Sullivan

I. Statement of Facts and Procedural Background

Defendant Oracle Corporation (“Oracle”) is a Delaware corporation with its principal place of business in California. Plaintiffs are “Instructors” — to use Oracle’s term — who trained customers to use Oracle software. The parties stipu-

*The Honorable Louis H. Pollak, Senior United States District Judge for the Eastern District of Pennsylvania, sitting by designation.

1841 1842 SULLIVAN v. ORACLE CORP. lated in federal district court that from April 1999 to June 2006 (the date of the stipulation) Oracle “utilized Instructors on a contract basis through its subsidiary, Oracle Corporation Canada, to perform work inside the United States [and] inside the State of California.” According to the stipulation, Oracle provided the training materials used by Plaintiffs. Oracle “rec- ognized revenue” for work performed by Plaintiffs in the United States (including California). Oracle “required its Instructors to travel to destinations within the United States away from their city of domicile for the purpose of perform- ing work for Oracle.” At all relevant times, all three plaintiffs resided in the United States. All three of…