UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before The Honorable Cameron R. Elliot
`Administrative Law Judge
`
`
`
`
`Investigation No. 337-TA-1159
`
`In the Matter of
`
`CERTAIN LITHIUM ION BATTERIES,
`BATTERY CELLS, BATTERY
`MODULES, BATTERY PACKS,
`COMPONENTS THEREOF, AND
`PROCESSES THEREFOR
`
`
`
`
`
`RESPONDENTS’ IDENTIFICATION OF EXPERT WITNESSES
`
`
`Pursuant to the Procedural Schedule Order No. 6, Respondents SK Innovation Co., Ltd.
`
`(“SKI”) and SK Battery America, Inc. (“SKBA”) (collectively “Respondents” or “SK”), by and
`
`through their undersigned counsel, hereby provide their Identification of Experts. Respondents
`
`reserve the right to identify additional experts as Complainants LG Chem, Ltd. and LG Chem
`
`Michigan Inc. (collectively “LGC” or “Complainants”) potentially clarify their alleged trade
`
`secrets, many of which are vague, ambiguous, overbroad, unclear, and lack specificity.
`
`Respondents also reserve the right to elicit testimony from any expert identified by Complainants
`
`in this Investigation.
`
`Paul A. Kohl, Ph.D.
`
`1.
`Dr. Kohl is the Regents’ Professor and Thomas L. Gossage Chair at the Georgia Institute
`
`of Technology. Dr. Kohl’s expertise includes chemistry, electrochemistry, electrochemical
`
`engineering, and materials science and engineering. Dr. Kohl’s expertise is set forth in more
`
`detail in his curriculum vitae, which is attached hereto as Exhibit A.
`
`Dr. Kohl may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
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`Inv. No. 337-TA-1159;
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`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Kohl may further offer opinions and/or testimony
`
`in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection with any
`
`claims or issues asserted by Complainants or Staff.
`
`Mehrdad (Mark) Ehsani, Ph.D.
`
`2.
`Dr. Ehsani is the Robert M. Kennedy ’26 Professor II at the Texas A&M University. Dr.
`
`Ehsani’s expertise includes electrical engineering, power systems, and control systems. Dr.
`
`Ehsani’s expertise is set forth in more detail in his curriculum vitae, which is attached hereto as
`
`Exhibit B.
`
`Dr. Ehsani may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Ehsani may further offer opinions and/or testimony
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`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection with any
`
`claims or issues asserted by Complainants or Staff.
`
`Thomas Fuller, Ph.D.
`
`3.
`Dr. Fuller is a Professor at the Georgia Institute of Technology. Dr. Fuller’s expertise
`
`includes chemistry, electrochemistry, electrochemical engineering, and materials science and
`
`engineering. Dr. Fuller’s expertise is set forth in more detail in his curriculum vitae, which is
`
`attached hereto as Exhibit C.
`
`Dr. Fuller may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Fuller may further offer opinions and/or testimony
`
`in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection with any
`
`claims or issues asserted by Complainants or Staff.
`
`Marc Herniter, Ph.D.
`
`4.
`Dr. Herniter is a Professor at the Rose-Hulman Institute of Technology. Dr. Herniter’s
`
`expertise includes electrical engineering with specialties in analog electronics, power electronics,
`
`and control systems. Dr. Herniter’s expertise is set forth in more detail in his curriculum vitae,
`
`which is attached hereto as Exhibit D.
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`Respondents’ Identification of Expert Witnesses
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`Dr. Herniter may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Herniter may further offer opinions and/or
`
`testimony in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection
`
`with any claims or issues asserted by Complainants or Staff.
`
`Michael Pecht, Ph.D.
`
`5.
`Dr. Pecht is the George E. Dieter Professor at the University of Maryland. Dr. Pecht’s
`
`expertise includes mechanical engineering and the development and manufacturing of battery
`
`products and battery systems. Dr. Pecht’s expertise is set forth in more detail in his curriculum
`
`vitae, which is attached hereto as Exhibit E.
