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Government Exhibit P3036 [Non-designated testimony redacted]

00005
 
 
 
 
 
6    Q. Would you, please, state your full
7 name for the record and your business address.
8    A. Yes. Richard Allen, A-L-L-E-N,
9 Knowles. Business address: I'm housed out of Atlanta,
10 Georgia, 555 Glenridge Connector, Suite 900, Atlanta,
11 Georgia 30328.
 
 
 
 
 
 
 
 
 
 
 
 
 
 

00015
 
 
3    Q. Do you know generally how long SAP
4 has had a presence in the United States in terms of a
5 subsidiary here?
6    A. Out of the 31 or so years that SAP AG
7 has been in existence, to the best of my recollection,
8 SAP America has been doing business in the United States
9 since the late 80s, mid to late '80s.
10    Q. And why is it that SAP AG has decided
11 to develop regional headquarters throughout the world?
12    A. I think it fundamentally goes to
13 strategy. Most customers want to do business with a
14 local entity, and they want to have local people that
15 they deal with. So in order to reach our customers the
16 best, it made sense to have a local presence and to
17 have a local infrastructure versus just being running
18 the operation out of Walldorf. So basically for
19 customer acquisition reasons and to build up a local
20 force to show that we are invested and have a
21 significant presence within the local country, which is
22 the U.S. and Canada.
23    Q. And in terms of SAP America, what's
24 the infrastructure that's been established here?
25    A. Infrastructure that's been established

00016
1 primarily is: We have regional headquarters building,
2 which is this campus that you're in today. We have
3 regional offices out, scattered throughout the United
4 States, which I cannot name them all, but they are in
5 certain cities. The acquisition of an employee base
6 northwards of 4,000 plus employees comprised of sales
7 staff, support, marketing, sales; a good chunk of
8 consulating, our own consultants. That's what I mean
9 by infrastructure. We of course have the back-office
10 function, we have our own finance team here, our own
11 marketing team, etcetera.
 
 
 
 
 
 
 
 
 
 
 
 
 
 

00024
 
 
 
 
 
 
 
 
 
 
 
 
 
 
15    Q. And the fourth area of revenue that
16 you identified was the consulting organization. Could
17 you explain that.
18    A. Yes. Consulting, our consulting
19 organization is a service offering that we provide to
20 our clients. Typically in the implementation of
21 enterprise application software, it requires more
22 consultants to support the implementation of these
23 changes inside of a company than even we're capable of
24 delivering. We do have a small, relatively small
25 consulting organization in terms of what the customer

00025
1 needs. We maybe support anywhere from 10 to sometimes
2 20 percent of the implementation services needed to
3 install the software.
4          Our consultants are typically viewed
5 as functional experts on our software, and they assist
6 the client in implementing the software inside the
7 company. In addition, there's multiple partners that
8 are typically involved in the implementation. Those
9 companies are some of the bigger names that you may
10 have heard of such as Accenture, Deloitte Consulting,
11 Cap Gemini, etcetera. In general, we support the
12 implementation, not all of it, though.
13    Q. So that the consulting organization
14 is responsible for assisting in implementations;
15 correct?
16    A. Correct.
17    Q. However, in these implementations
18 SAP's role is limited to about 10 to 20 percent of the
19 implementation; is that right?
20    A. Yes; on average. There are occasions
21 where a client will not want to use an outside firm or
22 a partner firm. They'll want us to handle the full
23 implementation. That's a rare case. It does happen.
24 But on average, if you were to say, could we handle a
25 hundred percent of the consulting needed to implement

00026
1 our software? The answer is, absolutely not, we cannot
2 do it alone, we rely on our partners.
3    Q. Why is it you cannot do it alone?
4    A. Primarily it's a business model
5 question. And the reason why is we are not a services
6 company. We make our revenues and our profit margins
7 are derived primarily from the sale of enterprise
8 application software, not delivery of services. So it
9 is a service but it is not our primary business model,
10 and that's why.
11    Q. In speaking of implementations, given
12 that SAP has a limited role in these implementations
13 typically, is it left to the customer to negotiate with
14 a company to implement SAP software or does SAP partner
15 with an implementer?
16    A. Typically the customer negotiates
17 their implementation fees and services with the partner
18 firm. That is something that we are excluded from.
19 They may want to get some of our consultants on the
20 project, and that is a specific negotiation with SAP.
21 But if they want to deal with IBM or Accenture, they
22 are dealing with IBM and Accenture separately from us.
23    Q. Does SAP play any role in negotiating
24 those implementation contracts with a client?
25    A. No.

