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00001

1

IN RE:

2

 THE MATTER OF ORACLE'S PROPOSED ACQUISITION OF PEOPLESOFT
3

    CIVIL INVESTIGATIVE DEMAND NO. 22796
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              San Francisco, Califonia

8

               Tuesday, January 20, 2004
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11

    
12

    
13

  

Videotaped Deposition of CLIFFORD GODWIN, JR., a

14

   witness herein, called for examination in the above-entitled
15

   matter, pursuant to notice, taken at the offices of the United
16

   States Department of Justice, Antitrust Division, 450 Golden
17

   Gate Avenue, San Francisco, California, 94102, beginning at
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   9:45 a.m. before Carol Nygard Drobny, Certified Shorthand
19

   Reporter, RMR, Registered Merit Reporter, and RPR, Registered
20

   Professional Reporter in and for the State of California.
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22

    
Godwin 01-20-04

00008
13

  

Q. Okay. Mr. Godwin, is it correct that you are

14

 employed by Oracle Corporation currently?
15

   A. Yes. Yes, it is.
16

   Q. What is your position currentry with Oracle?
17

   A. Senior Vice President for Applications Technology.
 
Godwin 01-20-04

00023

8

  

Mr. Godwin, do you also have any responsibilities

9

 that relate to direct interaction with customers?
10

   A. As part of the role, applications and technology
11

 role, I deal with making presentations to customers in user
12

 group forums, for example, and also periodically I'm asked to
13

 participate in customer visits, either for existing customers
14

 or for sales opportunities.
Godwin 01-20-04

00086

6

  

Q. How long did Oracle work on building functional

7

improvements for the 11i product family before it was first

8

 commercially released?
9

   A. Pretty much from the release of 11.0 in '98 until
10

 the time we released it in 2000, so a couple of years.
11

   Q. And if I heard you correctly earlier, is it also
12

 correct you've continued to build improvements in to the 11i
13

product line family since its initial release?

14

   A. Yes, we have.
Godwin 01-20-04

00088

6

  

Q. Okay. Since the release of version 11i, initially

7

in the spring of 2000, approximately how many developers,

8

 technical developers and R&D personnel, have Oracle -- has
9

 Oracle deployed to supporting and enhancing the 11i product
10

 line?
11

   A. I'm sorry.
12

   How many do we have now or over a period of time?
13

   I'm not sure of the question.
14

  

Q. Well, perhaps -- perhaps the numbers changed over

15

 time. So maybe --
16

   A. Yeah, it has substantially.
17

   Q. I'll take that up. Today-
18

   A. Yeah.
19

   Q. -- how many developers and R&D personnel are
20

 deployed to support the 11i product line?
21

   A. I think the aggregate is something in the order of
22

 6,000 worldwide.
Godwin 01-20-04

00089

1

  

In the applications business there are people,

2

 obviously, you could allocate, interpet as -- doing work in
3

 math for the applications from the system products and database
4

 and application server groups as well, if you're trying to make
5

 things fully comparable to another vendor.
6

   In our business the people that build the tools,
7

 technology, and reporting tools, and things like that actually
8

 work under the application server group and wouldn't be counted
9

 in my 6,000.
10

   There's 6,000 people basically in Ron Wohl's
11

 organization.
Godwin 01-20-04

00090

12

  

There is a support organization that doesn't do

13

 engineering but answers the phone, and that group has a bunch
14

 of people allocated to applications as well.
Godwin 01-20-04

00101

4

  

The -- what has changed on the server side in going

5

 to the Internet computing architecture?
6

   What software functionality architecture needs to
7

be put on the server that wasn't there on the client server

8

 side?
9

   A. Okay. There's a big portion of what used to be in
10

 the client, which is all of the software that is implementing
11

 the business logic and user interface processing to basically
12

 decide how the screen works, that is now moving from being a
13

Windows program running on the client to being a program

14

 deployed on a server, which may be Windows, or Unix, or some
15

 other -- you know, whatever operating system you chose.
16

   So there is -- there is a redeployment in that
17

 sense then.
18

   Q. Okay. And what is the benefit to a customer in
19

 going through that type of redeployment?
20

   What does a customer achieve that they couldn't
21

 achieve under the older architecture?
22

   A. Under the current server?
Godwin 01-20-04

00102
1

  

MR. GAUL: Sure.

