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3	VIDEOGRAPHER: The Court Reporter today is
4	Dawn M. Hart of LegaLink San Francisco. I will now
5	swear in the witness.
6	Thereupon ---
7	WILLIAM POLLIE
8	having been duly sworn, testified as follows:
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11	Q Good morning, Mr. Pollie.
12	A Good morning, Mr. Yates.
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18	Q And when you left Integral Systems in
19	approximately '91 or '92 where did you go?
20	A I went to a company called SAP.
21	Q And for how long were you with SAP?
22	A Through September 2001.
23	Q And what positions did you hold at SAP?
24	A Variety of positions in product management,
25	direct sales, global sales, strategic account

00014
1	management, and management positions; Vice-President
2	of Field Operations for SAP.
3	Q Your last position was Vice President of
4	Field Operations for SAP?
5	A Yes.
6	Q And what did you do as the Vice President of
7	Field Operations for SAP?
8	A I ran a particular industry sector for SAP
9	in the field and operation which had consulting,
10	presales, sales targeted at an industry sector that we
11	were growing.
12	Q And what sector was that?
13	A Financial services and insurance, brokerage.
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16	Q So in approximately September of 2001 SAP
17	did not have a fully developed CRM product; is that
18	your understanding?
19	A It was fairly new, yes.
20	Q And what about today, do you have an
21	understanding of SAP's CRM product offering today?
22	A Not in detail, no.
23	Q And you left SAP in approximately September
24	of 2001?
25	A Yes.

00016
1	Q And who did you join?
2	A Microsoft Business Solutions-Great Plains.
3	At the time it was called Microsoft Great Plains
4	Business Solutions.
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17	Q Sure. At or about the time you joined
18	Microsoft Business Solutions, did Microsoft Business
19	Solutions have a direct sales force?
20	A Not to my understanding, no.
21	Q What kind of sales force did it have?
22	A All of Microsoft Business Solutions
23	activities were delivered through a partner
24	organization.
25	Q But your title was U.S. Sale -- Vice

00019
1	President of U.S. Sales?
2	A Yes.
3	Q What were your duties and responsibilities
4	in or about September of 2001?
5	A To manage a, a group of Microsoft employees
6	that assisted our partners in providing software
7	services and product to, to customers.
8	Q And how would the Microsoft salespeople
9	assist the partners in that role?
10	A In a variety of ways, by providing them
11	assistance in pricing data and by providing them
12	assistance in access to Microsoft resources that might
13	provide them detailed product information that they
14	needed, to help them monitor and control their
15	pipeline and activities, to assist them in sales
16	techniques, sales training, product training.
17	Q So is it fair to say that the partners acted
18	as an extension of the Microsoft sales force?
19	A I think it's safe to say that the Microsoft
20	partners were the sales force and were not necessarily
21	an extension of, but the sales force for Microsoft
22	Business Solutions.
23	Q Did you meet with customers of Microsoft
24	Business Solutions in or about September of 2001?
25	A Yes.

00020
1	Q And did salespeople at Microsoft Business
2	Solutions working under you meet with customers in
3	approximately September of 2001?
4	A Microsoft Business Solution employees met
5	with customers. They weren't necessarily called
6	salespeople. They're called partner account managers,
7	they're called business development managers. So from
8	a clarification point of view, yes, my staff did meet
9	with customers, but they were not called salespeople.
10	Q And what position do you hold with Microsoft
11	Business Solutions today?
12	A I'm a General Manager within Microsoft
13	working in the enterprise business sector.
14	Q What is the enterprise business sector?
15	A The enterprise business sector are -- is
16	comprised of Microsoft's corporate account customers,
17	as well as some of the larger, more strategic
18	customers in Microsoft as well.
19	Q What are corporate account customers?
20	A Corporate account customers are, are
21	Microsoft -- is Microsoft's description of the way
22	they tier the number of accounts for coverage
23	purposes. So that these representatives in the
24	classic Microsoft point of view are provided certain
25	coverage models to make sure that these customers are,

00021
1	maintain a high level of satisfaction with their
2	partners and with the performance of the products.
3	Q And is there -- you said they're tiered in
4	some way. Is there any kind of threshold in terms of
5	numbers of PCs, or annual revenue, or number of
6	employees that's used in order to obtain a space
7	within the corporate account space within Microsoft?
8	A I know that there is a way for them to
9	determine the number of accounts and the coverage, but
10	I'm not intimate with the detail on the actual
11	specific requirements on what makes somebody a
12	corporate account and what makes someone -- I think it
13	does vary and there are some exceptions made based on
14	opportunity or high profile of accounts, level of,
15	level of business revenue, those kinds of things.
16	Q Can you give me some examples of exceptions
17	that have been made for high profile accounts?
18	A I think if there's a particular account
19	that's, has a very high PC count let's say, but isn't
20	necessarily a high revenue account, the customer may,
21	may require further service capabilities, in which
22	case they provide a higher coverage model for that
23	account. That could be one example.
24	Q And what kinds of companies are you involved
25	with within the enterprise business sector?

00022
1	A Just as clarification purpose, myself person
2	personally?
3	Q Yes.
4	A Accounts that are asking for executive
5	representation of Microsoft Business Solutions from a
6	strategic point of view, how Microsoft views their
7	acquisition of the Great Plains in the division
8	organizations, and how we, we provide services to our
9	partners and support to our partners to make them
10	successful.
11	Q Can you give me some examples of the kinds
12	of companies that you're involved with on that basis?
13	A Certainly. Companies like Ingersoll-Rand,
14	companies like Home Bank Corporation, United Missouri
15	Bank, Merial Corporation, Bound, Bound Global, Chanel,
16	as examples.
17	Q In -- what is, what -- what is your
18	involvement, for example, with Ingestible-Rand? What
19	do you do with them?
20	A What do I do with them?
21	Q Yes.
22	A I have a -- fairly regular communications
23	with their global CIO regarding their relationship
24	with Microsoft Business Solutions and the partners
25	that are servicing their accounts; work with them on

00023
1	putting programs together for executive briefings,
2	making sure they're aware of our current state of
3	product, as well as our investment in particular
4	product that could be of interest to them for the
5	future, keeping them up-to-date on relationships we're
6	forming with other partners and other products that
7	are out in the marketplace that they might find
8	interesting.
9	Q And has Ingestible-Rand purchased any
10	Microsoft Business Solutions software products?
11	A Yes.
12	Q What have they purchased?
13	A They've purchased a product called Navision.
14	Q And what is Navision?
15	A Navision is an accounting and core back
16	office accounting system that's being used, that's
17	available on a global basis.
18	Q And how is Ingestible-Rand using it to your
19	knowledge?
20	A Ingestible-Rand has a project by which
21	they're implementing the Navision product at their
22	bobcat dealers. So they're very small, five- to
23	six-user type of operations, but it's a way for them
24	to standardize the back office among the various
25	bobcat dealerships around the world.

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19	Q What about Bound Global, what's your
20	understanding of what products from -- they have
21	purchased from Microsoft Business Solutions?
22	A Bound Global has purchased our Axapta
23	product.
24	Q Do you know where that product has been
25	implemented?