00033
 
 
3    Q. So you mentioned that all of the
4 clients have kind of a different way of approaching
5 things, and that requires consultants to come in and
6 kind of help explain how SAP software will work; is
7 that correct?
8    A. In their environment to support their
9 business processes.
10    Q. Now, in this process, are they
11 converting to, I mean, are they maintaining their
12 differences, in other words, is the software they are
13 implementing the same whether it is a national company
14 or multinational company, subsidiaries, all the
15 different examples you used?
16    A. Without explaining the way our
17 systems are coded, because that's not my area of
18 expertise, at the core, yes; the software is similar
19 and the same. However, the way you configure our
20 systems to operate in a single site customer versus a
21 national versus a multinational conglomerate is
22 different. So it is similar but it can be different
23 based on configuration and what the needs of the client
24 are.
25    Q. So between those three types of

00034
1 organizations, you have differences in how it is
2 configured. How about looking at multinational
3 corporations just as a group, do they have different
4 configurations depending on how they run their
5 business?
6    A. Yes, they do. One of the caveats to
7 make it different is which vertical industry are they
8 operating in? For instance, a multinational or a
9 conglomerate. A multinational conglomerate that's in
10 the retail space typically runs their systems quite a
11 bit different than a discrete manufacturing in high
12 tech. So, yes, the systems have -- at the core the
13 code may be similar or close to the same, but the way
14 they actually use the system is quite a bit different;
15 and that means their configurations are going to be
16 substantially different.
 
 
 
 
 
 
 
 
 

00041
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
24    Q. So you think of these as separate
25 categories of product, you have the my SAP Business

00042
1 Suite as one category, my SAP All-In-One is another
2 category, and then mySAP One is a separate category; is
3 that correct?
4    A. Yes, sure.
5    Q. What is mySAP All-In-One?
6    A. Okay. All-In-One and Business One
7 are products that we've positioned in the market or the
8 way that we're going to market are really designed for
9 what we would consider our channels segment. And what
10 I mean by channels is companies that have revenues of
11 approximately 200 million and below in annual revenues,
12 we sell our solutions through a re-seller channel. And
13 the products that really fall into that space that they
14 can sell, they can try to sell mySAP ERP or Business
15 Suite, but that's a very substantiate sell to a hundred
16 fifty million dollar company.
17          So over the last two years we have
18 developed a smaller solution that's targeted for that
19 segment of companies. And those products are referred
20 to as All-In-One or Business One. So those are
21 products that are designed and targeted for that, the
22 companies of that size.
23    Q. Now, you mentioned these two products,
24 mySAP All-In-One and Business One, these were developed
25 in the last two years; is that right?

00043
1    A. We -- SAP acquired a company, and I
2 don't remember the date, several years back, and they
3 have expanded on the functionality, added some English
4 language and other languages to it in order to tailor
5 this solution to meet the needs of a smaller enterprise,
6 a smaller company, of the 200 million revenue smaller
7 type companies.
8          From a functional standpoint, it can
9 satisfy some of the same things that a large enterprise
10 company might buy; for instance, financials, human
11 capital, management or human resources, etcetera, but
12 it is targeted for a smaller company.
13    Q. Now, these two products, mySAP
14 All-In-One and Business One, are they two separate
15 products or are they the same code?
16    A. Cannot technically answer that
17 question at the code level.
18    Q. Is it your understanding it is the
19 same product but just with two different names?
20    A. They are designed to meet different
21 needs of the client. So I would, logic says they are
22 different because we're using them in and targeting
23 them differently. Do they share code? I'm sure they
24 share code. What is the level? I do not know.
25

00044
 
   
3    Q. And then I believe you just said that
4 they are designed to perform different functions?
5 Could you explain to me, what is mySAP All-In-One
6 designed to do?
7    A. Without having the list in front of
8 me, I can't even -- at a high level I can tell you it's
9 going to be similar to my other answers, but without
10 having the specifics in front of me, I'm not going to
11 be able to answer the question to your satisfaction,
12 probably.
13    Q. Maybe it's easier to look at it this
14 way. What do you understand the difference to be
15 between the two products?
16    A. One is really to be, from a positioning
17 standpoint, the way at least we're positioning it in
18 our go-to-market plans, where one is for a single
19 entity or a small entity that's under 200 million
20 dollars in revenues, to be able to use the product
21 within their enterprises is one thing. Whereas, we
22 take Business One, it has the ability to actually scale
23 up. And one of the thoughts from a positioning
24 standpoint is for these larger companies that we do
25 business with today, often times we do not have