2

   MR. ROSS: Objection. Asked and answered
3

 previously.
4

   You can answer again.
5

   THE WITNESS: That's the savings - it's largely
6

 the cost savings of centralized administration, because it's
7

 expensive to maintain and version - - make version changes to
8

 desktop software on some large number of user desktops as
9

opposed to being able to do it centrally under data central

10

 control.
11

  

So for IT departments it's a huge simplification of

12

 their lives, and users experience less volatility in what's
13

 installed with the associated reliability problems on their
14

 desktops.
15

   So it's actually an improvement in the reliability
16

 of the system from their perspective as well.
Godwin 01-20-04

00106

4

  

Q. I'd like to switch gears back again to E-business

5

 Suite version 11i.
6

   A. Uh-huh.
7

   Q. You had made reference earlier to additional
8

 functional improvements to the suite.
9

   I was wondering if you could perhaps list for me
10

 what you view as the major functional improvements that were
11

 rolled out with 11i and have been rolled out subsequent to its
12

 initial release.
13

   A. Oh, gosh.
14

  

I mean, we have - I mean, 11i has had an enormous

15

 amount of new functionality. I mean, the entire CRM family of
16

 applications is new in 11i. Not the entire, but, I mean,
17

 virtually the entire family of CRM applications is new in 11i.
18

   We've vastly increased the amount of manufacturing
19

 supply chain functionality in 11i.
20

   We've -- introduced new modules in human resources
21

 and financials and the projects area.
22

   I mean, there's more development investment and
Godwin 01-20-04

00107

1

more development progress in even during 11i, since we

2

 initially released it in 2000, more kind of person years of new
3

 development that's occurred in that than there was in the
4

 entire history of applications up until that point.
5

   So we've -- we have been putting in a substantial
6

 investment in building out new functionality, and I can't -- I
7

 mean, I can only begin to characterize it in terms of, you
8

 know, support for -- I mean, industry specific support
9

 features, whole areas of supply chain collaboration, built out
10

 a whole new transportation management logistics system.
11

  

I mean, these are all not my area. I'm just aware

12

 that we're doing these things at large, because, you know, I'm
13

 aware that the products have come in to existence.
14

   But, I mean, there's -- there's -- if you looked at
15

 a list of all the products that we had in existence in 11.0 and
16

 the ones we had in 11i, it would -- the list is probably not
17

 -- "products" is not the right word, because that has a price
18

 -- that has a price list connotation like things we sell.
19

   But, I mean, the number of modules, the -- you
20

 know, the -- sort of the volume of products we have by any kind
21

of, you know, development centric physical measurement would

22

 be, you know, vastly greater than 11i.
Godwin 01-20-04

00108

1

  

So I don't know if you have a more precise way you

2

 wanted me to answer that, but I -- that's -- that's a fire
3

 hydrant of new functionality.
4

   So you can decide how you want to drink from it.
5

   Q. Well put.
6

   To what extent is the fire hydrant of new
7

 functionality driven by the demands of customers attempting to
8

 meet customer needs?
9

   A. Well, most of it is trying to meet customer needs.
10

   I mean, that's -- we're trying to satisfy
11

customers. That's why we're in business. They'll do things

12

 they want.
13

   Q. And to what extent is any of this fire hydrant of
14

 new functionality, as you put it, driven by attempting to meet
15

 functional improvements that other companies that Oracle
16

 competes against have - have rolled out?
17

   MR. ROSS: Objection. Vague and ambiguous.
18

   You can answer.
19

   THE WITNESS: I -- are you looking for -- I mean, I
20

 don't know that I can -- there's no -- I can't give you a
21

precise or a meaningful metric to say what proportion of things

22

 are to meet competitive requirements versus what things are
Godwin 01-20-04

00109

1

requested specifically by customers, because there's not a

2

 metric I could use to give you a meaningful answer.
3

 BY MR. GAUL:
4

   Q. Well, let's - let's - let's maybe establish a
5

 base line.
6

   Does Oracle add functionality to meet competitive
7

 requirements?
8

   A. Yes.
9

   I think there are occasions when -- clearly there
10

 are occasions when we do that.
11

  

Like I say, I'm -- yes.

