UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`Before the Honorable Dee Lord
`Administrative Law Judge
`
`In the Matter of
`
`Certain Electronic Devices, Including
`Computers, Tablet Computers, and
`Components and Modules Thereof
`
`Investigation No. 337-TA-1208
`
`RESPONDENTS’ AND INTERVENOR’S UNOPPOSED MOTION FOR LEAVE
`TO FILE JOINT AMENDED IDENTIFICATION OF EXPERT WITNESSES
`
`Pursuant to Commission Rule 210.15(d), Respondents Lenovo (United States) Inc., Lenovo
`
`Group Limited, Lenovo (Beijing) Limited, Lenovo PC HK Limited, Lenovo (Shanghai) Electronics
`
`Technology Co. Ltd., Lenovo Information Products Shenzhen Co. Ltd., Lenovo Mobile
`
`Communication, and Lenovo Centro Tecnologico S. de RL CV (collectively, “Lenovo” or
`
`“Respondents”) respectfully request leave to file the attached Amended Identification of Expert
`
`Witnesses.
`
`Ground Rule 3.2 Certification
`
`Pursuant to Ground Rule 3.2, counsel for Lenovo confirms that it made reasonable, good-
`
`faith efforts to resolve this matter with Nokia, Google and Staff prior to filing this motion. On
`
`January 15, 2021, Lenovo contacted Nokia, Google, and Staff and sought their position on the
`
`present motion. Nokia, Google, and Staff indicated that they do not oppose the motion and agreed
`
`to waive the two-day requirement.
`
`Argument
`
`On January 8, 2021, Lenovo timely filed its Identification of Expert Witnesses identifying
`
`individuals as experts who may testify on behalf of Lenovo in this Investigation. See Doc. ID No.
`
`1
`
`

`

`730009 (January 8, 2021). Nokia filed its Identification of Expert Witnesses on January 8, 2021 as
`
`well. See Doc. ID No. 729990 (January 8, 2021). In its submission, Nokia identified, among other
`
`individuals, Dr. Peter Georg Picht. See id. at 2. According to Nokia’s submission, Dr. Picht is an
`
`expert in “the field of international law, competition law, intellectual property, and Swiss law,” and
`
`may be called to testify “regarding the remedy, public interest, as well as the enforceability of the
`
`Patents-in-Suit, including ITU, JVT, and VCEG IPR policies, licensing negotiations, RAND, and
`
`Swiss law.” Id. Nokia’s identification of Dr. Picht as a purported expert regarding Swiss law was
`
`unexpected to Lenovo because, among other things, Dr. Picht has not been disclosed under the
`
`Protective Order.
`
`In light of Nokia’s disclosure of a purported expert on Swiss law, Lenovo respectfully
`
`requests leave to file its own Amended Identification of Expert Witnesses in order to disclose its
`
`expert on Swiss law, Mr. Simon Holzer. Good cause exists for Lenovo to amend its Identification
`
`of Expert Witnesses to identify Mr. Holzer in light of Nokia’s unexpected disclosure. See Certain
`
`Audio Players and Controllers, Components Thereof, and Products Containing Same, Inv. No.
`
`337-TA-1191, Order No. 10 (May 27, 2020) (finding good cause for moving party to amend Initial
`
`Identification of Expert Witnesses where moving party did not have prior notice that the other side
`
`would be disclosing an expert on a particular issue). And Nokia, Google, and Staff do not oppose
`
`Lenovo’s Motion.
`
`
`
`Lenovo respectfully requests that the ALJ grant its unopposed Motion for Leave and permit
`
`its Amended Identification of Expert Witnesses, appended here as Attachment 1, to be filed.
`
`2
`
`Inv. 337-1208 - Respondents' and Intervenor's Unopposed Motion for Leave to File Joint Amended
`Identification of Expert Witnesses
`
`

