Oracle Corporation et al v. SAP AG et al

Filing 819

Declaration of Tharan Gregory Lanier in Support of 818 Reply in Support of Defendants' Motion for Partial Summary Judgment (FILED PURSUANT TO D.I. 810) filed by SAP 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, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34)(Related document(s) 810 ) (Froyd, Jane) (Filed on 8/27/2010) Modified on 8/30/2010 (vlk, COURT STAFF).

Oracle Corporation et al v. SAP AG et al

Doc. 819 Att. 6

EXHIBIT 6

Dockets.Justia.com

BOB GEIB HIGHLY

January 9, 2009 CONFIDENTIAL
Page 1

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

ORACLE CORPORATION, a Delaware corporation, ORACLE USA, INC., a Colorado corporation, and ORACLE INTERNATIONAL CORPORATION, a California corporation, Plaintiffs, vs. SAP AG, a German corporation, SAP AMERICA, INC., a Delaware corporation, TOMORROWNOW, INC., a Texas corporation, and DOES 1-50, inclusive, Defendants. ______________________________

) ) ) ) ) ) ) ) ) ) No. 07-CV-1658 (PJH) ) ) ) ) ) ) ) ) )

VIDEOTAPED DEPOSITION OF BOB GEIB _________________________________ FRIDAY, JANUARY 9, 2009 HIGHLY CONFIDENTIAL

REPORTED BY:

HOLLY THUMAN, CSR No. 6834, RMR, CRR (1-415440)

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BOB GEIB HIGHLY

January 9, 2009 CONFIDENTIAL
Page 40

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Q.

When you were promoted to SVP in 2007, how

did your responsibilities change? A. At that point in time, I took on more of So picked up Australia Asia, PAC and Europe.

the global sales functions. and New Zealand and Europe.

We had an office in Singapore, Australia, and in Europe we had offices. Q. Okay. So your position, then, was more of Is that right?

a global sales position. A. Q. time? A. Correct.

Do you recall who reported to you at that

At the time that I was promoted to SVP?

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January 9, 2009 CONFIDENTIAL
Page 41

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Q. A.

Correct. Bob Ludlam, promoted him to VP of sales for Then had direct reports for, out of

North America.

the regions -- the account executives out of the regions in the global territories. Q. I'm going to hand you what's been

previously marked Plaintiff's Deposition Exhibit No. 4. Can you turn to the second-to-the-last page? I believe it's -- does that appear to

represent the structure of the global sales team after you were promoted to SVP? A. Yeah, at the time I was promoted to SVP,

that looks like the structure. Q. well? A. Yes. Originally, when -- at the time of Later, Nigel So did Mr. Pullan have a sales function as

promotion, I had the North American.

took a different role, and I took over the global function. Q. A. role. Q. So at that point, did you take on his sales What role did Mr. Pullan move to? He moved into an overall customer services

responsibilities in a managerial sense for EMEA and

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BOB GEIB HIGHLY

January 9, 2009 CONFIDENTIAL
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APAC? A. Yes. That happened right toward the end of

my tenure. Q. was? A. Q. Summer, fall of '07, I believe. And when did you end your tenure at Do you know approximately what date that

TomorrowNow? A. I believe October, November of '07.

TEXT REMOVED - NOT RELEVANT TO MOTION

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TEXT REMOVED - NOT RELEVANT TO MOTION