Free Notice to Take Deposition - District Court of Delaware - Delaware

Case 1 :06-cv-00414-SLR Document 37 Filed 07/19/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ORACLE CORPORATION and )
ORACLE l}.S.A. INC., )
Plaintiffs, g
v. 5 C.A. No. O6—4l4~SLR
- EPICREALM LICENSING, LP, g
Defendant. g
NOTICE OF RULE 30{b}g6) DEPOSITION OF ORACLE CORPORATION
PLEASE TAKE NOTICE that on July 31, 2007 at 9:00 a.m. at the Garden Court Hotel,
520 Ccwper Street, Palo Alto, California 94301, or at such other tinie and place as agreed by the
parties, defendant and countenplaintiff epicRealm Licensing LP, pursuant to Fed. R. Civ. P. 26
and 30, shall take the deposition upon oral examination of plaintiff and counter—defendant Oracle
Corporation. The deposition will continue {rom day to day until completed and shall be taken
before a duly certified court reporter and notary public or other person authorized by law to
administer oaths. The deposition will be recorded by stenograpliic, sound and video means.
Pursuant to Fed. R. Civ. P. 30(b)(6), Oracle Corporation shall designate one or more
officers, directors, managing agents or other representatives who consent to testify on its behaltl
to testify to matters known or reasonably available to Oracle Corporation regarding the topics
listed herein. To the extent more than one deponent is identified, Oracle Corporation shall state
in advance of the deposition which portions of this notice each deponent is prepared to address.

Case 1:06-cv—00414-SLR Document 37 Filed 07/19/2007 Page 2 of 3
Rule 30gblg6) Deposition Topics
In accordance with Fed. R. Civ. P. 30(b)(6), epicllealm identifies the following matters
for examination:
l. The identification of each of Oracie’s "software products that are
used in conjunction with the delivery of dynamic web pages" (as used in Oracle’s
Co1nplaint’s Prayer), Oracie’s largest 100 customers ranked on the basis of
revenue to Oracle for such products for the period of Oracle’s fiscal years 200l—
2007, the geographic location where said custorners’ products are located andthe
geographic location where said custo1ners’ products are licensed for use, Oracle°s
revenues on a product~by-·product basis for such products for each of those
customers and the identification of any Oracle agreement to indemnify those
customers for patent infringement by those products.
For purposes of this Topic No. 1, "Oracle’° means Oracle Corporation and Oracle U.S.A.
Inc., plaintiffs and connter—clefendants in this action, and all predecessors, successors,
subsidiaries, divisions, parents and/or afiiiiates thereof, past or present, and all past or present
officers, directors, affiliates, agents, employees, attorneys, consultants, representatives and any
other person acting or purporting to act on behalf of Oracle.
You are invited to attend and exercise your rights under the Federal Rules of Civil
Procedure.
OF COUNSEL: POTTER ANDERSON & CORROON LLP
Herr 4*- Kors By: wan E. Moore
George S. Bosy . .
Richard L. Horwrtz (#2246)
Aaron A. Barlow D .d E M (#3983
Paul D Margolis aw ` Dom is )
Bmjanéin J Bradford Hercules Plaza, 6 Floor
Jsrsusn a sroor; $,13 li Mmm Strict
rlmington, DE 19899
330 N. Wabash Avenue TSP (302) 9846000
Chicago, IL 60611-7603 ` h ' .t tt d
TCT (312) 923_83O5 r orwr z@po eran ersorreom
‘ [email protected]
Qggigi, 19* 2007 l Attomeysfor Defendant
epzcRec¢lm Lzcensmg, LP
2

Case 1:06-cv—00414-SLR Document 37 Filed 07/19/2007 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
I, David E. Moore, hereby certify that on July 19, 2007, the attached document was hand
delivered to the following persons and was electronically flied with the Clerk of the Court using
CM/ECP which will send notification to the registered attorr1ey(s) of record that the document
has been tiled and is available for viewing and downloading:
Mary B. Graham
Morris, Nichols, Arsht & Tunnell LLP
1201 North Market Street
P.O. Box 1347
Wilmington, DE 19899
I hereby certify that on July 19, 2007, I have Electronically Mailed the documents to the
following:
Mary B. Graham James G. Gilliland
Morris, Nichols, Arsht & Tunnell LLP Theodore T. Herald
1201 North Market Street Eric M. Hutchins
P.O. Box 1347 Chad E. King
Wilmington, DE l9899 Robert J. Artuz
[email protected] Townsend and Townsend and Crew LLP
379 Lytton Avenue
Palo Alto, CA 94301
OracleEpicrealm§@,townSend.com
/s/ David E. Moore
i Richard L. Horwitz
David E. Moore
Potter Anderson & Corroon LLP
Hercuies Plaza — Sixth Floor
1313 North Market Street
P.O. Box 95l
Wilmington, DE 19899-0951
(302) 984—~6000
rhorwitz@_1gotteranderson.com
[email protected]
806755 / 31393/Oracle