00025
1	A The implementation resides in the New York/
2	New Jersey area.
3	Q Is that Bound Global's headquarters?
4	A Bound Global is part of Bound. And for
5	Bound Global, yes, that is their headquarters.
6	Q What is Bound Global's business, if you
7	know?
8	A Bound Global's business is to provide
9	translation services. They are a Microsoft supplier
10	in that they do a lot of the translation services for
11	a number of Microsoft products around the world, and
12	provide those kinds of services to other companies as
13	well.
14	Q And you say that the Microsoft Axapta
15	product has been implemented in the New York/New
16	Jersey area by Bound Global?
17	A It resides there, yes.
18	Q Does it service other Bound Global locations
19	throughout the United States?
20	A Yes. I believe there's seven different
21	countries running on that instance today.
22	Q When you say there's seven countries running
23	on that instance, what do you mean?
24	A They're providing service, financial
25	accounting, application software functionality to, I

00026
1	believe it's six or more countries around the world
2	from their facility in New York covering approximately
3	35 to 40 users.
4	Q And how, how do the users in other countries
5	obtain access to the Axapta application?
6	A I believe through a dial-in network,
7	although I'm not sure.
8	Q What's your understanding of which countries
9	are being serviced by the Axapta application in the
10	New York/New Jersey area?
11	A I'm not sure of the details.
12	Q What is Axapta?
13	A Axapta is a - an application software
14	package that was acquired as part of the Microsoft
15	acquisition of Navision in Cope - out of Denmark, and
16	it is a, another application edition of products that
17	Microsoft Business Solution sells and markets through
18	its partner organizations.
19	Q What's the target market of Axapta if you
20	know?
21	A Axapta fits very well in markets where
22	customers have international requirements, and it is
23	also targeted at locations in the manufacturing sector
24	because of its functionality versus other editions of
25	Microsoft Business Solutions. It's -- it has a more

00027
1	robust manufacturing functionality.
2	Q When you say it has a more robust
3	manufacturing functionality, what do you mean?
4	A The Axapta product, through the acquisition,
5	provided Microsoft Business Solutions a product which
6	has some of the functionality associated with
7	production planning, manufacturing, bill of material
8	management, inventory management, most of the discreet
9	type of manufacturing, very simple bill of material,
10	assembly-type of work that many companies require in
11	the market in the manufacturing sector.
12	Q And when you say that Axapta is -- fits
13	well, or has international capabilities, what do you
14	mean?
15	A Axapta is a product that is available and
16	supported in many countries around the world. And in
17	comparison to our Great Plains product --
18	(Interruption.)
19	A In comparison with our Great Plains or
20	Solomon products, it is a product that is offered in
21	far more countries than currently the Solomon and
22	Great Plains product are supported.
23	Q Do you know in how many countries -- let me
24	withdraw the question.
25	Do you have an understanding of the, whether

00028
1	Axapta has functionality in 30 or more countries?
2	A I have seen documentation that relates the
3	availability of Axapta, implementation of Axapta in
4	approximately that amount of countries, provided
5	either through localized support or through direct
6	Axapta support.
7	Q When you talk about localized support versus
8	direct Axapta support, what do you mean?
9	A There are some countries where partners have
10	taken the responsibility to localize and to provide
11	functionality for local regulatory requirements for
12	the Axapta product that is not Microsoft intellectual
13	property or owned -- or owned by Microsoft.
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19	Q And you also mentioned Chanel. What's your
20	understanding of what Microsoft Business Solutions
21	product has been sold the Chanel?
22	A Chanel is using the Axapta product in a very
23	decentralized approach, targeting a number of small
24	remote operations that they own on a worldwide basis.
25	Q Is Axapta used by Chanel in the United

00029
1	States?
2	A No.
3	Q Where is it used, to your knowledge?
4	A There is an implementation that's going on
5	today in Europe, and one that's being planned in the
6	Asia-Pacific region.
7	Q Do you know who is implementing Axapta for
8	Chanel?
9	A A partner of ours is doing most of the work,
10	a company by the name of Columbus IT.
11	Q And what is Columbus IT?
12	A Columbus IT is a certified Microsoft Axapta
13	business partner that has implementation resources, as
14	well as project people that implement Microsoft.
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5	Q Can you describe the financial management
6	modules that are provided with Axapta?
7	A The Axapta financial management system
8	consists much of the modules that you described;
9	general ledger, accounts payable, accounts receivable,
10	fixed assets, traditional accounting applications that
11	are required in most small, medium, and large
12	corporate account-type of structures.
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21	Q I've read in some publications that
22	Microsoft Business Solutions hopes to grow its annual
23	sales to approximately $10 billion a year by 2010. Is
24	that true?
25	A I really can't, can't state that for the

00036
1	record.
2	Q Have you seen a Business Week article in
3	which Jeff Rakes made a statement like that?
4	A Yes, I have.
5	Q And is it your understanding that, that
6	Microsoft has publicly stated that it plans to grow
7	the revenues of Microsoft Business Solutions to
8	approximately $10 billion a year by year 2010?
9	A I've read that article, yes.
10	Q Have you discussed those plans with anyone
11	within Microsoft?
12	A Yes.
13	Q With whom?
14	A With my direct management, my team.
15	Q Who is your direct management?
16	A I work for the General Manager in charge of
17	enterprise sales operations.
18	Q And who's that?
19	A Phil Sorgen.
20	Q And you mentioned your team. Who's on your
21	team?
22	A I have two direct -- or one direct report
23	and 17 members of a virtual team that are employed
24	throughout the United States.
25	Q Who -

00037
1	A And when I say my team, I should clarify
2	that to say my virtual team.
3	Q Your virtual team. Those are people in
4	various geographic locations throughout the United
5	States who report up to you?
6	A They don't report directly to me. They
7	report to the local geography.
8	Q And how -- how are they part of your team if
9	they report to the local geography?
10	A It's a virtual team that I helped build from
11	a community point of view; common objectives, common
12	goals, common job responsibilities around the
13	Microsoft Business Solutions products.
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14	Q Within the enterprise group, do you focus on
15	the GSM clients -- this is you personally -- or the
16	CAS, the corporate accounts-based clients?
17	A I don't focus on either. I help our
18	partners in specific situations where they require
19	some Microsoft leadership support based on who they're
20	talking to on the opportunity. I really don't focus
21	on either.
22	Q So it could vary. If a partner comes to
23	you --
24	A Could vary.
25	Q -- with a GSM prospect that they need you

00041
1	your assistance with, you'll help them on that?
2	A Correct.
3	Q And if it's a corporate accounts-based
4	prospect, you'll help them with that, too?
5	A Correct.
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11	Q Are you involved in selling anything other
12	than Microsoft Business Solution products to these
13	enterprise clients?
14	A No.
15	As a clarification --
16	Q Sure.
17	A -- when you say selling, I'm in -- I'd just
18	like to clarify that that means assisting -- in our
19	methodology, helping the partner sell to that account.
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19	Q And what's your involvement at Deloitte?
20	A I participated in an executive briefing with
21	their global CIO who has a number of our Navision
22	product installations in Europe for some of their very
23	small firms that are doing some back office accounting
24	work.
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12	Q Do you have any understanding concerning
13	whether there's any sort of relationship between
14	Deloitte and Microsoft for implementation of Microsoft
15	Business Solution products? Any sort of alliance or
16	anything like that?
17	A Can we clarify that; for the United States?
18	Q Yes.
19	A I'm not aware of any on Deloitte or on
20	Accenture.
21	Q How about Kapp, Gemini, Ernst & Young?
22	A We have begun working with Sogetti, which I
23	believe is part of CGEY. My understanding is they're
24	part of CGEY.
25	Q And how about Bearing Point?

00045
1	A I'm not aware of the details of that
2	relationship.
3	Q Do you have an understanding one way or the
4	other concerning whether there is a relationship
5	between Microsoft and Bearing Point concerning
6	Microsoft Business Solution products?
7	A My awareness is that we're pursuing a more
8	aggressive relationship with Bearing Point, but I
9	don't know the details of the relationship at this
10	point.
11	Q Do you know who is in charge of managing
12	that relationship?
13	A I believe it's being pursued by Carla
14	Heimbigner.
15	Q And who is she?
16	A She works in our partner recruiting area out
17	of Redmond.
18	Q Do you have interactions with Ms.
19	Heimbigner?
20	A On occasion, yes.
21	Q Have you learned anything from her about the
22	relationship between Microsoft and Bearing Point for
23	Microsoft Business Solution products?
24	A While it has come up in conversation, I'm
25	not aware of the details behind the relationship.

