UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C. 20436
Before the Honorable Thomas B. Pender
Administrative Law Judge
In the Matter of
CERTAIN COMPUTING OR GRAPHICS
SYSTEMS, COMPONENTS THEREOF,
AND VEHICLES CONTAINING SAME
Investigation No. 337-TA-984
RESPONDENTS’ JOINT IDENTIFICATION OF EXPERTS
Pursuant to the Procedural Schedule set by Order No. 6 in this Investigation,
Respondents 1 provide their Joint Identification of Experts. 2 This disclosure also includes a
description of each expert’s qualifications and the general nature of the subject matter on which
each expert is expected to testify. This identification of experts is based on Respondents’ current
understanding of the evidence produced thus far during discovery and to the extent discernible,
Complainant’s positions taken to date. Inasmuch as discovery is ongoing, Respondents reserve
the right to supplement or amend this identification. In addition to the experts identified below,
1
Respondents include (1) Bayerische Motoren Werke AG, BMW of North America, LLC, and
BMW Manufacturing Co., LLC (collectively “BMW”); (2) FUJITSU TEN LIMITED and
FUJITSU TEN CORP. OF AMERICA (collectively “Fujitsu Ten”); (3) Harman Int’l Industries,
Inc., Harman Becker Automotive Sys., Inc., and Harman Becker Automotive Sys. GmbH
(collectively “Harman”); (4) Honda Motor Co., Ltd., Honda North America, Inc., American
Honda Motor Co., Inc., Honda Engineering North America, Inc., Honda of America Mfg., Inc.,
Honda Manufacturing of Alabama, LLC, Honda Manufacturing of Indiana, LLC, and Honda
R&D Americas, Inc. (collectively “Honda”); (5) NVIDIA Corporation (“NVIDIA”); (6) Renesas
Electronics Corporation and Renesas Electronics America Inc. (collectively “Renesas”);
(7) Texas Instruments Incorporated (“TI”); (8) Toyota Motor Corporation, Toyota Motor North
America, Inc., Toyota Motor Sales, U.S.A., Inc., Toyota Motor Engineering & Manufacturing,
North America, Inc., Toyota Motor Manufacturing, Indiana, Inc., Toyota Motor Manufacturing,
Kentucky, Inc., and Toyota Motor Manufacturing, Mississippi, Inc. (collectively “Toyota”); and
(9) Volkswagen AG, Volkswagen Group of America, Inc., Volkswagen Group of America
Chattanooga Operations, LLC, Audi AG, and Audi of America, LLC (collectively “VW/Audi”).
2
“Asserted Patents” means U.S. Patent Nos. 6,339,428 (“the ’428 patent”), 6,546,439 (“the ’439
patent”), 6,630,935 (“the ’935 patent”), and 8,933,945 (“the ’945 patent”).
Respondents reserve the right to proffer testimony from any expert identified by Complainant in
this Investigation.
1.
Dr. Tor Aamodt
Dr. Tor Aamodt is an expert in the fields of computer engineering, computer architecture,
and graphics processing hardware and software. Dr. Aamodt’s qualifications are set forth in his
curriculum vitae, attached as Attachment 1. The general nature of Dr. Aamodt’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr. Aamodt
may rebut expert witness testimony and reports of Complainant’s experts.
2.
Dr. John Airey
Dr. John Airey is an expert in the technical matters in this Investigation, including
without limitation, computer graphics, including computer graphics architectures; graphics
software; graphics processors; microprocessors; and the usage of graphics software, graphics
processors, microprocessors, and computer graphics in vehicles. Dr. Airey’s qualifications are
set forth in his curriculum vitae, attached as Attachment 2. The general nature of Dr. Airey’s
hearing testimony is presently expected to relate to the technical background of the Asserted
Patents, qualifications of a person of ordinary skill in the art, claim construction of the Asserted
Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack
of domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
Airey may rebut expert witness testimony and reports of Complainant’s experts.
2
3.
Dr. David H. Albonesi
Dr. David H. Albonesi is an expert in the fields of computer engineering, computer
architecture, and graphics processing unit (“GPU”) design. Dr. Albonesi’s qualifications are set
forth in his curriculum vitae, attached as Attachment 3. The general nature of Dr. Albonesi’s
hearing testimony is presently expected to relate to technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
Albonesi may rebut expert witness testimony and reports of Complainant’s experts.
4.
Dr. Donald Alpert
Dr. Donald Alpert is an expert in the technical matters in this Investigation, including
without limitation, computer systems; computer architecture; microprocessors; parallel
processing; computer memory; computer graphics; graphics processors; and the usage of
computer memory with graphics processors. Dr. Alpert’s qualifications are set forth in his
curriculum vitae, attached as Attachment 4. The general nature of Dr. Alpert’s hearing
testimony is presently expected to relate to technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr. Alpert
may rebut expert witness testimony and reports of Complainant’s experts.
5.