`
`Dr. Pecht may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
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`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Pecht may further offer opinions and/or testimony
`
`in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection with any
`
`claims or issues asserted by Complainants or Staff.
`
`Kevin Konecky
`
`6.
`Mr. Konecky is a battery consultant at Advanced Battery Systems Consulting, LLC. Mr.
`
`Konecky’s expertise includes the design, development, and manufacturing of battery products
`
`and battery systems. Mr. Konecky’s expertise is set forth in more detail in his curriculum vitae,
`
`which is attached hereto as Exhibit F.
`
`Mr. Konecky may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Mr. Konecky may further offer opinions and/or
`
`testimony in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection
`
`with any claims or issues asserted by Complainants or Staff.
`
`Yet-Ming Chiang, Ph.D.
`
`7.
`Dr. Chiang is the Kyocera Professor at the Massachusetts Institute of Technology. Dr.
`
`Chiang’s expertise includes materials science and engineering and the design, development, and
`
`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`
`

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`manufacturing of battery products and battery systems. Dr. Chiang’s expertise is set forth in
`
`more detail in his curriculum vitae, which is attached hereto as Exhibit G.
`
`Dr. Chiang may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Chiang may further offer opinions and/or testimony
`
`in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection with any
`
`claims or issues asserted by Complainants or Staff.
`
`Joseph Havlicek, Ph.D.
`
`8.
`Dr. Havlicek is the Gerald Tuma Presidential Professor of Electrical & Computer
`
`Engineering Professor at the University of Oklahoma. Dr. Havlicek’s expertise includes the
`
`processing and analysis of images and signals. Dr. Havlicek’s expertise is set forth in more detail
`
`in his curriculum vitae, which is attached hereto as Exhibit H.
`
`Dr. Havlicek may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`6
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`

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`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Havlicek may further offer opinions and/or
`
`testimony in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection
`
`with any claims or issues asserted by Complainants or Staff.
`
`Tequila A. L. Harris, Ph.D.
`
`9.
`Dr. Harris is an Associate Professor at the Georgia Institute of Technology. Dr. Harris’s
`
`expertise includes rheology, polymer processing, mechanical system design, and fluid flow. Dr.
`
`Harris’s expertise is set forth in more detail in her curriculum vitae, which is attached hereto as
`
`Exhibit I.
`
`Dr. Harris may offer opinions and/or testimony relating to Complainants’ trade secret
`
`misappropriation claim, including but not limited to the technical background and state of the art
`
`relevant to the Complainants’ alleged trade secrets; the design, development, and manufacture of
`
`Complainants’ domestic industry products; Respondents’ independent development of lithium-
`
`ion battery technologies for electric vehicles; whether the Complainants in fact own the alleged
`
`trade secrets; whether the alleged trade secrets are in fact secret, confidential, or proprietary to
`
`Complainants; whether the alleged trade secrets are readily ascertainable by lawful means;
`
`whether the alleged trade secrets lack independent economic value; the time and effort it would
`
`take to develop the alleged trade secrets. Dr. Harris may further offer opinions and/or testimony
`
`in rebuttal to Complainants’ or Staff’s experts or fact witnesses, and in connection with any
`
`claims or issues asserted by Complainants or Staff.
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`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`Seth T. Kaplan, Ph.D.
`
`10.
`Dr. Kaplan is President of International Economic Research LLC, and Senior Economic
`
`Advisor at Capital Trade, Incorporated. Dr. Kaplan’s expertise includes the fields of economics,
`
`financial analysis, and international trade. Dr. Kaplan may offer opinions and/or testimony in
`
`this Investigation relating to the economics of Complainants’ alleged domestic industry; the
`
`injury or likelihood of injury to Complainants’ alleged domestic industry as a result of
`
`Respondents’ alleged trade secret misappropriation; and the appropriate remedies if a violation is
`
`found, including whether a bond should be required in the event of a violation and, if so, the
`
`amount of the bond. Dr. Kaplan may further offer opinions and/or testimony in rebuttal to
`
`Complainants’ or Staff’s experts, fact witnesses and in connection with any claims or issues
`
`asserted by Complainants. Dr. Kaplan’s expertise is set forth in more detail in his curriculum
`
`vitae, which is attached hereto as Exhibit J.