00046
1	Q What have you learned in conversation?
2	A That she was actively pursuing Bearing Point
3	to establish a practice around Microsoft Business
4	Solutions.
5	Q Did she say -- did you have an understanding
6	of why?
7	A Microsoft Business Solution is always
8	looking for partners that have very high reputations
9	in the market, that have familiarity with company
10	business needs, and are able to interpret those
11	business needs into business solutions through
12	application software.
13	Q Is it your understanding that Ms. Heimbigner
14	has met with Bearing Point about this relationship?
15	A Yes.
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00048
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4	Q And on a day-to-day basis, can you describe,
5	if you can generalize, you know, how often you are
6	actually meeting with clients or potential clients?
7	A On average, I probably talk to two to three
8	clients per week either via phone, conference call, or
9	face-to-face with a client. Probably meet with two to
10	three partners per week to help them review their
11	pipeline and their strategy around particular sales
12	efforts in the CAS space, and the rest education,
13	training.
14	Q And the -- your virtual team, are they -- do
15	they report up to you in some fashion?
16	A In a dotted-line basis, correct.
17	Q And do you receive reports from them about
18	whether they've met with potential clients?
19	A Yes.
20	Q And is it your understanding -- let me back
21	up for a second. This virtual team, are they
22	organized in any sort of vertical fashion or
23	geographical fashion? Why don't you tell me how
24	they're organized.
25	A Geographic fashion.

00049
1	Q Geographic. And are there various regions
2	throughout the country?
3	A Microsoft is organized by district, and
4	there are representatives in most, if not all,
5	districts that focus on MBS as a solution specialty
6	area.
7	Q And when you talk about MBS as a solution
8	specialty area, what do you mean?
9	A The role that the Microsoft Business
10	Solution people play are what's called solution sales
11	specialists. Within each district, there are solution
12	sales specialists that focus on Office, Windows, SQL
13	Server, and Microsoft Business Solutions has its own
14	solution specialists where an account manager will get
15	involved in an account and has ultimate ownership. A
16	solution specialist will help out with specific
17	opportunities around certain product lines.
18	Q And is there any sort of vertical focus of
19	the -- to the Microsoft sales force?
20	A No -- excuse me. Let me clarify that.
21	Microsoft Business Solutions sales force?
22	Q Yes.
23	A There is not.
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12	Q Sure. I'm trying to figure out if -- well,
13	let's back up for one second. It's your understanding
14	that there are, there are salespeople who focus on
15	selling what you call classic Microsoft products,
16	Windows, SQL Server, things like that. There are
17	salespeople who focus on particular industry
18	verticals?
19	A (Nods head.)
20	Q Is that correct?
21	A That's correct.
22	Q And what I'm trying to figure out is, do you
23	have an understanding one way or the other concerning
24	whether those salespeople also participate in efforts
25	to sell Microsoft Business Solutions products?

00051
1	A If there's an opportunity identified by the
2	Microsoft classic vertical sales representative, they
3	have the opportunity to call in the geographic sales
4	specialist for Microsoft Business Solution where that
5	account resides for assistance if they need help,
6	providing a Microsoft Business Solutions partner, or
7	helping them evaluate whether there's an opportunity
8	where Microsoft Business Solution has the opportunity
9	to fit.
10	Q Are these, these people who are, who are --
11	who focus on a particular industry vertical, are they
12	trained in any way concerning the Microsoft Business
13	Solutions product offerings?
14	A At a very high level, a 101-type of context
15	regarding Microsoft Business Solutions.
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22	Q How many people are there who focus on
23	assisting partners in selling Microsoft Business
24	Solution software products?
25	A In the enterprise sector?

00052
1	Q Yes.
2	A Seventeen.
3	Q And how many in the SMS&P sector?
4	A Don't know the exact head count.
5	Q Can you give me an estimate?
6	A The only estimate I have is last year, or
7	the year before the reorganization, there were
8	approximately 190 people that focused on assisting
9	partners in selling Microsoft Business Solutions in
10	the organization that I was responsible for.
11	Q This was prior to the July --
12	A Prior to the July.
13	Q -- reorganization?
14	A Yes.
15	Q And these 17 people report up to you?
16	A Dotted line.
17	Q And what about enterprise salespeople who
18	focus on the classic Microsoft products, are they
19	trained in the Microsoft Business Solutions products
20	in any way?
21	A Some better than others that have taken the
22	initiative. Most are at a level of a 101-type of
23	Microsoft Business Solution level.
24	Q When you say a 101-type of level, what do
25	you mean?

00053
1	A Core introduction to the products, where
2	they were acquired from, how they fit from a strategic
3	point of view, high level strategy documents, high
4	level functionality documents.
5	Q And have you ever received an inquiry from
6	any of the classic enterprise Microsoft sales force
7	concerning a potential opportunity and they've asked
8	you to come in as more of a specialist in the
9	Microsoft Business Solutions products?
10	A Yes, I've received requests like that.
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14	Q Now have you heard the term mid market?
15	A Yes.
16	Q What's your understanding of the meaning of
17	that term?
18	A It varies from, from everyone you talk to.
19	There is -- my understanding of mid market is there's
20	a large group of the center of the pyramid that makes
21	up most of the corporations in America that everyone
22	is going about discussing in terms of the underserved
23	requirements and the ability for those companies to
24	grow and start to now take upon themselves some of the
25	benefits that only the larger corporations were able

00055
1	to take on with some of these advanced techniques and
2	functionality that were provided only by the large
3	corporations in the past.
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00057
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2	Q Do you consider the corporate accounts space
3	to be mid market space at all?
4	A Do I personally?
5	Q Yes.
6	A The corporate account space has many of the
7	characteristics that are prevalent in many of the mid
8	market accounts, yes.
9	Q And were you working with any mid market
10	customers prior to July of last year?
11	A Yes.
12	Q And based upon that experience, do you have
13	a sense concerning whether mid market customers are
14	attempting to obtain the kinds of functionality that
15	you say only used to be available to the very largest
16	companies?
17	A I, I say -- I said there are some
18	functionality that the mid market companies are very
19	interested in adopting that were only available to
20	large companies before, and the answer to that is yes.
21	Q And what kind of functionality is that?
22	A Connections through the Internet to be able,
23	be able to bid and reply to bids from very large
24	contract and suppliers, the ability to communicate
25	electronically with your suppliers, the ability

00058
1	through EDI or other techniques, the ability to do
2	electronic banking and fund management -- funds of
3	management for being able to deal on a more
4	international basis. Those kinds of things are good
5	examples of functions that were only available for
6	large corporations that smaller companies now can take
7	advantage of.
8	Q And how about integrating the supply chain
9	with the financial aspects of the company, is that
10	something that the mid market companies are more and
11	more interested in?
12	A I think so, yes. I think that most of those
13	companies are single location, single organization,
14	and see some efficiencies in, in a software package
15	that allows for visibility across the entire chain of
16	order to cash.
17	Q And as the world economy becomes more
18	global, are companies in the mid market increasingly
19	interested in multilanguage, multicurrency
20	capabilities in their software?
21	A I -- I don't know if I'm qualified to answer
22	that. It would be my opinion that they would be, yes.
23	Q Have you seen that in your experience at
24	Microsoft Business Solutions?
25	A I think there is a greater -- what I've seen

00059
1	in my experience in Microsoft Business Solution is a
2	greater awareness from the mid marketplace that there
3	is a global economy out there that has potential for
4	their products and services, yes.
5	Q And in your experience, are there mid market
6	clients of Microsoft Business Solutions interested in
7	software that provides multilanguage, multicurrency
8	capabilities?
9	A More of the multicurrency situation, the
10	ability to transact with companies located in other
11	parts of the world, but rarely did we see
12	opportunities that necessitated a multilanguage-type
13	of functionality.
14	Q How about for instance Chanel, is that a mid
15	market company in your view?
16	A No, I think, I think it is classified as a
17	corporate account, a CAS-based account, and I think it
18	has the name recognition and the brand recognition
19	that entitles it to certain special treatments in
20	terms of customer sat. and some other things.
21	Q It's the perfume and the high-end clothing
22	manufacturer, that's the company we're talking about?
23	A Correct.
24	Q Were they interested in the multilanguage,
25	multicurrency capabilities of Axapta?