`

`Dated: January 19, 2021
`
`Respectfully submitted,
`/s/ Kate Saxton _______________
`William F. Lee
`Joseph J. Mueller
`Richard W. O’Neill
`Sarah R. Frazier
`Andrew Danford
`Kate Saxton
`WILMER CUTLER PICKERING HALE AND
`DORR LLP
`60 State Street
`Boston, MA 02109
`Telephone: (617) 526-6000
`WHLenovo-Nokia1208servicelist@WilmerHale.com
`
`Michael D. Esch
`Todd Zubler
`WILMER CUTLER PICKERING HALE AND
`DORR LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Telephone: (202) 663-6000
`WHLenovo-Nokia1208servicelist@WilmerHale.com
`
`Counsel for Respondents
`
`Lenovo (United States) Inc., Lenovo Group Limited,
`Lenovo (Beijing) Limited, Lenovo PC HK Limited,
`Lenovo (Shanghai) Electronics Technology Co. Ltd.,
`Lenovo Information Products Shenzhen Co. Ltd.,
`Lenovo Mobile Communication, and Lenovo Centro
`Tecnologico S. de RL CV
`
`3
`
`Inv. 337-1208 - Respondents' and Intervenor's Unopposed Motion for Leave to File Joint Amended
`Identification of Expert Witnesses
`
`

`

`WHITE & CASE LLP
`
`/s/ Shamita D. Etienne-Cummings
`
`Shamita D. Etienne-Cummings
`David Markoff
`701 13th Street NW
`Washington, DC 20005-3807
`Telephone: 202.626.3600
`Facsimile: 202.639.9355
`
`Eric Lancaster
`Don Zhe Nan Wang
`Emily Yang
`3000 El Camino Real
`2 Palo Alto Square, Suite 900
`Palo Alto, CA 94306
`Telephone: 650.213.0300
`Facsimile: 650.213.8158
`
`Counsel for Intervenor Google LLC
`
`4
`
`Inv. 337-1208 - Respondents' and Intervenor's Unopposed Motion for Leave to File Joint Amended
`Identification of Expert Witnesses
`
`

`

`ATTACHMENT 1
`
`ATTACHMENT 1
`
`

`

`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`Before the Honorable Dee Lord
`Administrative Law Judge
`
`In the Matter of
`
`Certain Electronic Devices, Including
`Computers, Tablet Computers, and
`Components and Modules Thereof
`
`Investigation No. 337-TA-1208
`
`RESPONDENTS LENOVO (UNITED STATES) INC., LENOVO GROUP LIMITED,
`LENOVO (BEIJING) LIMITED, LENOVO (SHANGHAI) ELECTRONICS
`TECHNOLOGY CO. LTD., LENOVO PC HK LIMITED, LENOVO INFORMATION
`PRODUCTS SHENZHEN CO. LTD., LENOVO MOBILE COMMUNICATION IMPORT
`AND EXPORT (WUHAN) CO. LTD., AND LENOVO CENTRO TECNOLOGICO S. DE
`R.L. C.V. AND INTERVENOR GOOGLE LLC’S AMENDED
`JOINT IDENTIFICATION OF EXPERT WITNESSES
`
`Pursuant to the Administrative Law Judge’s Ground Rules (Order No. 2) and the
`
`Procedural Schedule (Order No. 6) in this Investigation, Respondents Lenovo (United States)
`
`Inc., Lenovo Group Limited, Lenovo (Beijing) Limited, Lenovo (Shanghai) Electronics
`
`Technology Co. Ltd., Lenovo PC HK Limited, Lenovo Information Products Shenzhen Co. Ltd.,
`
`Lenovo Mobile Communication Import and Export (Wuhan) Co. Ltd., and Lenovo Centro
`
`Tecnologico S. de R.L. C.V. (collectively, “Respondents” or “Lenovo”), and Intervenor Google
`
`LLC, (“Intervenor” or “Google”) by and through their undersigned attorneys, hereby identify the
`
`following expert witnesses who may offer opinions and/or testimony in this Investigation. This
`
`amended identification of expert witnesses is based on Respondents’ and Intervenor’s current
`
`understanding of the evidence and issues to be decided at the hearing. Respondents and
`
`Intervenor reserve the right to amend and/or supplement these disclosures as appropriate,
`
`including in response to new information or allegations.
`1
`
`

