throbber
Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`9
`10
`
`11
`
`12
`
`13
`
`14
`15
`
`16
`
`17
`
`18
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`VERSATA SOFTWARE, INC.
`• Civil Docket No.
`* 2:07-CV-153
`* Marshall, Texas
`
`vs.
`
`*
`* August 18, 2009
`* 8:30A.M.
`SAP AMERICA INC., ET AL
`
`TRANSCRIPT OF TRIAL
`BEFORE THE HONORABLE CHAD EVERINGHAM
`UNITED STATES MAGISTRATE JUDGE
`ANDAJURY
`APPEARANCES:
`FOR THE PLAINTIFFS: MR. SAM BAXTER
`McKooi-Smith
`104 East Houston, Suite 300
`Marshall, TX 75670
`
`MR. THEODORE STEVENSON, Ill
`McKooi-Smith
`300 Crescent Court, Suite 1500
`Dallas, TX 75201
`MR. SCOTT COLE
`MR. STEVEN J. POLLINGER
`MS. LAURIE L. GALLUN
`MR. JOSH W. BUDWIN
`MR. KEVIN M. KNEUPPER
`McKooi-Smith
`300 West 6th Street, Suite 1700
`Austin, TX 787011
`
`19
`20 APPEARANCES CONTINUED ON NEXT PAGE:
`21
`
`MS. SUSAN SIMMONS, CSR
`COURT REPORTERS:
`MS. JUDITH WERLINGER, CSR
`Official Court Reporters
`100 East Houston, Suite 125
`Marshall, TX 75670
`903/935-3868
`(Proceedings recorded by mechanical stenography,
`
`22
`
`23
`
`24
`25
`
`VERSATA v. SAP
`
`Unsigned
`A001369
`
`Page 1
`
`VERSATA EXHIBIT 2011
`SAP v. VERSATA
`CASE CBM2012-00001
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`adjustments, condition tables, condition records. Those
`
`things aren't very familiar to people who haven't spent
`
`a long time studying pricing.
`
`But, actually, it's very similar to the
`
`process of fishing, and so we're going to use an analogy
`
`where the old R/3 does fishing by casting a line and
`
`trying to catch one fish at a time, and then we're going
`
`to introduce a different analogy for the patented
`
`technology.
`
`10
`
`Q. And this is with respect to the problem of too
`
`11 many accesses?
`
`12
`
`A. Yes, sir. That's what this-- this
`
`13
`
`illustration focuses on; there are too many accesses.
`
`14
`
`Q. Well, let's turn to your animation, and I'll
`
`15
`
`let you explain it, if you could, while we watch it.
`
`16
`
`17
`
`18
`
`Let's watch the first part.
`
`What do you show here, Dr. Nettles?
`
`A. Well, this is the customer hierarchy that was
`
`19
`
`found in the patent, and we've seen this customer
`
`20
`
`hierarchy a number of times already in this case. And
`
`21 we'll, I'm sure, see it a large number of times
`
`22
`
`subsequently.
`
`23
`
`So we thought it would be a good example of a
`
`24
`
`hierarchy to use as an illustration.
`
`25
`
`Q. Should we go to the next part?
`
`VERSATA v. SAP
`
`Unsigned
`A001392
`
`Page 24
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`A. We should.
`
`Q. What are you showing here?
`
`A. Well, it's a little bit easier to understand
`
`the fishing analogy if the hierarchy, instead of going
`
`from left to right, goes up and down, and so we rotate
`
`it, and now next we're going to redraw it.
`
`Q. Let's go to the next. What do you show here?
`
`A. Well, this is the same hierarchy, but it's
`
`been redrawn so it's a little bit easier to read. And
`
`10 we added to it a number of price adjustments. So we've
`
`11
`
`been talking about retrieving price adjustments and
`
`12
`
`applying price adjustments, and we've used the analogy
`
`13
`
`that the price adjustments are fish.