Dr. David I. August
Dr. David I. August is an expert in the fields of computer science, computer engineering,
and computer architecture. Dr. August’s qualifications are set forth in his curriculum vitae,
attached as Attachment 5. The general nature of Dr. August’s hearing testimony is presently
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expected to relate to technical background of the Asserted Patents, qualifications of a person of
ordinary skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted
Patents, noninfringement of the Asserted Patents, and/or lack of domestic industry technical
prong with regard to the Asserted Patents. Additionally, Dr. August may rebut expert witness
testimony and reports of Complainant’s experts.
6.
Dr. Mike Bailey
Dr. Mike Bailey is an expert in the fields of computer engineering, computer architecture,
and graphics processing. Dr. Bailey’s qualifications are set forth in his curriculum vitae,
attached as Attachment 6. The general nature of Dr. Bailey’s hearing testimony is presently
expected to relate to the technical background of the Asserted Patents, qualifications of a person
of ordinary skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted
Patents, noninfringement of the Asserted Patents, and/or lack of domestic industry technical
prong with regard to the Asserted Patents. Additionally, Dr. Bailey may rebut expert witness
testimony and reports of Complainant’s experts.
7.
Dr. Nader Bagherzadeh
Dr. Nader Bagherzadeh is an expert in the fields of electrical engineering, computer
engineering, computer architecture, and graphics processing. Dr. Bagherzadeh’s qualifications
are set forth in his curriculum vitae, attached as Attachment 7. The general nature of Dr.
Bagherzadeh’s hearing testimony is presently expected to relate to the technical background of
the Asserted Patents, qualifications of a person of ordinary skill in the art, claim construction of
the Asserted Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents,
and/or lack of domestic industry technical prong with regard to the Asserted Patents.
Additionally, Dr. Bagherzadeh may rebut expert witness testimony and reports of Complainant’s
experts.
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8.
Mr. Kaylan Banerjee
Mr. Kaylan Banerjee is an expert in the field of electrical engineering, specializing in
relevant areas such as the review of software source code and hardware description languages as
relates to the operation of computer software and hardware. Mr. Banerjee’s qualifications are set
forth in his curriculum vitae, attached as Attachment 8. The general nature of Mr. Banerjee’s
hearing testimony is presently expected to relate to the technical background of the Asserted
Patents, qualifications of a person of ordinary skill in the art, claim construction of the Asserted
Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack
of domestic industry technical prong with regard to the Asserted Patents. Additionally, Mr.
Banerjee may rebut expert witness testimony and reports of Complainant’s experts.
9.
Mr. Kevin Bergen
Mr. Kevin Bergen is an expert in the field of electrical engineering, specializing in
relevant areas such as the review of software source code and hardware description languages as
relates to the operation of computer software and hardware. Mr. Bergen’s qualifications are set
forth in his curriculum vitae, attached as Attachment 9. The general nature of Mr. Bergen’s
hearing testimony is presently expected to relate to the technical background of the Asserted
Patents, qualifications of a person of ordinary skill in the art, claim construction of the Asserted
Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack
of domestic industry technical prong with regard to the Asserted Patents. Additionally, Mr.
Bergen may rebut expert witness testimony and reports of Complainant’s experts.
10.
Mr. Grant Bewers
Mr. Grant Bewers is an expert in the field of computer science, specializing in relevant
areas such as the review of software source code and hardware description languages as relates
to products incorporating the same. Mr. Bewers’s qualifications are set forth in his curriculum
5
vitae, attached as Attachment 10. The general nature of Mr. Bewers’s hearing testimony is
presently expected to relate to the technical background of the Asserted Patents, qualifications of
a person of ordinary skill in the art, claim construction of the Asserted Patents, invalidity of the
Asserted Patents, noninfringement of the Asserted Patents, and/or lack of domestic industry
technical prong with regard to the Asserted Patents. Additionally, Mr. Bewers may rebut expert
witness testimony and reports of Complainant’s experts.
11.
Mr. Randy M. Bonella
Mr. Randy M. Bonella is an expert in the technical matters in this Investigation, including
without limitation, computer memory; computer graphics; graphics processors; microprocessors;
the usage of computer memory with graphics processors, microprocessors, and computer
graphics; and the usage of graphics processors, microprocessors, and computer graphics in
vehicles. Mr. Bonella’s qualifications are set forth in his curriculum vitae, attached as
Attachment 11. The general nature of Mr. Bonella’s hearing testimony is presently expected to
relate to the technical background of the Asserted Patents, qualifications of a person of ordinary
skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Mr. Bonella may rebut expert witness testimony
and reports of Complainant’s experts.
12.
Dr. Robert P. Colwell
Dr. Robert P. Colwell is an expert in processor architecture, computer graphics
processing, parallel processing, and related hardware and software. Dr. Colwell’s qualifications
are set forth in his curriculum vitae, attached as Attachment 12. The general nature of Dr.
