Oracle Corporation et al v. SAP AG et al

Filing 775

Declaration of Tharan Gregory Lanier in Support of 774 MOTION Defendants' Notice of Motion and Motion to Exclude Expert Testimony of Paul C. Pinto 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)(Related document(s) 774 ) (Froyd, Jane) (Filed on 8/19/2010)

Oracle Corporation et al v. SAP AG et al

Doc. 775 Att. 17

EXHIBIT 17

Dockets.Justia.com

Subject:
From: To: Cc:

RE: Complete Source Code for the "Oracle products" recited in Paul Pinto's report
Donnelly, Amy 02/09/2010 02:13 PM 'Jeffrey M Butler', Howard, Geoff "Hann, Bree", "Russell, Chad", "Pickett, Donn", "House, Holly", "Polito, John A.", "Jindal, Nitin", "Alinder, Zachary J.", "Elaine Wallace", "[e-mail]", "Joshua L Fuchs", "Jason McDonell", "Greg Lanier", "Laurens Wilkes", "Scott Cowan"

Jeff, Thank you for your email. The bates numbers you identify below correspond to the ISO files from which Mr. Pinto accessed and analyzed the source code using a standard Personal Computer and text editor. For your reference, the following table identifies the code base pulled from each ISO file. Please note that with regard to PeopleSoft, a significant component of the source code was written in PeopleCode, which resided as objects within the database. For the purpose of Mr. Pinto's analysis, Mr. Pinto was provided with the set of PeopleCode as text files. These text files were produced to Defendants at ORCLX-PIN-000024 to ORCLX-PIN-000062. ISO File ORCL00485750 ORCL00485778 ORCL00264053 ORCL00264039 ORCL00264023 ORCL00264027 ORCL00264021 ORCL00264037 ORCL00264024 and 25 Code Base JDE EnterpriseOne 8.12 Standalone Base Components - Windows JDE EnterpriseOne 8.12 JDE EnterpriseOne 8.12 Update 1 Windows PeopleSoft Student Admin 8.0 PeopleSoft EPM 8.8 PeopleSoft CRM 8.8 PeopleSoft HRMS 8.8 PeopleSoft FSCM 8.4 PeopleSoft Peopletools 8.4

Thus, to confirm, Defendants have all of the materials Mr. Pinto relied upon to conduct his analysis. In order to replicate Mr. Pinto's analysis, Defendants can utilize the cited ISO files containing the germane JDE and PeopleSoft source code files (as per the table above), the text files containing the PeopleCode source code (produced as ORCLX-PIN-000024 to ORCL-PIN000062), and the SLOC counting utilities which were specifically developed to count the number of Logical Source Lines of Code for each different code base within each module (produced as ORCLX-PIN-000066 to ORCLX-PIN-000085). I hope this resolves your question. Kind Regards, Amy
Amy K. Donnelly | Associate Bingham McCutchen LLP Three Embarcadero Center San Francisco CA 94111 T 415.393.2262 direct | F 415.393.2286 [e-mail]