`
`14
`
`And in the process of searching for a price
`
`15
`
`adjustment, it's-- the analogy is ifs going to be like
`
`16
`
`trying to catch a fish.
`
`17
`
`Q. So each of these fish is representing a price
`
`18
`
`adjustment?
`
`19
`
`A. That's correct. And one of the things that's
`
`20
`
`important to notice is that there's not a price
`
`21
`
`adjustment on every node of the tree. Some places there
`
`22
`
`aren't any fish; there aren't any price adjustments.
`
`23
`
`And so.you might not be able to catch a fish
`
`24
`
`in those locations.
`
`25
`
`Q. And by nodes, you mean every spot on the tree?
`
`VERSATA v. SAP
`
`Unsigned
`A001393
`
`Page 25
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`A. Yes, sir. All the different places inside the
`
`tree, in computer science speak, we call them nodes.
`
`Q. Should we go to the next part?
`
`A. Yes, sir.
`
`Q. What are we showing here?
`
`A. Well, here we're going to try to calculate a
`
`price for Frank, and so the first thing we're going to
`
`do is we're going to go and look and see if there's a
`
`price adjustment of fish on Frank.
`
`Q. Frank is right here (indicates)?
`
`A. That's right.
`
`And what we see here is that we failed, and
`
`13
`
`so-- because there's no price adjustment there, and so
`
`14 we've represented that with a try icon.
`
`15
`
`16
`
`17
`
`Q. We didn't find a price adjustment there?
`
`A. That's right.
`
`Q. Let's go to the next part. Now, what are you
`
`18
`
`showing?
`
`19
`
`A. Well, the way that these pricing systems work
`
`20
`
`is if they don't find a price at one level of the
`
`21
`
`hierarchy, they move up the hierarchy. And so we see
`
`22
`
`here we've moved up to Texas, because Frank lives in
`
`23
`
`Texas. And, again, we've tried to catch a. fish, but we
`
`24
`
`haven't succeeded.
`
`25
`
`MR. POLLINGER: Let's go to the next
`
`VERSATA v. SAP
`
`Unsigned
`A001394
`
`Page 26
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`part.
`
`Q.
`
`(By Mr. Pollinger) 'Mlat are you showing here;
`
`another try?
`
`A. Now we're trying with states; again, we fail.
`
`Q. And then this next part?
`
`A. We tried for the U.S., and we fail.
`
`Q. And this next part?
`
`A. So now we try for geography, and we actually
`
`get a fish.
`
`Q. We got a price adjustment?
`
`A. That's right. We got a price adjustment.
`
`12 And so what we've done in this particular example is we
`
`13
`
`try, try, try again, and finally, we've been successful.
`
`14 And then finally--
`
`15
`
`16
`
`Q.
`
`'Mlat happens next?
`
`A. We stop. Once we've caught a fish, there's no
`
`17
`
`reason to keep going up the hierarchy and looking for
`
`18 more fish, because, as we talked about yesterday, we
`
`19 want the most specific adjustment. And that's going to
`
`20
`
`be the deepest adjustment in the tree.
`
`21
`
`And in our analogy, it's going to be the
`
`22
`
`biggest fish. So we want to catch the biggest fish we
`
`23
`
`can that's along the hierarchical path from where we
`
`24
`
`started.
`
`25
`
`Q. So the hierarchical path from Frank would have
`
`VERSATA v. SAP
`
`Unsigned
`A001395
`
`Page 27
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`taken us all the way up the chain to world?
`
`A. That's righ~.
`
`Q. But we didn't get all the way to world. We
`
`stopped after we found a price adjustment here at
`
`geography?
`
`A. No reason to keep fishing once you have the
`
`price adjustment that you want in this approach.
`
`Q. Now, this is an old R/3 where you try, try,
`
`try, find one and then stop? Is that-- is that how it
`
`10 works?
`
`11
`
`12
`
`13
`
`A. Yes, sir. This is basically one of the main
`
`algorithm aspects of the old condition technique.
`
`Q . And is this illustrating the problem of too
`
`14 many accesses in the old R/3 products?