12

   Q. And is monitoring new functionality and
13

 improvements by Oracle's competitors one of your job elements?
14

   A. Not in the -- I mean, in the technology area
15

 specifically I'm aware of -- you know, I try to keep aware of
16

 things that are -- sort of the analogous things -- issues that
17

 I worry about I try to keep aware of the -- those -- how those
18

 issues are being handled by our competitors.
19

   It's less a feature function type of battle in my
20

 issue -- in my area, because mine is more kind of general, it
21

 applies to everything, set of concerns, and - and so, you
22

 know, it's just a -- that's just what I deal with.
Godwin 01-20-04

00110

1

  

Q. The folks who do deal with futures and functions --

2

   A. Uh-huh.
3

   Q. -- to your knowledge do they monitor what the
4

 competitors are doing with features and functions?
5

   A. To some degree.
6

   Q. And does Oracle ever add Features and functions
7

 because a competitor has added a feature or function that
8

 appears to be valuable to customers?
9

   A. Yeah, I'm sure that happens.
10

   Q. To your knowledge has Oracle ever added a feature
11

or function because PeopleSoft had it?

12

   A. I'm sure that's happened.
13

   Q. Can you think of any examples where Oracle has
14

 responded to something PeopleSoft has added?
15

   A. You know, I'm not close enough -- here's the reason
16

 I can't really give you an answer on that.
17

   I'm not close enough to the product planning
18

 activities in these other areas to know if the like main or
19

 only reason that they added something was because PeopleSoft
20

 did it.
21

  

They may have also had customer requests to do it.

22

   And so I just -- I'm not enough in their chain of
Godwin 01-20-04

00111

1

 inputs to know like did we build this feature just, you know,
2

just because PeopleSoft had it did we build this feature,

3

 because like our biggest customer asked for it also.
4

   I mean, I'm not in that loop on that. I don't have
5

 the big picture.
6

   Q. Well, in an area of your responsibility, web
7

 enabling --
8

   A. Uh-huh.
9

   Q. - did PeopleSoft have a browser based client prior
10

 to Oracle?
11

   A. No. We had it before PeopleSoft.
12

   Q. Did PeopleSoft have HTML rendering prior to
13

Oracle's HTML rendering?

14

   A. No. We had it before PeopleSoft.
15

   Q. To what extent, if at all, is it your perception
16

 that PeopleSoft added that functionality in response to Oracle
17

 having added it?
18

   MR. ROSS: Objection. Lacks foundation.
19

   THE WITNESS: I have no idea what - why PeopleSoft
20

 - I mean, you got to ask PeopleSoft.
21

   I really don't know why --
22

 BY MR. GAUL:
Godwin 01-20-04

00112

18

  

Q. Okay--

19

   A. -- they've done what they've done.
Godwin 01-20-04

00125

3

  

Based on your general understanding of the industry

4

 and business applications --
5

   A. Yeah.
6

   Q. - segment that Oracle is in, do you believe that
7

 today Oracle's, as you phrased it, mature HR application is
8

 functionally equivalent for most needs to that offered by
9

 PeopleSoft?
10

   MR. ROSS: Again, lacks foundation.
11

   THE WITNESS: I--I have-I have a perception
12

 that we are -- that for some requirements we are a better fit
13

than PeopleSoft and for other requirements we might be less of

14

 a good fit than PeopleSoft and that it - there's not a general
15

 sense that we're, you know, behind in everything.
16

   I mean, it's now - there is a situation where, you
17

 know, for certain purposes ours is a better fit and for other
18

 purposes theirs may be a better fit.
19

   So it's -- it's more a -- you know, fit to
20

 requirements discussion in individual situations now, is my
21

 general sense.
22

 BY MR. GAUL:
Godwin 01-20-04

00126

1

  

Q. And is it correct that individual customers have

2

 differing needs and that the vendor's fit may be different for
3

 customers with different needs?
4

   A. Yes, certainly.
5

   Q. And based on your experience with customers is it
6

 fair to say that each customer is to some extent unique in what
7

 their needs are?
8

   A. Yes, customers' needs will vary based on a whole
9

 variety of things.
10

   Q. Such as?
11

   A. Their business -- their business practice -- well,
12

first off, what they intend -- what the project is that they

13

 intend to do.
14

   A -- customers try - or, you know, have -- the
15

 project for which they're buying the software will have a
16

certain scope in their organization, and that will determine a

17

 great deal of what the fit is.
18

   The -- there are a number off -- I mean, any -- the
19

 business practice decisions, the business policies they're
20

 trying to implement, the business processes they've defined,
21

 you know, just any -- any number of factors will cause customer
22

 requirements to vary.
Godwin 01-20-04

00127

1

  