00060
1	A Yes.
2	Q Is that one of the reasons you understood
3	they purchased Axapta?
4	A Yes.
5	Q And Microsoft is selling Axapta globally,
6	correct?
7	A Yes.
8	Q How about Bound Global, they've implemented
9	Axapta here in the New York/New Jersey area of the
10	United States, correct?
11	A Uh-huh.
12	Q But it's my understanding from your
13	testimony that that implementation of Axapta is
14	supporting five, six, seven other countries; is that
15	correct?
16	A That's correct.
17	Q Were they interested to your knowledge in
18	the multilanguage/multicurrency capabilities of
19	Axapta?
20	A Yes.
21
22
23
24
25

00063
1
2
3
4
5	Q Was Microsoft Business Solutions successful
6	in selling through partners a product to Indianapolis
7	Motor Speedway?
8	A Yes.
9	Q Which product?
10	A Great Plains.
11	Q And what about sports teams? Philadelphia
12	Eagles, was the Microsoft successful in selling a
13	product to them through partners?
14	A Yes.
15	Q Which product?
16	A I'm not sure.
17	Q Any other sports teams that you're aware of
18	in which, which have bought Microsoft Business
19	Solution software products?
20	A Most of the NFL teams today use Microsoft
21	Business Solutions; Great Plains, Solomon, Division.
22
23
24
25

00064
1
2
3
4
5	Q What other -- are there any other high-
6	profile, larger opportunities that Mr. Malme was
7	responsible for other than the sports teams and the
8	Indianapolis Motor Speedway?
9	A His team was responsible for Esselte, his
10	team was responsible for the initial conversations at
11	Ingersoll-Rand, his team was responsible for the
12	Division work we did at a division of Bound, Bound
13	Global, a small division of Bound, his team was
14	responsible for engagements at the Phoenix Suns, some
15	of the other organizations out there.
16
17
18
19
20
21
22
23
24
25

00065
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16	Q Mr. Pollie, we've had marked as Exhibit 1449
17	a, I think a far more legible copy of the document
18	bearing Bates Nos. 4144 through 4153. The power
19	points are now normal sized. Do you see that?
20	A Yes.
21	Q Exhibit 1449, is that a document you
22	received on or about April 22, 2003?
23	A Yes.
24	Q And you received it from Mr. Malme?
25	A Yes.

00066
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25	Q What was the discussion within Microsoft

00067
1	Business Solutions concerning corporate sales
2	acceleration in or about April 2003?
3	A We were discussing the addition of head
4	count that might result in increased amounts of
5	revenue and positioning our products in the
6	divisional/departmental solutions in the enterprise
7	market.
8	Q When you're talking about positioning the
9	products in the divisional -- divisional solutions in
10	the enterprise market, what do you mean?
11	A The focus of our initiatives in the
12	enterprise market are targeted at very targeted spoke
13	type opportunities within a major corporation, much
14	like the situation at Bound or Chanel or others we've
15	been discussing. We are not serving as the core
16	enterprise system, but much of a remote location or a
17	departmental or a divisional solution where the needs
18	are very much akin to a very small mid market account
19	as an example.
20	Q Now, I understand that you've been involved
21	with a company called       ?	REDACTED
22	A Yes.
23	Q That's an eight or $9 billion advertising
24	holding company?
25	A Yes.

00068
1	Q And I understand you've had discussions
2	concerning an Axapta implementation at one of their
3	subsidiaries called       ?	REDACTED
4	A Yes.
5	Q And was the discussion concerning        that	REDACTED
6	Axapta would be the business application software that
7	would be run at       ?	REDACTED
8	A No.
9	Q What was it?
10	A We are presenting a solution in the
11	Microsoft Business Solutions offering by the name of
12	Solomon. Solomon is a product that's designed to
13	account for professional service needs. Many
14	organizations in the construction professional service
15	time and material billing environment use our Solomon
16	product.
17	Q Was -- have there been any discussions with
18	concerning the use of Axapta?	REDACTED
19	A In the past there have been some evaluations
20	of all the Microsoft Business Solution products,
21	including Axapta and including the Great Plains
22	product as well.
23	Q Is either Axapta or Great Plains, has either
24	one of those been implemented at any        company?	REDACTED
25	A        has implemented Great Plains at a	REDACTED

00069
1	few of their locations.
2	Q Do you know which ones?
3	A The corporate headquarters is using Great
4	Plains and one of their small divisions called DOS is
5	also in the midst of implementing Great Plains as
6	well.
7	Q What's the corporate headquarters of	REDACTED
8	using Great Plains for?
9	A Ten, fifteen users, just integrating core
10	financials just at a high level. As you mentioned,
11	they're a holding company so they have very limited
12	production or any other kind of capabilities. So
13	they're using it as a financial reporting system at
14	the corporate level to consolidate some data.
15
16
17
18
19
20
21
22
23
24
25	Q So Great Plains is the corporate accounting

00070
1	software that's in use at              corporate	REDACTED
2	headquarters?
3	A It's in use at              corporate	REDACTED
4	headquarters. I'm not aware of any others.
5	Q And where is              corporate headquarters?	REDACTED
6	A In New York.
7	Q New York. Have you met with the Chief
8	Financial Officer of       ?	REDACTED
9	A Yes.
10	Q Have you discussed the Great Plains product
11	with him?
12	A Yes.
13	Q Is he happy with it?
14	A Yes.
15	Just from a clarification point of view,
16	again, it's very small Great Plains implementation of
17	15, 20 users that is being supported through a
18	partner, and the partner has implemented that system
19	for a number of years in a very contained environment.
20	Q And who's the partner?
21	A A company by the name of Altara.
22	Q And Altara -- what is Altara?
23	A It's a Microsoft Business Solutions partner
24	based out of New Jersey, one of our leading partners
25	that is in charge of reselling the Microsoft Business

00071
1	Solution products and implementing those products to
2	customers all around the northeast. She has also
3	offices in Denver and a few other places as well.
4	Q And when's the last time you had a
5	discussion with the Chief Financial Officer of	REDACTED
6	concerning Great Plains software product?
7	A Within the past two months.
8	Q And what was your discussion about?
9	A The discussion was about Microsoft Business
10	Solutions playing a greater role in        in terms	REDACTED
11	of a standard way for        to roll out accounting,	REDACTED
12	core accounting software. And the way that they're
13	organized, they have 1400 independent agencies.
14	They're very small agencies with one to two to three
15	users.        is very interested in using the	REDACTED
16	product, or evaluating the use of the product in those
17	agency and company roles where Microsoft Business
18	Solution could become the standard for        across	REDACTED
19	the corporation.
20	Q And that would be across all of	REDACTED
21	subsidiaries?
22	A Potentially.
23	Q Has any decision been made to your
24	knowledge?
25	A No decision, no final decision has been

00072
1	made, no.
2	Q But there have been discussions with the CFO
3	of        about having a Microsoft Business Solution	REDACTED
4	software product as the standard across all the
5	companies?	REDACTED
6	A Yes.
7	Q And what's your understanding of the size of
8	, in terms of revenue or employees?	REDACTED
9	A My internal briefing is much more
10	surrounding the total number of users that would be
11	involved in implementing a successful site at	REDACTED
12	which currently targets approximately two to 300 total
13	users of our product, our Solomon product for core
14	financial accounting systems as a spoke in the	REDACTED
15	wheel.
16
17
18
19
20
21
22
23
24
25

00074
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24	Q Now you talked about the use of Great Plains
25	in a distributed fashion. What do you mean by that?