`
`11. G. Michael Phillips, Ph.D.
`Dr. Phillips is a professor of finance, financial planning, and insurance at the David
`
`Nazarian College of Business and Economics at California State University, Northridge.
`
`Dr. Phillips is also the President of Phillips Research Applications, Inc., Chief Scientist &
`
`President at Center for Computationally Advanced Statistical Techniques, and Principal at
`
`Walnut Oak Capital, LLC. Dr. Phillips’ expertise includes the field of finance and economics,
`
`and Dr. Phillips specializes in complex financial modeling, financial and intellectual property
`
`valuation, damages, licensing, economic modeling and forecasting, statistical and econometric
`
`analysis, labor market analysis and employment economics, economic substance valuation, and
`
`other issues related to the economic value of trade secrets. Dr. Phillips may offer opinions
`
`and/or testimony in this Investigation relating to the economic value of Complainants’ alleged
`
`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`trade secrets, the injury or likelihood of injury to Complainants’ alleged domestic industry as a
`
`result of Respondents’ alleged trade secret misappropriation, and the appropriate remedies if a
`
`violation is found, including whether a bond should be required in the event of a violation and, if
`
`so, the amount of the bond. Dr. Phillips may further offer opinions and/or testimony in rebuttal
`
`to Complainants’ or Staff’s experts, fact witnesses, and in connection with any claims or issues
`
`asserted by Complainants or Staff. Dr. Phillips’ expertise is set forth in more detail in his
`
`curriculum vitae, which is attached hereto as Exhibit K.
`
`Rodney L. Crawford
`
`12.
`Mr. Crawford is the founding member of Crawford & Winiarski, a CPA firm specializing
`
`in the practice of forensic accounting, economic damages analysis in complex commercial
`
`disputes, business valuation, financial fraud investigation, consulting services to public
`
`companies related to accounting matters, and corporate insolvency situations. Mr. Crawford’s
`
`expertise includes the field of finance and economics, and Mr. Crawford specializes in
`
`intellectual property valuation, licensing, damages, complex financial modeling, and other issues
`
`related to the economic value of trade secrets. Mr. Crawford’s most significant industry
`
`concentration has been in the automotive and automotive components industry. Mr. Crawford
`
`may offer opinions and/or testimony in this Investigation relating to the economic value of
`
`Complainants’ alleged trade secrets, the injury or likelihood of injury to Complainants’ alleged
`
`domestic industry as a result of Respondents’ alleged trade secret misappropriation, and the
`
`appropriate remedies if a violation is found, including whether a bond should be required in the
`
`event of a violation and, if so, the amount of the bond. Mr. Crawford may further offer opinions
`
`and/or testimony in rebuttal to Complainants’ or Staff’s experts, fact witnesses, and in
`
`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`connection with any claims or issues asserted by Complainants or Staff. Mr. Crawford’s
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`expertise is set forth in more detail in his curriculum vitae, which is attached hereto as Exhibit L.
`
`Robert Kirtley
`
`13.
`Mr. Kirtley is a Director of Cyber Security for iDiscovery Solutions (iDS). Mr. Kirtley’s
`
`expertise includes the fields of technology infrastructure, security systems, and management
`
`consulting, and Mr. Kirtley specializes in cyber security, information management, and other
`
`issues related to the protection of trade secrets. Mr. Kirtley has also worked with clients to
`
`assess cyber information and trade secret protection programs and plan and execute incident
`
`response efforts in the event of a suspected data breach or system compromise. Mr. Kirtley may
`
`offer opinions and/or testimony in this Investigation relating to Complainants’ failure to employ
`
`reasonable efforts to protect the secrecy of Complainants’ alleged trade secrets. Mr. Kirtley may
`
`further offer opinions and/or testimony in rebuttal to Complainants’ or Staff’s experts, fact
`
`witnesses, and in connection with any claims or issues asserted by Complainants or Staff.