It's not really even a -- I mean, there's not even

2

 a clear taxonomy to even frame all the ways in which customer
3

 things may vary.
4

   Q. Almost infinitely variable?
5

   A. Yeah.
Godwin 01-20-04

00128

13

  

Q. What are the advantages to a customer of getting a

14

 system that has configuration options, whether built in during
15

 development or partly preconfigured, as you just described?
16

   A. Well, we--are focused on trying to make --I'm
17

 not -- I'm not sure you're -- you're saying what's the benefit
18

 of getting something that's configured or configurable.
19

   That's two different questions.
20

   Q. Well, that's a good question you just asked.
21

   How about configurable?
22

   A. Okay. Okay.
Godwin 01-20-04

00129

1

  

We try to build a system to be highly configurable,

2

 because we only have one product, and it needs to meet a really
3

 wide variety of customer requirements out there in the world
4

   And so we try to make the system as configurable as
5

 possible without - without having people have to go in and
6

 invasively modify the code that we shipped to get it to work
7

 for their business.
8

   And so we put a lot of effort in to building
9

 capabilities that will let the customer set it up to get it to
10

 work how they want it, without having to either ourselves build
11

different products for all sorts of different needs or

12

 requiring the customer to go in and do like brain surgery on
13

 the product that we shipped to get it to work the way they
14

 want.
15

   We want them to be able to have a good experience
16

 using standard techniques for configuring the product to make
17

 it work the way they want without having to have a high level
18

 of expense.
19

  

Q. And the--among the types of brain surgery, as you

20

 called it, that a customer might wish to avoid by having a
21

 highly configurable product, would that include avoiding having
22

 to do actual programming in the code on the product?
Godwin 01-20-04

00130

1

  

A. Right.

2

   Making one distinction, many people will need to --
3

 will want to build some extension to the product which captures
4

 information about something that we don't track that's just not
5

 covered in our applications at all.
6

   But what we're trying to help them avoid, the key
7

 cost issue to help them avoid, is modifying the actual code
8

 that we shipped, because then when we ship an update to that,
9

 then they have to go reapply their customization to the new
10

 version, and that's the cycle that causes them to have just a
11

-- you know, ongoing set of costs, which is --

12

   So one of the keys to keeping the costs low for
13

 customers is to give them a system where these configuration
14

 choices don't involve the kind of code change. They get it to
15

 work the way they want.
16

   And then when we release an updated version of the
17

 code, it just works with their configuration information, so
18

 they don't have development expenses associated with consuming
19

 that update.
20

  

That's what we're really trying to do for people.

21

   Q. A term that you just used a moment ago was
22

 "customization."
Godwin 01-20-04

00131

1

  

A. Yeah.

2

   Q. Could you give me a sense as to how customization
3

 by a client is different from simply implementing a
4

 configuration?
5

   A. Yeah. I'll try and make a distinction.
6

   There's three different words I'm using with a
7

 precise meaning.
8

   One is when I say "configuration" or "tailoring,"
9

 what I mean is defining values in data that are typically
10

 stored in the database, occasionally stored in files, but most
11

typically stored in the database that indicate how the software

12

 should behave for their business practice.
13

   "Extension" means building additional functionality
14

 that we didn't supply using the same techniques that we used to
15

 build the application and the same tools, and so it all kind of
16

 works as if we'd built it, but they car build something in
17

 addition to what we build.
18

   That's okay, too, from a cost perspective, because
19

 when we change or update the software that we delivered, then
20

 their customization -- their extensions aren't hurt. They
21

still work. So that's not a high cost problem.

22

   The third piece, "customization," would be a case
Godwin 01-20-04

00132

1

where somebody actually takes some of the code that we

2

 delivered and, you know, brings up -- brings it up in a
3

 development environment just like our developers do and they
4

 change it to work a different way.
5

   And the problem with that is that when we ship an
6

 update, they don't - they have to go through that process
7

 again with the updated version and essentially merge their
8

 changes in with our changes and figure out how to get the new
9

 thing we delivered to work their way, which is just a gift that
10

keeps on giving.

11

   You keep having to take that expense over and over.
12

 And that's why we generally try to guide people away from doing
13

 that and try to build as much configurability in to the system
14

 as possible so that people don't have to do that.
Godwin 01-20-04

00156

21

  

Q. One other related aspect of the commons components

22

 that I just want to touch on very briefly is reuse of code and
Godwin 01-20-04

00157

1

reuse of programming objects in your Oracle applications suite.