00075
1	A The way we have consistently positioned
2	Microsoft Business Solutions in the market is as a, a
3	business solution for independent business units of
4	major corporations, very small divisions or one-off
5	business units that have a requirement for an
6	accounting back office application.
7	Q And can you explain what -- I'm not sure I
8	understood your answer. When you're talking about a
9	distribute implementation, are you talking about
10	various spoke implementations throughout a larger
11	enterprise?
12	A Many organizations today have a variety of
13	small business units that have a variety of systems in
14	place. It's not uncommon to talk to a large
15	corporation where they have 14 or 15 different general
16	ledgers implemented along with their core ERP system
17	which is provided by an Oracle, an SAP or a
18	PeopleSoft. In many cases our target in talking to
19	that account is finding a way for Microsoft Business
20	Solutions to be positioned as a solution for those
21	independent divisions or locations to provide back
22	office accounting functionality.
23
24
25

00076
1
2
3
4	Q Going back to Exhibit 1449, Mr. Pollie,
5	there's some bullet points under the power point. Do
6	you see that?
7	A Which page are you on?
8	Q Excuse me, 4146.
9	A Yes.
10	Q Same page we were on earlier.
11	The first bullet point says position MBS
12	solutions in GSM accounts when these solutions meet
13	customer's needs. Do you see that?
14	A Uh-huh.
15	Q Do you have an understanding of what that
16	means, sir?
17	A My understanding is that when a large
18	corporation is looking for a mid market solution to
19	service some of their remote locations and small
20	division subsidiary location needs, that we would
21	entertain the discussion with those GSM accounts in
22	order to provide our product demonstrations through
23	partners to have them evaluate it.
24
25

00079
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24	Q Did the Microsoft U.S. corporate accounts
25	space and GSM account managers have a quota for

00080
1	Microsoft Business Solution products in fiscal year
2	'04?
3	A No.
4	Q Do they currently?
5	A They were assigned a quota at a MS U.S. CAS
6	level, which was based on a team base quota for the
7	entire geography for CAS. No GSM quota was assigned.
8	Q What was the CAS quota if you recall?
9	A It -- it differed based on various
10	geographies and the amount of corporate accounts that
11	were present in, and as well as the existing accounts
12	that were generating some maintenance revenues and
13	some other factors.
14	Q What is a sales quota?
15	A It's an objective by which a salesperson is
16	measured by.
17	Q Is it fair to say that the Microsoft U.S.
18	CAS salespeople needed to sell a certain amount of
19	Microsoft Business Solution products in order to meet
20	their quota?
21	A The Microsoft CAS salespeople worked closely
22	with the SSP and the partners within the district that
23	they identified to generate opportunities and revenues
24	in MBS within the geographic district. It was a
25	team-based quota such that the total district was

00081
1	responsible for generating a specific team-based
2	number, of which the entire team participated in
3	evangelizing MBS to customers and to partners and to
4	just in general seminar participations and such that
5	Microsoft Business Solutions had these divisional-type
6	of spoke solutions for companies that were evaluating
7	that kind of opportunity.
8	Q So is it fair to say that each of the 17
9	geographies had a quota for Microsoft Business
10	Solution software products?
11	A Yes.
12	Q And the quota would vary depending upon how
13	many CAS accounts were within the particular region?
14	A Correct.
15	Q And the salespeople were measured by the
16	sales of Microsoft Business Solution products to the
17	CAS accounts within the region?
18	A CAS accounts and where appropriate, we would
19	provide coverage to certain industry accounts and GSM
20	accounts. As shareholders of the company, we wanted
21	to make sure those accounts, if there was a fit that
22	arose, that we were servicing those accounts from a
23	satisfaction point of view. But the quotas, the
24	focus, the marketing was all derived and dedicated at
25	the CAS space accounts.

00082
1
2
3
4
5
6	Q Sure. I'm trying to figure out, I believe
7	you said that if there was an appropriate fit within
8	the GSM, within the GSM space, if some vertical
9	specialist brought some sort of GSM opportunity that
10	people believed was appropriate, that that would be
11	pursued by the CAS salespeople?
12	A No. Let me clarify that. If as an example
13	Deloitte and Touche came in and said, we have a number
14	of Navision locations. We want to talk to Microsoft
15	about setting up an executive briefing. The Microsoft
16	Business Solution representative in the geography
17	where Deloitte and Touche resides would assist the
18	Microsoft GSM rep in setting up the appropriate
19	resources and presentations and partners that could
20	assist Deloitte in finding out the information they
21	were looking for.
22
23
24
25

00085
1
2
3
4
5
6
7
8
9
10	Q And Axapta, what's the target market of
11	Axapta?
12	A Axapta, as I mentioned earlier, is a product
13	that is targeted at manufacturing-based companies,
14	companies with manufacturing functionality, and some
15	of the international location from a spoke perspective
16	where a company needs international divisions or
17	locations that could be fulfilled by Axapta.
18	Q Is Axapta targeted at companies with up to a
19	billion dollars a year in annual revenue?
20	A That's possible, depending on the complexity
21	of the organization or the number of users or
22	employees, or it really depends on the complexity.
23	Q Is it targeted at corporate accounts-based
24	customers?
25	A If, if the requirements and the partners

00086
1	believe Axapta would be a strong fit, yes.
2	Q And you mentioned earlier a company called
3	Esselte?
4	A Yes.
5	Q Are you familiar with that company?
6	A Yes, a little bit.
7	Q And Axapta is being implemented in that
8	company, right?
9	A Yes.
10	Q And when did that implementation start?
11	A The licensing of the Axapta product to
12	Esselte took place in June of 2003.
13	Q And is Axapta currently been implemented at
14	Esselte?
15	A To my knowledge it is, yes.
16	Q And is it being implemented across the
17	world?
18	A To my knowledge there are international
19	locations. I don't know about around the world.
20	Q What international locations are you
21	familiar with at Esselte?
22	A I'm not particularly privy to any particular
23	ones.
24	Q Is Axapta being implemented in the United
25	States for Esselte?

