Oracle America, Inc. v. Google Inc.

Filing 525

Proposed Pretrial Order CORRECTED Joint Proposed Pretrial Order by Oracle America, Inc.. (Attachments: #1 Appendix A (Joint Trial Exhibit List), #2 Appendix B (Oracle Witness List), #3 Appendix C (Google Witness List))(Muino, Daniel) (Filed on 10/13/2011)

Appendix A

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MORRISON & FOERSTER LLP
MICHAEL A. JACOBS (Bar No. 111664)
[e-mail]
MARC DAVID PETERS (Bar No. 211725)
[e-mail]
DANIEL P. MUINO (Bar No. 209624)
[e-mail]
755 Page Mill Road
Palo Alto, CA 94304-1018
Telephone: [phone] / Facsimile: [phone]

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BOIES, SCHILLER & FLEXNER LLP
DAVID BOIES (Admitted Pro Hac Vice)
[e-mail]
333 Main Street
Armonk, NY 10504
Telephone: [phone] / Facsimile: [phone]
STEVEN C. HOLTZMAN (Bar No. 144177)
[e-mail]
1999 Harrison St., Suite 900
Oakland, CA 94612
Telephone: [phone] / Facsimile: [phone]

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ORACLE CORPORATION
DORIAN DALEY (Bar No. 129049)
[e-mail]
DEBORAH K. MILLER (Bar No. 95527)
[e-mail]
MATTHEW M. SARBORARIA (Bar No. 211600)
[e-mail]
500 Oracle Parkway
Redwood City, CA 94065
Telephone: [phone] / Facsimile: [phone]
Attorneys for Plaintiff
ORACLE AMERICA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ORACLE AMERICA, INC.

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Plaintiff,

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v.

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GOOGLE INC.
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Defendant.
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PLAINTIFF ORACLE’S FED. R. CIV. P. 26(A)(3) WITNESS LIST
CASE NO. CV 10-03561 WHA
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Case No. CV 10-03561 WHA
PLAINTIFF ORACLE’S FED. R.
CIV. P. 26(a)(3) WITNESS LIST

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Plaintiff Oracle America, Inc. (“Oracle”) hereby submits its witness list for both the

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liability and damages phases of the trial, pursuant to Fed. R. Civ. P. 26(a)(3) and the Court’s

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Guidelines for Trial and Final Pretrial Conference in Civil Jury Cases.

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Oracle identifies the name, contact information, and substance of the testimony of each

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witness it expects to present or may present at trial, other than solely for impeachment. Pursuant

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to the Court’s Guidelines, non-cumulative testimony is identified below in italics.

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I.

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LIVE WITNESSES
Oracle expects to present live testimony from the following witnesses:

Witness
Bloch, Joshua

Contact Information
Google. Contact
through Google’s
counsel.

Substance of Trial Testimony
Mr. Bloch is a Google engineer who was involved
in the development of Android. He was formerly
an engineer at Sun Microsystems. He is expected
to testify regarding Google’s development of
Android and inclusion of Java technology therein;
Google’s copying of Java APIs into Android; the
value and importance of the Java APIs; Google’s
copying of certain Java code into Android;
Google’s awareness of Sun’s Java intellectual
property rights and the need for Google to obtain a
Java license for Android; Google’s Java-related
discussions with Sun and Oracle; and facts
relating to Google’s willful patent and copyright
infringement.

Bornstein, Daniel

Google. Contact
through Google’s
counsel.

Mr. Bornstein is a Google engineer who was
involved in the development of Android. He is
expected to testify regarding Google’s
development of Android and inclusion of Java
technology therein; the functionality of the
infringing components of Android, including the
Dalvik virtual machine, the dexopt component, the
dx tool, the zygote process, and the java.security
framework; Google’s copying of Java APIs into
Android; Google’s awareness of Sun’s Java
intellectual property rights and the need for
Google to obtain a Java license for Android;
Google’s Java-related discussions with Sun and
Oracle; and facts relating to Google’s willful
patent and copyright infringement.

