throbber

`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`Before the Honorable Cameron R. Elliot
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN ELECTRONIC DEVICES,
`SEMICONDUCTOR DEVICES, AND
`COMPONENTS THEREOF
`
`
`
`
`
`Inv. No. 337-TA-1340
`
`
`
`
`
`NXP RESPONDENTS’ CORRECTED IDENTIFICATION OF EXPERT WITNESSES
`
`Pursuant to the Procedural Schedule set forth in Order No. 11, entered by the Court on
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`December 28, 2022, Respondents, NXP Semiconductors, N.V., NXP B.V., and NXP USA, Inc.
`
`(the “NXP Respondents”) hereby submit this Corrected Identification1 of the following expert
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`witnesses, including their expertise and curriculum vitae. To the extent these expert witnesses
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`testify, the NXP Respondents (and/or other Respondents) will present the testimony of these
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`expert witnesses live or by remote means, as well as through depositions. Curriculum vitae for
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`these experts are attached hereto as Exhibits A-I.
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`This identification of experts is preliminary and is based on the NXP Respondents’
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`current understanding of the evidence and the case thus far. Given ongoing discovery, the NXP
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`Respondents reserve the right to supplement this identification as warranted by further
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`developments. Respondents also reserve the right to call any expert witness that a party deposes,
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`any expert identified or called to testify at the hearing by Complainant, and/or any expert for
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`impeachment purposes, even if not identified below.
`
`
`1 This Corrected Identification replaces the NXP Respondents’ Identification of Expert Witness,
`filed on March 14, 2023 (EDIS Doc. ID 792453).
`
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`

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`1.
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`R. Jacob Baker
`
`Dr. Baker has a background in electrical engineering research and development, with
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`over 25 years of experience in the field. Mr. Baker has held various positions throughout his
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`career, including serving as a professor and chair of the Electrical and Computer Engineering
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`Department at the University of Nevada, Las Vegas, where he currently works. He has also
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`worked as a senior engineer for Texas Instruments. At Texas Instruments he conducted research
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`on compound semiconductors, high-frequency circuits, and mixed-signal integrated circuits
`
`(ICs). He also led several projects on device modeling, process integration, and reliability
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`testing, which resulted in several patents and publications.
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`In addition to his professional experience, Mr. Baker is also the author of several books
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`on electronic circuit design, which have been widely used in college courses and industry
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`training programs. Dr. Baker is also a named inventor on over 150 patents for his innovative
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`work in areas such as low-power circuits, high-speed circuits, and mixed signal design. Given
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`his breadth of work and experience in IC design, Dr. Baker has been called to testify as an expert
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`witness in a dozen proceedings, including seven ITC investigations. Dr. Baker’s CV is attached
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`hereto as Exhibit A.
`
`Dr. Baker may provide expert testimony regarding the technical background of one or
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`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
`
`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
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`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
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`

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`
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`Asserted Patents; and any other technical issues that may arise. Dr. Baker may also be called to
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`rebut the testimony of Complainant’s experts or fact witnesses, should any be presented,
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`regarding any of the areas described above.
`
`2.
`
`Soheil Ghiasi
`
`Soheil Ghiasi is a computer and electrical engineer, an inventor, an author, and an
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`academic, and has been involved in computer engineering for over 25 years. Dr. Ghiasi has been
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`involved in numerous professional roles, including as a regular Technical Program Committee
`
`member at the IEEE. He is widely published in more than 100 professional publications,
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`including over 35 journal publications, over 60 conference papers, and 2 book contributions, and
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`is a named inventor on 5 patents (including pending applications). Dr. Ghiasi currently a
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`Professor at the University of California, Davis, where he has worked for 19 years.
`
`Dr. Ghiasi received Bachelor’s degrees in Computer Engineering from the Sharif
`
`University of Technology in Tehran, Iran. He received his Master’s degree in Computer
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`Science, as well as his Doctorate degree, from the University of California, Los Angeles. His
`
`field of study and research focuses principally on design methodologies for digital circuits and
`
`computing systems. Dr. Ghiasi’s CV is attached hereto as Exhibit B.
`
`Dr. Ghiasi may provide expert testimony regarding the technical background of one or
`
`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
`
`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
`
`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
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`

