plaintiffs' Intellectual Property filed byOracle EMEA Limited, Oracle International Corporation, Oracle USA Inc.. (Attachments: # 1 Exhibit A)(Related document(s) 358 ) (Hann, Bree) (Filed on 7/21/2009)

Oracle Corporation et al v. SAP AG et al

Doc. 362

Case4:07-cv-01658-PJH Document362

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BINGHAM MCCUTCHEN LLP DONN P. PICKETT (SBN 72257) GEOFFREY M. HOWARD (SBN 157468) HOLLY A. HOUSE (SBN 136045) ZACHARY J. ALINDER (SBN 209009) BREE HANN (SBN 215695) Three Embarcadero Center San Francisco, CA 94111-4067 Telephone: [phone] Facsimile: 415.393.2286 [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] DORIAN DALEY (SBN 129049) JENNIFER GLOSS (SBN 154227) 500 Oracle Parkway, M/S 5op7 Redwood City, CA 94070 Telephone: [phone] Facsimile: 650.506.7114 [e-mail] [e-mail] Attorneys for Plaintiffs Oracle USA, Inc., Oracle International Corporation, and Oracle EMEA Limited UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ORACLE USA, INC. et al, v. Plaintiffs, No. 07-CV-01658 PJH (EDL) DECLARATION OF ROBERT SCHWENTKER IN SUPPORT OF PLAINTIFFS' REPLY IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS RELATED TO DAMAGES MODEL AND INTERROGATORY RESPONSES RELATED TO USE OF PLAINTIFFS' INTELLECTUAL PROPERTY Date: Time: Place: Judge: August 4, 2009 2:00 p.m. Courtroom E, 15th Floor Hon. Elizabeth D. Laporte
Case No. 07-CV-01658 PJH (EDL)

SAP AG, et al., Defendants.

DECLARATION OF ROBERT SCHWENTKER IN SUPPORT OF PLAINTIFFS' REPLY TO DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL

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I, Robert Schwentker, declare as follows: 1. I work for CITENT, Inc. of Costa Mesa, California. I specialize in the

design, architecture, development and administration of enterprise-wide IBM collaboration applications, including Lotus Notes. I have personal knowledge of the matters stated in this Declaration by virtue of my retention by Oracle in this action. If called and sworn as a witness, I could and would competently testify as to such matters. 2. Oracle has retained me as an expert in this action to, among other roles,

provide insight and technical guidance on issues relating to Lotus Notes and SAS. 3. I am a Senior IBM/Lotus Domino Systems Administrator, Application

Developer and Instructor. I have worked on large scale Lotus Notes projects for clients including IBM, Citigroup, Inc., Bank of America, and Kaiser Permanente. My current CV is attached as Exhibit A to this declaration. 4. Defendants' SAS database ("SAS"), built using a Lotus Notes platform,

has a highly customizable and technically complex database structure. There are many workflows to enter and update the data in the database, including a wide variety of forms that are filled in and edited as well as dozens of views by which to access the data. In comparison with my other large scale Lotus Notes projects, SAS is particularly complicated in that it contains an especially complex user interface. In addition, the data is recorded in a layered fashion that cannot easily be extracted. 5. Defendants' SAS databases are also very large in size. At the time of

Defendants' initial production of SAS, they contained approximately 165,925 documents. After Defendants' latest SAS production in March 2009, the databases contain approximately 369,030 documents. 6. SAS is a "non-relational" database, which means that it contains "flat file"

documents, rather than data points that are easy to extract and analyze. "Flat files" are data files that contain records with no structured relationships, thereby requiring additional knowledge to interpret these files. The non-relational nature of SAS means that a person possessing expertise in the data is better able to analyze that data. 1
Case No. 07-CV-01658 PJH (EDL)

DECLARATION OF ROBERT SCHWENTKER IN SUPPORT OF PLAINTIFFS' REPLY TO DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL

Case4:07-cv-01658-PJH Document362

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