2

   A. Uh-huh.
3

   Q. I believe you very briefly mentioned earlier this
4

 morning that there is some calling to code modules across the
5

 application suite; is that correct?
6

   A. Certainly.
7

   Q. Could you describe what he purpose of that is?
8

   A. The purpose is so that you implement functionality
9

in one place and get consistent behavior and lower development

10

 expense by having all of the different use cases of a
11

 particular bit of functionality reference the same actual
12

 implementation of that functionality.
Godwin 01-20-04

00158

3

  

Q. Okay. Well, let me break it down a little bit

4

   Is presence of code reuse -
5

   A. Yes.
6

   Q. -- a desirable feature from the customer's
7

 perspective?
10

   THE WITNESS: It - from the customer's
11

 perspective.
12

   That is actually a - matter of opinion.
13

 Different people will give you different opinions on that
14

BY MR. GAUL:

15

   Q. What is - well, strike that.
16

   Is there a consistent opinion on that issue at
17

 Oracle?
20

   THE WITNESS: I -- well, our -- with respect to our
21

 applications, we assert in the market that it is desirable to
22

 have an integrated set of applications as opposed to obtaining
Godwin 01-20-04

00159

1

an integrating functionality from a lot of different sources.

2

   And we assert a set of benefits that -- the reason
3

 I was hedging on your earlier question is that there are other
4

 people in the market who will assert that you can achieve
5

 whatever benefits we're asserting are achievable with less
6

 code reuse.
7

   So there's not a -- there's an argument in the
8

 market to some degree or arguments -- there are arguments that
9

 different people have about the extent to which a given benefit
10

 comes from code reuse.
12

  

Q. Why has Oracle adopted the marketing position that

13

 it is desirable to have an integrated let of applications?
14

   A. Because the -- it's less from the code reuse
15

 perspective.
16

   It is because having the data together that --
17

 bringing your data together across different functional areas
18

 lets you answer more efficiently business questions that
19

 involve data that may have come from different areas.
20

   And to the extent to which you implement a wider
21

 set of functionality in a -- in an integrated environment,
22

 where all the data is in one place and was all designed to be
Godwin 01-20-04

00160

1

-- to fit together and reference each other correctly, let's

2

 you more easily get business value out of -- out of that
3

 information.
4

   So we assert that that's an extremely important
5

 benefit.
Godwin 01-20-04

00169

22

   Q. Now, with that understanding, the -- is it correct
Godwin 01-20-04

00170

1

that the E-business Suite applications that are marketed by

2

 Oracle at present rely on and require the Oracle database
3

 running underneath them?
4

   A. Yes, it is.
Godwin 01-20-04

00174

3

  

Now, there are, of course, a number of different

4

 database products that are sold by different companies other
5

 than Oracle; is that correct?
6

   A. Unfortunately.
7

   Q. For example, Microsoft Sequel Server?
8

   A. Yes.
9

   Q. For example, IBM's DB2?
10

   A. Uh-huh.
11

   Q. For example, Cybase?
12

   A. (Nodding head)
13

  

Q. Does Oracle support any relationship database

14

 product underneath its business apps other than Oracle's own
15

 database products?
16

   A. No.
Godwin 01-20-04

00176

2

  

Q. Are you familiar with the term "global single

3

 instance"?
4

   A. Yes.
5

   Q. What does that mean to you?
6

   A. "Global single instance" is a - sort of shorthand
7

 for the idea of deploying all our -- or for deploying
8

 applications - deploying the E-business Suite in a single
9

 implementation with a single database and single installation
10

 of the E-business Suite, and running your entire operation on
11

 that in terms of recommending both that you use a broad range
12

 of our functionality and that you not implement separately
13

instances of the Oracle applications in different parts of the

14

 world to support individual countries or something like that,
15

 which, instead, that you would actually bring all your data
16

 together in one place.
17

   So global single instance is the vision of keeping
18

 all your data together in one place.
19

   Q. Using the example that you just gave -
20

   A. Uh-huh.
21

   Q. -- of not having separate databases in separate
22

 countries --
Godwin 01-20-04

00177

1

  

