Oracle Corporation et al v. SAP AG et al

Filing 381

Declaration of Tharan Gregory Lanier in Support of 380 Memorandum in Opposition Declaration of Tharan Gregory Lanier in Support of Defendants' Opposition to Plaintiffs' Motion to Amend Complaint filed bySAP AG, SAP America Inc, Tomorrownow Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Errata E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M)(Related document(s) 380 ) (Lanier, Tharan) (Filed on 7/29/2009)

Oracle Corporation et al v. SAP AG et al

Doc. 381 Att. 5

Case4:07-cv-01658-PJH Document381-6

Filed07/29/09 Page1 of 2

EXHIBIT F

Dockets.Justia.com

Case4:07-cv-01658-PJH Document381-6

Filed07/29/09 Page2 of 2

"Hann, Bree" <[e-mail]> 04/24/2009 04:34 PM

To "'Scott Cowan'" <[e-mail]> cc "Pickett, Donn" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "Howard, Geoff" <[e-mail]>, "House, Holly" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "'[e-mail]'" <[e-mail]>, "Alinder, Zachary J." <[e-mail]> bcc Subject RE: Oracle/SAP: draft stipulation

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Scott, Attached are clean and a redline copies of Oracle's changes to the stipulation. The redline was compared against Defendants' last proposal. We have accepted all of your recent changes, with the exception of the sentence about appearing for a status conference. The Court can of course request a status conference with the Parties of its own accord, and we do not want to suggest to Judge Hamilton that she should schedule one unless she feels that she needs it. As you requested, we have provided a list of possible copyright registrations. The registrations fall into two categories. The first category consists of pre-existing registrations. By including this list, Oracle does not commit to adding any or all of the registrations to an amended complaint. Oracle does not in fact believe that any of these registrations are relevant or necessary, and intends to make that argument in response to Defendants' motion to compel. However, if Judge Laporte disagrees with that argument, and while reserving its rights to assert the irrelevancy of these additional registrations at trial, Oracle may add them to its complaint since it may be producing them anyway. We suggest that if Defendants prevail on their motion to compel -- in other words, if Judge Laporte agrees that these registrations are relevant -then Oracle will reserve the right to add these registrations, and if Defendants do not prevail on the grounds that the registrations are not relevant or necessary, then Oracle will not add them. The second category is a new registration of collective knowledge management solutions and code changes/updates to track Defendants' various productions. Please let me know about questions, and have a good weekend. Thanks, Bree Bree Hann | Counsel Bingham McCutchen LLP Three Embarcadero Center | San Francisco, CA 94111 T [phone] | F [phone] [e-mail] -----Original Message----From: Scott Cowan [mailto:[e-mail]] Sent: Wednesday, April 22, 2009 10:11 AM