00045
1 software located in a lot of their subsidiaries.
2          And one of the thoughts is to be able
3 to use the scaled-up version of Business One, actually
4 use it in some of the subsidiaries. So if we had to
5 segment where the products could fall, we could
6 actually say, we could take that product a little bit
7 up market, maybe even up to a 500 million dollar size
8 company, whereas the other product is really more for a
9 very small entity, and what we categorically call small
10 entity being under 200 million dollars.
11    Q. Just so I'm clear, mySAP All-In-One
12 is really limited to this 200 million dollar and below
13 company; correct?
14    A. Correct.
15    Q. And the Business One product currently
16 is, the go-to-the-market plan for this is limited for
17 this 200 million dollar company; correct?
18    A. Right. We've not made a determination,
19 but we have looked at trying to position out how we use
20 that with our direct sales force to actually target a
21 lot of subsidiaries of the larger company subsidiaries.
22    Q. The option in the future is to take
23 this Business One product and market it to subsidiaries
24 of companies that are already using the mySAP Business
25 Suite?

00046
1    A. Right. That might be using a component
2 in their headquarters operation, but yet maybe their
3 local subsidiary has a unique targeted need, and we've
4 not been able to satisfy, that maybe use this because
5 it's a lower price point and a lot less functionality;
6 and maybe a subsidiary might be primed to use that.
7    Q. Now, you mentioned you use your
8 channel partners to resell these products, mySAP
9 All-In-One and the Business One. And if they can, they
10 are free to also market the mySAP Business Suite to
11 these companies as well; is that right?
12    A. Correct.
13    Q. You mentioned that's a pretty
14 substantial sell. Could you explain, what's the
15 challenge in selling this Business Suite to these
16 smaller companies?
17    A. The needs of a 100 million dollar
18 company for maybe their supply chain for a small
19 manufacturer makes about a hundred million dollars in
20 revenue versus the needs of like a multinational
21 conglomerate manufacturing operation. Their needs are
22 going to be substantially different. To say we would
23 like to take mySAP Business Suite and sell it to a
24 hundred million dollar company, the price tag and the
25 processes -- it would be overkill to sell to it them.

00047
1 They would have more functionality. They would be able
2 to maybe grow into a billion dollar company and not buy
3 another piece of software in their life.
4          The problem is, they wouldn't be able
5 to afford it. Too much functionality for a hundred
6 million dollar company. That's the problem. One of
7 our attempts is to, in order to meet the needs of the
8 lower end of the market, 200 million dollar companies
9 and below, we needed a product that was not as rich in
10 features, as rich in functionality, as big a scale that
11 we have developed with our Business Suite and be able
12 to target it more to specific applications in a much
13 smaller way. So that's why we came up with this
14 product line. That's why we procured the company and
15 have gone to market with these guys.
16    Q. So these companies, these 200 million
17 dollar and below companies, their needs are simpler
18 than, say, customers that are using this Suite. My
19 understanding is there's just too much functionality
20 within the Business Suite for them to be able to use
21 it?
22    A. To benefit from, correct.
 
 
 

00048
1    Q. Is the mySAP All-In-One product and
2 the Business One product priced differently than the
3 mySAP Business Suite?
4    A. It's priced similar in the way that
5 we price it but the price point is different because
6 there's less functionality, so you don't have to
7 charge, we do not need to charge as much; but the
8 pricing licensing model is the same.
9    Q. And so that the prices between these
10 three products really depends on the functionality of
11 the product?
12    A. That's being delivered, correct.
13    Q. Now, you had mentioned, you've got
14 this line at 200 million dollars and below for a
15 Business One and mySAP All-In-One. Why not sell these
16 two products to companies above 200 million dollars?
17    A. As I said before, we were considering
18 taking one of the products up market to, say, 500
19 million, 750 million, and allowing our direct sales
20 force to do that. That's still under consideration,
21 still is a possibility.
22          I think your question is a good
23 question except that the premise of your question is a
24 little bit wrong. And the way we look at it is, we
25 have not historically played very well, meaning, we've

