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Rimini Street clients praise the product quality, comprehensiveness, and well-timed delivery of Rimini Street’s tax, legal and regulatory updates in media interviews, client recommendations for leads, and press materials. 19. Rimini Street respects the intellectual property privileges of Oracle. As detailed herein, Rimini Street takes extraordinary initiatives, in both process and procedure, to ensure that Oracle’s intellectual property rights are reputed by Rimini Street employees dealing with Oracle Software and Support Materials.

D. Oracle has an extended History of Trying to Stifle Rimini Street Competition. 20. Today’s lawsuit is only Oracle’s latest effort to stifle the competitive danger posed by Rimini Street. 21. Rimini Street began functions in September 2005, supplying a competitive aftermarket support offering for Siebel Systems software products. 22. At a comparable time Rimini Street began operations, Oracle Corporation announced that it intended to acquire Siebel Systems. Oracle completed the acquisition of Siebel Systems thereafter soon.

24. Since after Rimini Road’s inception shortly, Oracle started a systematic marketing campaign to disrupt and halt Rimini Street’s business. Initially, Oracle’s efforts consisted of numerous hostile words, some of that have been published in the press as soon as 2005 as examples of how Oracle was wanting to forestall after-market competition from a just-launched Rimini Street. 25. Over the years, Rimini Street responded to each Oracle letter, explained the appropriateness of Rimini Street’s methods and procedures, and repeatedly offered to meet and discuss any questions or concerns Oracle may have about Rimini Street’s procedures and methods.