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Witness
Brady, Patrick

Contact Information
Google. Contact
through Google’s
counsel.

Substance of Trial Testimony
Mr. Brady is Google’s Director of Android
Partner Engineering. He is expected to testify
regarding Google’s use of Android devices for
testing and other purposes; Google’s development
of Android applications; Google’s involvement in
and knowledge of development of Android devices
by third parties; Google’s compatibility
requirements for Android implementations; and
facts relating to Google’s willful patent and
copyright infringement

Cockburn, Iain

Expert retained by
Oracle. Contact
through Oracle’s
counsel.

Dr. Cockburn is an expert retained by Oracle to
testify regarding damages. He will testify
regarding the matters disclosed in his expert
reports, including his damages analysis for patent
and copyright infringement and all supporting
information.

Ellison, Larry

Oracle. Contact
through Oracle’s
counsel.

Mr. Ellison is Oracle’s founder and CEO. He will
testify regarding Oracle’s reasons for acquiring
Sun Microsystems; the importance of Java to
Oracle’s business; Oracle’s use and licensing of
Java prior to its acquisition of Sun; the effort and
resources that Oracle has invested in developing
Java; Oracle’s Java licensing business; the prelawsuit Java-related discussions between Oracle
and Google; and the harm caused by Android.

Gosling, James

Former Sun and
Google. Currently
with Liquid Robotics,
Inc. Contact through
Michael Lisi, Esq.,
Krieg Keller Sloan
Reilly & Roman, 555
Montgomery Street,
17th Floor, San
Francisco, CA 94111.

Dr. Gosling was formerly a software engineer and
Chief Technology Officer at Sun Microsystems.
He is also the named inventor on Oracle’s ’104
patent. He will testify regarding the inventions of
the ’104 patent and their benefits; the
development history, design, and innovations of
the Java platform, including the Java virtual
machine and class libraries; the creation and
importance of the Java APIs; and the importance
of Java implementation compatibility and Sun’s
efforts to ensure compatibility and prevent
fragmentation.

Gupta, Vineet

Former Oracle and
Sun. 2963 Richland
Avenue, San Jose, CA
95125.

Mr. Gupta was formerly the Senior Director,
Chief Technology Strategy Officer at Sun
Microsystems, and subsequently an employee of
Oracle. He is expected to testify about Sun’s and
Oracle’s Java business and Java licensing; Sun’s
and Oracle’s efforts to prevent fragmentation of
the Java platform and eco-system, including Java
compatibility requirements; Java-related
discussions with Danger, Android, and Google;
and the harm caused by Android.

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Witness
Kaul, Jeet

Contact Information
Former Sun and
Oracle. Currently
with Juniper
Networks. Contact
through Oracle’s
counsel.

Substance of Trial Testimony
Mr. Kaul was formerly the Vice President of the
Java Clients Software Group at Sun
Microsystems. He will testify regarding Sun’s
Java business and Java licensing; Sun’s efforts to
develop a smart phone software stack; the impact
of Android on Sun’s Acadia project; Sun’s efforts
to prevent fragmentation of the Java platform and
eco-system, including Sun’s Java compatibility
requirements; Sun’s efforts to protect Java
intellectual property; and Java-related discussions
between Sun and Google.

Knopoff, Kathleen

Former Sun. Contact
through Oracle’s
counsel.

Ms. Knopoff was formerly the Senior Director of
Business Operations at Sun Microsystems. She
will testify regarding Sun’s Java business and Java
licensing; the 2005-2006 Java-related discussions
between Sun and Google (Project Armstrong);
Sun’s business model and projected revenues for
Project Armstrong; and the harm caused by
Android.

Lee, Bob

Former Google. 883
46th Avenue, San
Francisco, CA 94121.

