Oracle Corporation et al v. SAP AG et al

Filing 821

EXHIBITS re 657 Declaration of Zachary J. Alinder in Support Main Document is Exhibit 17 [UNREDACTED] to Declaration in Support of 649 MOTION for Partial Summary Judgment (filed pursuant to Order on Motion to Seal, Dkt. No. 810) filed by Oracle International Corporation, Oracle USA Inc., Siebel Systems, Inc.. (Attachments: # 1 Exhibit 18 [UNREDACTED], # 2 Exhibit 115, # 3 Exhibit 116, # 4 Exhibit 117)(Related document(s) 657 ) (Russell, Chad) (Filed on 8/27/2010) Modified on 8/30/2010 (vlk, COURT STAFF).

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Oracle Corporation et al v. SAP AG et al Doc. 821 Att. 2 EXHIBIT 115 Dockets.Justia.com 97. Under the first approach, Oracle's lost profits damages are calculated based on its total lost support revenue on all relevant cancelled contracts related to the support customers that were lost to TomorrowNow. Oracle's total lost support revenue under this approach is shown on SCHEDULES 34.SU and 34.1.SU. REDACTED P S age 247 of 281 H bject to Protective Order u ighly 3 Confidential Information ­ Attorneys' Eyes Only REDACTED 18. Under the first scenario, calculated based on the lost profits incurred by the Oracle organization as a whole, Oracle has experienced lost profit damages of $349.0 million on lost support revenue through May 2015, and $99.6 million s n support revenue lost during the period for which TomorrowNow provided upport services to the Lost Customers.774 R EDACTED P S age 257 of 281 H bject to Protective Order u ighly 4 Confidential Information ­ Attorneys' Eyes Only EDACTED 55. i I have quantified the total personnel expense incurred by Oracle to nvestigate SAP's alleged misconduct based on Dr. Koehler's estimations of i the amount of time spent by the individuals on the investigations, and salary nformation for those individuals obtained from Oracle's Human Resources R REDACTED P S age 278 of 281 H bject to Protective Order u ighly 4 Confidential Information ­ Attorneys' Eyes Only epartment. Based on that information, it is my opinion that Oracle incurred approximately $300,000 of personnel expense related to the investigation of SAP's alleged activity.850 I have not quantified the cost to Oracle from the use of the 12 hard drives and 5 laptops identified by Dr. Koehler. REDACTED P S age 279 of 281 H bject to Protective Order u ighly Confidential Information ­ Attorneys' Eyes Only d

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