`
`Mr. Kirtley’s expertise is set forth in more detail in his curriculum vitae, which is attached hereto
`
`as Exhibit M.
`
`Charlie Platt
`
`14.
`Mr. Platt is a Director of Cyber Security for iDiscovery Solutions (iDS). Mr. Platt’s
`
`expertise includes the fields of cyber security and digital forensics, and Mr. Platt specializes in
`
`data systems and analytics, cyber security, and incident response, information systems
`
`development, infrastructure planning, database design, eDiscovery, software development,
`
`project management, computer forensic analysis, methodologies and procedures, and other issues
`
`related to misappropriation of trade secrets, and other issues related to the protection and
`
`misappropriation of trade secrets. Mr. Platt may offer opinions and/or testimony in this
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`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`Investigation relating to Complainants’ allegations of misappropriation of trade secrets,
`
`including Complainants’ purported forensic analyses, whether Complainants used proper and
`
`reliable methods when conducting their purported forensic investigations, and Complainants’
`
`failure to employ reasonable efforts to protect the secrecy of Complainants’ alleged trade secrets.
`
`Mr. Platt may further offer opinions and/or testimony in rebuttal to Complainants’ or Staff’s
`
`experts, fact witnesses, and in connection with any claims or issues asserted by Complainants or
`
`Staff. Mr. Platt’s expertise is set forth in more detail in his curriculum vitae, which is attached
`
`hereto as Exhibit N.
`
`Ryan Bilbrey
`
`15.
`Mr. Bilbrey is the Managing Director for Reckoning Consulting Partners. Mr. Bilbrey’s
`
`expertise includes the fields of electronic discovery, digital forensics, forensic accounting, data
`
`analytics, and strategic consulting services, and Mr. Bilbrey specializes in eDiscovery, cyber
`
`security data breach response, structured data analytics, information governance, damage
`
`analysis, forensic investigations, computer forensic analysis, methodologies and procedures, and
`
`other issues related to misappropriation of trade secrets. Mr. Bilbrey may offer opinions and/or
`
`testimony in this Investigation relating to Complainants’ allegations of misappropriation of trade
`
`secrets, including Complainants’ purported forensic analyses, whether Complainants used proper
`
`and reliable methods when conducting their purported forensic investigations, and
`
`Complainants’ failure to employ reasonable efforts to protect the secrecy of Complainants’
`
`alleged trade secrets. Mr. Bilbrey may further offer opinions and/or testimony in rebuttal to
`
`Complainants’ or Staff’s experts, fact witnesses, and in connection with any claims or issues
`
`asserted by Complainants or Staff. Mr. Bilbrey’s expertise is set forth in more detail in his
`
`curriculum vitae, which is attached hereto as Exhibit O.
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`James D. Vaughn
`
`16.
`Mr. Vaughn is a Managing Director of iDiscovery Solutions (iDS). Mr. Vaughn’s
`
`expertise includes the field of digital forensics, and Mr. Vaughn specializes in evidence
`
`preservation, documentation of events, and digital forensic analysis, methodologies and
`
`procedures, and other issues related to misappropriation of trade secrets. Mr. Vaughn may offer
`
`opinions and/or testimony in this Investigation relating to Complainants’ allegations of
`
`misappropriation of trade secrets, including Complainants’ purported forensic analyses, whether
`
`Complainants used proper and reliable methods when conducting their purported forensic
`
`investigations, and Complainants’ failure to employ reasonable efforts to protect the secrecy of
`
`Complainants’ alleged trade secrets. Mr. Vaughn may further offer opinions and/or testimony in
`
`rebuttal to Complainants’ or Staff’s experts, fact witnesses, and in connection with any claims or
`
`issues asserted by Complainants or Staff. Mr. Vaughn’s expertise is set forth in more detail in
`
`his curriculum vitae, which is attached hereto as Exhibit P.