Mr. Lee was formerly a Google engineer involved
in the development of Android. He is expected to
testify regarding Google’s development of
Android and inclusion of Java technology therein;
Google’s copying of Java APIs into Android; the
value and importance of the Java APIs;Google’s
awareness of Sun’s Java intellectual property
rights and the need for Google to obtain a Java
license for Android; and Google’s Java-related
discussions with Sun.

Lindholm, Tim

Google. Contact
through Google’s
counsel.

Mr. Lindholm is a Google engineer who was
formerly employed by Sun. He is expected to
testify regarding the development history, design,
and innovations of the Java platform, including
the Java virtual machine and class libraries; the
importance of Java implementation compatibility
to Sun and its efforts to prevent fragmentation;
Google’s development of Android and inclusion
of Java technology therein; Google’s
consideration of alternatives to Java for Android;
Google’s awareness of Sun’s Java intellectual
property rights and the need for Google to obtain a
Java license for Android; Google’s Java-related
discussions with Android; Google’s Java-related
discussions with Sun and Oracle; and facts
relating to Google’s willful patent and copyright
infringement.

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Witness
McFadden, Andy

Contact Information
Google. Contact
through Google’s
counsel.

Substance of Trial Testimony
Mr. McFadden is a Google engineer who was
involved in the development of Android. He is
expected to testify regarding Google’s
development of Android and inclusion of Java
technology therein; the functionality of the
infringing components of Android, including the
Dalvik virtual machine, the dexopt component, the
dx tool, the zygote process, and the java.security
framework; Google’s copying of Java APIs into
Android; Google’s awareness of Sun’s Java
intellectual property rights and the need for
Google to obtain a Java license for Android;
Google’s Java-related discussions with Sun and
Oracle; and facts relating to Google’s willful
patent and copyright infringement.

Mitchell, John

Expert retained by
Oracle. Contact
through Oracle’s
counsel.

Dr. Mitchell is an expert retained by Oracle to
testify regarding patent and copyright
infringement. He will testify regarding the
matters disclosed in his copyright reports of
July 29, August 12, and August 19, 2011, and his
patent reports of August 8 and September 1, 2011.

Morrill, Dan

Google. Contact
through Google’s
counsel.

Mr. Morrill is Google’s Technical Program
Manager for Android Compatibility. He is
expected to testify regarding Google’s
compatibility requirements for Android
implementations; Google’s use of Android devices
for testing and other purposes; Google’s
development of Android applications; Google’s
involvement in and knowledge of development of
Android devices by third parties; and facts relating
to Google’s willful patent and copyright
infringement.

Page, Larry

Google. Contact
through Google’s
counsel.

Mr. Page is Google’s co-founder and CEO. He is
expected to testify regarding Google’s Javarelated discussions with Sun and Oracle; Google’s
awareness of Sun’s Java intellectual property
rights and the need for Google to obtain a Java
license for Android; the benefits associated with
Java and Google’s lack of alternatives; Google’s
business plan and marketing strategy for Android,
including the acquisition of Motorola; benefits to
Google from Android; Google’s revenue and
profit projections for Android, including
advertising revenues; Google’s efforts to prevent
Android fragmentation; and facts relating to
Google’s willful patent and copyright
infringement.

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Witness
Reinhold, Mark

Contact Information
Oracle. Contact
through Oracle’s
counsel.

Substance of Trial Testimony
Dr. Reinhold is Chief Architect of the Java
Platform Group at Oracle. He will testify
regarding the development history, design, and
innovations of the Java platform, including the
Java virtual machine and class libraries; the key
developers involved in creating the Java platform;
the creation and importance of the Java APIs;
Sun’s copyright registrations for Java; patented
features of the Java platform; the effort and
resources that Sun and Oracle have invested in
developing Java; the nature of the Java SE, ME,
and EE platforms; Sun’s Java business and Java
licensing; and Oracle’s products that practice the
asserted claims of the patents-in-suit.

Rizvi, Hasan

Oracle. Contact
through Oracle’s
counsel.