`

`Samrat “Bobby” Bhattacharjee
`
`Dr. Bhattacharjee has a Ph.D. in Computer Science from the Georgia Institute of
`
`Technology. He is a Professor in the Computer Science Department and in the Institute for
`
`Advanced Computer Studies at the University of Maryland, as well as an Affiliate Professor in
`
`the Department of Electrical and Computer Engineering at the University of Maryland. Dr.
`
`Bhattacharjee has expertise in the areas set forth in his curriculum vitae, including computer
`
`science and/or computer engineering. Dr. Bhattacharjee has worked in the field of computer
`
`science for more than twenty years and has published extensively. A copy of Dr. Bhattacharjee’s
`
`curriculum vitae is attached hereto as Exhibit A. Dr. Bhattacharjee may testify, without
`
`limitation, on issues including noninfringement, the technical prong of the domestic industry
`
`requirement, and on technical issues, if any, relating to remedy. In addition, Dr. Bhattacharjee
`
`may provide rebuttal to opinions offered by Complainant’s experts.
`
`John Crockett
`
`Mr. Crockett has a Masters of Science in Electrical Engineering from Utah State
`
`University. He is a consulting engineer and has expertise in the areas set forth in his curriculum
`
`vitae, including computer science and/or computer engineering. Mr. Crockett has worked in
`
`these fields for more than ten years and also has experience as a practicing engineer. A copy of
`
`Mr. Crockett’s curriculum vitae is attached hereto as Exhibit B. Mr. Crockett may testify,
`
`without limitation, on issues including noninfringement, the technical prong of the domestic
`
`industry requirement, and on technical issues, if any, relating to remedy. In addition, Mr.
`
`Crockett may provide rebuttal to opinions offered by Complainant’s experts.
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`2
`
`