00087
1	A I don't recall.
2	Q Do you know -- do you know how many
3	employees Esselte has?
4	A I know that Esselte is looking at rolling
5	out approximately 15 different locations, or we
6	licensed the product to accommodate for up to 15
7	locations of use of the Axapta product which could
8	accommodate as many 3,000 users. It also -- you know,
9	all across those 15 locations. It's really up to
10	Esselte how they're deploying it. I'm not privy to
11	how -- what the latest status is.
12	Q Can Axapta support up to over 3,000 users?
13	A Up to 15 locations I believe that there's a
14	good possibility that it can support those users.
15	Q You sold it Esselte based on the fact that
16	it could support that many users over that many
17	locations, correct?
18	A Correct.
19	Q And --
20	A But this is a situation where Esselte is
21	going to be, just as clarification point, we are not
22	looking at one 3,000-user system. We're looking at 15
23	systems with maybe 200 users at a maximum stretched
24	out over those 15 locations.
25

00088
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19	Q And it's your understanding Axapta is being
20	implemented at 15 different locations across Esselte?
21	A It's my understanding that the license
22	accommodated for Esselte to have the opportunity to
23	implement Axapta to up to 15 locations for 3,000
24	users.
25	Q And how many --

00089
1	A But I don't know how they're going to
2	actually deploy the product, or if they are currently
3	implementing all 15, or one at a time. I'm not privy
4	to that information.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

00091
1
2
3
4
5	Q Do you have a recollection or an
6	understanding of the amount of consulting revenue that
7	Microsoft expects to receive or has received from
8	Esselte?
9	A In the initial review, we were looking at
10	somewhere in excess of $        in consulting	REDACTED
11	revenue associated with billable services to Esselte,
12	but I have no information on what is actually billed
13	to the client or what is the current, current status
14	of that.
15	Q But the projections were for more than $	REDACTED
16	in consulting revenue?	REDACTED
17	A Associated with the project, that's correct.
18	Q Do you know whether Microsoft gave Esselte
19	any discount off any the list price for the Axapta
20	product?
21	A I believe that based on the commitments of
22	our larger clients, there are discount processes that
23	were set up to accommodate Esselte, which I believe
24	they did qualify for, yes.
25

00092
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18	Q I'd like you to take a look at what's
19	previously been marked as Exhibit 1420.
20	A (Reviewing.)
21	I'm familiar with this.
22	Q You've seen Exhibit 1420 before?
23	A Yes.
24	Q What is Exhibit 1420, sir?
25	A This Exhibit originally started out as a, as

00093
1	a partner request from -- for a press release. The
2	partner was asking us to provide just the approval to
3	allow them to tout what, at the time and still is, the
4	largest single Microsoft Business Solution sales
5	opportunity, and then we took this and posted it
6	actually on our web.
7	Q So Exhibit 1420 is posted on the Microsoft
8	web site?
9	A From what I can see here, it is the
10	Microsoft Business Solutions web site that's listed
11	here.
12	Q And Exhibit 1420 concerns the sale of
13	Microsoft Business Solutions Axapta to Esselte?
14	A Yes.
15	Q And it's titled Billion Dollar Manufacturer
16	To Deploy Microsoft Business Solution System Across
17	Four Continents. Do you see that?
18	A Yes.
19	Q And it refers to support -- Microsoft Axapta
20	supporting 3,000 concurrent users in their daily work.
21	Do you see that?
22	A Yes, I see that.
23	Q Is it your understanding that Microsoft
24	Axapta will support 3,000 concurrent users in their
25	daily work at Esselte?

00094
1	A It will not support 3,000 concurrent users
2	on a single implementation or system. The
3	clarification on the 3,000 concurrent users as we
4	discussed is that we licensed the product to run 3,000
5	users over 15 installation -- over 15 implementation
6	sites with the idea that we would not exceed two to
7	300 users at any particular one instance.
8	Q And do you have an understanding concerning
9	whether the statement that Esselte's a billion-dollar
10	manufacturer is accurate?
11	A I believe that's accurate.
12
13
14
15
16
17
18	Q And you are, you are quoted in Exhibit 1420,
19	correct?
20	A My name appears here as, under this quote,
21	that's correct. But I -- a partner wrote this on my
22	behalf. We reviewed it, sent it to our internal
23	public relations folks for draft. I did change the --
24	I wrote the first sentence which states, we're excited
25	to work with our partners to deliver a comprehensive

00095
1	solution that truly meets the needs of Esselte's
2	business. The second part of that question was not
3	something I wrote, but wound up sending through the
4	process for approval and it was published.
5	Q So you reviewed what the partner provided to
6	you?
7	A That's correct.
8	Q And you agreed with it and approved it?
9	A I don't agree with it in the way it's worded
10	here. I did pass it on for approval, but I think this
11	is an example of perhaps a little overzealous reaction
12	to the Esselte sale. And also, when the deal took
13	place in June and when this was published, the
14	organization had changed dramatically and people were
15	in completely different roles in September of 2003.
16	So that this one sort of got through the process
17	without maybe going through some of the review it
18	should have gone through. But there was a change in
19	our public relations department, there was a change in
20	my job, there was a change in the partner, you know,
21	sort of publishing this release for -- and then our
22	using it internally.
23	Q But you reviewed it and --
24	A I do recall reviewing this statement and
25	passing it on to public relations for their drafting.

00096
1	Q And the statement you're referring to is
2	this is a great example of how Microsoft Axapta can
3	scale to meet even the most complex requirements of
4	billion-dollar manufacturing businesses operating in
5	multiple countries around the world?
6	A I don't believe that is a -- that could be
7	interpreted as a misleading example of --
8	Q Have you asked that the Microsoft web site
9	be corrected to -- so that this, this customer example
10	is changed?
11	A No, I've not.
12	Q Are there any plans to change it?
13	A Yes.
14	Q When is it going to be changed?
15	A As soon as I can.
16	Q What's it going to say?
17	A I think this is a great example of how
18	Microsoft Axapta can meet complex requirements. I
19	mean this, this particular sentence gives the
20	impression that Microsoft Business Solutions is, is
21	meeting a very complex sort of large billion-dollar
22	manufacturing corporation, when in effect what we're
23	actually doing is licensing of a product to be used in
24	15 remote locations --
25	Q But that's --

00097
1	A -- 200 users, and using very valuable
2	partners to deliver on some of this complex
3	functionality.
4	Q So the functionality is complex in Axapta,
5	right?
6	A The complex -- the functionality that's
7	being delivered to, to the Esselte account could not
8	be delivered solely through Axapta.
9	Q Because partners are adding value from --
10	A Partners are adding specific products to the
11	customer, as well as third-party partners have -- it's
12	referenced here that Microsoft Axapta functionality
13	with lean manufacturing module offered by eBECS.
14	EBECS is a third party ISV product that the company is
15	going to use for a majority of their manufacturing. A
16	majority of their manufacturing in Esselte will not
17	even be done through Axapta, nor could it be done
18	through Axapta. But --
19	Q So there was a gap, and the partners are
20	filling the gap, right?
21	A There is a gap, and the customer has decided
22	to allow a -- to evaluate and allow a third-party
23	product to do manufacturing functionality that is not
24	currently present or planned to be present in the
25	Axapta product.

00098
1	Q And the Deloittes and the Bearing Points of
2	the would do gap analyses concerning SAP products,
3	right?
4	A I would assume so, sure.
5	Q And they have to figure out ways to get from
6	75 or 80 percent fulfilling the client's functional
7	needs to as much as the client wants, right?
8	A If they're contracted to do that. But in
9	this particular case, we have a client that's in the,
10	in the marketplace. Most customers would -- are
11	looking for -- very complex customers would not settle
12	for an Axapta product that didn't have all of the
13	functionality delivered in its entirety. In this
14	particular case, because we're rolling it out over 15
15	or 20 locations at a very small user level, the client
16	were willing and familiar to use a third-party product
17	to conduct a majority of its manufacturing
18	functionality.
19	Q So Esselte decided that because of its
20	business structure, it could meet its needs through
21	Axapta, right?
22	A Esselte determined that while Axapta -- that
23	Axapta would be a fit for the divisional locations for
24	the planned -- or the potential 15 rollout sites only
25	if it could supplement that product through a third-