Mr. Rizvi is Oracle’s Senior Vice President of
Fusion Middleware and Java. He will testify
regarding Oracle’s licensing practices for Java;
and the harm caused by Android.

Rubin, Andy

Google. Contact
through Google’s
counsel.

Mr. Rubin is a founder of Android Inc. and the
head of Google’s Android division. He is
expected to testify regarding development of
Android and inclusion of Java technology therein;
the Java license obtained by Danger Inc.;
discussions between Android Inc. and Sun
regarding a Java license; Google’s awareness of
Sun’s Java intellectual property rights and the
need for Google to obtain a Java license for
Android; Google’s Java-related discussions with
Sun and Oracle; the benefits associated with Java
and Google’s lack of alternatives; Google’s
business plan and marketing strategy for Android,
including the acquisition of Motorola; benefits to
Google from Android; Google’s revenue and
profit projections for Android, including
advertising revenues; Google’s efforts to prevent
Android fragmentation; and facts relating to
Google’s willful patent and copyright
infringement.

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Witness
Schmidt, Eric

Contact Information
Google. Contact
through Google’s
counsel.

Substance of Trial Testimony
Mr. Schmidt is Google’s Chairman and former
CEO. He was previously Chief Technology
Officer at Sun Microsystems. He is expected to
testify regarding Google’s Java-related
discussions with Sun and Oracle; Google’s
awareness of Sun’s Java intellectual property
rights and the need for Google to obtain a Java
license for Android; his knowledge of Java
technology and Sun’s Java licensing practices
from his tenure at Sun; the benefits associated
with Java and Google’s lack of alternatives;
Google’s business plan and marketing strategy for
Android, including the acquisition of Motorola;
benefits to Google from Android; Google’s
revenue and profit projections for Android,
including advertising revenues; Google’s efforts
to prevent Android fragmentation; and facts
relating to Google’s willful patent and copyright
infringement.

Screven, Edward

Oracle. Contact
through Oracle’s
counsel.

Mr. Screven is Oracle’s Chief Corporate
Architect. He will testify regarding Oracle’s
reasons for acquiring Sun Microsystems; the
importance of Java to Oracle’s business; the harm
caused by Android; and Oracle’s own
maintenance of a Java license prior to the Sun
acquisition.

Shugan, Steven

Expert retained by
Oracle. Contact
through Oracle’s
counsel.

Dr. Shugan is an expert retained by Oracle to
conduct a consumer study to evaluate the effect of
particular technology features on the demand for
Android devices. He will testify regarding the
matters disclosed in his September 12, 2011
expert report.

Singh, Param

Oracle. Contact
through Oracle’s
counsel.

Mr. Singh is the Senior Director of Java Product
Management at Oracle. He was previously
employed by Sun Microsystems. He will testify
regarding Sun’s Java licensing business and
practices; Sun’s efforts to prevent fragmentation
of the Java platform and eco-system, including
Sun’s Java compatibility requirements; Sun’s
efforts to protect and enforce Java intellectual
property; Sun’s efforts to develop a smart phone
software stack; the impact of Android on the
Acadia project; and Java-related discussions
between Sun and Google.

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Witness
Steele, Guy

Contact Information
Oracle. Contact
through Oracle’s
counsel.

Substance of Trial Testimony
Dr. Steele is a Software Architect at Oracle, and
formerly at Sun Microsystems. He will testify
regarding the development history, design, and
innovations of the Java platform; the key
developers involved in creating the Java platform;
the creation and importance of the Java APIs;
Sun’s copyright registrations for Java; patented
features of the Java platform; the effort and
resources that Sun and Oracle have invested in
developing Java; the nature of the Java SE, ME,
and EE platforms; Sun’s Java business and Java
licensing; and Oracle’s products that practice the
asserted claims of the patents-in-suit

Swetland, Brian

Google. Contact
through Google’s
counsel.