00049
1 not gotten enough penetration. We're not satisfied
2 with the business results in the 200 million dollar and
3 below market, and we want to grow that business.
4          In order to grow that business, we
5 had to develop a much, you know, I'll use the simpler
6 term, a lighter solution offering for that space for us
7 to get some traction in that space. That's why we did
8 it. We're not looking at it the other way, the way
9 your question was phrased. And let me tell you why.
10          The reason why is because we know
11 that in the near future we're going to have a pretty
12 incredible competitive threat that's going to start
13 encroaching on that space and growing up market. And
14 we're doing this as a move to hopefully try to prepare
15 for an ensuing battle in that space. And that space
16 is - and who I'm speaking of is Microsoft. We view
17 Microsoft as a massive competitive threat.
18          And we totally anticipate, and they
19 have already entered this space through their
20 acquisition of Navision and Great Plains. And their
21 penetration rate right now based on our business
22 analysis is greater and better than ours. They have a
23 better distribution channel than ours. They have wider
24 reach, and they have really two very good products and
25 channels that already existed that they acquired. They

00050
1 are in a much better position than we are. They are
2 growing up market. We know from a business standpoint
3 we have to go down market in order to prepare for the
4 battle.
5    Q. And this battle -- the battle that
6 you've identified is in this 200 million dollars and
7 below market?
8    A. That's just the beginning. The
9 battle we would term is the mid-market. So we would
10 say anything below 1.5 billion in revenues is really
11 going to be the battle ground of the future. And we,
12 from a business standpoint, everything we do from an
13 analysis standpoint going forward is in preparing for
14 Microsoft to come up market.
15    Q. So Microsoft's threat, just so I
16 understand, Microsoft's threat to SAP is in companies
17 currently in this 200 million dollars and below market;
18 is that correct?
19    A. Predominantly. But they are growing
20 rapidly and we anticipate their arrival up market very
21 quickly. When I say quickly, I mean, in terms of a
22 life cycle within a year or two.
23    Q. When you say up market, that's
24 companies 1.5 billion dollars and below; correct?
25    A. Yes, that is correct.

00051
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
19    Q. Turning back to these mySAP
20 All-In-One and the Business One products. You had
21 mentioned they could potentially, your term is, scale
22 up to 500 million dollars and even 750 million dollar
23 companies; correct?
24    A. Depends on their needs, yes.
25    Q. What's the problem with using those

00052
1 products for customers even beyond that; why not use
2 one of these products to, why not sell one of these
3 products to companies with even greater revenues
4 perhaps?
5    A. Again, it's going to depend on the
6 customer and their needs and their architectural
7 limitations to the way the product is designed. What
8 those technical limitations are from a code standpoint,
9 I can't speak to, but there are limitations, and the
10 number of things it will do or the number of transactions
11 it will process; so it's a functionality limitation.
 
 
 
 
 
 
 
 
 
 
 
 
 
 

00054
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
24    Q. So you have an SAP client -- where
25 are they running SAP? If they are not running it at

00055
1 the subsidiary -- I guess I don't understand why the
2 subsidiary is not running the same thing as, say, the
3 parent company. What is the difference? Why is there
4 that distinction?
5    A. That's a very good question, by the
6 way. If we take a multinational conglomerate who may
7 be organized, they may have multiple companies. The
8 parent company may be running SAP but maybe two of
9 their subsidiaries or three of their subsidiaries they
10 may be running, because they are smaller subsidiaries
11 and they are rolling up to a parent conglomerate, they
12 may be running an older application, the Legacy
13 system. And the price point to solve that need, maybe
14 it's a 300 million dollar company that's rolling up to
15 this conglomerate.
16          For us to go and sell Business Suite
17 down to that 300 million dollar company, maybe we were
18 just not very good at it, maybe price point or their
19 needs were not met with trying to tie them into the
20 Business Suite offering that we did of the conglomerate.
21 So one of our marketing thoughts is that we've really
22 not, we've done really good penetrating some of the
23 bigger names and the bigger companies, but we really
24 haven't focused and been able to go down market fast
25 enough to serve all of the needs of these companies.