Colwell’s hearing testimony is presently expected to relate to the technical background of the
Asserted Patents, qualifications of a person of ordinary skill in the art, claim construction of the
6
Asserted Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents,
and/or lack of domestic industry technical prong with regard to the Asserted
Patents. Additionally, Dr. Colwell may rebut expert witness testimony and reports of
Complainant’s experts.
13.
Dr. Dan Connors
Dr. Dan Connors is an expert in processor architecture, computer graphics processing,
parallel processing, and related hardware and software. Dr. Connors’s qualifications are set forth
in his curriculum vitae, attached as Attachment 13. The general nature of Dr. Connors’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
Connors may rebut expert witness testimony and reports of Complainant’s experts.
14.
Dr. Thomas Martin Conte
Dr. Thomas Martin Conte is an expert in processor architecture, computer graphics
processing, parallel processing, and related hardware and software. Dr. Conte’s qualifications
are set forth in his curriculum vitae, attached as Attachment 14. The general nature of Dr.
Conte’s hearing testimony is presently expected to relate to the technical background of the
Asserted Patents, qualifications of a person of ordinary skill in the art, claim construction of the
Asserted Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents,
and/or lack of domestic industry technical prong with regard to the Asserted
Patents. Additionally, Dr. Conte may rebut expert witness testimony and reports of
Complainant’s experts.
7
15.
Dr. Roger Crawfis
Dr. Roger Crawfis is an expert in the field of computer science, specializing in relevant
areas such as computer graphics, computer graphics processing systems, and related software
and hardware. Dr. Crawfis’s qualifications are set forth in his curriculum vitae, attached as
Attachment 15. The general nature of Dr. Crawfis’s hearing testimony is presently expected to
relate to the technical background of the Asserted Patents, qualifications of a person of ordinary
skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Dr. Crawfis may rebut expert witness testimony
and reports of Complainant’s experts.
16.
Mr. John Crockett
Mr. John Crockett is an expert in the field of electrical engineering and computer science,
specializing in areas such as source code and hardware description languages relating to
computer software and hardware. Mr. Crockett’s qualifications are set forth in his curriculum
vitae, attached as Attachment 16. The general nature of Mr. Crockett’s hearing testimony is
presently expected to relate to the technical background of the Asserted Patents, qualifications of
a person of ordinary skill in the art, claim construction of the Asserted Patents, invalidity of the
Asserted Patents, noninfringement of the Asserted Patents, and/or lack of domestic industry
technical prong with regard to the Asserted Patents. Additionally, Mr. Crockett may rebut expert
witness testimony and reports of Complainant’s experts.
17.
Mr. Keith Diefendorff
Mr. Keith Diefendorff is an expert in the field of electrical and computer engineering,
specializing in relevant areas such as processor architecture and operation. Mr. Diefendorff’s
qualifications are set forth in his curriculum vitae, attached as Attachment 17. The general
8
nature of Mr. Diefendorff’s hearing testimony is presently expected to relate to the technical
background of the Asserted Patents, qualifications of a person of ordinary skill in the art, claim
construction of the Asserted Patents, invalidity of the Asserted Patents, noninfringement of the
Asserted Patents, and/or lack of domestic industry technical prong with regard to the Asserted
Patents. Additionally, Mr. Diefendorff may rebut expert witness testimony and reports of
Complainant’s experts.
18.
Dr. David Ebert
Dr. David Ebert is an expert in the fields of computer science and graphics processing
hardware and software. Dr. Ebert’s qualifications are set forth in his curriculum vitae, attached
as Attachment 18. The general nature of Dr. Ebert’s hearing testimony is presently expected to
relate to the technical background of the Asserted Patents, qualifications of a person of ordinary
skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Dr. Ebert may rebut expert witness testimony and
reports of Complainant’s experts.
19.
Dr. Adam Finkelstein
Dr. Adam Finkelstein is an expert in the field of computer science, specializing in areas
such as computer architecture, computer graphics, computer graphics processing systems, and
related software and hardware. Dr. Finkelstein’s qualifications are set forth in his curriculum
vitae, attached as Attachment 19. The general nature of Dr. Finkelstein’s hearing testimony is
presently expected to relate to the technical background of the Asserted Patents, qualifications of
a person of ordinary skill in the art, claim construction of the Asserted Patents, invalidity of the
Asserted Patents, noninfringement of the Asserted Patents, and/or lack of domestic industry
9
technical prong with regard to the Asserted Patents. Additionally, Dr. Finkelstein may rebut
expert witness testimony and reports of Complainant’s experts.
20.
Dr. Eugene Fiume
Dr. Eugene Fiume is an expert in computer graphics, computer graphics processing
systems, and related software and hardware. Dr. Fiume’s qualifications are set forth in his
curriculum vitae, attached as Attachment 20. The general nature of Dr. Fiume’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr. Fiume
may rebut expert witness testimony and reports of Complainant’s experts.
21.