`
`Dan Regard
`
`17.
`Mr. Regard is an electronic discovery and computer science consultant with iDiscovery
`
`Solutions (iDS). Mr. Regard’s expertise includes the fields of electronic discovery, digital
`
`forensics, structured data, and information management, and Mr. Regard specializes in system
`
`investigations, created data collections, computer forensic analysis, methodologies, and
`
`procedures, managed discovery, and other issues related to misappropriation of trade secrets.
`
`Mr. Regard may offer opinions and/or testimony in this Investigation relating to Complainants’
`
`allegations of misappropriation of trade secrets, including Complainants’ purported forensic
`
`analyses, whether Complainants used proper and reliable methods when conducting their
`
`purported forensic investigations, and Complainants’ failure to employ reasonable efforts to
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`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`12
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`protect the secrecy of Complainants’ alleged trade secrets. Mr. Regard may further offer
`
`opinions and/or testimony in rebuttal to Complainants’ or Staff’s experts, fact witnesses, and in
`
`connection with any claims or issues asserted by Complainants or Staff. Mr. Regard’s expertise
`
`is set forth in more detail in his curriculum vitae, which is attached hereto as Exhibit Q.
`
`18. Opinion Testimony from Other Witnesses
`In addition to the expert witnesses identified above, Respondents reserve the right to offer
`
`opinion testimony from lay witnesses called by any of the parties at the hearing in this
`
`Investigation as to matters within the scope of lay witness testimony. Respondents further
`
`reserve the right to elicit testimony that may be deemed expert testimony from percipient
`
`witnesses who have the requisite scientific, technical or other specialized knowledge to provide
`
`that testimony, and hereby designate those lay witnesses as experts with regard to any such
`
`testimony. These reservations of rights to offer such testimony include, but are not limited to,
`
`opinion or expert testimony.
`
`
`
`Dated: September 3, 2019
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`/s/ Sturgis M. Sobin
`Sturgis M. Sobin
`Shara L. Aranoff
`Maureen F. Browne
`Alexander D. Chinoy
`Daniel E. Johnson
`Augustus Golden
`Kristin M. Cobb
`Erin E. Biel
`Emily M. Mondry
`COVINGTON & BURLING LLP
`One CityCenter, 850 Tenth Street, N.W.
`Washington, DC 20001
`Telephone: +1 202-662-6000
`
`
`Teena-Ann V. Sankoorikal
`Matthew B. Phelps
`13
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`Respondents’ Identification of Expert Witnesses
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`Gregory Nieberg
`Heng Gong
`Amy Bond
`Jennifer D. Cieluch
`Joanna Hoodes
`COVINGTON & BURLING LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018-1405
`Telephone: +1 212-841-1000
`
`
`Robert T. Haslam
`COVINGTON & BURLING LLP
`3000 El Camino Real
`5 Palo Alto Square
`Palo Alto, CA 94306
`Telephone: +1 650-632-4700
`
`Michael K. Plimack
`Nitin Subhedar
`Stephanie M. Tennant
`COVINGTON & BURLING LLP
`Salesforce Tower
`415 Mission Street
`San Francisco, CA 94105-2533
`Telephone: +1 415-591-6000
`
`William H.Y. Park
`Scott A. Schrader
`Chang Sik (Charles) Kim
`Marian Sooyun Lee
`22nd Floor, Meritz Tower
`382, Gangnam-daero
`Gangnam-gu, Seoul
`Republic of Korea
`Telephone: +82-2-6281-0000
`Counsel for Respondents SK Innovation Co., Ltd. and
`SK Battery America, Inc.
`
`
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`Inv. No. 337-TA-1159;
`Respondents’ Identification of Expert Witnesses
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`14
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`INDEX OF EXHIBITS
`
`Exhibit
`
`Description
`
`Exhibit A
`
`Exhibit B
`
`Exhibit C
`
`Exhibit D
`
`Exhibit E
`
`Exhibit F
`
`Exhibit G
`
`Exhibit H
`
`Exhibit I
`
`Exhibit J
`
`Exhibit K
`
`Exhibit L
`
`Exhibit M
`
`Exhibit N
`
`Exhibit O
`
`Exhibit P
`
`Exhibit Q
`
`Curriculum Vitae of Paul A. Kohl, Ph.D.