`

`Michael A.M. Davies
`
`Mr. Davies has an MBA from London Business School, a Masters Degree in Engineering
`
`from the University of Durham (United Kingdom) and a Masters Degree in Electrical Sciences
`
`from St. Catharine’s College at the University of Cambridge. He is a Senior Partner and
`
`Chairman at Endeavour Partners, Lecturer at the Massachusetts Institute of Technology, and
`
`Guest Lecturer at London Business School. Mr. Davies has expertise in the areas set forth in his
`
`curriculum vitae, including economic and competitive analysis, corporate operations, supply
`
`chain management, and the economics of hardware electronic and mechanical systems, in
`
`particular semiconductor and hardware manufacturing, modern computing systems, and
`
`consumer electronics. Mr. Davies has nearly thirty years’ experience in the telecommunications
`
`and related industries with a particular focus on innovation in mobile devices, communications
`
`services, and network infrastructure. A copy of Mr. Davies’ curriculum vitae is attached hereto
`
`as Exhibit C. Mr. Davies may testify, without limitation, on issues including the public interest,
`
`economic prong of the domestic industry requirement, remedy, and bonding. In addition, Mr.
`
`Davies may provide rebuttal to opinions offered by Complainant’s experts.
`
`Jeffrey A. Eisenach, Ph.D.
`
`Dr. Eisenach has a Ph.D. in economics from the University of Virginia. He is a
`
`Managing Director and Co-Chair of NERA Economic Consulting’s Communications, Media,
`
`and Internet Practice. He is also an Adjunct Professor at George Mason University Law School,
`
`where he teaches Regulated Industries, and a Visiting Scholar at the American Enterprise
`
`Institute. Previously, Dr. Eisenach has served in senior policy positions at the U.S. Federal
`
`Trade Commission and the White House Office of Management and Budget. A copy of Dr.
`
`Eisenach’s curriculum vitae is attached hereto as Exhibit D. Dr. Eisenach may testify, without
`3
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`limitation, on issues including the public interest, economic prong of the domestic industry
`
`requirement, remedy, and bonding. In addition, Dr. Eisenach may provide rebuttal to opinions
`
`offered by Complainant’s experts.
`
`James E. Fowler
`
`Dr. Fowler has a Ph.D. in Electrical Engineering from Ohio State University. He is a
`
`Professor in the Department of Electrical and Computer Engineering at Mississippi State
`
`University. Dr. Fowler has expertise in the areas set forth in his curriculum vitae, including
`
`video coding, computer science and/or computer engineering. Dr. Fowler has published
`
`extensively on topics including video and image compression, video coding, and motion
`
`compensation. A copy of Dr. Fowler’s curriculum vitae is attached hereto as Exhibit E. Dr.
`
`Fowler may testify, without limitation, on issues including level of one of ordinary skill in the
`
`art, claim construction, noninfringement, prior art, the state of the art at the time of the purported
`
`inventions, invalidity, unenforceability of the asserted video coding patents, including with
`
`respect to technical proposals made during the standards-setting process, the technical prong of
`
`the domestic industry requirement, and on technical issues, if any, relating to remedy. In
`
`addition, Dr. Fowler may provide rebuttal to opinions offered by Complainant’s experts.
`
`Benjamin F. Goldberg
`
`Dr. Goldberg has a Ph.D. in Computer Science from Yale University. He is an Associate
`
`Professor in the Department of Computer Science at New York University. Dr. Goldberg has
`
`expertise in the areas set forth in his curriculum vitae, including computer science and/or
`
`computer engineering. A copy of Dr. Goldberg’s curriculum vitae is attached hereto as Exhibit
`
`F. Dr. Goldberg may testify, without limitation, on issues including noninfringement, the
`
`technical prong of the domestic industry requirement, and on technical issues, if any, relating to
`4
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`remedy. In addition, Dr. Goldberg may provide rebuttal to opinions offered by Complainant’s
`
`experts.
`
`Christopher J. Hansen
`
`Dr. Hansen has a Ph.D. in Electrical Engineering from the University of California, Los
`
`Angeles. He has more than 20 years of experience in industry as an engineer and is the named
`
`inventor on more than 125 issued patents. Dr. Hansen has expertise in the areas set forth in his
`
`curriculum vitae, including computer science and/or computer engineering. A copy of Dr.
`
`Hansen’s curriculum vitae is attached hereto as Exhibit G. Dr. Hansen may testify, without
`
`limitation, on issues including noninfringement, the technical prong of the domestic industry
`
`requirement, and on technical issues, if any, relating to remedy. In addition, Dr. Hansen may
`
`provide rebuttal to opinions offered by Complainant’s experts.
`
`Dr. David Money Harris
`
`Dr. Harris received a Ph.D. from Stanford University in Electrical Engineering and is a
`
`Professor of Engineering Design at Harvey Mudd College. Dr. Harris has expertise in the areas
`
`set forth in his curriculum vitae, including computer science and/or computer engineering. Dr.
`
`Harris has worked in the field of circuit design for many years and has published extensively on
`
`the topic. A copy of Dr. Harris’ curriculum vitae is attached hereto as Exhibit H. Dr. Harris may
`
`testify, without limitation, on issues including noninfringement, the technical prong of the
`
`domestic industry requirement, and on technical issues, if any, relating to remedy. In addition,
`
`Dr. Harris may provide rebuttal to opinions offered by Complainant’s experts.
`
`Joseph P. Havlicek
`
`Dr. Havlicek received a Ph.D. from the University of Texas at Austin in Electrical
`
`Engineering and is a Professor in the School of Electrical & Computer Engineering at the
`5
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`University of Oklahoma. Dr. Havlicek has expertise in the areas set forth in his curriculum vitae,
`
`including signal, image, and video processing, video coding and computer science and/or
`
`computer engineering. Dr. Havlicek has worked in the fields of signal, image, and video
`
`processing for more than twenty years and has published extensively on these topics. He has
`
`also received awards related to Image Processing from the IEEE and is a senior member of the
`
`IEEE. A copy of Dr. Havlicek’s curriculum vitae is attached hereto as Exhibit I. Dr. Havlicek
`
`may testify, without limitation, on issues including level of one of ordinary skill in the art, claim
`
`construction, noninfringement, prior art, the state of the art at the time of the purported
`
`inventions, invalidity, unenforceability of the asserted video coding patents, including with
`
`respect to technical proposals made during the standards-setting process, the technical prong of
`
`the domestic industry requirement, and on technical issues, if any, relating to remedy. In
`
`addition, Dr. Havlicek may provide rebuttal to opinions offered by Complainant’s experts.
`
`David Levin
`
`Dr. Levin has a Ph.D. from the University of Maryland and is an Assistant Professor of
`
`Computer Science at the University of Maryland. Dr. Levin has expertise in the areas set forth in
`
`his curriculum vitae, including computer science and/or computer engineering. Dr. Levin has
`
`published extensively on these topics. A copy of Dr. Levin’s curriculum vitae is attached hereto
`
`as Exhibit J. Dr. Levin may testify, without limitation, on issues including noninfringement, the
`
`technical prong of the domestic industry requirement, and on technical issues, if any, relating to
`
`remedy. In addition, Dr. Levin may provide rebuttal to opinions offered by Complainant’s
`
`experts.
`
`6
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`Paul K. Meyer