Mr. Swetland is a Google engineer who was
involved in the development of Android. He is
expected to testify regarding Google’s
development of Android and inclusion of Java
technology therein; Google’s copying of Java
APIs into Android; Google’s awareness of Sun’s
Java intellectual property rights and the need for
Google to obtain a Java license for Android; the
benefits associated with Java and Google’s lack of
alternatives; Google’s Java-related discussions
with Sun and Oracle; and facts relating to
Google’s willful patent and copyright
infringement.

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Oracle may present live testimony from the following witnesses:
Witness
Angioletti, T.J.

Contact Information
Oracle. Contact
through Oracle’s
counsel.

Trial Testimony
Mr. Angioletti is an in-house attorney for Oracle.
He may testify regarding the pre-lawsuit Javarelated discussions between Google and Oracle,
including the July 20, 2010 meeting between
counsel for Google and Oracle.

Catz, Safra

Oracle. Contact
through Oracle’s
counsel.

Ms. Catz is the President of Oracle. She may
testify regarding Oracle’s reasons for acquiring
Sun Microsystems; the importance of Java to
Oracle’s business; Oracle’s use and licensing of
Java prior to its acquisition of Sun; the effort and
resources that Oracle has invested in developing
Java; Oracle’s Java licensing business; the prelawsuit Java-related discussions between Oracle
and Google; and the harm caused by Android.

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Witness
Cizek, Leo

Contact Information
Oracle. Contact
through Oracle’s
counsel.

Trial Testimony
Mr. Cizek is an Account Manager, Java Licensing
at Oracle. He may testify about Sun’s and
Oracle’s Java business and Java licensing; efforts
to prevent fragmentation of the Java platform and
eco-system, including through Java compatibility
requirements; Java-related discussions with
Danger, Android, and Google; and the harm
caused by Android.

Goldberg, Ben

Expert retained by
Oracle. Contact
through Oracle’s
counsel.

Dr. Goldberg is an expert retained by Oracle to
testify regarding the validity of the patents-in-suit.
He may testify regarding the matters disclosed in
his August 25, 2011 expert report.

Kearl, James

FRE 706 courtappointed expert.
Contact through John
Cooper, Esq., Farella
Braun & Martel LLP.

Dr. Kearl is an expert appointed by the Court
under FRE 706 to testify regarding damages. He
may testify regarding the matters disclosed in his
expert report to be submitted on November 14,
2011.

Kessler, Peter

Oracle. Contact
through Oracle’s
counsel.

Mr. Kessler is an Oracle engineer. He may testify
regarding Oracle’s products that practice the
asserted claims of the patents-in-suit.

Kurian, Thomas

Oracle. Contact
through Oracle’s
counsel.

Mr. Kurian is Oracle’s Executive Vice President
of Product Development. He may testify
regarding Oracle’s reasons for acquiring Sun
Microsystems; the importance of Java to Oracle’s
business; Oracle’s use and licensing of Java prior
to its acquisition of Sun; the effort and resources
that Oracle has invested in developing Java;
Oracle’s Java business and Java licensing; the prelawsuit Java-related discussions between Oracle
and Google; and the harm caused by Android.

Landau, Erez

Oracle. Contact
through Oracle’s
counsel.

Mr. Landau is an Oracle engineer. He may
testify regarding the performance testing he
conducted pertaining to the Android functionality
accused of infringing the ’720 patent, as disclosed
in his August 8, 2011 report; and Oracle’s
products that practice the asserted claims of the
patents-in-suit.

Lee, Ben

Former Google. 604
Wellsbury Court, Palo
Alto, CA 94306-3060.

Mr. Lee was formerly an in-house attorney for
Google. He is expected to testify regarding the
pre-lawsuit Java-related discussions between
Google and Oracle, including the July 20, 2010
meeting between counsel for Google and Oracle;
and Google’s awareness of Sun’s and Oracle’s
Java intellectual property rights and the need for
Google to obtain a Java license for Android.

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Witness
McGuire, Joshua

Contact Information
Google. Contact
through Google’s
counsel.