A. Uh-huh.

2

   Q. -- what, if any, benefit does a customer achieve by
3

 having that?
4

   A. Same that I described earlier, in terms of keeping
5

 your data together, so you can answer business questions,
6

 because your - ability to get information out of the system is
7

 -- the relevance of the information you can get out of the
8

 system or the importance of it goes up as you -- as the scope
9

 of that information broadens.
10

  

So if I can get an answer that is -- gives me my,

11

 you know, sales forecast for the entire world all at once
12

 without having to collect that information and integrate it
13

 from 30 different sources, then that -- I can make better
14

 business decisions than if I have the fragmented information.
Godwin 01-20-04

00179

4

  

Is it correct that Oracle 11i does support multiple

5

 languages?
6

   A. Yes.
7

   Q. And by "support of multiple languages" I take it
8

 that means something more than simply has access to different
9

 character sets for different types of languages; is that fair?
10

   A. Yes.
11

   Q. What is required in database access and database
12

 interaction for a product such as Oracle 11i to truly support
13

 multiple languages?
14

  

A. To support particular combinations of languages

15

 that somebody might want to run, you would need to support the
16

 uni-code character set in particular.
17

   That's a -- that's one of the more advanced
18

 features of multi-lingual support.
19

   And so it's not sufficient to Support the
20

 straightforward Western European -- it's not sufficient to
21

 support the Western European character set.
22

   If you're trying to run, say, German and Japanese
Godwin 01-20-04

00180

1

in the same database, you actually have to support a character

2

 set that contains all the Japanese characters and all the
3

 Western European characters, which means there's a superset
4

 called Unicode that does that. So our applications support
5

 that.
Godwin 01-20-04

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9

  

Q. Is it correct that Oracle's multiple language

10

 support permits users that are using different languages to
11

 access and modify the same corporate data?
12

   A. Yes.
13

   Q. Are you aware of how many different languages
14

 Oracle supports?
15

   A. I believe we currently support 30.
16

   Q. And why is it that Oracle supports that many
17

 languages?
18

  

A. Well, it's an investment decision.

19

   We have requirements and requests from customers to
20

 support languages, and it costs a certain amount of money to
21

 perform each of these translations.
22

   And so we -- there's no initial technical costs
Godwin 01-20-04

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1

associated with supporting the first language.

2

   It's a question whether it's a good investment to
3

 translate the software, and the -- and to some - whatever the
4

 degree the documentation in all the languages.
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12

  

Q. Is there a set of users that have a need for

13

 support in multiple languages?
14

   A. Well, typically -- I mean, here are -- there are
15

 customers who need -- who choose to implement support in
16

 multiple languages.
17

   I'm just -- I don't have a -- I don't think there's
18

 a clean taxonomy that explains -- correlates that with some
19

 other attributes about the customers
20

   I mean, it's just that there's some people that
21

 choose to do that and there's some who don't.
22

   But clearly customers who only operate in one
Godwin 01-20-04

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1

country and only have use for one language don't have the

2

 requirement.
3

   There are many other customers, and some of them
4

 choose to actually implement multiple languages, and others
5

 choose to not implement in all the languages where they're --
6

 where they do business.
7

   Q. In your experience I take it you have run across
8

 customers that, for example, are multi-national corporations
9

 that have a need for language localization in multiple
10

 languages?
11

  

A. Yeah. Actually, multi-national corporations--I

12

 have found there are multi-national corporations who decide to
13

 run in multiple languages, yes.
Godwin 01-20-04

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19

  

Q. Let me turn to a - another topic, which is perhaps

20

 related to sets of books, which is multiple organizations.
21

   Does Oracle 11i support a customer that needs to
22

 separately track and report multiple organizations within the
Godwin 01-20-04

00203
1

 overall customer?
2

   A. Yes.
17

  

Q. Mr. Godwin, you've been handed a document that has

18

 been marked as Exhibit 10, and I will represent that this is a
19

 document that was recently downloaded from Oracle's website as
20

 a PDF file --
21

   A. Uh-huh.
22

   Q. -- and, in fact, is one of the documents that I
Godwin 01-20-04

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1

believe we saw earlier this morning listed on an earlier

2

 exhibit that indexed the documents that were available to
3

 support 11i.
4

   This document is entitled "Multiples Organizations
5

 in Oracle Applications Release 11i," and is dated March 2002.
6

   A. Uh-huh.
7

   Q. This morning I believe I asked you about this
8

 document title and you indicated your organization did not
9

 prepare this document; is that correct?
10

   A.