`
`Mr. Meyer has a B.S. degree in Commerce from the University of Virginia. He has held
`
`positions with Stanford University’s School of Civil and Environmental Engineering since 1994
`
`and is President of TM Financial Forensics, LLC. He has over 30 years of experience consulting
`
`on financial, accounting, economic and damages-related issues, including patent infringement
`
`cases. He has conducted analyses and valuations of intellectual property in many industries. A
`
`copy of Mr. Meyer’s curriculum vitae is attached hereto as Exhibit K. Mr. Meyers may testify,
`
`without limitation, on issues including the unenforceability of the asserted video coding patents,
`
`the public interest, economic prong of the domestic industry requirement, remedy, and bonding.
`
`In addition, Mr. Meyer may provide rebuttal to opinions offered by Complainant’s experts.
`
`Friedhelm Rodermund
`
`Mr. Rodermund has an Electrical Engineering degree from the University of Technology
`
`Aachen, as well as a graduate degree during which he completed a thesis focusing on design of a
`
`dual processor computer for digital signal processing in power electronics. Mr. Rodermund has
`
`expertise in the areas set forth in his curriculum vitae, including in technology innovation and
`
`evolution, standards development and policy, technology strategy, and patent development. He
`
`has had key roles in developing standards across many standard-setting organizations such as
`
`ETSI, IETF and more. A copy of Mr. Rodermund’s curriculum vitae is attached hereto as
`
`Exhibit L. Mr. Rodermund may testify, without limitation, on issues including standards
`
`development and policy and unenforceability of the asserted video coding patents. In addition,
`
`Mr. Rodermund may provide rebuttal to opinions offered by Complainant’s experts.
`
`7
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`James A. Storer
`
`Dr. Storer has a Ph.D. in Computer Science from Princeton University and is a Professor
`
`in the Computer Science Department at Brandeis University. Dr. Storer has expertise in the
`
`areas set forth in his curriculum vitae, including data compression and archiving (including text,
`
`images, video, and multi-media), storage and processing of large data sets, image retrieval,
`
`object recognition, text, image, video processing, video coding, computer science and/or
`
`computer engineering. Dr. Storer has published extensively on these topics, including on
`
`encoding of H.263+ video, and has edited publications on image processing for the IEEE. He
`
`also is the named inventor on multiple patents, including patents related to including encoding
`
`and decoding of digital data. A copy of Dr. Storer’s curriculum vitae is attached hereto as
`
`Exhibit M. Dr. Storer may testify, without limitation, on issues including level of one of
`
`ordinary skill in the art, claim construction, noninfringement, prior art, the state of the art at the
`
`time of the purported inventions, invalidity, unenforceability of the asserted video coding
`
`patents, including with respect to technical proposals made during the standards-setting process,
`
`the technical prong of the domestic industry requirement, and on technical issues, if any, relating
`
`to remedy. In addition, Dr. Storer may provide rebuttal to opinions offered by Complainant’s
`
`experts.
`
`Robert S. Tidwell
`
`Mr. Tidwell has a Master of Science in Computer Engineering from the University of
`
`North Texas and is continuing work in a Ph.D. program focusing on wireless communications.
`
`Mr. Tidwell has expertise in the areas set forth in his curriculum vitae, including computer
`
`science and/or computer engineering. A copy of Mr. Tidwell’s curriculum vitae is attached
`
`hereto as Exhibit N. Mr. Tidwell may testify, without limitation, on issues including
`8
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`noninfringement, the technical prong of the domestic industry requirement, and on technical
`
`issues, if any, relating to remedy. In addition, Mr. Tidwell may provide rebuttal to opinions
`
`offered by Complainant’s experts.
`
`Stephan Wenger
`
`Dr. Wenger has an Ph.D. in Computer Science from Technische Universität Berlin. Dr.
`
`Wenger has expertise in the areas set forth in his curriculum vitae, including on standards
`
`development and policy, technology strategy, and patent development. He had a key role in
`
`developing the H.264 standard, including consideration of intellectual property issues
`
`surrounding the H.264 standard. A copy of Dr. Wenger’s curriculum vitae is attached hereto as
`
`Exhibit O. Dr. Wenger may testify, without limitation, on issues including standards
`
`development and policy, prior art and unenforceability of the asserted video coding patents. In
`
`addition, Dr. Wenger may provide rebuttal to opinions offered by Complainant’s experts.
`
`Joseph A. Konstan
`
`Dr. Joseph A. Konstan is the distinguished McKnight University Professor, and the
`
`College of Science and Engineering’s Associate Dean for Research, at the University of
`
`Minnesota. He has a Ph.D. and M.S. in Computer Science from the University of California,
`
`Berkeley, and an A.B. in Computer Science from Harvard University. Dr. Konstan has expertise
`
`in the areas set forth in his curriculum vitae, including, but not limited to, human-computer
`
`interaction, social computing, collaborative information filtering, multimedia systems, scientific
`
`visualization, interface toolkits and frameworks. A copy of Dr. Konstan’s curriculum vitae is
`
`attached hereto as Exhibit P. Dr. Konstan may testify, without limitation, on issues including
`
`technical matters related to U.S. Patent No. 8,854,706 (the “’706 patent”), the subject matter of
`
`the ’706 patent, the state of the art at the time of the alleged invention of the ’706 patent,
`9
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`qualifications of a person of ordinary skill in the art, the invalidity and/or unenforceability of the
`
`’706 patent, the construction of claims and claim terms of the ’706 patent, the structure, design,
`
`functionality, and operation of the products at issue in this Investigation, non-infringement of the
`
`’706 patent, the lack of the required domestic industry technical prong relating to the ’706 patent,
`
`other defenses, and/or any other technical issue that may arise relating to the ’706 patent. In
`
`addition, Dr. Konstan may provide rebuttal to opinions offered by Complainant’s experts, and
`
`other issues Complainant may assert.
`
`W. Todd Schoettelkotte
`
`Mr. W. Todd Schoettelkotte has a Master of Accounting from Rice University, and a B.S.
`
`in Management from Rice University. Mr. Schoettelkotte has more than 20 years of experience
`
`in the evaluation and quantification of economic damages arising from patent, copyright and
`
`trademark infringement, and trade secret misappropriation disputes. A copy of Mr.
`
`Schoettelkotte’s curriculum vitae is attached hereto as Exhibit Q. Mr. Schoettelkotte may testify,
`
`without limitation, on issues including the public interest and the economic prong of the
`
`domestic industry requirement. In addition, Mr. Schoettelkotte may provide rebuttal to opinions
`
`offered by Complainant’s experts, and other issues Complainant may assert.
`
`Simon Holzer
`
`Mr. Simon Holzer has a law degree from the University of Berne and serves as an adjunct
`
`judge of the Swiss Federal Patent Court. Mr. Holzer has expertise in the areas set forth in his
`
`curriculum vitae, including the field of unfair competition law, intellectual property law, and
`
`Swiss law. A copy of Mr. Holzer’s curriculum vitae is attached hereto as Exhibit R. Mr. Holzer
`
`may testify, without limitation, on issues including remedy, public interest, the unenforceability
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`10
`
`