00099
1	party decision that it determined it could make based
2	on its organizational structure.
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00100
1
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4
5	Q If I can get you to turn back for a moment
6	to what's been marked as Exhibit 1449, and still on
7	Page 4151, the page we were looking at before lunch.
8	And the portion of that page which is the box entitled
9	MBS Positioning.
10	A Yes.
11	Q We talked about corporate, we spent a little
12	bit of time talking about the corporation portion of
13	that graph. And above is major, and above that is
14	global and strategic. Do you see that?
15	A Yes.
16	Q And then the bubble to the right of that
17	says Microsoft value delivered by hub and spoke
18	integrated and distributed solutions. Do you see
19	that?
20	A Yes.
21	Q Do you have an understanding of what an
22	integrated solution that Microsoft Business Solutions
23	might provide to the global, strategic, major space
24	might be?
25	A I don't have specific definitions involved

00101
1	with what an integrated solution is.
2	Q How about a distributed solution?
3	A Don't know what Mr. Malme was driving here
4	as well.
5	Q Is a distributed solution a situation like
6	Esselte in which Esselte is implementing, or the
7	client is implementing various versions of Axapta
8	around the world?
9	A It's my understanding Esselte is
10	implementing various implementations of Axapta in
11	individual locations around the world.
12	Q Okay. And is that a distributed solution?
13	A I don't know if it qualifies for what you
14	describe as distributed.
15	Q Do you have an understanding based upon your
16	years at SAP and at Microsoft concerning what a
17	distributed solution business application solution is?
18	A My understanding of a centralized versus a
19	distributed environment allow a customer to look at a
20	central location where all processing is achieved for
21	the total corporation versus one in which they may
22	install one or multiple different vendor solutions at
23	other locations around the world; the second one being
24	distributing the systems to other locations.
25	Q And based on your experience, do some

00102
1	corporations choose a distributed model as opposed to
2	a centralized model?
3	A Some corporations are organized in a fashion
4	that would accommodate a distributed solution,
5	although I've never met a client that organizes its
6	company or its software -- or organizes its company
7	around a software or a business solution.
8	Q But they -- the company may be set up in a
9	way that that can be addressed by a distributed
10	solution?
11	A I think the company is set up prior to any,
12	any solution being --
13	Q Sure.
14	A -- being brought to, to evaluate.
15	Q Absolutely. Absolutely. What I'm trying to
16	figure out is, the company -- you're talking about
17	companies which are organized in a certain way, and
18	those kind of companies, I think you your testimony
19	is, that a distributed solution might be appropriate
20	for those companies?
21	A A company which is organized in such a way
22	where they have small and medium size divisions,
23	organizations, independent business units that they
24	own and operate or are a controlling interest of in
25	many cases can use our products in that environment.

00104
1
2
3	A
4	Q What about a hub and spoke solution, what is
5	that?
6	A A hub and spoke solution is really the, the
7	focus that we've been describing where Microsoft
8	Business Solutions is positioned in all of these
9	sectors, corporate, major, strategic, global, as being
10	a spoke in an operation that traditionally would
11	communicate with a large Tier 1-type of solution at a
12	main headquarters or major manufacturing facility
13	where it's either not cost-effective or in certain
14	situations, not technically feasible to implement a
15	large complex solution in an organization which would
16	be overkill in a very small division or department.
17	So in looking at these spokes, traditionally
18	they're being maintained today by many different
19	general ledgers and financial accounting system, many
20	of those vendors being out of business for many years,
21	off support, and Microsoft Business Solution is really
22	looking to, to offer a standard operating solution for
23	those small spokes that are out surrounding the major
24	hub location for that company.
25	Q And in the corporate account space, can

00105
1	Microsoft Business Solutions Axapta, for instance,
2	serve as the hub ERP product?
3	A In the corporate accounts space, it is --
4	depends on the complexity of the account, the number
5	of users, the size of the business, the business
6	processes that they're looking to implement.
7	Q How many --
8	A Traditionally we don't target the hub
9	location as our business.
10	Q How many users can Axapta accommodate?
11	A I don't know the specifics on the
12	benchmarking on absolute, and it would depend again on
13	the particular business process that was being
14	implemented at the customer that would impact the
15	benchmarking of what it could and could not support.
16	Q Are you aware that Axapta has been
17	benchmarked at 3900 users?
18	A I've read materials based on one particular
19	business process that was, was benchmarked, although I
20	don't believe the statistics based in what I've seen
21	in real-life situations for some of the customers.
22	Q Are you aware of any Axapta users who have
23	more than, more than 1,000 concurrent users at the
24	moment?
25	A No, I'm not.

00106
1
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5
6
7	Q Going back to Exhibit 1420, the piece from
8	the Microsoft web site entitled Billion Dollar
9	Manufacturer To Deploy Microsoft Business Solution
10	System Across Four Continents, and going back to your
11	quote at the bottom of the first page of Exhibit 1420.
12	A Yes.
13	Q Can Axapta scale to meet the most complex
14	requirements of billion-dollar manufacturing
15	companies?
16	A I don't believe that statement is accurate,
17	and I don't think that is neither the public, nor the
18	internal intent of our target markets or where we're
19	going after marketing for Axapta or supporting Axapta.
20	Q Well, I understand it may not be your target
21	market, but Axapta is -- was purchased by Esselte to
22	operate across four continents, right?
23	A Esselte licensed the product to operate in
24	up to 15 locations for 3,000 users. It was -- the
25	complexity of large manufacturing accounts extends

00107
1	beyond numbers of users or business process. We are
2	not really geared from a product functionality point
3	of view to handle tremendously complex manufacturing.
4	As I stated earlier for the record, this would not be
5	an account we could offer satisfaction to without
6	them, Esselte, making a decision consciously to do
7	most of their manufacturing through the third-party
8	product eBECS. So Axapta is not scalable to meet the
9	most complex business requirements.
10	Q But it is in conjunction with the eBECS
11	product, right?
12	A For the Esselte situation they believe that
13	it would provide the functionality that they're
14	willing to accept and implement to meet their
15	particular needs, which they believe are complex, the
16	partner believes are complex, but in general, I --
17	I -- again to answer your question, the Axapta product
18	as it stands is not geared to meet complex business
19	requirements of complex manufacturing.
20	Q There are a variety of independent software
21	vendors who sell products that are complimentary with
22	Axapta, right? Like the eBECS solution?
23	A Yes, there's a variety of ISVs that work
24	with our products, with Oracle, with SAP, with
25	PeopleSoft, correct.

00108
1	Q And the eBECS product, that works with
2	Axapta?
3	A The eBECS product is a niche manufacturing
4	for lean software that works in conjunction with our
5	Axapta product, yes.
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00112
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22	Q Now, can you tell me, what is Convergence?
23	A Convergence is Microsoft Business
24	Solutions's annual user conference held for the past
25	few years in Orlando, Florida. It's a session by

00113
1	which users can exchange ideas and set up networking
2	with each other. It's an educational session where
3	executives and leaders from Microsoft and Microsoft
4	Business Solutions present strategy, visioning,
5	individual meetings with customers to thank them for
6	business and to understand their strategy as a
7	business, see where Microsoft can help.
8	Q Now, is this a Microsoft conference or
9	Microsoft Business Solutions conference?
10	A It's traditionally been a Microsoft Business
11	Solution conference. This year there was more of a
12	presence of some of the Microsoft Technology, as well
13	as the Microsoft Business Solutions. It's targeted at
14	Microsoft Business Solution clients.
15	Q And it took place in this March in Orlando?
16	A March 2004 in Orlando.
17	Q And did you meet any corporate account space
18	or GSM customers at Convergence?
19	A Yes.
20	Q Do you recall who you -- with whom you met?
21	A I'm trying to think.
22	I met with        which is a CAS	REDACTED
23	customer; I met with Bound Global, I met with Chanel,
24	I met with        -- they're not a CAS customer, but
25	I think -- those are the ones I can recall offhand.	REDACTED