Trial Testimony
Mr. McGuire is an in-house attorney for Google.
He is expected to testify regarding the pre-lawsuit
Java-related discussions between Google and
Oracle, including the July 20, 2010 meeting
between counsel for Google and Oracle; and
Google’s awareness of Sun’s and Oracle’s Java
intellectual property rights and the need for
Google to obtain a Java license for Android.

McNealy, Scott

Former Sun.

Mr. McNealy is the former Chief Executive Officer
and Board Chairman of Sun Microsystems. He
may testify regarding Sun’s Java business and
Java licensing; Java-related discussions between
Sun and Google; Oracle’s acquisition of Sun; the
interest of Sun and its Board of Directors in
preventing Java fragmentation, enforcing Java
intellectual property rights, and protecting Java
licensing revenue; and Sun’s position regarding
Google’s release of Android and the harm caused
by Android.

Messinger, Adam

Oracle. Contact
through Oracle’s
counsel.

Mr. Messinger is Vice President Development at
Oracle. He may testify regarding Oracle’s Java
business and Java licensing; and the harm caused
by Android.

Pampuch, John

Oracle. Contact
through Oracle’s
counsel.

Mr. Pampuch is an Oracle engineer. He may
testify regarding Oracle’s products that practice
the asserted claims of the patents-in-suit.

Periakaruppan,
Nachi

Former Sun.

Mr. Periakaruppan was formerly an employee of
Sun Microsystems involved in marketing. He may
testify regarding Sun’s Java business and Java
licensing; the 2005-2006 Java-related discussions
between Sun and Google (Project Armstrong); and
Sun’s business model and projected revenues for
Project Armstrong.

Persi, Lino

Oracle. Contact
through Oracle’s
counsel.

Mr. Persi is a Sales Manager at Oracle. He may
testify regarding Sun’s and Oracle’s Java business
and Java licensing; and the harm caused by
Android.

Poore, Noel

Oracle. Contact
through Oracle’s
counsel.

Mr. Poore is an Oracle engineer. He may testify
regarding the performance testing he conducted
pertaining to the Android functionality accused of
infringing the ’702 and ’520 patents, as disclosed
in his August 8, 2011 report; Sun’s efforts to
develop a smart phone software stack; the impact
of Android on the Acadia project; the harm caused
by Android; and Oracle’s products that practice
the asserted claims of the patents-in-suit.

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Witness
Purdy, Alan

Contact Information
Expert retained by
Oracle. Contact
through Oracle’s
counsel.

Trial Testimony
Mr. Purdy is an expert retained by Oracle to
perform a comparison of certain Java and
Android source code. He may testify regarding
the matters disclosed in his reports of July 29 and
August 19, 2011.

Schulman, Eric

Google. Contact
through Google’s
counsel.

Mr. Schulman is an in-house attorney for Google.
He is expected to testify regarding the pre-lawsuit
discussions between Google and Oracle regarding
a Java license, including the July 20, 2010
meeting between counsel for the two sides; and
Google’s awareness of Sun’s and Oracle’s Java
intellectual property rights and the need for
Google to obtain a Java license for Android.

Serwin, Ken

Expert retained by
Oracle. Berkeley
Research Group.
Contact through
Oracle’s counsel.

Mr. Serwin is an expert retained by Oracle who
may testify as a rebuttal witness regarding
damages.

Sutphin, Brian

Oracle. Contact
through Oracle’s
counsel.

Mr. Sutphin is a Senior Vice President at Oracle.
He was formerly employed by Sun Microsystems.
He may testify regarding Sun’s and Oracle’s Java
business and Java licensing; Oracle’s acquisition
of Sun; the interest of Sun and its Board of
Directors in preventing Java fragmentation,
enforcing Java intellectual property rights, and
protecting Java licensing revenue; Sun’s position
regarding Google’s release of Android; and the
harm caused by Android.

Vandette, Bob

Oracle. Contact
through Oracle’s
counsel.

