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. 24 EXHIBIT X Dockets.Justia.com CATHERINE HYDE May 12, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Page 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CASE NO. 07-CV-01658 PJH(EDL) ORACLE USA, INC., a Colorado corporation, et al., Plaintiffs, -vsSAP AG, a German corporation, et al., Defendants. / ************************** HIGHLY CONFIDENTIAL ATTORNEYS' EYES ONLY VIDEOTAPED DEPOSITION OF: DATE TAKEN: TIME: PLACE: REPORTED BY: CATHERINE HYDE TUESDAY, MAY 12, 2009 9:06 A.M. 9300 AIRPORT BOULEVARD ORLANDO, FLORIDA CARMEN THOMAS, REGISTERED PROFESSIONAL REPORTER AND NOTARY PUBLIC ************************** Merrill Legal Solutions (800) 869-9132 CATHERINE HYDE May 12, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Page 202 16:52:02 16:52:02 16:52:04 16:52:08 16:52:08 16:52:10 16:52:14 16:52:18 16:52:22 16:52:26 16:52:26 16:52:28 16:52:28 16:52:30 16:52:32 16:52:36 16:52:38 16:52:40 16:52:42 16:52:44 16:52:46 16:52:48 16:52:48 16:52:50 16:52:52 16:54:40 16:54:40 16:55:38 16:55:42 16:55:46 16:55:46 16:55:48 16:55:50 16:55:52 16:56:00 16:56:06 16:56:14 16:56:16 16:56:26 16:56:34 16:56:50 16:56:52 16:56:56 16:57:00 16:57:08 16:57:10 16:57:12 16:57:16 16:57:20 16:57:28 Page 204 Page 203 16:52:56 16:52:56 16:53:00 16:53:00 16:53:02 16:53:04 16:53:04 16:53:06 16:53:06 16:53:10 16:53:12 16:53:14 16:53:16 16:53:16 16:53:16 16:53:16 16:53:20 16:53:46 16:54:08 16:54:16 16:54:20 16:54:20 16:54:20 16:54:24 16:54:32 16:57:28 16:57:30 16:57:32 16:57:32 16:57:34 16:57:36 16:57:40 16:57:40 16:57:56 16:57:58 16:58:04 16:58:14 16:58:40 16:58:40 16:58:42 16:58:46 16:58:46 16:58:48 16:58:58 16:59:00 16:59:02 16:59:02 16:59:10 16:59:16 16:59:20 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 205 Q Let's look at them. MR. HOWARD: Exhibit 1300 is the February 2, 2005 development unit testing notes by C. Hyde. The -- which is the first document listed on the second to last page of Exhibit 1299. (Exhibit 1300 was marked for identification.) BY MR. HOWARD: Q A Q A Q A Q A Q Ms. Hyde, is Exhibit 1300 a document that you That's what it says. Do you have any reason to doubt it? No. Do you recall this document? No. And it relates to modification of a COBOL; is It's included in there, yes. On page three of the document there's a authored? that right, for a Pennsylvania state tax? 52 (Pages 202 to 205) Merrill Legal Solutions (800) 869-9132 CATHERINE HYDE May 12, 2009 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY Page 206 16:59:26 16:59:30 16:59:30 16:59:30 16:59:36 16:59:36 16:59:38 16:59:40 16:59:44 16:59:48 16:59:50 16:59:56 17:00:02 17:00:02 17:00:04 17:00:06 17:00:08 17:00:08 17:00:10 17:00:12 17:00:12 17:00:16 17:00:16 17:00:22 17:00:26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Page 208 17:02:52 17:02:52 17:02:58 17:03:02 17:03:06 17:03:20 17:03:22 17:03:24 17:03:30 17:03:34 17:03:34 17:03:42 17:04:02 17:04:06 17:04:08 17:04:10 17:04:14 17:04:16 17:04:18 17:04:20 17:04:22 17:04:22 17:04:26 17:04:26 17:04:28 before and after comparison of the COBOL changes Do you see that? A Yes Q Is that showing us an araxis merge comparison? A I believe so Q And what is the comparison that we see there on page three of the document? A It looks like it's highlighting the changes I've made Q This is the changes in the COBOL before you modified it compared to the changes after you modified it? MS LEE: Objection Vague and ambiguous THE WITNESS: According to this, that's what I'd get out of it, yes Page 207 17:00:26 17:00:30 17:00:34 17:00:36 17:00:40 17:00:44 17:00:48 17:00:48 17:00:50 17:00:54 17:00:54 17:00:56 17:01:00 17:01:04 17:01:06 17:01:32 17:01:42 17:01:46 17:01:58 17:01:58 17:02:26 17:02:36 17:02:38 17:02:42 17:02:50 Page 209 17:04:38 17:04:44 17:04:50 17:04:52 17:04:56 17:04:58 17:05:00 17:05:02 17:05:02 17:05:04 17:05:06 17:05:10 17:05:14 17:05:16 17:05:18 17:05:22 17:05:32 17:05:34 17:05:46 17:05:56 17:06:02 17:06:04 17:06:04 17:06:08 17:06:08 53 (Pages 206 to 209) Merrill Legal Solutions (800) 869-9132

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