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How do you deal with a person who believes in Orthodoxy and does not believe in metrics or feature validation?

Your organization has a legacy application that “works fine” but is getting increasingly difficult/ expensive to support. It is going to be re-written using modern technologies.

Sam is the Product Manager. Sam says the users are completely happy with the existing system and use all of its features (though usage statistics are not available).

Sam claims that the new system must “do exactly what the old system did.” Because of this, he says there is no need for a Product Owner or a Product Backlog, let alone any need for assigning business value. Is Sam helping or hindering? How?
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Sam is definitely hindering, the following steps would address this issue:

1) Understand his perspective- Why does he feel customer are happy. If metrics are not available, probably he is looking at some blogs, app store data or feedback from some of the customer

2) If execution metrics are not available, we can refer to progress metrics e.g. monetization numbers,app downloads, subscription numbers. These are numbers Sam cannot deny saying customer are happy.

3) Have Sam sign up to business goals e.g. revenue, customer base, number of app downloads etc. When he tries to evaluate these business goals, he will automatically have to refer to execution metrics.
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