Mr. Vandette is an Oracle engineer. He may
testify regarding the performance testing he
conducted pertaining to the Android functionality
accused of infringing the ’104 and ’205 patents, as
disclosed in his August 8, 2011 report; and
Oracle’s products that practice the asserted claims
of the patents-in-suit.

Visnick, Marc

Expert retained by
Oracle. Contact
through Oracle’s
counsel.

Mr. Visnick is an expert retained by Oracle to
perform a comparison of certain Java and
Android source code. He may testify regarding
the matters disclosed in his July 29, 2011 expert
report.

Zavery, Amit

Oracle. Contact
through Oracle’s
counsel.

Mr. Zavery is Vice President, Product
Management, Oracle Fusion Middleware. He
may testify regarding the importance of Java to
Oracle’s business; and the harm caused by
Android.

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PLAINTIFF ORACLE’S FED. R. CIV. P. 26(A)(3) WITNESS LIST
CASE NO. CV 10-03561 WHA
pa-1486903

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1

Oracle reserves the right to call any witness identified by Google. The above descriptions

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are not intended to cover every possible topic or sub-topic on which these witnesses may testify

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and are made without prejudice to Oracle eliciting other testimony, including without limitation

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testimony regarding matters addressed during the deposition of a given witness.

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II.

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DEPOSITION TESTIMONY
Oracle reserves the right to present the deposition testimony of Google’s corporate

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officers (Larry Page, Eric Schmidt, and Andy Rubin) and 30(b)(6) designees (Andy Rubin,

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Daniel Bornstein, and Patrick Brady) in addition to or in lieu of their live testimony. Oracle also

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reserves the right to present the deposition testimony of any witnesses listed above who are

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unavailable to testify at trial.
Oracle may present testimony from the following additional witnesses by deposition:
Witness
Agarwal, Aditya

Contact Information
Google. Contact
through Google’s
counsel.

Trial Testimony
Mr. Agarwal is a Senior Financial Analyst at
Google. He may testify regarding the benefits to
Google from Android; and Google’s revenue and
profit projections for Android, including
advertising revenues.

Camargo, Rafael
(Motorola 30(b)(6)
witness)

Motorola. Contact
through Tom
Pasternak, Esq.,
Steptoe & Johnson
LLP, 115 South
LaSalle Street, Suite
3100, Chicago IL
60603.
Google Ventures.
Contact through
Google’s counsel.

Mr. Camargo is Senior Director of BSP and
Kernel at Motorola Mobility. He may testify
regarding the installation of infringing
components of Android code on Motorola’s
Android devices; and Motorola’s development of
Android applications, including use of the
Android dx tool.

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Miner, Rich

Mr. Miner was a co-founder of Android Inc. and
was formerly involved in the development of
Android at Google. He may testify regarding the
development of Android and inclusion of Java
technology therein; Google’s awareness of Sun’s
Java intellectual property rights and the need for
Google to obtain a Java license for Android;
Google’s Java-related discussions with Sun and
Oracle; and facts relating to Google’s willful
patent and copyright infringement.

Oracle reserves the right to designate testimony from any witness identified by Google.
The above descriptions are not intended to cover every possible topic or sub-topic on which

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PLAINTIFF ORACLE’S FED. R. CIV. P. 26(A)(3) WITNESS LIST
CASE NO. CV 10-03561 WHA
pa-1486903

11

1

Oracle may offer deposition excerpts and are made without prejudice to Oracle offering other

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testimony.

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Dated: October 7, 2011

MICHAEL A. JACOBS
MARC DAVID PETERS
DANIEL P. MUINO
MORRISON & FOERSTER LLP

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By: /s/ Daniel P. Muino
DANIEL P. MUINO

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Attorneys for Plaintiff
ORACLE AMERICA, INC.

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PLAINTIFF ORACLE’S FED. R. CIV. P. 26(A)(3) WITNESS LIST
CASE NO. CV 10-03561 WHA
pa-1486903

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