`
`Curriculum Vitae of Mehrdad (Mark) Ehsani, Ph.D.
`
`Curriculum Vitae of Thomas Fuller, Ph.D.
`
`Curriculum Vitae of Marc Herniter, Ph.D.
`
`Curriculum Vitae of Michael Pecht, Ph.D.
`
`Curriculum Vitae of Kevin Konecky
`
`Curriculum Vitae of Yet-Ming Chiang, Ph.D.
`
`Curriculum Vitae of Joseph Havlicek, Ph.D.
`
`Curriculum Vitae of Tequila A. L. Harris, Ph.D.
`
`Curriculum Vitae of Seth T. Kaplan, Ph.D.
`
`Curriculum Vitae of G. Michael Phillips, Ph.D.
`
`Curriculum Vitae of Rodney L. Crawford
`
`Curriculum Vitae of Robert Kirtley
`
`Curriculum Vitae of Charlie Platt
`
`Curriculum Vitae of Ryan Bilbrey
`
`Curriculum Vitae of James D. Vaughn
`
`Curriculum Vitae of Dan Regard
`
`

`

`EXHIBIT (cid:36)
`
`EXHIBIT A
`
`

`

`PAUL A. KOHL, Ph.D., Regents’ Professor and Thomas L. Gossage Chair
`
`Georgia Institute of Technology
`311 Ferst St.
`Atlanta, GA 30332-0100 USA
`404-894-2893, kohl@gatech.edu
`
`Country of Residence: United States of America
`
`PROFESSIONAL EXPERIENCE
`
`1989 to Present
`
`Georgia Institute of Technology
`
`2006 to Present
`
`1999 to Present
`
`2006 to 2013
`
`2008-2011
`
`1994 to 1999
`
`1989 to 1994
`
`Hercules Inc./Thomas L. Gossage Chair
`
`Regents’ Professor
`
`Director, SRC Interconnect Focus Center
`
`Director, SRC Interconnect and Packaging Center
`
`Professor
`
`Associate Professor
`
`1978 to 1989
`
`AT&T Bell Laboratories
`
`1982 to 1989
`
`Technical Supervisor
`
`1978 to 1982
`
`Member of Technical Staff
`
`CONSULTANT:
`
`Dow Chemical (regarding fabrication of metal films for electronic packaging)
`
`EDUCATION
`
`Ph.D., Chemistry, University of Texas at Austin, 1978
`BS, Chemistry, Bethany College, 1974
`
`PROFESSIONAL AFFILIATIONS & AWARDS
`
`Editorial Service
`
`President, The Electrochemical Society, 2013-4
`Editor-in-Chief, Journal of The Electrochemical Society, 1995-2008
`Editor-in-Chief (Founding Editor), Electrochemical and Solid-State Letters, 1998-2003
`Editor (Founding Editor), The Electrochemical Society Interface, 1992-1995
`
`Professional Affiliations
`
`

`

`Paul A. Kohl, Ph.D.
`Resume
`
`Page 2.
`
`Member, Electrochemical Society
`Member, American Institute of Chemical Engineers (AICHE)
`Member, American Chemical Society
`Member, Materials Research Society
`Member, IEEE
`
`Honors and Awards
`
`Gordon E. Moore Award for excellence in solid state science and technology, ECS 2017
`Cooperative Research Award in Polymer Science, American Chemical Society 2017
`GT ChBE “Ronald W. Rousseau Award for Excellence in Mentoring", 2013
`Sigma Xi Sustained Research Award GT, 2013
`GT Class of 1934 Course Evaluation Excellence in Teaching Award, 2012
`Thomas D. Callinan Award for Advances in Dielectric Materials, Electrochemical
`Society, 2008
`Named Fellow of The Electrochemical Society, October 2002
`Best Paper Award, IEEE 52nd Electronic Components and Technology Conference, 2002
`Carl Wagner Memorial Award: The Electrochemical Society, 2001
`Zeigler Outstanding Faculty, School of Chemical Engineering, Georgia Tech., 2000-2001
`Research Award: NSF-ERC in Electronic Packaging, 1999
`Research Program Development Award, 1995, Georgia Tech.