`

`of the asserted video coding patents, and Swiss law. In addition, Mr. Holzer may provide
`
`rebuttal to opinions offered by Complainant’s experts, and other issues Complainant may assert.
`
`
`
`
`
`
`
`
`
`
`
`11
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`

`

`Dated: January 19, 2021
`
`Respectfully submitted,
`
`/s/ Kate Saxton
`William F. Lee
`Joseph J. Mueller
`Richard W. O’Neill
`Sarah R. Frazier
`Kate Saxton
`WILMER CUTLER PICKERING HALE AND
`DORR LLP
`60 State Street
`Boston, MA 02109
`Telephone: (617) 526-6000
`WHLenovo-Nokia1208servicelist@WilmerHale.com
`
`Michael D. Esch
`WILMER CUTLER PICKERING HALE AND
`DORR LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Telephone: (202) 663-6000
`WHLenovo-Nokia1208servicelist@WilmerHale.com
`
`Counsel for Respondents
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`12
`
`

`

`WHITE & CASE LLP
`
`/s/ Shamita D. Etienne-Cummings
`
`Shamita D. Etienne-Cummings
`David Markoff
`701 13th Street NW
`Washington, DC 20005-3807
`Telephone: 202.626.3600
`Facsimile: 202.639.9355
`
`Eric Lancaster
`Don Zhe Nan Wang
`Emily Yang
`3000 El Camino Real
`2 Palo Alto Square, Suite 900
`Palo Alto, CA 94306
`Telephone: 650.213.0300
`Facsimile: 650.213.8158
`
`Counsel for Intervenor Google LLC
`
`337-TA-1208 - Respondents’ and Intervenor’s Amended Joint Identification of Expert Witnesses
`
`13
`
`