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`
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`Asserted Patents; and any other technical issues that may arise. Dr. Ghiasi may also be called to
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`rebut the testimony of Complainant’s experts or fact witnesses regarding any of the areas
`
`described above.
`
`3.
`
`Puneet Gupta
`
`Puneet Gupta is a computer and electrical engineer, an inventor, an author, and an
`
`academic, and has been involved in computer engineering for nearly 25 years. Dr. Gupta has
`
`been involved in numerous leadership roles within his field of interest and study, including as the
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`inaugural Vice-Chair of the Computer Engineering Program at the University of California, Los
`
`Angeles. He is widely published in more than 200 professional publications, including over 70
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`journal publications, nearly 120 conference papers, and 3 book contributions, and is a named
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`inventor on 18 patents. Dr. Gupta currently a Professor at the University of California, Los
`
`Angeles, where he has worked for 16 years.
`
`Dr. Gupta received a Bachelor’s degree in Electrical Engineering from the Indian
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`Institute of Technology in New Delhi, India. He then received his Doctorate degree from the
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`University of California, San Diego, where his thesis focused on compensation of systematic
`
`manufacturing variations in physical design. Dr. Gupta’s CV is attached hereto as Exhibit C.
`
`Dr. Gupta may provide expert testimony regarding the technical background of one or
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`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
`
`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
`
`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
`
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`

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`
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`Asserted Patents; and any other technical issues that may arise. Dr. Gupta may also be called to
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`rebut the testimony of Complainant’s experts or fact witnesses regarding any of the areas
`
`described above.
`
`4.
`
`Matthew Guthaus
`
`Dr. Guthaus is an accomplished academician and researcher in the field of computer
`
`engineering. He is a faculty member of the Baskin School of Engineering at the University of
`
`California, Santa Cruz, where he has served since 2006. His research interests focus on
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`Integrated Circuits (ICs), low-power design, computer-aided design (CAD), and design
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`automation. He teaches courses ranging from early undergraduate to advanced graduate,
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`including introductory logic design, CAD of electronic systems, very large scale integration
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`(VLSI) digital system design, advanced logic design using the Verilog hardware description
`
`language (VHDL), custom integrated circuit design, emerging technologies and computer
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`security. Before joining UC Santa Cruz, Professor Guthaus was a researcher at IBM’s T.J.
`
`Watson Research Center, where he researched various aspects of physical design including
`
`physical synthesis using statistical timing.
`
`In addition to his academic achievements, Dr. Guthaus has published more than 50
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`papers in top-tier conferences, workshops and symposia, including the International Symposium
`
`on Circuits and Systems (ISCAS). He is also a co-author on several books on IC design and co-
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`inventor on numerous patents. Dr. Guthaus obtained a Bachelor’s degree in Computer
`
`Engineering, a Master’s degree in Electrical Engineering, and a Doctorate degree in Electrical
`
`Engineering from the University of Michigan, Ann Arbor. Dr. Guthaus’s CV is attached hereto
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`as Exhibit D.
`
`Dr. Guthaus may provide expert testimony regarding the technical background of one or
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`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
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`
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`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
`
`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
`
`Asserted Patents; and any other technical issues that may arise. Dr. Guthaus may also be called
`
`to rebut the testimony of Complainant’s experts or fact witnesses, should any be presented,
`
`regarding any of the areas described above.
`
`5.
`
`Andrew B. Kahng
`
`Dr. Kahng is a true pioneering researcher in the field of electronic design automation
`
`(“EDA”). His seminal papers on dummy metal fill are frequently cited, including “Area Fill
`
`Synthesis for Uniform Layout Density,” “Manufacturing-Aware Physical Design,” and “Filling
`
`and Slotting : Analysis and Algorithms.” Dr. Kahng has an impressive work history that spans
`
`several decades and includes numerous achievements that have earned him international
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`recognition.
`
`Dr. Kahng began his career in academia, where he conducted research in computer
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`science and electrical engineering at the University of California, Los Angeles. He joined the
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`University of California, San Diego in 2001 where he continues his research today as U.C. San
`
`Diego’s Jacobs School of Engineering's Computer Science & Engineering Chair of High-
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`Performance Computing. In 2004, Dr. Kahng co-founded Blaze DFM, Inc., an EDA software
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`company that delivered new cost and yield optimizations at the IC design-manufacturing
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`interface.
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`Throughout his career, Dr. Kahng has made pioneering contributions to the field of EDA,
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`which focuses on the development of computer-aided design tools for integrated circuits. His
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`work has helped advance the state-of-the-art in EDA, making it possible to design more complex
`
`and sophisticated integrated circuits with greater efficiency and accuracy. Dr. Kahng’s research
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`has been widely published in top-tier academic journals and presented at leading conferences in
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`the field. He is also the recipient of numerous awards and honors, including seven best paper
`
`awards at distinguished conferences including the ACM/IEEE Design Automation Conference
`
`and International Conference on VLSI Design. Dr. Kahnh is also an IEEE and ACM fellow
`
`As an expert in EDA, Dr. Kahng has also served as a consultant to various companies and
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`government agencies, providing valuable insight and guidance on the development of new
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`technologies and products. He has also played an active role within the EDA community, serving
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`as a member of various technical committees and editorial boards. Dr. Kahng is also a co-author
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`of numerous books on VLSI design and a co-inventor on over 30 patents relating to integrated
`
`circuits. Dr. Kahng obtained his Bachelor’s degree in Applied Mathematics (Physics) from
`
`Harvard College, and his Master’s degree and Doctorate degree in Computer Science from the
`
`University of California, San Diego. Dr. Kahng’s CV is attached hereto as Exhibit E.
`
`Dr. Kahng may provide expert testimony regarding the technical background of one or
`
`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
`
`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
`
`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
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`