`Named Institute Fellow, 1994, Georgia Tech.
`Outstanding Faculty Award, 1990-1991, Chemical Engineering, Georgia Tech.
`Outstanding Faculty Award, 1990-1991, AICHE Student Chapter Georgia Tech.
`Outstanding Alumni Achievement Award presented by Bethany College in 1986
`Named one of "America's 100 Brightest Scientists Under 40" by Science Digest in 1985
`Edward Weston Fellowship from the Electrochemical Society in 1977
`Gilbert H. Ayers for outstanding graduate work in chemistry in 1977
`Awarded Academic Distinction in chemistry from Bethany College in 1974
`Analytical Chemistry Award from the American Chemical Society in 1973
`
`U.S. ISSUED PATENTS (64)
`
`Patent Number
`
`Year Issued
`
`Title
`
`9,740,096
`
`9,242,243
`
`8,999,629
`
`8,956,805
`
`2017
`
`2016
`
`2015
`
`2015
`
`Postive-tone, Chemically Amplified,
`Aqueous-developable, Permanent
`Dielectric
`
`Anion Exchange Polyelectrolytes
`
`Photosensitive Sacrificial Polymer with
`Low Residue
`
`Polymers, Methods and Use Thereof, and
`Methods of Decomposition
`
`

`

`Paul A. Kohl, Ph.D.
`Resume
`
`8,895,196
`
`8,765,512
`
`8,728,717
`
`8,637,137
`
`8,476,956
`
`8,455,174
`
`8,405,170
`
`8,133,634
`
`7,923,194
`
`7,875,404
`
`7,847,669
`
`7,799,516
`
`7,798,817
`
`7,745,100
`
`7,695,894
`
`2014
`
`2014
`
`2014
`
`2014
`
`2013
`
`2013
`
`2013
`
`2012
`
`2011
`
`2011
`
`2010
`
`2010
`
`2010
`
`2010
`
`2010
`
`Page 3.
`
`Electrochemical Devices Based on Multiple
`Junction Ionic Conductive Membranes
`
`Packaging Compatible Wafer Level
`Capping of MEMS Devices
`
`Photosenstive Sacrifical Polymer with Low
`Residue
`
`Microstructures and Methods of
`Fabrication Thereof
`
`Packaging for Micro Electro-Mechanical
`Systems and Methods of Fabricating
`Thereof
`
`Polymers, Methods of Use Thereof, and
`Methods for Decomposition Thereof
`
`Packaging for Micro Electro-Mechanical
`Systems and Methods of Fabricating
`Thereof
`
`Fuel Cell with Porous Frit Based Composite
`Proton Exchange Membrane
`
`Sacrificial Compositions and Methods of
`Fabricating a Structure Using Sacrificial
`Compositions
`
`Microstructures and Methods of Fabrication
`Thereof
`
`Micro-Electromechanical Switched Tunable
`Inductor
`
`Polymers, Methods of use Thereof, and
`Methods of Decomposition Thereof
`
`Integrated Circuit Interconnects with
`Coaxial Conductors
`
`Polymers, Methods of Use Thereof, and
`Methods of Decomposition Thereof
`
`Sacrificial Compositions and Methods of
`Fabricating a Structure Using Sacrificial
`Compositions
`
`

`

`Paul A. Kohl, Ph.D.
`Resume
`
`7,554,347
`
`2009
`
`7,504,699
`
`7,459,267
`
`7,182,875
`
`7,052,821
`
`6,954,576
`
`6,947,651
`
`6,933,165
`
`6,888,249
`
`6,87