Dr. Henry Fuchs
Dr. Henry Fuchs is an expert in the fields of computer science, computer architecture,
and graphics processing hardware and software. Dr. Fuchs’s qualifications are set forth in his
curriculum vitae, attached as Attachment 21.
The general nature of Dr. Fuchs’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr. Fuchs
may rebut expert witness testimony and reports of Complainant’s experts.
22.
Dr. Donald Fussell
Dr. Donald Fussell is an expert in the technical matters in this Investigation, including
without limitation, computer graphics, including computer graphics architectures; graphics
software; graphics processors; microprocessors; and the usage of graphics software, graphics
10
processors, microprocessors, and computer graphics in vehicles. Dr. Fussell’s qualifications are
set forth in his curriculum vitae, attached as Attachment 22. The general nature of Dr. Fussell’s
hearing testimony is presently expected to relate to the technical background of the Asserted
Patents, qualifications of a person of ordinary skill in the art, claim construction of the Asserted
Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack
of domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
Fussell may rebut expert witness testimony and reports of Complainant’s experts.
23.
Mr. Richard M. Goodin
Mr. Richard Goodin is an expert in processor architecture, computer graphics processing,
parallel processing, and related hardware and software. Mr. Goodin’s qualifications are set forth
in his curriculum vitae, attached as Attachment 23. The general nature of Mr. Goodin’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Mr. Goodin
may rebut expert witness testimony and reports of Complainant’s experts.
24.
Mr. Carlos Greaves
Mr. Carlos Greaves is an expert in the field of electrical engineering, specializing in
relevant areas such as semiconductor design and manufacturing and the review of software
source code and hardware description languages as relates to the operation of computer software
and hardware. Mr. Greaves’s qualifications are set forth in his curriculum vitae, attached as
Attachment 24. The general nature of Mr. Greaves’s hearing testimony is presently expected to
relate to the technical background of the Asserted Patents, qualifications of a person of ordinary
skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
11
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Mr. Greaves may rebut expert witness testimony
and reports of Complainant’s experts.
25.
Karl M. Guttag
Mr. Karl M. Guttag is an expert in processor architecture, computer graphics processing,
parallel processing, and related hardware and software. Mr. Guttag’s qualifications are set forth
in his curriculum vitae, attached as Attachment 25. The general nature of Mr. Guttag’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Mr. Guttag
may rebut expert witness testimony and reports of Complainant’s experts.
26.
Mr. William K. Hoffman
Mr. William K. Hoffman is an expert in the field of electrical engineering and computer
science, specializing in areas such as computer and processor architecture, memory systems, and
related software and hardware. Mr. Hoffman’s qualifications are set forth in his curriculum
vitae, attached as Attachment 26. The general nature of Mr. Hoffman’s hearing testimony is
presently expected to relate to the technical background of the Asserted Patents, qualifications of
a person of ordinary skill in the art, claim construction of the Asserted Patents, invalidity of the
Asserted Patents, noninfringement of the Asserted Patents, and/or lack of domestic industry
technical prong with regard to the Asserted Patents. Additionally, Mr. Hoffman may rebut
expert witness testimony and reports of Complainant’s experts.
12
27.
Dr. Robert Horst
Dr. Robert Horst is an expert in the technical matters in this Investigation, including
without limitation, computer memory; computer graphics; graphics processors; microprocessors;
the usage of computer memory with graphics processors, microprocessors, and computer
graphics; and the usage of graphics processors, microprocessors, and computer graphics in
vehicles. Dr. Horst’s qualifications are set forth in his curriculum vitae, attached as Attachment
27. The general nature of Dr. Horst’s hearing testimony is presently expected to relate to the
technical background of the Asserted Patents, qualifications of a person of ordinary skill in the
art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Dr. Horst may rebut expert witness testimony and
reports of Complainant’s experts.
28.
Mr. Joachim Kobinger
Joachim H. Kobinger is a self-employed consultant on matters of automotive
management, technology, and engineering. Mr. Kobinger spent 20 years at Harman (and its
predecessor, Becker) as a Development Engineer and Vice President for Product Engineering in
the automotive infotainment and audio spaces. Mr. Kobinger’s qualifications are set forth in his
curriculum vitae, attached as Attachment 28. The general nature of Mr. Kobinger’s hearing
testimony is presently expected to relate to the potential impact of the relief requested by the
Complainant on the public interest, economic and market conditions, the EPROMS factors,
remedy, and exclusionary order issues. Additionally, Mr. Kobinger may rebut expert witness
testimony and reports of Complainant’s experts.
13
29.
Ms. Priti Jacob Kujur
Ms. Priti Jacob Kujur is an expert in the field of electrical engineering, specializing in
relevant areas such as the review of software source code and hardware description languages as
relates to the operation of computer software and hardware. Ms. Kujur’s qualifications are set
forth in her curriculum vitae, attached as Attachment 29. The general nature of Ms. Kujur’s
hearing testimony is presently expected to relate to the technical background of the Asserted
Patents, qualifications of a person of ordinary skill in the art, claim construction of the Asserted
Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack
of domestic industry technical prong with regard to the Asserted Patents. Additionally, Ms.