`
`15
`
`16
`
`A. Yes, sir, it is.
`
`MR. POLLINGER: Let's go to the next
`
`17
`
`slide here.
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`Q .
`
`(By Mr. Pollinger) Do you next explain the
`
`problem in the old product, old R/3, of too many tables?
`
`A. Yes, sir.
`
`Q. And do you have an animation to illustrate
`
`this as well?
`
`A.
`
`I do.
`
`Q. Let's step through it. Let's go to the first
`
`25
`
`part.
`
`VERSATA v. SAP
`
`Unsigned
`A001396
`
`Page 28
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`What do we see here?
`
`A. Well, these are the two hierarchies from the
`
`patent. And the documentation we saw earlier said that
`
`you had to -- if you wanted to completely represent the
`
`price adjustments, you had to -- you had to make all the
`
`different combinations between the two hierarchies, and
`
`each of those needed to be a table.
`
`And so we're going to take the patent's
`
`example, and we're going to show all of the tables that
`
`10
`
`you would have to create and then potentially access in
`
`11
`
`the old technique.
`
`12
`
`MR. POLLINGER: Let's go to the next
`
`13
`
`part.
`
`14
`
`15
`
`A. So the first thing we see is we see we're
`
`going to create a table where the indices are customer
`
`16
`
`size, customer type, and product ID.
`
`17
`
`Q.
`
`(By Mr. Pollinger) So is this a table- a
`
`18
`
`combination of one of these spots in the customer
`
`19
`
`hierarchy and one of these spots in the product
`
`20
`
`hierarchy?
`
`21
`
`22
`
`23
`
`24
`
`A. Actually, two in the customer hierarchy and
`
`one in the product hierarchy.
`
`Q. Okay.
`
`MR. POLLINGER: Let's go to the next
`
`25
`
`part.
`
`VERSATA v. SAP
`
`Unsigned
`A001397
`
`Page 29
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8118/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`Q. (By Mr. Pollinger) What are you illustrating
`
`here?
`
`A. Well, two things. First, we're illustrating
`
`that if that table didn't have a price adjustment, that
`
`would be a place where you would have to fish and
`
`potentially miss.
`
`And then we're also illustrating the next
`
`table, which is one that involves state and customer
`
`size, customer type, and, again, product I D.
`
`Q. So if you miss, you go look in the next table?
`
`A. That's right.
`
`MR. POLLINGER: Let's go ahead.
`
`Q.
`
`(By Mr. Pollinger) What are you showing here
`
`14
`
`now?
`
`15
`
`A. Well, now we're showing all of the other
`
`16
`
`tables that had to be created first and then later
`
`17
`
`accessed. And as you can see, there is-- there's a
`
`18
`
`large number of them.
`
`19
`
`Eventually, you will get to a table that has a
`
`20
`
`pricing adjustment, if there is a pricing adjustment for
`
`21
`
`that particular operation in this -- in this tree. So
`
`22
`
`eventually you will catch one.
`
`23
`
`Q. And this, again, is illustrating -- are we
`
`24
`
`done?
`
`25
`
`A.
`
`I think we're done with that one.
`
`VERSATA v. SAP
`
`Unsigned
`A001398
`
`Page 30
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4·
`
`5
`
`6
`
`7
`
`8
`
`9
`
`But there are a few more tables that would get
`
`created, and those are ones that you wouldn't access.
`
`So eventually, you'd catch a· fish and then you stop.
`
`But all total, there are 136 tables here.
`
`Q. Again, is this illustrating the problem in
`
`SAP's old product of too many tables?
`
`A. Exactly that problem.
`
`MR. POLLINGER: If we can go back to
`
`Slide 4 for a timeline.
`
`10
`
`Q.
`
`(By Mr. Pollinger) Have you now described to
`
`11
`
`us with your fishing illustration the problem in SAP's
`
`12
`
`old product?
`
`13
`
`14
`
`A. Yes, sir, I have.