00118
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19	Q And you recall meeting with	REDACTED
20	Corporation at Convergence in March of this year?
21	A Yes. We had a dinner meeting where I had
22	the opportunity to interact with them and a brief
23	offline conversation for five or ten minutes with the
24	gentleman that attended.
25

00120
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18	Q Do you have an understanding that Miss
19	Tudela was attempting to sell        Corporation	REDACTED
20	Axapta for use in Mexico, Australia and Honduras?
21	A There were, there were three separate
22	evaluations going on with two separate partners in
23	Honduras, Mexico and Australia, and the company asked
24	for us to get involved and tell us more about the
25	product offering because three of their divisions were

00121
1	reporting in that it was a very attractive product for
2	their independent business units. And those are the
3	three I believe Miss Tudela was really focusing on as
4	part of this visit by the client.
5	Q And is -- does Axapta have functionality to
6	support operations in Mexico, Australia and Honduras?
7	A We have partners in each of those areas
8	that, that are able -- that have the ability to
9	implement the Axapta product in those three locations,
10	that's correct.
11	Q And the -- either the Axapta product or
12	through partners has the localizations necessary for
13	Mexico, Australia and Honduras?
14	A I'm not positive how that's, how that's
15	attained.
16	Q Miss Tudela says that she's hoping to widen
17	the scope worldwide. Do you see that?
18	A Yes.
19	Q And then she says, this is the objective?
20	A Yes.
21	Q Do you have an understanding concerning
22	whether Miss Tudela wanted to sell Axapta to	REDACTED
23	Corporation on a worldwide basis?
24	A After the briefing document and
25	conversations with Miss Tudela, we discussed that

00122
1	there are many locations that have a common separation
2	that is exhibited in Honduras, Mexico and Australia
3	that would also be potential opportunities for the
4	future should we be successful in these other remote
5	locations. It was her intent to prove that through
6	successful implementations of those, that we could
7	have the opportunity to be evaluated for those other
8	locations as well.
9	Q What other locations was she referring to?
10	A I don't have specific knowledge of where,
11	where and how many there are.
12	Q Locations inside the United States?
13	A There are some locations in the United
14	States, yes.
15	Q And your understanding is	REDACTED
16	Corporation is headquartered in Alabama?
17	A Yes.
18	Q If you rum to Page 8748 of Exhibit 1450,
19	sir.
20	is a page entitled	REDACTED
21	Participant Profile, correct?
22	A Yes.
23	Q And it says current scope ERP Axapta
24	opportunity for Mexico, Australia and Honduras?
25	A Yes.

00123
1	Q That's consistent from your understanding
2	your discussions with Miss Tudela?
3	A Yes.
4	Q And also with        Corporation?	REDACTED
5	A From conversations with        Corporation,	REDACTED
6	that's correct, Mexico, Australia and Honduras
7	locations.
8	Q And potential scope includes ERP Axapta
9	worldwide to include U.S. subsidiaries?
10	A Potential scope is an optimistic
11	representation of what the total opportunity would be
12	on a worldwide, multilocation basis should	REDACTED
13	Corporation say, we want all of our remote locations
14	to install the Axapta product line.
15	Q And it's 2000 to 2500 users is the potential
16	scope?
17	A It appears that that's the estimate that's
18	currently in this document listed out over multiple --
19	five different divisions, and I'm unsure -- five
20	different lines of business, five different divisions,
21	and I'm not sure exactly how many locations that would
22	represent on a worldwide basis. There are five
23	separate business divisions that operate autonomously.
24	Q Inside       ?	REDACTED
25	A Yes.

00124
1	Q So this is another company that's organized
2	in sort of a distributed fashion?
3	A It would be             , the	REDACTED
4	ones that are listed here,          ,	REDACTED
5	being the one that's probably the	REDACTED
6	most well-known.
7	Q And according to Miss Tudela's summary
8	report to you on              in advance of Convergence,	REDACTED
9	has over a billion dollars in annual sales?	REDACTED
10	A That's what appears here.
11	Q And more than 15,000 employees worldwide?
12	A That's what appears here as well.
13	Q And did you have any discussions with
14	about --           Corporation about	REDACTED
15	implementing Axapta ERP on a worldwide basis?
16	A We certainly -- actually           had brought	REDACTED
17	up to us that they would like to find a way to get
18	their other divisions up with a more standard sort of
19	solution offering potentially with Microsoft, but
20	they're also evaluating many different other vendors
21	as well.
22	Q What other vendors?
23	A They're looking at, I believe it's J.D.
24	Edwards, they're looking at -- other than J.D. Edwards
25	I'm not sure exactly all the different vendors they're

00125
1	looking at.
2	Q J.D. Edwards has been acquired by
3	PeopleSoft?
4	A That's right.
5	Q So they're looking at PeopleSoft; is that
6	fair?
7	A It's fair to say that, yes.
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00126
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8	Q And do you have an understanding from your
9	conversations with where they were interested	REDACTED
10	in potentially implementing Axapta, Axapta in the long
11	term?
12	A We focused on Mexico, Australia and
13	Honduras.
14	Q Did you have any discussions about
15	implementing it worldwide, including the U.S.
16	subsidiaries?
17	A It was mentioned in their system overview of
18	their organization structure that there would be other
19	remote opportunities that are running older
20	Legacy-based systems that were not supported anymore.
21	Q When you say remote opportunities what do
22	you mean?
23	A Distributed divisions of one of these five
24	business units, independent operating sort of
25	remote -- more of the spoke examples we mentioned

00127
1	earlier where they have a plant or a factory in a
2	remote location that provides either strictly
3	manufacturing or strictly distribution or strictly
4	warehousing to service some of these particular
5	business units.
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20	Q Now, the estimated value of the           sale	REDACTED
21	to the MBS ecosystem is listed at        to $	REDACTED
22	Axapta worldwide, right?
23	A That's what I read here, yes.
24
25

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18	Q Did you have any discussions with	REDACTED
19	about deploying a hub and spoke system in which
20	everything was going to be Axapta?
21	A At the spoke level we have been having
22	conversations about having an Axapta spokes around a
23	centralized hub.
24	Q And did you have any discussions with
25	that -- concerning having Axapta as the	REDACTED

00133
1	centralized hub?
2	A No, we've not.
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00134
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13	Q So at Indianapolis Motor Speedway they've
14	implemented Great Plains as the hub?
15	A They have one location, one operation, so --
16	there are no real spokes. So it's one implementation.
17
18
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20
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24	Q What did you tell           Corporation about	REDACTED
25	the Axapta product when you met with them?

00135
1	A They were, they were interested in our
2	investment strategy around Axapta, where we were
3	positioning the Axapta product, how it was working in
4	the hub and spoke model, what divisions of
5	international companies had deployed Axapta
6	successfully in remote operations operating in a
7	spoke-type environment. We talked about partner
8	selection and how Microsoft supports its partners in
9	delivering those solutions, how we were working
10	closely with their two partners that they had been
11	engaged with so far.
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22	Q Do you recall what sort of functionality
23	Corporation was interested in in Axapta?	REDACTED
24	A Core financial systems operating in Mexico,
25	Australia, and Honduras.

00136
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17	Q What do you recall about the business
18	processes at the various locations?
19	A Pretty straightforward single location
20	processes, core financial functionality added to some
21	basic inventory and storage-type requirements.
22	Q How was the information going to be
23	transmitted from Honduras, Australia and Mexico to
24	Alabama?
25	A I don't have specific knowledge of that.