`

`EXHIBIT A
`
`EXHIBIT A
`
`

`

`Curriculum Vitae
`Bobby Bhattacharjee
`
`Department of Computer Science
`The University of Maryland
`College Park
`
`1 Personal Information
`
`Professor,
`Computer Science Department and
`the Institute for Advanced Computer Studies,
`University of Maryland
`Appointed Fall, 1999.
`
`Affiliate Professor,
`Department of Electrial and Computer Engineering,
`University of Maryland.
`
`Alfred P. Sloan Research Fellow (2004–2006).
`
`1.1 Education
`• Ph.D. in Computer Science
`Georgia Institute of Technology, Atlanta, Georgia, Summer 1999
`Dissertation title: Active Networking: Architectures, Composition, and Applications
`Advisors: Kenneth L. Calvert and Ellen W. Zegura
`• Bachelor of Science in Mathematics and Computer Science
`Georgia College and State University, Milledgeville, Georgia, Spring 1994
`Graduated Summa Cum Laude and Outstanding Department Major
`
`1.2 Employment
`
`Summer 2009 to present
`
`Professor
`University of Maryland, College Park, Maryland
`
`Summer 2005 to present
`
`Associate Professor
`University of Maryland, College Park, Maryland
`
`Fall 2006
`
`Visiting Professor
`Max Planck Instit¨ut f¨ur Software Systems, Saarbr¨ucken, Germany
`
`Spring, Summer 2007
`
`Visiting Researcher
`
`1
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`337-TA-1208 - Exhibit A, Respondents' and Intervenor's Joint Amended Identification of Expert Witnesses
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`

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`AT&T Labs, Florham Park, New Jersey
`
`Fall 1999 to Spring 2005
`
`Assistant Professor
`University of Maryland, College Park, Maryland
`
`Fall 1995 to Summer 1999
`
`Research Assistant
`Georgia Institute of Technology, Atlanta, Georgia
`
`Summer 1998
`
`Summer 1997
`
`Summer 1995
`
`Instructor
`Georgia Institute of Technology, Atlanta, Georgia
`
`Member of Technical Staff
`AT&T Labs, Florham Park, New Jersey
`
`Member of Technical Staff
`GTE Labs, Waltham, Massachusetts
`
`Fall 1994 to Spring 1995
`
`Teaching Assistant
`Georgia Institute of Technology, Atlanta, Georgia
`
`2 Research, Scholarly, and Creative Activities
`
`2.1 Chapters in Books
`
`1. Gisli Hj´almt´ysson and Samrat Bhattacharjee. “Control on Demand”, In Proceedings of
`the First International Working Conference on Active Networks volume 1653 of Lecture
`Notes in Computer Science (Stefan Covaci, editor), pages 315-329, Springer-Verlag, June
`1999.
`
`2. Pete Keleher, Samrat Bhattacharjee, and Bujor Silaghi. “Are Virtualized Overlay Net-
`works Too Much of a Good Thing?”, Peer-to-Peer Systems First International Workshop,
`Lecture Notes in Computer Science, Vol. 2429, (Peter Druschel et. al. Editors) pages
`225–231, Springer-Verlag, 2002.
`
`3. Bobby Bhattacharjee, Sudarshan S. Chawathe, Vijay Gopalakrishnan, Peter J. Keleher,
`and Bujor D. Silaghi. “Efficient Peer-To-Peer Searches Using Result-Caching”, Peer-to-
`Peer Systems II, Second International Workshop, IPTPS 2003, Lecture Notes in Com-
`puter Science, Vol. 2735, (M. Frans Kaashoek and Ion Stoica, Editors), pages 225–236,
`Springer-Verlag, 2003.
`
`“Using Trust in Recommender Systems: an
`4. Paolo Massaand Bobby Bhattacharjee.
`Experimental Analysis”, In Second International Conference, iTrust 2004, Lecture Notes
`in Computer Science, Vol. 2995 Jensen, Christian; Poslad, Stefan; Dimitrakos, Theo
`(Eds.), pages 221-235, Springer-Verlag, 2004.
`
`2
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`337-TA-1208 - Exhibit A, Respondents' and Intervenor's Joint Amended Identification of Expert Witnesses
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`