`
`Q. Those products are not accused of
`
`15
`
`infringement, are they?
`
`16
`
`17
`
`18
`
`A. No, sir, they are not.
`
`Q. Let's turn now to the next part.
`
`THE COURT: Mr. Pollinger, let's avoid
`
`19
`
`repetition, please, sir.
`
`20
`
`21
`
`MR. POLLINGER: Thank you, Your Honor.
`
`Q.
`
`(By Mr. Pollinger) Let's now turn to the next
`
`22
`
`part of the timeline, the solution with Mr. Carter's
`
`23
`
`invention, his patent filed in 1996.
`
`24
`
`Do you have an illustration to describe that
`
`25
`
`aswell?
`
`VERSATA v. SAP
`
`Unsigned
`A001399
`
`Page 31
`
`

`

`A. Yes, sir. Again, using the analogy of
`
`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`fishing.
`
`please.
`
`MR. POLLINGER: Let's go to Slide 34,
`
`Q . (By Mr. Pollinger) And could you introduce to
`
`us the -- the analogy?
`
`A. Well, in this case, we're going to-- instead
`
`of fishing with a pole and trying to catch a pricing
`
`adjustment one at a time, we're going to fish with a
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`net. And so we're going to gather up all the potential
`
`11
`
`pricing adjustments at one time.
`
`12
`
`13
`
`14
`
`Q. Do you have an animation with this as well?
`
`A.
`
`I do.
`
`MR. POLLINGER: Let's go to that. I
`
`15
`
`believe it's--
`
`16
`
`17
`
`Q. (By Mr. Pollinger) L~t's step through it.
`
`Could you explain to us what we see here in
`
`18
`
`the first part?
`
`19
`
`A. Well, again, it's the same hierarchy with the
`
`20
`
`same adjustments, but this time we're going to try to do
`
`21
`
`a price adjustment for the Charlie customer.
`
`22
`
`And the first thing we see is that we're going
`
`23
`
`to retrieve all the price adjustments going l!P the
`
`24
`
`hierarchy to the root, to the world node, starting at
`
`25 Charlie. And so that's the fishing with the net or
`
`VERSATA v. SAP
`
`Unsigned
`A001400
`
`Page 32
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`retrieving step of the patented invention.
`
`Q. Now, do we go all the way up from Frank all
`
`the way to world?
`
`A. We did. So we actually gathered more data
`
`than would have been gathered by the old condition
`
`technique.
`
`MR. POLLINGER: Let's go to the next
`
`part.
`
`Q.
`
`(By Mr. Pollinger) What are you showing here,
`
`10 Dr. Nettles?
`
`11
`
`12
`
`A. Well, the thing is, since we've gotten a lot
`
`of pricing adjustments, we actually have to figure out
`
`13 which one we want, and we want the one which is most
`
`14
`
`specific. We want the biggest fish.
`
`15 ·
`
`16
`
`17
`
`18
`
`And so we have to sort them from least
`
`specific to most specific to find out that Charlie is
`
`actually the fish that we want.
`
`MR. POLLINGER: Let's go to the next
`
`19
`
`part.
`
`20
`
`21
`
`22
`
`Q.
`
`(By Mr. Pollinger) What are you showing here?
`
`A. Well, now we eliminate the pricing adjustments
`
`that are less specific than Charlie and that we don't
`
`23
`
`need to use, and we throw them back.
`
`24
`
`MR. POLLINGER: Let's go to the next
`
`25
`
`part.
`
`VERSATA v. SAP
`
`Unsigned
`A001401
`
`Page 33
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`A. And then finally, we apply the Charlie
`
`adjustment to calculate the price; in this case, $10 at
`
`Charlie's warehouse.
`
`Q.
`
`(By Mr. Pollinger) This is in the Trilogy
`
`patents?
`
`A. Yes, sir. This is exactly the algorithm and
`
`approach that the Trilogy patents describe for making
`
`these calculations.