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`
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`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
`
`Asserted Patents; and any other technical issues that may arise. Dr. Kahng may also be called to
`
`rebut the testimony of Complainant’s experts or fact witnesses, should any be presented,
`
`regarding any of the areas described above.
`
`6.
`
`Bill Lin
`
`Dr. Lin is an accomplished Professor in the Department of Electrical and Computer
`
`Engineering, and an Adjunct Professor in the Department of Computer Science and Engineering,
`
`at the University of California, San Diego. He works on all aspects of network and VLSI
`
`architecture problems, including the design of data networks, high-performance switches and
`
`routers, high-speed network measurement mechanisms, and on-chip interconnection networks.
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`He is also interested in the design of multiprocessor Systems-on-Chips and 3D chip
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`architectures. He holds a Bachelor’s degree, a Master’s degree, and a Doctorate degree in
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`Electrical Engineering and Computer Science from the University of California, Berkeley.
`
`Prior to joining the U.C. San Diego, he headed the System Control and Communications
`
`Group at IMEC where he led a research team that worked on various aspects of VLSI
`
`architectures, system design methodologies, and systems-on-chip applications. Dr. Lin has co-
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`authored over 160 journal and conference publications, including two Best Paper awards, three
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`Best Paper nominations, and two Distinguished Paper citations. In addition, he has served as a
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`panelist and presenter at several major conferences, and he has served on over 50 program
`
`committees. Dr. Lin’s CV is attached hereto as Exhibit F.
`
`Dr. Lin may provide expert testimony regarding the technical background of one or more
`
`of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a person of
`
`ordinary skill in the art of one or more of the Asserted Patents; issues relating to whether the
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`
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`claimed domestic industry products practice the Asserted Patents; the design, structure, function
`
`and operation of the Accused Products; the non-infringement and non-practice of the Asserted
`
`Patents by the Accused Products; issues relating to the validity of one or more of the Asserted
`
`Patents; and/or other issues in connection with Complainant’s claims and Respondents’ defenses,
`
`including the scope of the alleged prior art and unenforceability of the Asserted Patents; and any
`
`other technical issues that may arise. Dr. Lin may also be called to rebut the testimony of
`
`Complainant’s experts or fact witnesses, should any be presented, regarding any of the areas
`
`described above.
`
`7.
`
`Patrick H. Madden
`
`Patrick H. Madden is a computer scientist, an inventor, an author, and an academic. Dr.
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`Madden has been involved in the computer science field for more than 35 years. Within his
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`fields of interest and study, he has been involved in the leadership of multiple industry
`
`conferences, is widely published in more than 55 professional publications, and is a named
`
`inventor on four patents. Dr. Madden is currently an Associate Professor at the State University
`
`of New York at Binghamton, where he has worked for 19 years.
`
`Dr. Madden received Bachelor’s degrees in Computer Science and Mathematics, as well
`
`as a Master’s degree in Computer Science, from the New Mexico Institute of Mining and
`
`Technology. Dr. Madden received his Doctorate degree from the University of California, Los
`
`Angeles, where he focused his study and research principally on VLSI CAD systems, while also
`
`studying Computer Architecture and Programming Languages and Systems. Dr. Madden’s CV
`
`is attached hereto as Exhibit G.
`
`Dr. Madden may provide expert testimony regarding the technical background of one or
`
`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
`
`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`
`
`

