UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before the Honorable Thomas B. Pender
`Administrative Law Judge
`
`In the Matter of
`CERTAIN ACCESS CONTROL
`SYSTEMS AND COMPONENTS
`THEREOF
`
`Investigation No. 337-TA-1016
`
`RESPONDENTS’ IDENTIFICATION OF EXPERT WITNESSES
`
`Respondents Techtronic Industries Company Limited; Techtronic Industries North
`
`America Inc.; One World Technologies, Inc.; OWT Industries, Inc.; Et Technology (Wuxi), Co.,
`
`Ltd.; and Ryobi Technologies, Inc.1 (collectively, the “Respondents”), pursuant to Ground Rule
`
`10, respectfully submit the following identification of expert witnesses who may testify on their
`
`behalf. The Respondents may present the testimony of its experts live, through witness
`
`statements, and/or depositions, as permitted by the Ground Rules. Curriculum vitae for these
`
`experts are attached hereto as Exhibits A - J.
`
`Michael S. Fagan
`
`Mr. Fagan is President and CEO of MokoNet, Inc., and has expertise in the areas set forth in his
`
`curriculum vitae, including, but not limited to, analysis of computer source code. Mr. Fagan
`
`may be called on to testify on the Respondents’ behalf in this Investigation, and may also be
`
`called to rebut the testimony of Complainant The Chamberlain Group, Inc.’s (“Chamberlain”)
`
`fact or expert witnesses, should any be presented. Mr. Fagan’s expertise is set forth in more
`
`detail in his curriculum vitae, which is attached hereto as Exhibit A.
`
`
`1 Ryobi does not exist and is the subject of pending motions to terminate and to stay.
`
`

`
`Philip Green
`
`Mr. Green is a Principal at Hoffman Alvary & Company LLC, and has expertise in the areas set
`
`forth in his curriculum vitae, including, but not limited to, public accounting, valuation, and
`
`financial analyses. Mr. Green may be called on to testify on the Respondents’ behalf in this
`
`Investigation, and may also be called to rebut the testimony of Chamberlain’s fact or expert
`
`witnesses, should any be presented. Mr. Green’s expertise is set forth in more detail in his
`
`curriculum vitae, which is attached hereto as Exhibit B.
`
`Stephen B. Heppe, D.Sc.
`
`Dr. Heppe operates Telenergy, Inc., and has expertise in the areas set forth in his curriculum
`
`vitae, including, but not limited to, communications systems and product integration. Dr. Heppe
`
`may be called on to testify on the Respondents’ behalf in this Investigation, and may also be
`
`called to rebut the testimony of Chamberlain’s fact or expert witnesses, should any be presented.
`
`Dr. Heppe’s expertise is set forth in more detail in his curriculum vitae, which is attached hereto
`
`as Exhibit C.
`
`Stuart Lipoff
`
`Mr. Lipoff is a consultant with over 40 years of engineering experience, and has expertise in the
`
`areas set forth in his curriculum vitae, including, but not limited to, communications systems and
`
`product integration. Mr. Lipoff may be called on to testify on the Respondents’ behalf in this
`
`Investigation, and may also be called to rebut the testimony of Chamberlain’s fact or expert
`
`witnesses, should any be presented. Mr. Lipoff’s expertise is set forth in more detail in his
`
`curriculum vitae, which is attached hereto as Exhibit D.
`
`Vijay K. Madisetti, Ph.D.
`
`Dr. Madisetti is a Full Professor of Electrical & Computer Engineering at the Georgia Institute of
`
`2
`
`

`
`Technology, and has expertise in the areas set forth in his curriculum vitae, including, but not
`
`limited to, wireless communications, digital signal processing, and control systems. Dr.
`
`Madisetti may be called on to testify on the Respondents’ behalf in this Investigation, and may
`
`also be called to rebut the testimony of Chamberlain’s fact or expert witnesses, should any be
`
`presented. Dr. Madisetti’s expertise is set forth in more detail in his curriculum vitae, which is
`
`attached hereto as Exhibit E.
`
`Massoud Pedram, Ph.D.
`
`Dr. Pedram is a Full Professor of Electrical & Computer Engineering at the Georgia Institute of
`
`Technology, and has expertise in the areas set forth in his curriculum vitae, including, but not
`
`limited to, power systems. Dr. Pedram may be called on to testify on the Respondents’ behalf in
`
`this Investigation, and may also be called to rebut the testimony of Chamberlain’s fact or expert
`
`witnesses, should any be presented. Dr. Pedram’s expertise is set forth in more detail in his
`
`curriculum vitae, which is attached hereto as Exhibit F.
`
`James Rice, Ph.D.
`
`Dr. Rice is President of MechExpert, and has expertise in the areas set forth in his curriculum
`
`vitae, including, but not limited to, mechanical design and solid mechanics. Dr. Rice may be
`
`called on to testify on the Respondents’ behalf in this Investigation, and may also be called to
`
`rebut the testimony of Chamberlain’s fact or expert witnesses, should any be presented. Dr.
`
`Rice’s expertise is set forth in more detail in his curriculum vitae, which is attached hereto as
`
`Exhibit G.
`
`Michael E. Tate
`
`Mr. Tate is a Vice President at Charles River Associates, and has expertise in the areas set forth
`
`in his curriculum vitae, including, but not limited to, accounting and economics. Mr. Tate may
`
`3
`
`

`
`be called on to testify on the Respondents’ behalf in this Investigation, and may also be called to
`
`rebut the testimony of Chamberlain’s fact or expert witnesses, should any be presented. Dr.
`
`Tate’s expertise is set forth in more detail in his curriculum vitae, which is attached hereto as
`
`Exhibit H.
`
`Hamid A. Toliyat, Ph.D.
`
`Dr. Toliyat is a Professor of Electrical Engineering at Texas A&M University, and has expertise
`
`in the areas set forth in his curriculum vitae, including, but not limited to, the analysis and design
`
`of electrical machines. Dr. Toliyat may be called on to testify on the Respondents’ behalf in this
`
`Investigation, and may also be called to rebut the testimony of Chamberlain’s fact or expert
`
`witnesses, should any be presented. Dr. Toliyat’s expertise is set forth in more detail in his
`
`curriculum vitae, which is attached hereto as Exhibit I.
`
`Jonathan R. Wood, Ph.D.
`
`Dr. Wood is President of Altor Limited LC, and has expertise in the areas set forth in his
`
`curriculum vitae, including, but not limited to, analog and power electronics. Dr. Wood may be
`
`called on to testify on the Respondents’ behalf in this Investigation, and may also be called to
`
`rebut the testimony of Chamberlain’s fact or expert witnesses, should any be presented. Dr.
`
`Wood’s expertise is set forth in more detail in his curriculum vitae, which is attached hereto as
`
`Exhibit J.
`
`Respondents reserve the right, as the circumstances warrant, to call and elicit adverse
`
`testimony from expert witnesses identified by, or called to testify at the hearing by Chamberlain,
`
`and to call impeachment witnesses not identified above. Respondents further reserve the right to
`
`supplement this Identification in response to information, contentions, or allegations not
`
`currently known to Respondents, including any objection by Chamberlain to any expert.
`
`4
`
`

`
`Dated: September 30, 2016
`
`Respectfully submitted,
`
`Eric S. Namrow
`Riccardo S. Macchiaroli
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Ave, N.W.
`Washington, D.C. 20004
`Telephone: (202) 739-3000
`Facsimile: (202) 739-3001
`
`Jason C. White
`Sanjay K. Murthy
`Nicholas A. Restauri
`MORGAN, LEWIS & BOCKIUS LLP
`77 West Wacker Drive
`Chicago, IL 60601
`Telephone: (312) 324-1000
`Facsimile: (312) 324-1001
`
`Sean C. Cunningham
`Erin P. Gibson
`DLA PIPER LLP
`401 B Street
`Suite 1700
`San Diego, CA 92101-4297
`Telephone: (619) 699-2700
`Facsimile: (619) 699-2701
`
`Aaron G. Fountain
`DLA PIPER LLP
`401 Congress Avenue
`Suite 2500
`Austin, TX 78701-3799
`Telephone: (512) 457-7000
`Facsimile: (512) 457-7001
`
`Counsel for Respondents
`Techtronic Industries Co. Ltd.;
`Techtronic Industries North America Inc.;
`One World Technologies, Inc.;
`OWT Industries, Inc.; Ryobi Technologies, Inc.;
`and Et Technology (WUXI) Co., Ltd.
`
`5
`
`

`
`EXHIBIT A
`
`EXHIBIT A
`
`

`
`MokoNet, Inc.
`57 Rodman Oval
`New Rochelle, NY 10805
`914-712-3778 (office)
`646-418-1047 (cell)
`http://www.mokonet.com
`Updated: September 30, 2016
`
`Michael S. Fagan
`
`mfagan@mokonet.com
`
`Skills
`
`Area of Expertise
`
`
`Computer software. Architecting, designing, and building large scale
`heterogeneous distributed Internet applications including e-Commerce systems.
`Linux/Unix, Windows, p-System
`VMware/ESX, Xen, KVM
`Java, C, C++, PHP, Python, JSP, JavaScript, Perl, VB/ASP, Pascal, Assembly,
`and more than 20 other languages
`VHDL, Verilog, Matlab and many others
`
`Operating Systems
`Virtualization
`Programming Languages
`(used extensively)
`Programming Languages
`(can understand)
`EXT*, NTFS, FAT, NFS, AFS, DFS, UFS, VMFS
`File Systems
`TCP/IP, Routers, Switches, Wireless, Monitoring Tools
`Networking
`DNS, Email, Web, FTP, TFTP, SSH, VNC, RDP
`Server Admin Tools
`Firewalls, Digital Certificates, PGP, TrueCrypt, AFS/Kerberos, LDAP
`Security
`802.11, Bluetooth, CDPD, Ricochet
`Wireless
`XML, XSL, HTML, DHTML, WML, CSS, TeX, *roff
`Markup Languages
`DB2, Oracle, Microsoft SQL, MySQL, Sybase
`Database Systems
`Windowing Environments X-Windows, Microsoft Windows
`
`Experience
`
`MokoNet, Inc.
`
`
`
`
`
`
`
`New York, NY
`
`1996 –
`President and CEO
` Founded MokoNet in 1996. See web site: http://www.mokonet.com for more information.
` Key Tasks:
` Run day-to-day operations.
` Technical Consultant for MokoNet clients.
` Technical lead for many of the MokoNet projects.
` Expert Witness.
` MokoNet is an Internet Technology Consulting Company focusing on back-end solutions for Internet, Intranet
`and Extranet. We build e-commerce and e-business systems for real-world business purposes.
` MokoNet provides expert witness services in the areas of computer software, networking, and security.
`
`Track Data Corporation
`1994 – 1996
`Director of Internet Technology
` Led team that transformed company into an Internet based business. Architected and designed Internet
`infrastructure, rewrote applications to use TCP/IP (“Internet Friendly”), trained programmers and systems staff
`on Internet technology.
` Reported directly to the CEO.
`
`
`
`Brooklyn, NY
`
`
`
`
`
`Email: mfagan@mokonet.com
`
`Web: http://www.mokonet.com
`
`
`
`
`
`
`
`
`
`1 of 2
`
`

`
`IBM T.J. Watson Research Center
`1990 – 1994
`Project Leader, Programmer and Research Scientist
` Project Agora. Led team that built systems management tools for a large scale, heterogeneous environment
`consisting of more than 2000 Unix servers and workstations. Wrote software to automate the systems
`management. Extensive use of AFS, Kerberos, NFS, Hesiod, and Zephyr. Interacted with technical colleagues
`both inside and outside the company -- worldwide. Gave presentations internally and at industry conferences.
` OS Research. Part of a team that was researching ways to improve the IBM MVS operating system. Focus on
`CPU scheduling and memory management. Wrote simulation code in C and Pascal on IBM and Sun
`workstations.
`
`
`
`
`
`
`
`Hawthorne, NY
`
`Pecan Software Systems
`
`1986 – 1989
`Programmer
` Developed systems software for the p-System. Wrote code in Assembly, Pascal, and Modula-2. Supported
`more than 10 different computing environments that the p-System ran on top of including IBM native, IBM
`PC-Dos, IBM MS-Dos, Macintosh, Atari, Amiga, Lisa, PDP-11, RTS, Vax, IBM DisplayWriter, Apple IIe, and
`Apple IIgs.
` The p-System was a state of the art programming and runtime environment that had many of the same
`properties that Java has today.
`
`
`
`
`
`
`
`Brooklyn, NY
`
`
`
`Education
`
`University of Wisconsin at Madison
`1988 -- 1990
` Master’s Degree in Computer Science, 1990
` Focus: Internet, Distributed Systems, Operating Systems, and Networks
`
`State University of New York at Albany
`1982 – 1986
` Bachelor of Science Degree, 1986
` Double Major: Computer Science and Mathematics
`
`
`Activities
`
`
`
`
`
`
`
`
`
`
`
`
`
` Madison, WI
`
`
`
`Albany, NY
`
`
` Silicon Alley:
` Board Member, WWWAC, 1997-1998
` Board Member, MOUSE, 1997
` Member, NYNMA, 1996-2002
` President, SACM, University of Wisconsin at Madison, 1989-1990
` Varsity Lacrosse, SUNY Albany, 1983-1986
` Team Leader, Multiple Sclerosis (MS) Bike Tour, 1995-2011
` Community Fund-Raising Team: #1 in 2001, 2002, #2 in 1997, 1999, 2003, #3 in 1996, 1998, 2000
`Interests: Basketball, Lacrosse, Bike Riding, Gadgets
`
`
`
`Email: mfagan@mokonet.com
`
`Web: http://www.mokonet.com
`
`
`
`
`
`
`
`
`
`2 of 2
`
`

`
`EXHIBIT B
`
`EXHIBIT B
`
`

`
`EDUCATION
`
`PROFESSIONAL AND
`BUSINESS HISTORY
`
`PROFESSIONAL AND
`BUSINESS
`AFFILIATIONS
`
`PHILIP GREEN
`Principal of Hoffman Alvary & Company LLC
` Phone: (617) 209-5106
` philgreen@hoffmanalvary.com
`B.A., History, 1984 - Rutgers College
`M.B.A., Accounting, 1987 - Rutgers Graduate School of Management
`1996 – Present: Principal Hoffman Alvary & Company LLC, Newton, MA
`1994 - 1996: Price Waterhouse LLP, Manager/Senior Manager, Dispute
`Analysis and Corporate Recovery Services, New York
`1988 - 1994: Executive Consultant, Peterson Consulting Limited
`Partnership, New York
`1987 - 1988: Staff Accountant, Ernst & Whinney, New York
`1984 - 1985: Paralegal, Anderson, Russell, Kill & Olick, Washington, D.C.
`and New York
`Dispute Analysis Consulting – Accounting, financial analysis, and valuation
`assistance in connection with litigated matters focusing on intellectual
`property infringements, contract breaches, professional malpractice and
`investigations before the International Trade Commission. Work has
`included the calculation of lost profits and reasonable royalty damages,
`forensic and investigative accounting, valuation, opinions regarding
`commercial success and the evaluation of domestic industry and remedy
`issues. This assistance has been provided to a broad range of industries
`including: computer software and hardware, telecommunications and
`electronics companies, pharmaceutical, medical device, and biotechnology
`entities, and steel, glass and other manufacturers. Served as expert witness
`on damages, royalties, valuation and accounting-related issues.
`Other Consulting – Engagements related to intangible assets have included
`preparation of valuations in connection with purchases, sales and donations,
`royalty auditing and development of patent and intellectual property
`licensing strategies. Other consulting assistance has included business
`valuations, providing opinions on the “fairness” of compensation in
`transactions, and assistance with issues related to bankrupt or troubled
`companies.
`Certified Public Accountant - Registered to Practice by the State of New
`York
`Certified Management Accountant
`Accredited in Business Valuation by the AICPA
`Accredited Senior Appraiser – Business Valuation
`Member, American Institute of Certified Public Accountants
`Member, New York State Society of Certified Public Accountants
`Member, Institute of Certified Management Accountants
`Member, American Society of Appraisers
`Member, Licensing Executive Society
`
`

`
`Philip Green
`
`Testimony – January 2011 – Present
`
`Transched Systems Limited v. Versyss Transit Systems et al. – Superior Court, New Castle County
`Delaware – Deposition and Trial before Judge Carpenter
`
`*Certain Large Scale Integrated Circuit Semiconductor Chips and Products Containing the Same, Inv. No.
`337-TA-716, International Trade Commission – Deposition
`
`*Hon Hai Precision Industry Company, Ltd. v. TPV Technology Ltd., et al. – Federal Court – Eastern
`District of Texas – Deposition
`
`*Mondis Technology Limited v. TPV Technology Ltd. et al. Federal Court – Eastern District of Texas –
`Deposition
`
`*Atlantic Research Marketing Systems, Inc. v. LaRue Tactical, Inc. – Federal Court – District of
`Massachusetts – Deposition
`
`SMH Fine Foods v. Boston Baking, Inc., et al – Superior Court, Suffolk County Massachusetts –
`Deposition
`
`*comScore v. The Nielsen Companies – Federal Court – Eastern District of Virginia – Deposition
`
`*Cooper Notification, Inc. v. Federal Signal Corp., et. al. – District of Delaware – Deposition
`
`INC Research Holdings, Inc. v Shareholder Representative Services, LLC – Court of Chancery of the State
`of Delaware – Deposition
`
`*Uniloc USA, Inc. v. Microsoft Corporation – Federal Court – District of Rhode Island – Deposition and
`Trial Before Judge Young
`
`*Lee Valley Tools, et. al. v. Industrial Blade Company, et. al. – Federal Court – Western District of New
`York – Deposition
`
`*Certain Universal Serial Bus Portable Storage Devices, Including USB Flash Drives and Components
`Thereof, Inv. No. 337-TA-788 – International Trade Commission - Deposition
`
`*Atlantic Research Marketing Systems, Inc. v. Troy Industries, Inc. et, al. – Federal Court – District of
`Massachusetts – Deposition
`
`*Ambato Media LLC v. Garmin International Inc., et al. – Federal Court – Eastern District of Texas –
`Deposition and Trial before Judge Gilstrap
`
`*Certain Digital Televisions and Components Thereof .–Inv. No. 337-TA–789 – International Trade
`Commission – Deposition
`
`*Pacific Coast Marine Windshields Incorporated v. Malibu Boats, Inc. – Federal Court – Middle District
`of Florida – Deposition
`
`*AIA Engineering Limited. v. Magotteaux, Intc. et al. – Federal Court – Middle District of Tennessee –
`Trial before Judge Haynes
`
`*Certain Digital Photo Frames and Image Display Devices and Components Thereof – Inv. No. 337-TA-
`807 – International Trade Commission – Deposition
`
`* Denotes matter involving intellectual property
`
`Page 1 of 4
`
`

`
`*Certain Silicon Microphone Packages And Products Containing Same – Inv. No. 337-TA-825 –
`International Trade Commission – Deposition and Trial Before Judge Pender
`
`Thomas Bochnowski and Edward Muhlner v. Global Rescue Corp. – JAMS Arbitration – Hearing before
`Judge Van Gestel
`
`*Realtime Data, LLC d/b/a IXO v. Bloomberg LLP, et al. – Federal Court – Southern District of New York
`- Deposition
`
`*Certain Consumer Electronics and Display Devices and Products Containing Same – Inv. No. 337-TA-
`836 – International Trade Commission – Deposition
`
`ECi, Inc. et al v. MWAi, Inc. – Chancery Court of the State of Delaware – Deposition and Trial before
`Judge Parsons
`
`*EdiSync Systems, LLC v. Saba Software, Inc., – Federal Court – District of Colorado – Deposition
`
`*Mondis Technology Limited v. TPV Technology Ltd. et al. – JAMS Arbitration – Hearing before Judge
`Daniel Weinstein
`
`*Keurig Corporation v. Sturm Foods, Inc. – Federal Court – District of Delaware – Deposition
`
`*Blake v. PCGS et al. – Federal Court – District of Massachusetts – Trial before Judge Young
`
`*Smartphone Technologies LLC v. Apple Inc. and LG Electronics, Inc. – Federal Court - Eastern District
`of Texas – Deposition
`
`*Endo Pharmaceuticals, Inc. v. Mylan Pharmaceuticals, Inc. – Federal Court – District of Delaware –
`Deposition
`
`*Galderma Laboratories Inc. et al v. Amneal Pharmaceuticals, LLC et al.- Federal Court - District of
`Delaware – Deposition
`
`*Ventria Bioscience v. Daichang Yang - Superior Court of the State of California, County of Sacramento
`– Deposition
`
`*In the Matter of Certain Electronic Devices, Including Wireless Communication Devices, Tablet
`Computers, Media Players, and Televisions, and Components Thereof, Investigation No. 337-TA-862,
`International Trade Commission – Deposition and Trial before Judge Shaw
`
`*Alcon Pharmaceuticals LTD et al v. Apotex Inc. et al., Federal Court – District of Delaware, Deposition
`
`*GeoTag, Inc. v. Frontier Communications Corp., et. al., Federal Court – Eastern District of Texas –
`Deposition
`
`Paige Landscape Company, Inc. v. Apple D’Or Maintenance, Inc. – Superior Court – Worcester County
`Massachusetts - Trial
`
`*Certain Wireless Communication Base Stations and Components Thereof – Investigation No. 337-TA-
`871
`International Trade Commission – Deposition
`
`*Google, Inc. v. GeoTag, Inc. –Federal Court – District of Delaware - Deposition
`
`*Ethox Chemicals LLC v. The Coca-Cola Company – Federal Court – District of South Carolina –
`Deposition
`
`* Denotes matter involving intellectual property
`
`Page 2 of 4
`
`

`
`*Columbia Data Products, Inc. v. Autonomy Corporation Limited et al. – Federal Court – District of
`Massachusetts - Deposition
`
`*Mass Engineered, Inc. v. Humanscale, Inc. – Federal Court – Eastern District of Virginia – Deposition
`
`*Ascion LLP, et al v. Rouey Lung, Inc. et al. – Federal Court – District of Massachusetts – Trial before
`Judge O’Toole
`
`*Cheese Systems Inc. v. Tetra Pak Cheese & Powder Sys., Inc., et. al.. – Federal Court – Western District
`of Wisconsin – Trial before Judge Crabb
`
`*Certain Point-to-Point Network Communication Devices and Products Containing Same – Investigation
`No. 337-TA-892 – Deposition
`
`*In the Matter of a Plan of Compromise or Arrangement of Nortel Networks Corporation et al. – Ontario
`Superior Court of Justice and United States Bankruptcy Court for the District of Delaware – Deposition
`and Trial
`
`*GeoTag, Inc. v. Starbucks Corp., et. al., Federal Court – Eastern District of Texas – Deposition
`
`*B. Ravo and E. Nicolo v. Covidien LP, Federal Court – Western District of Pennsylvania – Deposition
`
`*Trebro Manufacturing, Inc. v. FireFly Equipment, LLC, Federal Court – District of Montana – Deposition
`
`Finn v. Ballentine Partners LLC, American Arbitration Association – Deposition and Hearing before three
`judge panel
`
`*BioMarin Pharmaceutical, Inc. v. Duke University – United States Patent Trial and Appeal Board –
`Declaration and Testimony via Deposition
`
`*Amneal Pharmaceuticals LLC v. Supernus Pharmaceuticals, Inc. – United States Patent Trial and Appeal
`Board – Declaration and Testimony via Deposition
`
`*GeoTag, Inc. v. AT&T Mobility, LLC, et. al., Federal Court – Northern District of Texas – Deposition
`
`*Accusoft Corporation v. Quest Diagnostics, Inc and Medplus, Inc. - Federal Court – District of
`Massachusetts - Deposition
`
`*Target Corp. v. Destination Maternity Corp. – United States Patent Trial and Appeal Board – Declaration
`and Testimony via Deposition
`
`Stockholder Representatives for Interlace Medical, Inc. v. Hologic, Inc. – Chancery Court for the State of
`Delaware – Deposition and Trial
`
`*Adaptix, Inc. v. LG Electronics, Pantech Wireless, Inc., AT&T Mobility LLC, Verizon Wireless, et. al.,
`Federal Court – Eastern District of Texas – Deposition
`
`*Adaptix, Inc. v. Apple, Inc., HTC Corporation, AT&T Mobility LLC, Verizon Wireless, et. al., Federal
`Court – Northern District of California – Deposition
`
`*Adaptix, Inc. v. Ericsson, Inc., AT&T Mobility LLC, T-Mobile USA, Inc, et. al., Federal Court – Eastern
`District of Texas – Deposition
`
`*Adaptix, Inc. v. Alcatel-Lucent USA, Inc., AT&T Mobility LLC, Verizon Wireless, Sprint Spectrum L.P.,
`et. al., Federal Court – Eastern District of Texas – Deposition and Trial before Judge Schroeder
`
`* Denotes matter involving intellectual property
`
`Page 3 of 4
`
`

`
`*Cell and Network Selection LLC v. ZTE (USA), Inc.,MetroPCS Communications, Inc., et. al., Federal
`Court – Eastern District of Texas – Deposition
`
`Glenridge Pharmaceuticals, LLC v. Questcor Pharmaceuticals, Inc. – Superior Court, Santa Clara County
`California – Deposition
`
`*Quiksilver, Inc., et. al. v. Rox Volleyball, Inc. et al. al., Federal Court – Central District of California –
`Deposition and Trial before Judge Guilford
`
`*U.S. Bancorp v. Solutran, Inc. – United States Patent Trial and Appeal Board – Declaration and
`Testimony via Deposition
`
`*EMC Corporation, et. al. v. Zerto, Inc. – Federal Court –District of Delaware – Deposition and Trial
`before Judge Sleet
`
`*Certain Consumer Electronics and Display Devices with Graphics Processing and Graphics Processing
`Units Therein – Investigation No. 337-TA-932 – Deposition
`
`*Certain Footwear Products – Investigation No. 337-TA-936 – Deposition
`
`*HSM Portfolio LLC and Technology Properties Limited, LLC, v. Micron Technology, Inc – Federal
`Court –District of Delaware – Deposition
`
`*Greatbatch, Inc. v. AVX, Inc. – Federal Court – District of Delaware – Deposition and Trial before Judge
`Stark
`
`*Speedfit LLC v. Woodway, Inc. – Federal Court – Eastern District of New York – Deposition
`
`*Beverage Dispensing Solutions, LLC v. The Coca-Cola Company - Federal Court District of Georgia –
`Deposition
`
`*Callwave, Inc. v. Broadsoft, Inc. – Federal Court - District of Delaware – Deposition
`
`*Callwave, Inc. v. Google, Inc. – Federal Court - District of Delaware – Deposition
`
`*SNMPRI, Inc. v. Avaya, Inc. – Federal Court – District of Delaware – Deposition
`
`*Bombardier Recreational Products, Inc. v. Arctic Cat, Inc. – Federal Court – District of Minnesota –
`Deposition
`
`*Brigham & Women’s Hospital and Investors Bio-Tech LLC v. Perrigo, Inc. – Federal Court – District of
`Massachusetts - Deposition
`
`*AngleFix LLC v. Wright Medical Products, LLC – Federal Court – Western District of Tennessee -
`Deposition
`
`*Cellular Communications Equipment LLC v. Apple Inc., HTC Corporation, ZTE Corporation, AT&T
`Mobility LLC, Verizon Wireless, Sprint Solutions, Inc., T-Mobile USA, Inc, et. al., Federal Court –
`Eastern District of Texas – Deposition and Trial before Judge Mitchell
`
`Publications Within the Past Ten Years
`
`“Evaluating Reasonable Royalties After ResQNet,” Philip Green, Rachel Hughey, IP Law360, Oct. 2010
`
`“The 25% Rule is Dead - Now What?” Philip Green, Creighton G. Hoffman, IP Law360, Jan. 2011
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`* Denotes matter involving intellectual property
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`Page 4 of 4
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`EXHIBIT C
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`EXHIBIT C
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`Stephen B. Heppe, D.Sc.
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`Professional Summary
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`Dr. Heppe has 35 years of technical and managerial experience in aerospace, navigation and
`communications supporting private industry, FAA, DoD, NASA, and other US Government
`agencies and international clients. He currently operates Telenergy, Inc., an engineering
`consulting firm specializing in absolute and relative positioning, navigation and RF
`communication systems as well as spectrum management and product integration.
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`From 2002 until 2009, Dr. Heppe was Vice President and Chief Scientist for Insitu, Inc., a
`manufacturer of small robotic aircraft (SeaScan, ScanEagle/Insight, Integrator). His primary
`areas of responsibility included the aircraft avionics (radios, GPS navigation including absolute
`and relative positioning for aircraft recovery, satellite communications, and video processing),
`engineering and flight safety reviews, support for technology roadmap development,
`management of the Company’s portfolio of intellectual property, and spectrum planning.
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`Prior project experience includes:
` Support for the international development and standardization of a VHF radio
`communications protocol for aircraft networking and GPS positioning (VDL-4);
` Spectrum engineering and sharing studies for a Big LEO satellite communications system
`(Globalstar); Gateway siting and coordination; GPS/GNSS interference assessments; and
`aeronautical support;
` Architectural development for a future mobile satellite communications system intended to
`support airborne users;
` Design and engineering support for various space-based Government systems, envisioned
`and operational, including Defense Satellite Communications System (DSCS), the Strategic
`Defense System (SDS), Space-Based Radar (SBR), Milstar, NASA's Tracking and Data
`Relay Satellite System (TDRSS) and its follow-ons;
` Various Naval satellite communications systems and the network for the US Air Force
`Consolidated Space Operations Center (CSOC).
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`Navigation Systems. Dr. Heppe’s areas of technical expertise include GPS position and velocity
`determination for aircraft, spacecraft and ground vehicles, relative positioning and attitude
`determination for aircraft recovery and antenna pointing, Differential GPS (DGPS) and
`Automatic Dependent Surveillance (ADS) systems, navigation accuracy determination, temporal
`and geographic studies of system effectiveness, architectural development, specification
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`Heppe CV
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`Page 1
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`development, flight testing of hardware/software systems, and cost/benefit studies for
`government and commercial customers. Dr. Heppe participated in RTCA Task Force 1, which
`developed the aviation industry position on appropriate transition planning to a GNSS-based
`navigation and surveillance architecture. He was the Chairman of RTCA/SC-159 WG6
`(Interference issues for GNSS) and teaches courses on GPS and DGPS technology and systems.
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`Project experience in the area of navigation includes:
` Design, development and successful flight test of a DGPS precision approach and landing
`system for the US Marine Corps;
` Concept development for GPS-based navigation systems for the International Space Station,
`the Strategic Defense System (SDS), Space-based Radar (SBR) and commercial ground
`vehicles;
` Standards development for the DGNSS Instrument Approach System: Special Category I
`(DIAS:SCAT-I; RTCA/DO-217), and participation in RTCA SC-159 regarding the Wide
`Area Augmentation System and local augmentations for Category II/III operations;
` Support to the US Navy for the ground-based augmentation system (GBAS) intended to
`support GPS-based precision approach and landing;
` Support for the international development and standardization of a VHF radio
`communications protocol for aircraft networking and GPS positioning (VDL-4).
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`Communication Systems. Government/military work includes system design and analysis for
`multiple MILSATCOM systems including DSCS, Milstar, FLTSATCOM, AFSATCOM, Space-
`Based Radar, the Strategic Defense System (SDS), and non-military systems for NASA
`(TDRSS/TDAS) and the FAA. Commercial work includes design of a candidate SATCOM
`system for Saudi Arabia, design of a VSAT network for domestic US customers, and support for
`the Globalstar mobile satellite service system noted above. Dr. Heppe also led the data link
`engineering effort for the design, development and successful flight testing of a precision
`approach and landing system relying on differential GPS, and concept development,
`testing/analysis, and demonstration of a commercial implementation of VDL-4. Dr. Heppe
`participated in the development of standards for DGPS data link (WAAS and LAAS) which
`currently define the infrastructure of GPS augmentation in the US National Airspace. Areas of
`technical expertise include protocol development, multi-access techniques, rain adaptation, fault
`detection/isolation/response, routing algorithms and overall network management.
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`Specific areas of technical expertise in the area of communications engineering include:
` Spacecraft and space system design including project experience in:
` Payload design (FAA satcom system design)
` Spacecraft bus elements (TDAS, Brilliant Pebbles, ISS video-conferencing)
` Constellation (Navy proliferated satcom, FAA, MILSATCOM architecture)
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`Heppe CV
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`Page 2
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` Communications analysis over linear and nonlinear channels
` Militarily significant channels (highly ionized/disturbed/obstructed)
` Commercial channels (multipath/fading for communications and GPS)
` Anti-jam and low probability of intercept system design (DSCS, Milstar, BP)
` Detailed communications engineering disciplines including:
` protocol design for RF communications (addressing, control, multiple access)
` modulation/coding/information theory
` network analysis and traffic loading studies
` propagation studies
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`Experience in the area of communications control includes protocol development for VDL-4 and
`data links for unmanned aircraft, as well as network design and control segment design for
`DSCS, Milstar, SBR, the SDS, and commercial SATCOM networks.
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`Surveillance Systems. Experience in the area of surveillance includes concept development and
`engineering analysis of GPS-based Automatic Dependent Surveillance (ADS) systems for en
`route and surface applications. Additional experience in the area of surveillance, specifically
`radar signal processing and direction finding, derives from Dr. Heppe's doctoral research and
`dissertation entitled "Iteratively Convergent Methods of Signal Characterization Based on
`Eigenspace Analysis." This work combines the popular MUSIC technique for signal
`characterization with adaptive beamforming and optimization strategies to simultaneously
`enhance DF performance for low-level signals, while reducing computational load.
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`Employment History
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`From:
`To:
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`1994
`Telenergy, Inc
`Present Hood River, OR
`Position: President
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`Dr. Heppe provides consulting services through Telenergy in the
`area of telecommunications, satellite communications and GPS
`positioning and navigation. Project experience includes:
` Support for development of new standards for command and
`control of