`
`MR. POLLINGER: Let's go to Slide 41,
`
`10
`
`please.
`
`11
`
`Q.
`
`(By Mr. Pollinger) 'Mlat do you show here, Dr.
`
`12 Nettles, from the patent?
`
`13
`
`A. Well, this is Claim 26, which we'll talk about
`
`14
`
`at length later. But what we see here is that Claim 26
`
`15
`
`requires that we do a retrieve, a sort, an eliminate,
`
`16
`
`and then finally a determine or apply step.
`
`17
`
`Q. How does this relate to the illustration you
`
`18
`
`just gave us?
`
`19
`
`A. Well, those are the same steps and are
`
`20
`
`performed in an analogous way to the illustration.
`
`21
`
`22
`
`23
`
`Q. Let's go to your next slide.
`
`What do you show here from the patents?
`
`A. Well, this is Figures 15-B and 15-C of the
`
`24
`
`patent, and it's a flowchart. So, basically, it's a way
`
`25
`
`that the computer scientists actually would describe the
`
`VERSATA v. SAP
`
`Unsigned
`A001402
`
`Page 34
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`flow of information and their algorithm.
`
`And so what it says is, what's the basic
`
`process that my patent claims.
`
`0. Let's go to your next slide.
`
`VVhat do you show here?
`
`A. That particular step describes the retrieve
`
`step, the fishing with the net part.
`
`0. And the next slide?
`
`A. This describes the sorting, the arranging the
`
`price adjustments in order so that we can pick the most
`
`specific.
`
`0. The next slide?
`
`A. This is the eliminate step where we throw back
`
`the price adjustments that we don't need.
`
`0. The next slide?
`
`A. And then this is the apply step where we use
`
`the pricing adjustment that we caught, that we actually
`
`18 want.
`
`19
`
`0. Is this similar to the illustration you gave
`
`20
`
`us?
`
`21
`
`22
`
`23
`
`A.
`
`It's the-- it's the same process, and each of
`
`these steps are analogous.
`
`MR. POLLINGER: Let's go to the next
`
`24
`
`slide.
`
`25
`
`0. (By Mr. Pollinger} Dr. Nettles, what do you
`
`VERSATAv. SAP
`
`Unsigned
`A001403
`
`Page 35
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`show on this slide here?
`
`A Well, this is just a little pictorial summary
`
`that shows that the old R/3 uses the try, try, try
`
`again, finally eventually catching one, stopping
`
`approach.
`
`And the patented technology solves the problem
`
`in a very different way. It first fishes with a net,
`
`and then it sorts, then it eliminates, and then,
`
`finally, it applies.
`
`10
`
`MR. POLLINGER: Let's go to Slide 4 of
`
`11
`
`the timeline.
`
`12
`
`Q.
`
`(By Mr. Pollinger) So what parts of this
`
`13
`
`timeline have we now discussed?
`
`14
`
`A. We've talked about before the patents, and
`
`15 we've talked about the patent itself.
`
`16
`
`17
`
`18
`
`19
`
`20
`
`Q. What do we have left to talk about?
`
`A. The accused products.
`
`Q. After the patents were filed?
`
`A Yes, sir, after the patents were filed.
`
`MR. POLLINGER: Let's go, if we could, to
`
`21
`
`Slide 48, Mr. Diaz.
`
`22
`
`Q.
`
`(By Mr. Pollinger) Dr. Nettles, let's turn now
`
`23
`
`to the SAP products that are accused of infringement in
`
`24
`
`this case.
`
`25
`
`Those are the products that include the
`
`VERSATA v. SAP
`
`Unsigned
`A001404
`
`Page 36
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`hierarchical access feature?
`
`A. Yes, sir.
`
`MR. POLLINGER: Go to Slide 50.
`
`Well, let's hold on for a second. Let me
`
`ask a question.
`
`Q. (By Mr. Pollinger) The hierarchical access
`
`feature again, that was added in 1998, two years after
`
`the patents were filed?
`
`A. Yes, sir, it was.