00056
1          So why not go to that 300 million
2 dollar company and say, we also have a solution for
3 you. You don't have to think you're operating this
4 bigger system, we actually have a smaller system that
5 you can use and, you know what, we could probably
6 position out how to tie it into the bigger SAP system,
7 too. That's why.
8    Q. Just so I understand, you've got the
9 corporate entity, say, the headquarters, and they are
10 running mySAP ERP; correct?
11    A. Yes, correct.
12    Q. But then underneath that corporate
13 headquarters you have a number of divisions at certain
14 companies; correct?
15    A. Sure.
16    Q. At each of those divisions they may
17 be running different software than, say, what the
18 headquarters is running?
19    A. Correct.
20    Q. So is it a different group of
21 companies that you may have one company at division
22 one, a different company at division two, and then at
23 the headquarters a completely different company,
24 software vendor?
25    A. Absolutely. We term that as a

00057
1 heterogenous environment. Most companies have a
2 heterogenous landscape in place. They do not use one
3 software package often times for everything in all of
4 their entities. We would love for them to do that, by
5 the way, but that is not often the case. So let me
6 give you another example.
7          It is not uncommon for a company, for
8 instance, to say, use SAP for their human resources
9 system in the United States, but yet use PeopleSoft in
10 their European operation, and maybe use Oracle in their
11 Asia-Pacific operation all for human resources. For
12 whatever reason, that is a typical heterogenous
13 decision that that company has made. Now, would we
14 like to have human resources globally for that entity?
15 Absolutely, but that's not normally the case.
 
 
 
 
 
 
 
 
 
 

00059
 
 
 
 
 
 
 
 
 
 
 
 
 
 
15    Q. Sure. I guess the question really
16 is, in marketing to companies above this 200 million
17 dollar threshold, why does SAP have a direct sales
18 force?
19    A. Why do we have a direct sales force?
20 That's an interesting question. The solutions that we
21 sell, if I go back to my supply chain example earlier,
22 it would be somewhat unrealistic to expect a channel
23 partner who is not an employee of our company to be
24 able to walk in and understand the supply chain
25 implications and how our software can help a client

00060
1 without them being a direct employee trained by SAP,
2 representing SAP.
3          Often times channel partners
4 represent multiple lines of business. They sell other
5 products and services. So to anticipate that they
6 could be an expert or even a functional, be able to
7 speak functionally about our solution and what it can
8 do would be unrealistic. So we have no choice to be an
9 direct sales force because what we sell is complicated.
10 This is not shrink-wrap software that you buy at a
11 store, you know, in a retail establishment. So that
12 the only way to correctly understand the business
13 implications is to have a direct sales force.
14    Q. So this expertise about the product
15 is necessary to effectively market the mySAP ERP or
16 mySAP Financials to a potential client?
17    A. Absolutely.
18    Q. And that expertise can't be really
19 duplicated with your channel partners?
20    A. Not at the level of depth that is
21 required to properly understand the business
22 implications and the processes.
 
 
 

00063
 
 
 
 
 
 
 
8          What is the difference, say, between
9 mySAP Human Resources and then the human resources
10 function in these other products Business One or
11 All-In-One?
12    A. Okay. That's a great question. I
13 would need to get you a map, a solution map and
14 actually be able to show that to you. To say I have it
15 memorized, I did not, and I do not have it with me. We
16 would need to look at by solution the differences in
17 functionality. And that is something that internally
18 we use for our own training purposes. For me to
19 articulate it, I would probably be speaking a little
20 bit amiss, and I don't want to be wrong.
21    Q. Let me ask you this, is mySAP Human
22 Resources, can it do more than what the human resources
23 function in the Business One or All-In-One product can
24 do?
25    A. Yes; in general, yes.

00064
1    Q. Do you have any idea of how big a
2 difference there is between the two?
3    A. No. And it would come down to the
4 function, you know. And for me to say, I do not know
5 this, but to say that, you know, the enablement of your
6 eRecruitment capability is existent in my SAP ERP but it
7 is not in Business One, I cannot off the top of my head
8 tell you that difference right now.
9    Q. Does the customer's choice really
10 come down to its requirements, what it wants?
11    A. Yes.
12    Q. The solutions it needs to do?
13    A. Yes. Typically when we work with a
14 client, it's not about what we're trying to sell them.
15 We don't go in and say, here, we have Business One or,
16 here, we have mySAP ERP. Look at everything we do. We
17 do financials, controlling, operations, HR. We don't
18 go in and do that.
19          The approach we take is, we go into
20 the customer and try to work with them on what business
21 process situation are they dealing with or what is it
22 that they are having the most struggles with? And
23 often times it is, well, I have three things that I'm
24 struggling with and we need to fix. We say, great,
25 that's wonderful. What are those three things? What

