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IBM Subpoenas Microsoft! Sun! Baystar and HP!
Groklaw ^ | 02/22/06 | Pamela Jones, et al.

Posted on 02/22/2006 10:03:02 AM PST by Salo

Hold on to your hats! IBM has subpoenaed Microsoft! And Sun! At last, we're getting to the core of the matter. We're going to get to find out the whole story. I'd pay for this. No kidding. Feast your eyes on these and don't skip the topics for deposition:

* Plaintiff IBM's Notice of Service of Subpoenas Duces Tecum - yes, plaintiff for the countercharge...oops, I meant counterclaims * Exhibit A - HP's (deposition set for March 15, 9 AM) * Exhibit B - Baystar's (deposition set for March 16, 9 AM) * Exhibit C - Microsoft's (deposition set for March 14, 9 AM) * Exhibit D - Sun's (deposition set for March 7, 9 AM)

If anyone has time to do a plain text of the topics, I'd appreciate the help. What a day.

I love Sun's. Among other things, IBM would like to have them testify about such matters as "restrictions or prohibitions on Sun employees having access to any UNIX product, including, but not limited to, its source code." And they'd like to hear all about all communications between Sun and SCO since June 28, 2002 (isn't that the date Darl joined SCO as CEO?), including any chats about any software licensing agreements and what Darl said to Scott McNealy in May of 2003 regarding SCO's rights to the UNIX operating system and "discussions of business opportunities between SCO and Sun." Oh, and involvement by Sun in the development of Linux.

IBM would like Baystar to hand over documents about any communication between Baystar and Microsoft regarding SCO, IBM or the SCO v IBM litigation and all documents regarding agreements between Baystar and SCO and all documents regarding Baystar's investment in SCO, and all documents concerning Baystar's knowledge of SCO's business". Say, that should be easy for a "pure financial animal".

Microsoft, Microsoft, Microsoft. Do tell IBM all about any agreements between Microsoft and SCO, and all communications or agreements relating to SCO or this litigation, including all communications between Microsoft and SCO since June 28, 2002, including Darl's communication in May of 2003 "with Steven Ballmer regarding SCO's rights to the UNIX operating system". Oh, and IBM would like to hear about "Microsoft's business strategy regarding Linux", and they'd like to chat about the Caldera antitrust litigation against Microsoft too. Me, too. Me, too. Now about those shredded documents... And finally, they'd like "all communications or agreements relating to SCO or this litigation, including all communications with Baystar, Royal Bank of Canada, and Everyone's Internet, Ltd."

Yoo hoo. PIPE Fairy. Hope you like sunshine.

As for HP, IBM would like to see their contract licensing them to use UNIX. They'd like to know about any restrictions on employees having access to UNIX source code and all documents concerning "any agreements relating to any Hewlett-Packard software product involving Hewlett-Packard and AT&T, USL, Novell, Santa Cruz, Tarantella, or SCO." And any documents regarding any open sourcing of any HP UNIX product and all documejnts concerning the origin of any UNIX source code "publicly disclosed or open sourced by Hewlett-Packard." And they would like to see, or hear about, any agreements between SCO and HP. They'd like to know more about the indemnification plan of HP's also. And this is interesting, number 12:

12. All documents concerning any efforts to ensure or maintain the secrecy or confidentiality of any UNIX source code, know-how, concepts, techniques, or methods, including but not limited to: (a) any rule, policy, practice or procedure relating to the confidentiality or secrecy, or lack of confidentiality or secrecy, of any UNIX source code, know-how, concepts, techniques, or methods; any breach of any such rule, policy, practice or procedure; (c) the use by any person of any UNIX source code, know-how, concepts, techniques,, or methods; and (d) the disclosure or availability of any UNIX source code, know-how, concepts, techniques, or methods to any person.

I begin to think that every question we've had, we will finally get to know the answer.

I see comments indicating that some of you thought discovery was over. Here, from Groklaw's IBM Timeline page, is the schedule:

22-Dec-05 - Final Deadline for Parties to Identify with Specificity All Allegedly Misused Material

27-Jan-06 - Close of All Fact Discovery Except As to Defenses to Claims Relating to Allegedly Misused Material

17-Mar-06 - Close of All Remaining Discovery (i.e., Fact Discovery As to Defenses to Any Claim Relating to Allegedly Misused Material)

As you can see, we're in the part that I've highlighted in red, which is over on March 17. It's all about defenses now. In other words, SCO filed it's list of ha ha allegedly misused material, and now IBM gets to do discovery to establish its defenses. Don't forget the expert witnesses also:

14-Apr-06 - Initial Expert Reports

19-May-06 - Opposing Expert Reports

16-Jun-06 - Rebuttal Expert Reports

10-July-06 - Final Deadline for Expert Discovery

And then, ta da! Dispositive motions.


TOPICS: Business/Economy; Crime/Corruption; Technical
KEYWORDS: ibm; linux; microsoft; sco; sun
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To: MikeinIraq
Pitty too, I really like to watch him twist and turn and try to explain away the various deficiencies in his Master's company and products.
41 posted on 02/22/2006 1:10:54 PM PST by AFreeBird (your mileage may vary)
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To: Salo; ShadowAce

Huh? I thought you said this trial was going to be over at the very first summary judgement request, but it's still going on? IBM is now the one on the fishing expedition? That sounds desperate to me, at least that's what you said about SCO's discovery. Looks like IBM is on the ropes now, doesn't it. Especially since they're on the hook already for giving Novell $50 million themselves.