`

`
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`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
`
`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
`
`Asserted Patents; and any other technical issues that may arise. Dr. Madden may also be called
`
`to rebut the testimony of Complainant’s experts or fact witnesses, should any be presented,
`
`regarding any of the areas described above.
`
`8.
`
`Massoud Pedram
`
`Dr. Pedram is the Charles Lee Powell Chair in Electrical Engineering and Computer
`
`Science at the Viterbi School of Engineering at the University of Southern California. Dr.
`
`Pedram has an impressive track record in the field of computer engineering, having made
`
`significant contributions to numerous areas, including low-power and high-performance
`
`computing, mobile computing, and microarchitecture design. His research work spans over 20
`
`years, and he has authored more than 200 papers published in prestigious journals and
`
`conferences across the world. Dr. Pedram has also served as a keynote speaker in several
`
`international conferences and workshops.
`
`Apart from his academic accomplishments, Dr. Pedram has also contributed significantly
`
`to the industry. His work on low-power design techniques for mobile computing devices has
`
`found practical applications in several products. He has received multiple awards and honors,
`
`including the IEEE Circuits and Systems Society's Technical Achievement Award, which
`
`recognizes his significant contributions to low-power design. Dr. Pedram’s research has been
`
`recognized for two Design Automation Conference Best Paper Awards, a Distinguished Paper
`
`Citation from the International Conference on Computer Aided Design, one Best Paper Award of
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`
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`

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`
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`the ACM/IEEE International Symposium on Low Power Design and Electronics, three Best
`
`Paper Awards from the International Conference on Computer Design, one Best Paper Award of
`
`the IEEE Computer Society Annual Symposium on VLSI, an IEEE Transactions on VLSI
`
`Systems Best Paper Award, and an IEEE Circuits and Systems Society Guillemin-Cauer Award.
`
`Dr. Pedram obtained his Bachelor’s degree in Electrical Engineering from the California
`
`Institute of Technology, and his Master’s degree and Doctorate degree in Electrical Engineering
`
`and Computer Sciences from the University of California, Berkeley. He has taught at the
`
`University of Southern California since 2017. Dr. Pedram’s CV is attached hereto as Exhibit H.
`
`Dr. Pedram may provide expert testimony regarding the technical background of one or
`
`more of the Asserted Patents; claim construction of the Asserted Patents; the knowledge of a
`
`person of ordinary skill in the art of one or more of the Asserted Patents; issues relating to
`
`whether the claimed domestic industry products practice the Asserted Patents; the design,
`
`structure, function and operation of the Accused Products; the non-infringement and non-practice
`
`of the Asserted Patents by the Accused Products; issues relating to the validity of one or more of
`
`the Asserted Patents; and/or other issues in connection with Complainant’s claims and
`
`Respondents’ defenses, including the scope of the alleged prior art and unenforceability of the
`
`Asserted Patents; and any other technical issues that may arise. Dr. Pedram may also be called
`
`to rebut the testimony of Complainant’s experts or fact witnesses, should any be presented,
`
`regarding any of the areas described above.
`
`9.
`
`Julia Rowe
`
`Julia Rowe is recognized as a top economic expert witness in the IAM Patent 1000. Ms.
`
`Rowe has also conducted economic analyses and provided opinions on appropriate remedies in
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`patent infringement matters and investigations under 19 U.S.C. § 1337 for disputes across
`
`numerous industries. Ms. Rowe has extensive experience analyzing international trade issues,
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`

`

`
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`including evaluating economic and market factors relevant to the existence of a domestic
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`industry, the appropriate bond rate, the existence of commercially significant inventories, the
`
`appropriateness of Limited and General Exclusion Orders (including on downstream products),
`
`and the commercial success of certain products due to certain features covered by asserted
`
`patents. Ms. Rowe has also performed economic and financial analysis relevant to assessing
`
`civil penalties in ITC enforcement actions. Ms. Rowe is a certified public accountant and holds a
`
`Bachelor’s degree in business administration from the University of Michigan, as well as a
`
`Master’s degree in accountancy from DePaul University. Ms. Rowe’s CV is attached hereto as
`
`Exhibit I.
`
`Ms. Rowe may provide testimony regarding issues related to the economic prong of the
`
`domestic industry, remedy, bond, and on the issues of secondary considerations of
`
`nonobviousness, and any related issues or economic-related issues. Ms. Rowe may also be
`
`called to rebut the testimony of Complainant’s experts or fact witnesses regarding any of the
`
`areas described above.
`
`
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`