`
`Q.
`
`It wasn't in the old R/3 product?
`
`A. No, sir.
`
`Q.
`
`Is there some deposition testimony from an SAP
`
`13 witness confirming that?
`
`14
`
`15
`
`16
`
`17
`
`18
`
`A. Yes, sir, there is.
`
`Q. Let's look at that.
`
`MR. POLLINGER: Slide 50.
`
`Q. (By Mr. Pollinger) What do we have here?
`
`A. Well, this is deposition testimony from
`
`19 Dr. Nieswand --he's an SAP engineer-- about the
`
`20
`
`hierarchical access feature.
`
`21
`
`22
`
`23
`
`Q. And what did he say?
`
`A. Well, I'll read it for you.
`
`QUESTIQN: R/3 2.2 did not include
`
`24
`
`hierarchical accesses, correct?
`
`25
`
`ANSWER: That's correct.
`
`VERSATA v. SAP
`
`Unsigned
`A001405
`
`Page 37
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`Q. So is he telling us that the old R/3 product
`
`did not have the hierarchical access feature?
`
`A. That's correct.
`
`MR. POLLINGER: Let's go to Slide 49,
`
`please.
`
`Q.
`
`(By Mr. Pollinger) This is Exhibit PX145 at
`
`Page 15.
`
`This is an SAP document, correct?
`
`A. Yes, sir. This is a presentation by SAP.
`
`Q. Describing its hierarchical access feature?
`
`A. Exactly.
`
`Q. Does this describe what you can do with
`
`13
`
`hierarchica.l access?
`
`14
`
`A. Yes, sir. It explains that with hierarchical
`
`15
`
`access, you only need a single table and one access to
`
`16
`
`solve the same problem that we were seeing solved in
`
`17 many tables before.
`
`18
`
`Q.
`
`If I read correctly here, does it say that the
`
`19
`
`functions in the hierarchical access enable you to solve
`
`20
`
`these problems?
`
`21
`
`22
`
`23
`
`24
`
`25
`
`A. Yes, sir.
`
`Q.
`
`Is that the problems we've been talking about?
`
`A. Of too many tables and too many accesses, yes.
`
`MR. POLLINGER: Let's go to Slide 51.
`
`Q.
`
`(By Mr. Pollinger) What do you show on this
`
`VERSATA v. SAP
`
`Unsigned
`A001406
`
`Page 38
`
`

`

`Trial: Day 02 Vol. A Nettles direct 8/18/2009 8:30:00 AM
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`slide here, Dr. Nettles?
`
`A yYell, this is a screen shot of my actual usage
`
`of the SAP product And we see on the -- on the
`
`right-hand side, we see that this particular access that
`
`we're doing is a hierarchical one.
`
`Q. And this is from Exhibit PX1390 at Page 9?
`
`A. Yes, sir.
`
`Q . Does this relate at all -- well, what is this
`
`icon down here, this picture?
`
`10
`
`A.
`
`It says that we're illustrating the retrieve,
`
`11
`
`the fishing-with-the-net step. And we see that over
`
`12
`
`here on the left-hand side where we see a number of
`
`13
`
`different price adjustments, all of which have been
`
`14
`
`15
`
`16
`
`17
`
`retrieved in the same access.
`
`Q. Let's go to your next slide here.
`
`'M1at do you show here?
`
`A. Well, this illustrates that after the
`
`18
`
`retrieval has been done, that SAP's going to sort
`
`19
`
`these-- these pricing adjustments from least specific
`
`20
`
`to most specific to get the order that we see here. So
`
`21
`
`that illustrates the sorting step.
`
`22
`
`23
`
`24
`
`25
`
`Q. And the next slide, what do you show here?
`
`A Well, the fact that SAP has put these red dots
`
`on the side of these four pricing adjustments indicate
`
`that those pricing adjustments aren't going to be used,
`
`VERSATAv. SAP
`
`Unsigned
`A001407
`
`Page 39
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket