UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Dee Lord
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN INFOTAINMENT SYSTEMS,
`COMPONENTS THEREOF, AND
`AUTOMOBILES CONTAINING THE SAME
`
`
`
`
`
`
`
`
`Investigation No. 337-TA-1119
`
`RESPONDENTS’ IDENTIFICATION OF EXPERT WITNESSES
`
`
`
`Pursuant to the procedural schedule set by Order No. 17 in this Investigation, Respondents1
`
`provide their joint Identification of Experts, Respondents, by and through their undersigned
`
`counsel, hereby identify the following expert witnesses who may be called to testify at the hearing
`
`in this investigation:
`
`
`
`This disclosure 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 discernable, Complainant’s positions taken to date. Discovery is ongoing and
`
`Respondents reserve the right to seek leave to supplement and or amend this identification. In
`
`
`1 Respondents include Renesas Electronics Corporation, Renesas Electronics America, Inc.,
`Socionext Inc., 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., Toyota Motor
`Manufacturing Mississippi, Inc., Toyota Motor Manufacturing, Texas, Inc., Panasonic
`Corporation, Panasonic Corporation of North America, Denso Ten Limited, Denso Ten America
`Limited, Japan Radio Co., Ltd., DENSO CORPORATION, DENSO International America,
`Inc., DENSO Manufacturing Tennessee, Inc., DENSO Wireless Systems America, Inc., u-
`blox AG, u-blox America, Inc,, u-blox San Diego, Inc., Pioneer Corporation, and Pioneer
`Automotive Technologies, Inc. (collectively “Respondents”)
`Inv. No. 337-TA-1119: Respondents’ Identification of Expert Witnesses
`
`

`

`addition to the experts identified below, Respondents reserve the right to proffer testimony from
`
`any expert identified by Complainant in this Investigation.
`
`(A) Dr. Seth Kaplan
`
`
`
`Dr. Kaplan’s is an expert in the nontechnical matters in this investigation, including without
`
`limitation, economic, valuation, and industry and market conditions, competition and innovation
`
`relating to infotainment systems and components thereof, and automobiles containing the same in
`
`the United States. Dr. Kaplan’s qualifications are set forth in his curriculum vitae attached hereto
`
`as Exhibit A. The general nature of Dr. Kaplan’s hearing testimony is presently expected to relate
`
`to the lack of economic domestic industry, alleged secondary considerations of nonobviousness
`
`related to commercial issues, remedy, bonding, and scope of exclusion order issues. He may also
`
`testify in rebuttal on other issues raised by Complainant, other defenses, and/or any other technical
`
`issue that may arise.
`
`(B) Dr. Alan Bovik
`
`
`
`Dr. Bovik is an expert in the technical matters in this investigation, including without
`
`limitation, video and graphics processing. Dr. Bovik’s qualifications are set forth in his curriculum
`
`vitae attached hereto as Exhibit B. The general nature of Dr. Bovik’s hearing testimony is presently
`
`expected to relate to the technical background of the Asserted Patents, invalidity of the Asserted
`
`Patents, aspects of Respondents’ products and operations relating to video- and graphics-
`
`processing technology, and those of Respondents’ customers. He may also testify as to the proper
`
`construction of the claims of the patents in issue; the scope of the claims of the patents in issue;
`
`the implications of certain art to the proper construction of the claims of the patents in issue; the
`
`non-infringement of the patents in issue by Respondents’ products, systems and devices, either
`
`2
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`alone or in combination with the products of others; and in rebuttal to claims of infringement and
`
`technical domestic industry asserted by Complainant. He may also testify in rebuttal on other
`
`issues raised by Complainant, other defenses, and/or any other technical issue that may arise.
`
`(C) Dr. Robert Colwell
`
`
`
`Dr. Colwell is an expert in the technical matters in this investigation, including without
`
`limitation, memory access management and power management. Dr. Colwell’s qualifications are
`
`set forth in his curriculum vitae attached hereto as Exhibit C. The general nature of Dr. Colwell’s
`
`hearing testimony is presently expected to relate to the technical background of the Asserted
`
`Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and operations
`
`relating to memory access management and power management, and those of Respondents’
`
`customers. He may also testify as to the proper construction of the claims of the patents in issue;
`
`the scope of the claims of the patents in issue; the implications of certain art to the proper
`
`construction of the claims of the patents in issue; the non-infringement of the patents in issue by
`
`Respondents’ products, systems and devices, either alone or in combination with the products of
`
`others; and in rebuttal to claims of infringement and technical domestic industry asserted by
`
`Complainant. He may also testify in rebuttal on other issues raised by Complainant, other defenses,
`
`and/or any other technical issue that may arise.
`
`(D) Mr. Rich Goodin
`
`
`
`Mr. Goodin is an expert in the technical matters in this investigation, including without
`
`limitation, source code, software, operating systems, control systems, and issues related to the
`
`same. Mr. Goodin’s qualifications are set forth in his curriculum vitae attached hereto as Exhibit
`
`D. The general nature of Mr. Goodin’s hearing testimony is presently expected to relate to the
`
`3
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`technical background of the Asserted Patents, invalidity of the Asserted Patents, aspects of
`
`Respondents’ products and operations, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`(E) Dr. Stephen Heppe
`
`
`
`Dr. Heppe is an expert in the technical matters in this investigation, including without
`
`limitation, satellite navigation and positioning, including GPS technology. Dr. Heppe’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit E. The general nature
`
`of Dr. Heppe’s hearing testimony is presently expected to relate to the technical background of the
`
`Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to GPS technology, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`4
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`(F)
`
`Dr. Samuel Pullen
`
`
`
`Dr. Pullen is an expert in the technical matters in this investigation, including without
`
`limitation, satellite navigation and positioning, including GPS technology. Dr. Pullen’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit F. The general nature
`
`of Dr. Pullen’s hearing testimony is presently expected to relate to the technical background of the
`
`Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to GPS technology, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`(G) Dr. Jing Hu
`
`
`
`Dr. Hu is an expert in the technical matters in this investigation, including without
`
`limitation, video and graphics processing. Dr. Hu’s qualifications are set forth in his curriculum
`
`vitae attached hereto as Exhibit G. The general nature of Dr. Hu’s hearing testimony is presently
`
`expected to relate to the technical background of the Asserted Patents, invalidity of the Asserted
`
`Patents, aspects of Respondents’ products and operations relating to video- and graphics-
`
`processing technology, and those of Respondents’ customers. He may also testify as to the proper
`
`construction of the claims of the patents in issue; the scope of the claims of the patents in issue;
`
`the implications of certain art to the proper construction of the claims of the patents in issue; the
`5
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`non-infringement of the patents in issue by Respondents’ products, systems and devices, either
`
`alone or in combination with the products of others; and in rebuttal to claims of infringement and
`
`technical domestic industry asserted by Complainant. He may also testify in rebuttal on other
`
`issues raised by Complainant, other defenses, and/or any other technical issue that may arise.
`
`(H) Dr. Andrew Mayo
`
`
`
`Dr. Mayo is an expert in the technical matters in this investigation, including without
`
`limitation, source code, software, operating systems, control systems, and issues related to the
`
`same. Dr. Mayo’s qualifications are set forth in his curriculum vitae attached hereto as Exhibit H.
`
`The general nature of Dr. Mayo’s hearing testimony is presently expected to relate to the technical
`
`background of the Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’
`
`products and operations, and those of Respondents’ customers. He may also testify as to the proper
`
`construction of the claims of the patents in issue; the scope of the claims of the patents in issue;
`
`the implications of certain art to the proper construction of the claims of the patents in issue; the
`
`non-infringement of the patents in issue by Respondents’ products, systems and devices, either
`
`alone or in combination with the products of others; and in rebuttal to claims of infringement and
`
`technical domestic industry asserted by Complainant. He may also testify in rebuttal on other
`
`issues raised by Complainant, other defenses, and/or any other technical issue that may arise.
`
`(I)
`
`Dr. Steven Przbylski
`
`
`
`Dr. Przbylski is an expert in the technical matters in this investigation, including without
`
`limitation, memory access management and power management. Dr. Przbylski’s qualifications are
`
`set forth in his curriculum vitae attached hereto as Exhibit I. The general nature of Dr. Przbylski’s
`
`hearing testimony is presently expected to relate to the technical background of the Asserted
`
`6
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and operations
`
`relating to memory access management and power management, and those of Respondents’
`
`customers. He may also testify as to the proper construction of the claims of the patents in issue;
`
`the scope of the claims of the patents in issue; the implications of certain art to the proper
`
`construction of the claims of the patents in issue; the non-infringement of the patents in issue by
`
`Respondents’ products, systems and devices, either alone or in combination with the products of
`
`others; and in rebuttal to claims of infringement and technical domestic industry asserted by
`
`Complainant. He may also testify in rebuttal on other issues raised by Complainant, other defenses,
`
`and/or any other technical issue that may arise.
`
`(J)
`
`Dr. Vivek Subramanian
`
`
`
`Dr. Subramanian is an expert in the technical matters in this investigation, including
`
`without limitation, memory access management and power management. Dr. Subramanian’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit J. The general nature
`
`of Dr. Subramanian’s hearing testimony is presently expected to relate to the technical background
`
`of the Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to memory access management and power management, and those of
`
`Respondents’ customers. He may also testify as to the proper construction of the claims of the
`
`patents in issue; the scope of the claims of the patents in issue; the implications of certain art to
`
`the proper construction of the claims of the patents in issue; the non-infringement of the patents in
`
`issue by Respondents’ products, systems and devices, either alone or in combination with the
`
`products of others; and in rebuttal to claims of infringement and technical domestic industry
`
`asserted by Complainant. He may also testify in rebuttal on other issues raised by Complainant,
`
`other defenses, and/or any other technical issue that may arise.
`
`7
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`(K) Dr. Edward John Delp III
`
`
`
`Dr. Delp is an expert in the technical matters in this investigation, including without
`
`limitation, video and graphics processing. Dr. Delp’s qualifications are set forth in his curriculum
`
`vitae attached hereto as Exhibit K. The general nature of Dr. Delps hearing testimony is presently
`
`expected to relate to the technical background of the Asserted Patents, invalidity of the Asserted
`
`Patents, aspects of Respondents’ products and operations relating to video- and graphics-
`
`processing technology, and those of Respondents’ customers. He may also testify as to the proper
`
`construction of the claims of the patents in issue; the scope of the claims of the patents in issue;
`
`the implications of certain art to the proper construction of the claims of the patents in issue; the
`
`non-infringement of the patents in issue by Respondents’ products, systems and devices, either
`
`alone or in combination with the products of others; and in rebuttal to claims of infringement and
`
`technical domestic industry asserted by Complainant. He may also testify in rebuttal on other
`
`issues raised by Complainant, other defenses, and/or any other technical issue that may arise.
`
`(L) Dr. Christopher Wilson
`
`
`
`Dr. Wilson is an expert in the technical matters in this investigation, including without
`
`limitation, satellite navigation and positioning, including GPS technology. Dr. Wilson’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit L. The general nature
`
`of Dr. Wilson’s hearing testimony is presently expected to relate to the technical background of
`
`the Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to GPS technology, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`8
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`(M) Dr. John Betz
`
`
`
`Dr. Betz is an expert in the technical matters in this investigation, including without
`
`limitation, satellite navigation and positioning, including GPS technology. Dr. Betz’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit M. The general nature
`
`of Dr. Betz’s hearing testimony is presently expected to relate to the technical background of the
`
`Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to GPS technology, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`(N) Dr. Phillip Dafesh
`
`
`
`Dr. Dafesh is an expert in the technical matters in this investigation, including without
`
`limitation, satellite navigation and positioning, including GPS technology. Dr. Dafesh’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit N. The general nature
`
`9
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`of Dr. Dafesh’s hearing testimony is presently expected to relate to the technical background of
`
`the Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to GPS technology, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`(O) Dr. William Michalson
`
`
`
`Dr. Michalson is an expert in the technical matters in this investigation, including without
`
`limitation, satellite navigation and positioning, including GPS technology. Dr. Michalson’s
`
`qualifications are set forth in his curriculum vitae attached hereto as Exhibit O. The general nature
`
`of Dr. Michalson’s hearing testimony is presently expected to relate to the technical background
`
`of the Asserted Patents, invalidity of the Asserted Patents, aspects of Respondents’ products and
`
`operations relating to GPS technology, and those of Respondents’ customers. He may also testify
`
`as to the proper construction of the claims of the patents in issue; the scope of the claims of the
`
`patents in issue; the implications of certain art to the proper construction of the claims of the patents
`
`in issue; the non-infringement of the patents in issue by Respondents’ products, systems and
`
`devices, either alone or in combination with the products of others; and in rebuttal to claims of
`
`infringement and technical domestic industry asserted by Complainant. He may also testify in
`
`10
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`rebuttal on other issues raised by Complainant, other defenses, and/or any other technical issue
`
`that may arise.
`
`
`
`
`
`11
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`
`
`
`
`Dated: January 28, 2019
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`12
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`/s/ Daniel P. Muino
`Mark L. Whitaker
`Daniel P. Muino
`G. Brian Busey
`Lynn I. Levine
`Fahd Hussein Patel
`Mary Prendergast
`Aaron D. Rauh
`MORRISON & FOERSTER LLP
`2000 Pennsylvania Ave., NW
`Suite 6000
`Washington, DC 20006
`Telephone: (202) 887-1500
`
`Yuka Teraguchi
`MORRISON & FOERSTER LLP
`Shin-Marunouchi Building, 29th Floor
`5-1, Marunouchi 1-chome
`Chiyoda-ku, Tokyo 100-6529
`Japan
`
`Email: RenesasITC1119@mofo.com
`
`Counsel for Respondents Renesas Electronics
`Corporation and Renesas Electronic America,
`Inc.
`
`
`/s/ Paul Steadman
`Paul Steadman
`DLA PIPER
`444 West Lake Street
`Suite 900
`Chicago, IL 60606-0089
`Telephone: (312) 368-2135
`Facsimile: (312) 251-2850
`DLA-BroadcomITC@dlapiper.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.,
`Toyota Motor Manufacturing, Mississippi, Inc.,
`Toyota Motor Manufacturing, Texas, Inc.,
`Panasonic Corporation, Panasonic Corporation
`of North America, Denso Ten Limited, Denso Ten
`America Limited, Denso Corporation, Denso
`International America, Inc., Denso
`Manufacturing Tennessee, Inc., Denso Wireless
`Systems America, Inc., and Japan Radio Co., Ltd.
`
`
`/s/ G. Brian Busey
`G. Brian Busey
`Lynn I. Levine
`Aaron D. Rauh
`MORRISON & FOERSTER LLP
`2000 Pennsylvania Ave., NW, Suite 6000
`Washington, DC 20006
`Telephone: (202) 887-1500
`
`A. Max Olson
`Akira Irie
`MORRISON & FOERSTER LLP
`Shin-Marunouchi Building,
`29th Floor
`5-1, Marunouchi 1-Chome
`Chiyoda-Ku, Tokyo
`100-6529, Japan
`Telephone: +81 3 3214 6522
`
`Hector G. Gallegos
`MORRISON & FOERSTER LLP
`707 Wilshire Boulevard, Suite 6000
`Los Angeles, CA 90017-3543
`Telephone: (213) 892-5200
`
`Email: SocionextITC1119@mofo.com
`
`Counsel for Respondent Socionext Inc.
`
`/s/ Craig E. Walter
`Smith R. Brittingham
`Elizabeth A. Niemeyer
`Timothy J. May
`Craig E. Walter
`13
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`
`
`
`
`

`

`Ruohan Jack Li
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, L.L.P.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Telephone:
`(202) 408-4000
`
`Email: UBlox-FH-1119@Finnegan.com
`
`Counsel for Respondents u-blox AG, u-blox
`America, Inc., and u-blox San Diego, Inc.
`
`
`/s/ Lora A. Brzezynski
`John G. Smith
`Brianna Lynn Silverstein
`Lora A. Brzezynski
`James R. Carpenter
`Nick Colic
`Yodi S. Hailemariam
`DRINKER BIDDLE & REATH LLP
`1500 K Street, NW
`Washington, DC 20005
`Telephone: (202) 842-8800
`Facsimile: (202) 842-8465
`
`Email: PioneerITC1119@dbr.com
`
`Counsel for Respondents Pioneer Corporation
`and Pioneer Automotive Technologies, Inc.
`
`
`
`
`
`
`
`
`14
`Inv. No. 337-TA-1119: Respondents’ Notice of Prior Art
`
`

`

`
`
`
`
`
`INV. NO. 337-TA-1119
`RESPONDENTS’ IDENTIFICATION OF EXPERT
`WITNESSES
`
`EXHIBIT A
`
`
`

`

`
`
`1
`
`
`
`
`
`SETH T. KAPLAN
`President IER-LLC
`
`
`Telephone: 202-403-9439
`
`Email: skaplan@ier-llc.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PH.D. ECONOMICS
`Michigan State University
`
`B.A. Economics and Philosophy
`
`New College of USF
`
`
`
`,
`
`
`Dr. Seth T. Kaplan is an expert in the economics of international trade disputes, including Section
`337, antidumping, countervailing duty, and escape clause investigations. He has provided expert
`
`testimony and prepared submissions for petitioners and respondents in over 100 investigations
`
`involving a wide range of high-tech, industrial, consumer, and agricultural products. He has also
`worked on behalf of clients in international arbitrations, antitrust matters, intellectual property
`
`litigation, and commercial damages.
`
`Dr. Kaplan is President of International Economic Research LLC. He also acts as a Senior
`Economic Advisor to Capital Trade, Incorporated. Dr. Kaplan has served as Principal and Director
`
`of The Brattle Group, and as Vice President and head of the International Trade Practice at CRA
`
`International. He also served as a Staff Economist at the U.S. International Trade Commission and
`as Director of Economic Research at Trade Resources Company. Dr. Kaplan taught international
`
`economics at The George Washington University from 1990 to 1998 and has published numerous
`
`articles on issues involving international trade and commercial policy. Dr. Kaplan has a Ph.D. in
`Economics from Michigan State University.
`
`PROFESSIONAL EXPERIENCE
`
`2011-present President, International Economic Research LLC
`
`2011-present Senior Economic Advisor, Capital Trade, Incorporated
`
`2007-2011
`
`Principal and Director, The Brattle Group
`
`1998–2007
`
`Vice President and Head of the International Trade Practice, CRA International
`
`1991–1998
`
`Director of Economic Research, Trade Resources Company
`
`1990–1998
`
`Professorial Lecturer, Department of Economics, The George Washington
`
`University
`
`1987–1991
`
`Economist, Research Division, Office of Economics, U.S. International Trade
`Commission
`
`1987–1988
`
`Economist for the Chairman, (Detail), U.S. International Trade Commission
`
`1986–1987
`
`Visiting Assistant Professor, Aquinas College
`
`1984–1986
`
`Visiting Instructor, University of Michigan-Dearborn
`
`
`
`

`

`
`
`
`
`
`SETH T. KAPLAN
`Page 2
`
`
`
`
`
`EXPERT BEFORE THE U.S. INTERNATIONAL TRADE COMMISSION
`
`Section 337 Investigations
`
` Sulfentrazone, Sulfentrazone Compositions, and Processes for Making Sulfentrazone, No. 337-
`TA-914. FMC Corporation v. Beijing Nutrichem Science and Technology Stock Co., Ltd.;
`
`Summit Argo USA, LLC; Summit Argo North America; and Jiangxi Hey Chemicals Co. Ltd.
`Retained by Summit Argo USA, LLC and Summit Argo North America. TEO Phase: Rebuttal
`
`Expert Report, Deposition, and Trial Testimony. Final Phase: Rebuttal Expert Report and Trial
`
`Testimony
`
` Certain Lithium Silicate Materials and Products Containing the Same, No. 337-TA-911. Ivoclar
`Vivadent AG, Ivoclar Vivadent Inc., and Ivoclar Vivadent Manufacturing Inc. v. Dentsply
`
`International Inc., Dentsply Prosthetics U.S. LLC, and DeguDent GmbH. Retained by
`Respondents. Rebuttal Expert Report
`
` Acousto-Magnetic Electronic Article Surveillance Systems, Components Thereof, and Products
`Containing Same, No.337-TA-904. Tyco Fire & Security GmbH; Sensomatic Electronics, LLC;
`and Tyco Integrated Security, LLC v. All-Tag Security Americas, Inc.; All-Tag Security Hong
`King Co., Ltd.; All-Tag Europe SPRL; All-Tag Secuirty UK, Ltd.; Best Security Industries; and
`
`Signatronic Corporation. Retained by Complainants. Expert Report and Deposition
`
` Antivenom Compositions and Products Containing the Same, No. 337-TA-903. BTG
`International, Inc. v. Veteria Laboratories; BioVeteria Life Sciences, LLC; Instituto Bioclon S.A.
`
`de C.V.; Laboratorios Silanes SA de CV; The Silanes Group; and Rare Disease Therapeutics,
`Inc. Retained by Instituto Bioclon S.A. de C.V.; Laboratorios Silanes SA de CV; and Rare
`
`Disease Therapeutics, Inc. Expert Report, Rebuttal Expert Report, and Deposition
`
` Certain Sintered Rare Earth Magnets, Methods of Making Same and Products Containing
`Same, No. 337-TA-855. Hitachi Metals, Ltd. And Hitachi Metals North Carolina, Ltd v. Yantai
`
`Zhenghai Magnetic Material Co., Ltd., Ningbo Jinji Strong Magnetic Material Co., Ltd., Earth-
`
`Panda Advance Magnetic Material Co., Ltd, Bunting Magnetics Co., Viona Corporation, Allstar
`Magnetics, Dura Magnetics Inc., Integrated Magnetics, Inc., Skullcandy, Inc., Beats Electronics,
`
`LLC, Monster Cable Products, Inc., Bose Corp., TELEX Communications, Inc., Bosch Security
`
`Systems, Inc., Electro-Voice, Inc., AKG Acoustics GmBH, Harman International Industries,
`Shure Inc., Milwaukee Electric Tool Corp., Techtronic Industries Co. Ltd., DeWALT Industrial
`
`Tool Co., Maxon Precision Motors, Inc., Dr. Fritz Faulhaber GmbH & Co. KG, MicroMo
`
`Electronics, Inc., Electro-Optics Technology, Inc, Nexteer Automotive Corp, Callaway Golf Co.,
`Taylor Made Golf Co., and Adidas America, Inc. Retained by Bunting Magnetics Co., Beats
`
`Electronics, LLC, Monster Cable Products, Inc., Bose Corp., Bosch Security Systems, Inc.,
`
`Milwaukee Electric Tool Corp., Techtronic Industries Co. Ltd., DeWALT Industrial Tool Co.,
`Maxon Precision Motors, Inc., MicroMo Electronics, Inc., and Dr. Fritz Faulhaber GmbH & Co.
`
`KG. Rebuttal Expert Report and Deposition
`
`
`
`

`

`
`
`
`
`
`SETH T. KAPLAN
`Page 3
`
`
`
`
`
` Certain Rubber Resins and Processes for Manufacturing Same, No. 337-TA-849. SI Group,
`Inc. v. Sino Legend Chemical Co., Ltd.; RedAvenue Chemical Corp. of America; Precision
`
`Measurement International LLC; Thomas R. Crumlish, Jr.; Ning Zhang; Quanhai Yang; and
`Shanghai Lunsai International Trading Company. Retained by Sino Legend Chemical Co, Ltd.
`
`Rebuttal Expert Report and Trial Testimony
`
` Certain Devices for Mobil Data Communications, No. 337-TA-845. Rovi Corporation; Rovi
`Guides, Inc.; United Video Properties, Inc.; Gemstar Development Corporation; and Index
`
`Systems, Inc. v. LG Electronics; Mitsubishi Electric Corp.; Netflix, Inc.; Roku, Inc.; and Vizio,
`
`Inc. Retained by Complainant. Expert Report, Rebuttal Expert Report, Deposition, and Trial
`Testimony
`
` Certain Mobile Electronics Devices Incorporating Haptics, No. 337-TA-834. Immersion
`Corporation v. Motorola Mobility and HTC Corporation. Retained by Complainant. Expert
`Report and Deposition
`
` Certain Products Containing Interactive Program Guide and Parental Control Technology. No.
`337-TA-820. Rovi Corporation; Rovi Guides, Inc.; United Video Properties, Inc.; Gemstar
`Development Corporation; and Index Systems, Inc. v. Vizio, Inc. Retained by Complainant.
`
`Expert Report and Deposition
`
` Certain Electronic Devices with Communication Capabilities, Components Thereof, and Related
`Software, No. 337-TA-799. MyKey Technology, Inc. v. Data Protection Solutions by Arco; CRU
`
`Acquisitions Group LLC; CRU-DataPort LLC; Digital Intelligence, Inc.; Diskology, Inc.; Guidance
`
`Software, Inc; Guidance Tableau LLC; Ji2, Inc.; MultiMedia Effects, Inc.; Voom Technologies,
`Inc; and YEC Co. Ltd. Retained by Respondents CRU and Guidance. Rebuttal Expert Report
`
`and Trial Testimony
`
` Certain Electronic Devices with Communication Capabilities, Components Thereof, and Related
`Software, Investigation No. 337-TA-808. HTC Corp. v. Apple Inc. Retained by Respondent.
`
`Rebuttal Expert Report, Deposition, and Trial Testimony
`
` Static Random Access Memories and Products Containing Same, Investigation No. 337-TA-
`792. Cypress Semiconductor Corporation v. GSI Technology, Inc.; Alcatel-Lucent; Alcatel-
`
`Lucent USA, Inc.; Telefonaktiebolaget LM Ericsson; Ericsson Inc.; Motorola Solutions, Inc.;
`
`Motorola Mobility, Inc.; Arrow Electronics, Inc.; Nu Horizons Electronics Corp.; Cisco Systems,
`Inc.; Hewlett Packard Company/Tipping Point; Avnet, Inc.; Nokia Siemens Networks US, LLC;
`
`Nokia Siemens Networks B.V.; and Tellabs. Retained by Complainant. Expert Report, Rebuttal
`
`Expert Report, and Deposition
`
` Certain Hand Held Electronic Computing Devices, Related Software and Components Thereof,
`Investigation No. 337-TA-769. Microsoft Corporation v. Barnes & Noble, Inc.;
`
`barnesandnoble.com LLC; Hon Hai Precision Industry Co., Ltd; Foxconn Electronics, Inc.;
`Foxconn Precision Component (Shenzhen) Co.; Foxconn International Holdings Ltd.; and
`
`Inventec Corporation. Retained by Complainant. Expert Report, Supplemental Report,
`Deposition, and Trial Testimony
`
`
`
`

`

`
`
`
`
`
`SETH T. KAPLAN
`Page 4
`
`
`
`
`
` Semiconduct