42 posted on 02/22/2006 2:20:48 PM PST by Golden Eagle
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To: Golden Eagle
I thought you said this trial was going to be over at the very first summary judgement request,...

See--that's what happens when you think. Things get all wrong in your head.

43 posted on 02/22/2006 2:23:32 PM PST by ShadowAce (Linux -- The Ultimate Windows Service Pack)
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To: AFreeBird
I wont miss him one bit, a rude spiteful little troll and were all better off with him gone. If you think he is crude on the board you should see some of the things he drops in peoples mailboxes..
44 posted on 02/22/2006 2:26:07 PM PST by N3WBI3 (If SCO wants to go fishing they should buy a permit and find a lake like the rest of us..)
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To: Golden Eagle

Yea SCO sends out discovery notices to Intel a few hours before its due and IBM is the desperate one? Thats what happens when you think, its like watching the Texans Play the Saints, its bound to be ugly but still fun to watch..


45 posted on 02/22/2006 2:28:47 PM PST by N3WBI3 (If SCO wants to go fishing they should buy a permit and find a lake like the rest of us..)
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To: N3WBI3
If you think he is crude on the board you should see some of the things he drops in peoples mailboxes..

It's always best to post abusive PMs right in the thread that spawned them.

46 posted on 02/22/2006 2:30:03 PM PST by Petronski (I love Cyborg!)
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To: ShadowAce
See--that's what happens when you listen to what I have to say.

What you should have said. Much more correct to the point.

47 posted on 02/22/2006 2:31:28 PM PST by Golden Eagle
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To: N3WBI3
IBM is the desperate one?

Must be, according to you guys. At least that's what you said about SCO's discovery, how is this any different?

48 posted on 02/22/2006 2:33:28 PM PST by Golden Eagle
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To: Salo

bttt


49 posted on 02/22/2006 2:40:49 PM PST by shield (The fear of the LORD is the beginning of knowledge: but fools despise wisdom and instructions.Pr 1:7)
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To: Golden Eagle
The Difference, if you could read, is this:

27-Jan-06 - Close of All Fact Discovery Except As to Defenses to Claims Relating to Allegedly Misused Material

17-Mar-06 - Close of All Remaining Discovery (i.e., Fact Discovery As to Defenses to Any Claim Relating to Allegedly Misused Material)

Given SCO did nothing but pile on last minute discovery (you were noticeably quiet on the SCO-Intel threads). IBM is now properly using this phase of the trial to gather information for its defense. This is a normal part of any proceeding in which the defendant (IBM) is allowed final discovery after the Plaintiff has finished making their claims. Now if IBM keeps this up for 3 years then, maybe, you'll have a point.
50 posted on 02/22/2006 2:41:11 PM PST by N3WBI3 (If SCO wants to go fishing they should buy a permit and find a lake like the rest of us..)
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To: Petronski

Decorum prevented me from doing so, and some of the ones I saw which he sent to others were even worse..


51 posted on 02/22/2006 2:42:15 PM PST by N3WBI3 (If SCO wants to go fishing they should buy a permit and find a lake like the rest of us..)
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To: N3WBI3

So what, this is still laaaaaaaaate in the process for IBM, who supposedly had this thing wrapped up before it even began, at least according to you guys. "Fishing Expedition" I seem to recall, many many times.


52 posted on 02/22/2006 2:47:36 PM PST by Golden Eagle
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To: N3WBI3

Oh you poor little things, so terrible they couldn't be repeated. Sure they were. Who you whiners talking about, anyway?


53 posted on 02/22/2006 2:48:48 PM PST by Golden Eagle
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To: N3WBI3

I've done it, with asterisks or "font color=white" to redact parts of words. Sunlight is the best disinfectant.


54 posted on 02/22/2006 2:48:55 PM PST by Petronski (I love Cyborg!)
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To: Petronski

I think at least one warning would be fair, and only if you post your own comments as well. I might do that before I cried to the administrators, but some around here seem to do that at the drop of a hat.


55 posted on 02/22/2006 2:57:03 PM PST by Golden Eagle
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To: N3WBI3
I see his sidekick showed up... I forgot all about the golden turkey... well no, I didn't really forget about him; actually, I think they're one and the same; spererated at birth; or competeing for the honors at their Master's butt.

Either way, they're a humorous bunch.

56 posted on 02/22/2006 2:58:45 PM PST by AFreeBird (your mileage may vary)
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To: Golden Eagle

If I get an abusive private mail out of the blue (and not part of an ongoing PM conversation), it goes in the thread.

I don't see where a warning is necessary.


57 posted on 02/22/2006 2:59:24 PM PST by Petronski (I love Cyborg!)
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To: Petronski

That's up to you, guess I've never gotten one I felt I couldn't handle on my own.


58 posted on 02/22/2006 3:07:23 PM PST by Golden Eagle
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To: Golden Eagle
...I felt I couldn't handle on my own.

That's how I handle it on my own.

59 posted on 02/22/2006 3:28:00 PM PST by Petronski (I love Cyborg!)
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To: Golden Eagle
Who you whiners talking about, anyway?

Like you don't know.

60 posted on 02/22/2006 3:37:30 PM PST by stainlessbanner (Downhome Dixie)
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