Kujur may rebut expert witness testimony and reports of Complainant’s experts.
30.
Dr. Anselmo Lastra
Dr. Anselmo Lastra is an expert in processor architecture, computer graphics processing,
parallel processing, and related hardware and software. Dr. Lastra’s qualifications are set forth
in his curriculum vitae, attached as Attachment 30. The general nature of Dr. Lastra’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr. Lastra
may rebut expert witness testimony and reports of Complainant’s experts.
31.
Mr. Peter D. MacWilliams
Mr. Peter D. MacWilliams is an expert in the fields of electrical engineering, computer
science, and computer architecture. Mr. MacWilliams’s qualifications are set forth in his
curriculum vitae, attached as Attachment 31. The general nature of Mr. MacWilliams’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
14
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
MacWilliams may rebut expert witness testimony and reports of Complainant’s experts.
32.
Dr. Dinesh Manocha
Dr. Dinesh Manocha is an expert in the field of computer science, specializing in relevant
areas such as computer graphics, computer graphics processing systems, and related software
and hardware. Dr. Manocha’s qualifications are set forth in his curriculum vitae, attached as
Attachment 32. The general nature of Dr. Manocha’s hearing testimony is presently expected to
relate to the technical background of the Asserted Patents, qualifications of a person of ordinary
skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Dr. Manocha may rebut expert witness testimony
and reports of Complainant’s experts.
33.
Dr. Pinaki Mazumder
Dr. Pinaki Mazumder is an expert in the fields of electrical engineering, computer
engineering, and computer architecture. Dr. Mazumder’s qualifications are set forth in his
curriculum vitae, attached as Attachment 33. The general nature of Dr. Mazumder’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents Additionally, Dr.
Mazumder may rebut expert witness testimony and reports of Complainant’s experts.
15
34.
Dr. Timothy N. Miller
Dr. Timothy N. Miller is an expert in the technical matters in this Investigation, including
without limitation, computer systems; computer architecture; microprocessors; parallel
processing; computer memory; computer graphics; graphics processors; and the usage of
computer memory with graphics processors. Dr. Miller’s qualifications are set forth in his
curriculum vitae, attached as Attachment 34. The general nature of Dr. Miller’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents Additionally, Dr. Miller
may rebut expert witness testimony and reports of Complainant’s experts.
35.
Dr. Todd Mowry
Dr. Todd Mowry is an expert in the technical matters in this Investigation, including
without limitation, computer systems; computer architecture; microprocessors; computer
memory; graphics processing, and parallel and multi-threaded processing. Dr. Mowry’s
qualifications are set forth in his curriculum vitae, attached as Attachment 35. The general
nature of Dr. Mowry’s hearing testimony is presently expected to relate to the technical
background of the Asserted Patents, qualifications of a person of ordinary skill in the art, claim
construction of the Asserted Patents, invalidity of the Asserted Patents, noninfringement of the
Asserted Patents, and/or lack of domestic industry technical prong with regard to the Asserted
Patents. Additionally, Dr. Mowry may rebut expert witness testimony and reports of
Complainant’s experts.
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36.
Ms. Carla Mulhern
Ms. Carla Mulhern’s area of expertise includes, but is not limited to, applied economic,
market and damage analysis and international trade disputes. Ms. Mulhern’s qualifications are
set forth in her curriculum vitae, attached as Attachment 36. The general nature of Ms.
Mulhern’s hearing testimony is presently expected to relate to the economic prong of the
domestic industry requirement as well as issues of remedy, bonding, public interest, and
secondary considerations, including any alleged commercial success. Additionally, Ms. Mulhern
may rebut expert witness testimony and reports of Complainant’s experts.
37.
Dr. John Owens
Dr. John Owens is an expert in the fields of electrical engineering, computer science,
computer architecture, and graphics hardware and software. Dr. Owen’s qualifications are set
forth in his curriculum vitae, attached as Attachment 37. The general nature of Dr. Owen’s
hearing testimony is presently expected to relate to the technical background of the Asserted
Patents, qualifications of a person of ordinary skill in the art, claim construction of the Asserted
Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack
of domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
Owens may rebut expert witness testimony and reports of Complainant’s experts.
38.
Mr. Isaac J. Pflaum
Mr. Isaac J. Pflaum is an expert in the field of electrical engineering and computer
science, specializing in relevant areas such as software source code and hardware description
languages as relates to the operation of computer software and hardware. Mr. Pflaum’s
qualifications are set forth in his curriculum vitae, attached as Attachment 38. The general
nature of Mr. Pflaum’s hearing testimony is presently expected to relate to the technical
background of the Asserted Patents, qualifications of a person of ordinary skill in the art, claim
17
construction of the Asserted Patents, invalidity of the Asserted Patents, noninfringement of the
Asserted Patents, and/or lack of domestic industry technical prong with regard to the Asserted
Patents. Additionally, Mr. Pflaum may rebut expert witness testimony and reports of
Complainant’s experts.
39.
Dr. Stephen D. Prowse
Dr. Stephen D. Prowse is an expert in economics analysis, financial statistical analysis,
and valuation. Dr. Prowse’s qualifications are set forth in his curriculum vitae, attached as
Attachment 39. The general nature of Dr. Prowse’s hearing testimony is presently expected to
relate to the potential impact of the relief requested by the Complainant on the public interest,
economic and market conditions, competitive conditions in the U.S. economy, the EPROMS
factors, lack of economic domestic industry, remedy, bonding, and exclusionary order issues.
Additionally, Dr. Prowse may rebut expert witness testimony and reports of Complainant’s
experts.
40.
Mr. Pogula Yashwanth Reddy
Mr. Pogula Yashwanth Reddy is an expert in the field of electrical engineering,
specializing in relevant areas such as the review of software source code and hardware
description languages as relates to products incorporating the same. Mr. Reddy’s qualifications
are set forth in his curriculum vitae, attached as Attachment 40. The general nature of Mr.
Reddy’s hearing testimony is presently expected to relate to the technical background of the
Asserted Patents, qualifications of a person of ordinary skill in the art, claim construction of the
Asserted Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents,
and/or lack of domestic industry technical prong with regard to the Asserted Patents.
Additionally, Mr. Reddy may rebut expert witness testimony and reports of Complainant’s
experts.
18
41.
Dr. Jeffrey J. Rodriguez
Dr. Jeffrey J. Rodriguez is an expert in the technical matters in this Investigation,
including without limitation, computer systems; computer architecture; microprocessors;
computer memory; and graphics processing. Dr. Rodriquez’s qualifications are set forth in his
curriculum vitae, attached as Attachment 41. The general nature of Dr. Rodriguez’s hearing
testimony is presently expected to relate to the technical background of the Asserted Patents,
qualifications of a person of ordinary skill in the art, claim construction of the Asserted Patents,
invalidity of the Asserted Patents, noninfringement of the Asserted Patents, and/or lack of
domestic industry technical prong with regard to the Asserted Patents. Additionally, Dr.
Rodriguez may rebut expert witness testimony and reports of Complainant’s experts.
42.
Dr. Carl Sechen
Dr. Carl Sechen is an expert in the fields of electrical engineering and computer
architecture. Dr. Sechen’s qualifications are set forth in his curriculum vitae, attached as
Attachment 42. The general nature of Dr. Sechen’s hearing testimony is presently expected to
relate to the technical background of the Asserted Patents, qualifications of a person of ordinary
skill in the art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Dr. Sechen may rebut expert witness testimony and
reports of Complainant’s experts.
43.
Mr. Jason Spotts
Mr. Jason Spotts is an expert in the field of electrical and computer engineering,
specializing in relevant areas such as the review of software source code and hardware
description languages as relates to products incorporating the same. Mr. Spotts’s qualifications
are set forth in his curriculum vitae, attached as Attachment 43. The general nature of Mr.
19
Spotts’s hearing testimony is presently expected to relate to the technical background of the
Asserted Patents, qualifications of a person of ordinary skill in the art, claim construction of the
Asserted Patents, invalidity of the Asserted Patents, noninfringement of the Asserted Patents,
and/or lack of domestic industry technical prong with regard to the Asserted Patents.
Additionally, Mr. Spotts may rebut expert witness testimony and reports of Complainant’s
experts.
44.
Dr. Harold S. Stone
Dr. Harold S. Stone is an expert in the field of electrical engineering and computer
science, specializing in areas such as computer and processor architecture, memory systems,
computer graphics processing systems, and related software and hardware. Dr. Stone’s
qualifications are set forth in his curriculum vitae, attached as Attachment 44. The general
nature of Dr. Stone’s hearing testimony is presently expected to relate to the technical
background of the Asserted Patents, qualifications of a person of ordinary skill in the art, claim
construction of the Asserted Patents, invalidity of the Asserted Patents, noninfringement of the
Asserted Patents, and/or lack of domestic industry technical prong with regard to the Asserted
Patents. Additionally, Dr. Stone may rebut expert witness testimony and reports of
Complainant’s experts.
45.
Dr. Thomas D. Vander Veen
Dr. Thomas D. Vander Veen is an expert in the field of economics with expertise in the
application of economics to intellectual property and international trade. Dr. Vander Veen’s
qualifications are set forth in his curriculum vitae, attached as Attachment 45. The general
nature of Dr. Vander Veen’s hearing testimony is presently expected to relate to the potential
impact of the relief requested by Complainant on the public interest, economic and market
conditions, competitive conditions in the U.S. economy, the EPROMS factors, lack of economic
20
domestic industry, remedy, bonding, and exclusionary order issues. Additionally, Dr. Vander
Veen may rebut expert witness testimony and reports of Complainant’s experts.
46.
Dr. Woodward Yang
Dr. Woodward Yang is an expert in the technical matters in this Investigation, including
without limitation, computer memory; computer graphics; graphics processors; microprocessors;
the usage of computer memory with graphics processors, microprocessors, and computer
graphics; and the usage of graphics processors, microprocessors, and computer graphics in
vehicles. Dr. Yang’s qualifications are set forth in his curriculum vitae, attached as Attachment
46. The general nature of Dr. Yang’s hearing testimony is presently expected to relate to the
technical background of the Asserted Patents, qualifications of a person of ordinary skill in the
art, claim construction of the Asserted Patents, invalidity of the Asserted Patents,
noninfringement of the Asserted Patents, and/or lack of domestic industry technical prong with
regard to the Asserted Patents. Additionally, Dr. Yang may rebut expert witness testimony and
reports of Complainant’s experts.
47.
Dr. Martin B. Zimmerman
Dr. Martin B. Zimmerman is an expert in the field of economics including the economics
of the automobile industry. Dr. Zimmerman’s qualifications are set forth in his curriculum vitae,
attached as Attachment 47. The general nature of Dr. Zimmerman’s hearing testimony is
presently expected to relate to the potential impact of the relief requested by Complainant on the
public interest, economic and market conditions, competitive conditions in the U.S. economy and
innovation relating to automobiles, the EPROMS factors, remedy, and exclusionary order issues.
Additionally, Dr. Zimmerman may rebut expert witness testimony and reports of Complainant’s
experts.
21
48.
Opinion Testimony from Other Witnesses
In addition to the expert witnesses identified above, Respondents reserve the right to offer
opinion testimony from lay witnesses that they call in the hearing in this Investigation as to
matters within the perception of the lay witness. Respondents further reserve the right to elicit
testimony that may be deemed expert testimony from lay witnesses who have the requisite
scientific, technical or other specialized knowledge to provide that testimony and Respondents
hereby designate those lay witnesses as experts with regard to any such testimony. Respondents’
reservations of rights to offer such testimony include, but are not limited to, opinion or expert
testimony.
Dated: April 1, 2016
By: /s/ Joseph P. Lavelle
Joseph P. Lavelle
Andrew N. Stein
DLA PIPER LLP (US)
500 Eighth Street, NW
Washington D.C. 20004
Telephone:
(202) 799-4000
Erin P. Gibson
DLA PIPER LLP (US)
401 B Street, Suite 1700
San Diego, CA 92101
Telephone:
(619) 699-2900
Erin McLaughlin
DLA Piper LLP (US)
2000 University Avenue
East Palo Alto, CA 94303-2215
Telephone:
(650) 833-2000
Email: BMW-AST-ITC@dlapiper.com
Counsel for Respondents Bayerische Motoren
Werke AG, BMW of North America, LLC, and
BMW Manufacturing Co., LLC
22
By: /s/ G. Brian Busey
G. Brian Busey
Hector G. Gallegos
Lynn I. Levine
Aaron D. Rauh
MORRISON & FOERSTER LLP
2000 Pennsylvania Avenue, N.W., Suite 6000
Washington, D.C. 20006
Telephone:
(202) 887-1500
A. Max Olson
Tak Miura
Yuka Teraguchi
MORRISON & FOERSTER LLP
Shin-Marunouchi Building, 29th Floor 5-1,
Marunouchi 1-Chome
Chiyoda-ku , Tokyo 100-6529, Japan
Telephone:
81-3-3214-6522
Ryan J. Malloy
Morrison & Foerster LLP
707 Wilshire Boulevard
Los Angeles, CA 90017-3543
Telephone: (213) 892-5200
Email: FJTen984@mofo.com
Counsel for Respondents FUJITSU TEN
LIMITED and FUJITSU TEN CORP. OF
AMERICA
By: /s/ Tobias W. Mock
Natalie Hanlon Leh
Mary V. (Mindy) Sooter
Anne Lee
WILMER CUTLER PICKERING
HALE & DORR LLP
1225 Seventeenth Street, Suite 1660
Denver, CO 80202
Telephone:
(720) 274-3160
Nina S. Tallon
WILMER CUTLER PICKERING
HALE & DORR LLP
1875 Pennsylvania Avenue, N.W.
Washington, D.C. 20006
Telephone:
(202) 663-6000
John P. Pettit
Tobias W. Mock
WILMER CUTLER PICKERING
HALE & DORR LLP
950 Page Mill Road
Palo Alto, CA 94304
Telephone:
(650) 858-6000
Email: WHHarman-ITCAdvancedSilicon
@wilmerhale.com
Counsel for Respondents Harman Int’l
Industries, Inc., Harman Becker
Automotive Sys., Inc., and Harman Becker
Automotive Sys. GmbH
By: /s/ G. Brian Busey
G. Brian Busey
Hector G. Gallegos
Lynn I. Levine
Aaron D. Rauh
MORRISON & FOERSTER LLP
2000 Pennsylvania Avenue, N.W., Suite 6000
Washington, D.C. 20006
Telephone:
(202) 887-1500
Vincent J. Belusko
Ryan J. Malloy
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, CA 90017-3543
Telephone:
(213) 892-5200
Takahiro Miura
Akira Irie
Yuka Teraguchi
MORRISON & FOERSTER LLP
Shin-Marunouchi Building, 29th Floor 5-1,
Marunouchi 1-Chome
Chiyoda-ku , Tokyo 100-6529, Japan
Telephone:
81-3-3214-6522
Email: Honda984@mofo.com
Counsel for Respondents Honda Motor Co.,
Ltd., Honda North America, Inc., American
Honda Motor Co., Inc., Honda Engineering
North America, Inc., Honda of America Mfg.,
Inc., Honda Manufacturing of Alabama, LLC,
Honda Manufacturing of Indiana, LLC,
and Honda R&D Americas, Inc.
23
By: /s/ Bert C. Reiser
Maximilian A. Grant
Bert C. Reiser
LATHAM & WATKINS LLP
555 Eleventh Street, NW, Suite 1000
Washington, DC 20004
Telephone:
(202) 637-2200
By: /s/ Kevin J. Malaney
John J. Feldhaus
Pavan K. Agarwal
Liane M. Peterson
Andrew R. Cheslock
Eoin P. Connolly
FOLEY & LARDNER LLP
Washington Harbour
3000 K Street, NW, Suite 600
Washington, DC 20007
Telephone:
(202) 672-5403
Justin M. Sobaje
FOLEY & LARDNER LLP
555 South Flower Street, Suite 3500
Los Angeles, CA 90071-2411
Telephone:
(213) 972-4500
Kevin J. Malaney
FOLEY & LARDNER LLP
777 East Wisconsin Avenue
Milwaukee, WI 53202-5306
Telephone:
(414) 271-2400
Email: Renesas-itc@foley.com
Counsel for Respondents Renesas
Electronics Corporation and Renesas
Electronics America Inc.
Ron E. Shulman
Latham & Watkins LLP
140 Scott Drive
Menlo Park, CA 94025
Telephone: (650) 328-4600
Facsimile: (650) 463-2600
Charles H. Sanders
LATHAM & WATKINS LLP
John Hancock Tower, 27th Floor
200 Clarendon Street
Boston, MA 02116
Telephone:
(617) 948-6000
Michael A. David
LATHAM & WATKINS LLP
885 Third Avenue
New York, NY 10022
Telephone:
(212) 906-2968
Email:
NVIDIAITCAST.LWTEAM@lw.com
Counsel for Respondent
NVIDIA Corporation
24
By: /s/ Dale A. Rice
Sturgis M. Sobin
Maureen F. Browne
Ranganath Sudarshan
Paul J. Wilson
COVINGTON & BURLING LLP
One CityCenter, 850 Tenth Street, NW
Washington, DC 20001
Telephone:
(202) 662-5040
Robert T. Haslam
Anupam Sharma
COVINGTON & BURLING LLP
333 Twin Dolphin Drive, Suite 700
Redwood Shores, CA 94065
Telephone:
(650) 632-4700
Dale A. Rice
COVINGTON & BURLING LLP
One Front Street
San Francisco, CA 94111
Telephone:
(415) 591-6000
Email: TI-AST@cov.com
Counsel for Respondent
Texas Instruments Incorporated
By: /s/ Thomas W. Winland
Thomas W. Winland
Smith R. Brittingham IV
James R. Barney
Houtan K. Esfahani
Anthony D. Del Monaco
Aidan C. Skoyles
Jose M. Recio
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, L.L.P.
901 New York Avenue, N.W.
Washington, D.C. 20001-4413
Telephone:
(202) 408-4000
Email: ToyotaITC984@finnegan.com
Counsel for Respondents Toyota Motor
Corporation, Toyota Motor North America,
Inc., Toyota Motor Sales, U.S.A., Inc., Toyota
Motor Engineering & Manufacturing, North
America, Inc., Toyota Motor Manufacturing,
Indiana, Inc., Toyota Motor Manufacturing,
Kentucky, Inc., and Toyota Motor
Manufacturing, Mississippi, Inc.
By: /s/ Nicholas J. Nowak
Daniel E. Yonan
Michael Specht
Nicholas J. Nowak
STERNE, KESSLER, GOLDSTEIN
& FOX P.L.L.C.
1100 New York Avenue
Washington, DC 20005
Telephone:
(202) 371-2600
Email: VW-AST-ITC@skgf.com
Counsel for Respondents Volkswagen AG,
Volkswagen Group of America, Inc.,
Volkswagen Group of America Chattanooga
Operations, LLC, Audi AG, and Audi of
America, LLC
25