00065
1 are implications of solving those three things? And
2 then go back and say, do we have a solution? Maybe
3 it's just one piece of mySAP ERP. Might be it is
4 three, it requires three components of my SAP ERP in
5 order to fix their issues. It's more of that
6 collaborative type self versus here's a list of all my
7 features and software modules and here's our price;
8 unfortunately it's not that simple of a sell.
9    Q. Why not, why not simply go in there
10 with your product and say, this is what we have, this
11 is what it does for you?
12    A. Why? Because in each vertical
13 industry each customer in those vertical industries
14 tend to try to differentiate the way they run their
15 business. You know, an example is, why is it that no
16 one else in the world has been able to replicate what
17 Michael Dell has done? Right? He's just got a unique
18 business process, a unique supply chain operation in
19 order to operate PCs, and he gets his cash up front.
20 Why hasn't someone else copied him? Why? Because in
21 his vertical industry he's running his business in a
22 very unique way.
23          Well, to say that I can now say that,
24 you know, Compaq or HP now owns Compaq, they should run
25 their PC business the same way, they both have supply

00066
1 chains, they operate their supply chains differently,
2 they run their businesses around their processes
3 differently. So for us to go in and say, we have
4 supply chain solutions, here's all the features and
5 benefits, would you like to buy it today? That would
6 be a misnomer, because that would mean we would be
7 discounting and trivializing the way they run their
8 business.
9          So it's a competitive advantage for
10 Dell to run his business the way he's done his way,
11 versus Compaq running their business their way using
12 their business processes. So we have to take a very
13 individualistic sales approach in understanding their
14 business issues, their business needs and business
15 process in order to properly propose a solution for
16 them, because we have to support their business their
17 way in their industry; that's why.
18    Q. So it sounds like one of the first
19 things you need to do once you contact a client is to
20 really understand or potential client rather than to
21 really understand how they run their business; is that
22 right?
23    A. Yes.
24    Q. And each business is run slightly
25 different?

00067
1    A. Yes.
2    Q. Now, does that include -- are there
3 differences between, say, how one company does
4 financials and another company does financials?
5    A. At the rudimentary level? No.
6 Everybody has to agree and abide by GAAP. But there's
7 nuances in the way they might account or recognize
8 revenue, the way they might want to run their expenses,
9 run their, configure their cost of goods sold. There
10 are nuances. And it depends on by industry. You know,
11 the way the chemical industry accounts for certain
12 components in their line of business is going to be a
13 little bit different than the way a retail manufacturer
14 runs their business.
15    Q. Now, within those -- you mentioned
16 broad industry differences. Going back to the example
17 you mentioned earlier, Dell and Compaq, might their be
18 differences between how each of those companies report
19 their financials that is important to SAP?
20    A. Sure, could be. For instance,
21 Dell -- I'm not speaking as an expert on Dell, just
22 know that up front, people -- but for Dell, they may
23 procure all of their parts from out-source vendors,
24 whereas Compaq who now that HP owns them may actually
25 still manufacture a lot of their components. So the

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1 way they are going to account for their in-process
2 manufacturing of raw components to go into their
3 product is going to be quite a bit different than the
4 way Michael Dell is going to have to account for using
5 a sourcing model. They have to roll-up numbers. The
6 way they do it is going to be different and the
7 process, the way they do it, is going to be different,
8 and these differences between not just industries but
9 between companies.
10    Q. Those differences have implications
11 on the software you provide them?
12    A. Oh, absolutely. Again, that comes
13 down to maybe the same solution financials,
14 hypothetically, but the way we configure it to work and
15 configure the processes and the transactions to flow
16 are going to be different.
17    Q. In terms of mySAP Human Resources, we
18 started this discussion on them.
19    A. That's fine.
20    Q. You've had these discussions with a
21 potential client to try to understand how their
22 business works and what are their problem areas;
23 correct?
24    A. Okay.
25    Q. From there you mentioned you have to

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1 configure it differently. What does that configuration,
2 just using Human Resources as an example, what does
3 that entail, what do you need to do?
4    A. That's a technical question. So at
5 the code level and how you actually implement it, that
6 is not my level of expertise. I would probably be
7 misspeaking if I tried to answer it correctly. I would
8 say that's a technical question for a technical
9 expert.
10    Q. But those are important questions to
11 understand if you're going to sell software solution to
12 a company?
13    A. To meet the needs of that client,
14 that specific client, yes. At a high level I can give
15 you an example though for human resources. Part of our
16 human resources is employee self-service. And this is
17 with all the privacy laws that are beginning to take
18 place, employees need to have the ability to update
19 their information, their address, their personal
20 information, things like that.
21          Human resources and a lot of the
22 privacy laws are saying that employees should be able
23 to modify his or her information themselves without
24 having to go to someone in the company or HR, because
25 that's private, that's confidential information, the

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