Oracle Corporation et al v. SAP AG et al

Filing 793

Declaration of Chad Russell in Support of 790 Memorandum in Opposition, to Defendants' Motions in Limine filed byOracle EMEA Limited, Oracle International Corporation, Oracle USA Inc., Siebel Systems, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit 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, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, # 27 Exhibit AA, # 28 Exhibit BB, # 29 Exhibit CC, # 30 Exhibit DD, # 31 Exhibit EE, # 32 Exhibit FF, # 33 Exhibit GG, # 34 Exhibit HH, # 35 Exhibit II, # 36 Exhibit JJ, # 37 Exhibit KK, # 38 Exhibit LL, # 39 Exhibit MM, # 40 Exhibit NN, # 41 Exhibit OO, # 42 Exhibit PP, # 43 Exhibit QQ, # 44 Exhibit RR, # 45 Exhibit SS, # 46 Exhibit TT)(Related document(s) 790 ) (Howard, Geoffrey) (Filed on 8/19/2010)

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Oracle Corporation et al v. SAP AG et al Doc. 793 Att. 23 EXHIBIT W Dockets.Justia.com CATHERINE LEE HYDE April 1, 2008 HIGHLY CONFIDENTIAL Page 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ORACLE CORPORATION, ET AL, * Plaintiffs, * * VS. * CASE NO. 07-CV-01658 (MJJ) * SAP AG, ET AL, * Defendants. * ******************************************************* HIGHLY CONFIDENTIAL ORAL AND VIDEOTAPED 30(b)(6) DEPOSITION OF CATHERINE LEE HYDE APRIL 1, 2008 ******************************************************* REPORTED BY: CAROL JENKINS, CSR, RPR, CRR CERTIFICATE NO. 2660 Merrill Legal Solutions (800) 869-9132 CATHERINE LEE HYDE April 1, 2008 HIGHLY CONFIDENTIAL Page 58 17:54:49 17:55:04 17:55:14 17:55:20 17:55:24 17:55:29 17:55:32 17:55:37 17:55:37 17:55:42 17:55:48 17:55:50 17:55:52 17:55:57 17:56:02 17:56:04 17:56:11 17:56:12 17:56:17 17:56:20 17:56:24 17:56:28 17:56:35 17:56:35 17:56:38 24 25 Page 60 17:58:37 17:58:42 17:58:44 17:58:47 17:58:53 17:58:59 17:59:03 17:59:09 17:59:15 17:59:16 17:59:19 17:59:26 17:59:32 17:59:45 17:59:51 17:59:55 18:00:01 18:00:03 18:00:06 18:00:08 18:00:11 18:00:13 18:00:20 1 2 3 4 5 6 7 8 9 10 11 12 done before you apply those same changes to the 75 -751 environment? A. We would look at the documentation that was delivered with the tax update. Q. And then you make the equivalent changes in the most recent 751 environment? A. Yes, which becomes the current 751. Q. And then you use Araxis Merge how in the 751 environment? A. What I just changed? I compare it to what was there before. And if that code can be used in the next release, the change, we'll attempt to make it work. Q. All right. So if I understand, you would do the comparison between the updated HR81 environment and 18:00:20 18:00:27 Page 59 17:56:44 17:56:55 17:56:59 17:57:04 17:57:15 17:57:18 17:57:21 17:57:26 17:57:29 17:57:31 17:57:36 17:57:40 17:57:43 17:57:46 17:57:52 17:57:59 17:58:07 17:58:08 17:58:13 17:58:18 17:58:22 17:58:24 17:58:24 17:58:31 17:58:33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 61 18:00:27 18:00:32 18:00:33 18:00:38 18:00:46 18:00:47 18:00:50 18:00:54 18:01:00 18:01:06 18:01:09 18:01:13 18:01:15 18:01:19 18:01:23 18:01:23 18:01:23 18:01:23 18:01:25 18:01:25 18:01:29 18:01:32 18:01:36 18:01:39 18:01:40 the most recent HR751 environment? A. I -- you would do the most recent 8SP1 to the prior 8SP1 and see the differences. And you'd apply those to HR751 and HG751. HR8 covers both ENG and commercial. Q. And then you would -- then you would compare the updated 751 environment to the prior 751 environment? A. Yes. Actually, we'd just compare the tax updates that we had done previously or whatever has changed. We can -- that's what we would use Araxis Merge for to see what we changed in one release. If you'd put them side by side, I know exactly what I just changed. Q. So you take a Bear Stearns login credential and download the newly posted update for 8.1, right? A. Yes. Q. And you then compare that 8.1 environment to the prior 8.1 environment? A. Just the objects that have changed. Q. And how do you determine which objects have changed? A. They're in the tax update. Q. Once you've done that comparison of the objects that have changed, is there any other comparison that's 16 (Pages 58 to 61) Merrill Legal Solutions (800) 869-9132

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