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`5. Cristian Lumezanu, Neil Spring, and Bobby Bhattacharjee. “Decentralized Message Or-
`dering for Publish/Subscribe Systems”, ACM/IFIP/Usenix 7th International Middleware
`Conference, Lecture Notes in Computer Science, Vol. 4290 (Maarten van Steen and Michi
`Henning, Editors), pages 162–179, Springer-Verlag, 2006.
`
`“Overlay Networks and Resiliency”, in
`6. Misha Rabinovich and Bobby Bhattacharjee.
`Guide to Reliable Internet Services and Applications , Charles R Kalmanek, Sudip Misra,
`and Y. Richard Yang (Editors). Springer-Verlag, 2010.
`
`2.2 Articles in Refereed Journals
`
`1. Kenneth L. Calvert, Samrat Bhattacharjee, Ellen W. Zegura, and James Sterbenz. “Di-
`rections in Active Networks”, IEEE Communications Magazine, No. 10, pages 72-78,
`1998.
`
`2. Samrat Bhattacharjee, Ellen W. Zegura, and Kenneth L. Calvert. “Active Networking
`and End-to-End Arguments”, IEEE Network Magazine, No. 3, pages 66-71, 1998.
`
`3. Gisli Hj´almt´ysson and Samrat Bhattacharjee. “Control on Demand - An Efficient Ap-
`proach to Router Programmability”, IEEE Journal on Selected Areas in Communications,
`JSAC, Vol. 17, No. 9, pages 1549-1562, September 1999.
`
`4. S. Bhattacharjee, W. C. Cheng, C.-F. Chou, L. Golubchik, and S. Khuller. “Bistro: a
`Platform for Building Scalable Wide-Area Upload Applications”, ACM SIGMETRICS
`Performance Evaluation Review, Vol. 28, No. 2, pages 29-35, September 2000.
`
`5. Ellen W. Zegura, Mostafa Ammar, Zongming Fei, and Samrat Bhattacharjee. “Application-
`Layer Anycasting: A Server Selection Architecture and Use in Replicated Web Service”,
`Transactions on Networking, Vol. 8, Issue 4, pages 455-466, August 2000.
`
`“Scalable Secure Group Communications
`6. Suman Banerjeeand Samrat Bhattacharjee.
`over IP-multicast”, IEEE Journal of Selected Areas in Communications, JSAC, Vol. 20,
`No. 8, pages 1511 - 1527, October 2002.
`
`7. U. Cetintemel, P. J. Keleher, B. Bhattacharjee, and M. J. Franklin. “Deno: A Decen-
`tralized, Peer-to-Peer Object-Replication System for Weakly-Connected Environments”,
`IEEE Transactions on Computers, Vol. 52, No. 7, pages 943–959, July 2003.
`
`8. Suman Banerjee, Christopher Kommareddy, and Bobby Bhattacharjee. “Efficient Peer
`Location on the Internet”, Computer Networks Journal, Vol. 5:1, pages 5-17, 2004.
`
`“P5: A Protocol for
`9. Rob Sherwood, Bobby Bhattacharjee, and Aravind Srinivasan.
`Scalable Anonymous Communications”, Journal of Computer Security, Vol 13:6, pages
`839-876, 2005.
`
`10. Suman Banerjee, Christopher Kommareddy, Koushik Kar, Bobby Bhattacharjee, and
`Samir Khuller.
`“OMNI: An Efficient Overlay Multicast Infrastructure for Real-time
`Applications”, Special Issue of Computer Networks on Overlay Distribution Structures
`and their Applications, Vol 50:6, pages 826-842, 2005.
`
`3
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`337-TA-1208 - Exhibit A, Respondents' and Intervenor's Joint Amended Identification of Expert Witnesses
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`

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`“Cooperative Peer Groups
`11. Rob Sherwood, Seungjoon Lee, and Bobby Bhattcharjee.
`in NICE”, Computer Networks Journal, Special Issue on Management in P2P systems:
`Trust, Reputation and Security, Vol 50:4, pages 523-544, 2006.
`
`12. Tuna Guven, Chris Kommareddy, Richard J. La, Mark A. Shayman, and Bobby Bhat-
`tacharjee. “Measurement-Based Optimal Routing on Overlay Architectures for Unicast
`Sessions”, Computer Networks J