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

Case 1 :06-cv-00414-SLR Document 36 Filed 07/19/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ORACLE CORPORATION and )
ORACLE U.S.A. INC., )
)
Plaintiffs, )
) C.A. No. 06-414-SLR
v. )
)
EPICREALM LICENSING, LP, )
)
Defendant. )
NOTICE OF RULE 30gb;g6) DEPOSITION OF ORACLE U.S.A. INC.
PLEASE TAKE NOTICE that on August l, 2007 at 9:00 am. at the Garden Court Hotel,
520 Cowper Street, Palo Alto, California 94301, or at such other time and place as agreed by the
parties, defendant and counter-plaintiff 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
U.S.A. inc. The deposition will continue from 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 stenographic, sound and video means.
Pursuant to Fed. R. Civ. P. 30(b)(6), Oracle U.S.A. Inc. shall designate one or more
officers, directors, managing agents or other representatives who consent to testify on its behalf,
to testify to matters known or reasonably available to Oracle U.S.A. Inc. regarding the topics
listed herein. To the extent more than one deponent is identified, Oracle U.S.A. Inc. shall state
in advance of the deposition which portions of this notice each deponent is prepared to address.

Case 1:06-cv—OO414-SLR Document 36 Filed 07/19/20-07 Page 2 of 3
Rule 30l b [{6} Deposition Topics
In accordance with Ped. R. Civ. P. 30(b)(6), epicRealm identities the following matters
for examination:
l. The identification of each of Oracle’s "sottware products that are
used in conjunction with the delivery of dynamic web pages" (as used in Oracle’s
Compiaint’s Prayer), Oracle’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 customers’ products are located and the
geographic location where said customers’ products are licensed for use, Oracle’s
revenues on a productiby-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. I, "Oracle" rneans Oracle Corporation and Oracle U.S.A.
Inc., plaintiffs and countendefendants in this action, and all predecessors, successors,
subsidiaries, divisions, parents and/or affiliates 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
Hwy J' Roper By: /s/ David E. Moore
George S. Bosy
Richard L. HOYW1LZ(#2246)
Aaron A. Barlow .
. David E. Moore (#3983)
Paul D. MHIgOl1S H 1 601
Benjamin J. Bradford 1§;§u§SM gig} St (Em
Jammu & BLOCK W. . ‘ ar e me
1lm1ngton, DE i9899
330 N. Wabash Avenue _ I
. Tel. (302) 984-6000
Chicago, IL 6061 l»·7603 h -t tt d
Tc} (N2) 923-8305 r orwi z@,po eran erson.co1n
' dmoore@,potteranderson.com
gggigj 19* 2007 Attorneysforr Defendant
epzcReoZm Lzcensmg; LP
‘ 2

Case 1:06-cv—00414-SLR Document 36 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 tiled with the Clerk of the Court using
CM/EGF which will send notification to the registered attorney(s) of record that the document
has been tiled and is available for viewing and downloading:
Mary B. Graham
Morris, Nichols, Arsht 8: Tunnell LLP
1201 North Market Street
P.(). Box 1347 ‘
Wilmington, DE 19899
I hereby certify that on July 19, 2007, 1 have Electronically Mailed the documents to the
following:
Mary B. Graham James G. Gilliland
Morris, Nichols, Arsht & '1"unne1l LLP Theodore T. Herald
1201 North Market Street Eric M. Hutchins
P.O. Box 1347 Chad E. King
Wilmington, DE 19899 Robert J. Artaz
MGraham@MNAT,com Townsend and Townsend and Crew LLP
379 Lytton Avenue
Palo Alto, CA 94301
[email protected]
/s/ David E. Moore
Richard L. Horwitz
David E. Moore
Potter Anderson & Corroon LLP
Hercules Plaza ~— Sixth Floor
1313 North Market Street
P.O. Box 951
Wilmington, DE 19899-0951
(302) 984-6000
[email protected]
dmoore@,potteranderson.com
806755 / 31393/Oracle