`

`
`
`Dated: March 15, 2023
`
`Respectfully submitted,
`
`
`
`
`
`
`
` /s/ Jeffrey A. Miller
`Jeffrey A. Miller
`Philip W. Marsh
`David A. Caine
`Joseph B. Palmieri
`ARNOLD & PORTER KAYE SCHOLER LLP
`3000 El Camino Real
`Five Palo Alto Square, Suite 500
`Palo Alto, CA 94306-3807
`Telephone: (650) 319-4500
`Facsimile: (650) 319-4700
`
`Matthew M. Wolf
`Jennifer Sklenar
`Mark A. Patrick
`ARNOLD & PORTER KAYE SCHOLER LLP
`601 Massachusetts Ave. NW
`Washington, DC 20001
`Telephone: (202) 942-5000
`Facsimile: (202) 942-5999
`
`Dina M. Hayes
`Kurt Riester
`Lindsay Strong
`ARNOLD & PORTER KAYE SCHOLER LLP
`70 W Madison Street, #4200
`Chicago, IL 60602
`Telephone: (312) 583-2300
`Facsimile: (312) 583-2360
`
`Joseph Farris
`Francesco Mangini
`ARNOLD & PORTER KAYE SCHOLER LLP
`Three Embarcadero Center, 10th Floor
`San Francisco, CA 94111-4024
`Telephone: (415) 471-3100
`Facsimile: (415) 471-3700
`
`Wallace Wu
`Krysti Papadopoulos
`ARNOLD & PORTER KAYE SCHOLER LLP
`777 S. Figueroa St., 44th Floor
`Los Angeles, CA 90017-5844
`Telephone: (213) 243-4000
`
`
`
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`

`

`
`Krista S. Schwartz
`Barrington Dyer
`WILLKIE FARR & GALLAGHER LLP
`One Front Street
`San Francisco, CA 9411
`
`Aliza George Carrano
`WILLKIE FARR & GALLAGHER, LLP
`1875 K Street, N.W.
`Washington, DC 20006
`
`Counsel for Respondents
`NXP Semiconductors NV, NXP BV, and
`NXP USA, Inc.
`
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`

`

`
`
`CERTAIN ELECTRONIC DEVICES, SEMICONDUCTOR DEVICES,
`AND COMPONENTS THEREOF
`Inv. No. 337-TA-1340
`
`CERTIFICATE OF SERVICE
`
`I, Sherri Mills, hereby certify that on March 15, 2023 a copy of NXP RESPONDENTS’
`
`CORRECTED IDENTIFICATION OF EXPERT WITNESSES was served upon the
`following parties as indicated:
`
`The Honorable Katherine Hiner
`Acting Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`☐ Via U.S. Mail
`☐ Via Overnight Courier
`☐ Via Electronic Mail
`☒ Via Electronic Filing
`Administrative Law Judge
`☐ Via U.S. Mail
`☐ Via Overnight Courier
`☐ Via Electronic Mail
`☒ Via Electronic Filing
`
`Honorable Cameron R. Elliot
`Administrative Law Judge
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street S.W., Room 317
`Washington, DC 20436
`Email: michael.turner@usitc.gov
`
`
`Cortney Hoecherl, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`Cortney.Hoecherl@usitc.gov
`
`Office of Unfair Import Investigations
`☐ Via U.S. Mail
`☐ Via Overnight Courier
`☐ Via Electronic Mail
`☒ Via Electronic Filing
`
`Complainant Bell Semiconductor, LLC
`
` ☐
`
` Via U.S. Mail
`☐ Via Overnight Courier
`☐ Via Electronic Mail
`☒ Via Electronic Filing
`
`David Sochia
`Richard Kamprath
`Alexandra Easley
`MCKOOL SMITH, P.C.
`300 Crescent Court Suite 1500
`Dallas, TX 75201
`Bell_Semiconductor-ITC@mckoolsmith.com
`
`Andrew F. Pratt
`Devlin Law Firm LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`Bell-337-1340@devlinlawfirm.com
`
`
`
`
`
`

`

`
`
`Respondents Acer America Corporation, & Acer, Inc.
`
` ☐
`
` Via U.S. Mail
`☐ Via Hand Delivery
`☐ Via Overnight Courier
`☒ Via Electronic Mail
`
`David F. Nickel
`Matthew N. Duescher
`John F. Presper
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1150 18th Street NW, Suite 775
`Washington, D.C. 20036
`Telephone: (202) 822-4100
`FM-AMD-1340@fostermurphy.com
`
`Kai Tseng
`Craig Kaufman
`Jeffy Chen
`TECHKNOWLEDGE LAW GROUP LLP
`20660 Stevens Creek Blvd., Suite 381
`Cupertino, CA 95014
`Telephone: (650) 517-5268
`Facsimile: (650) 562-8054
`Acer.SErviceBellITC@tklg-llp.com
`
`
`Respondent SMC Networks, Inc. d/b/a IgniteNet
`☐ Via U.S. Mail
`☐ Via Hand Delivery
`☒ Via Overnight Courier
`☒ Via Electronic Mail
`
`Richard C. Vasquez
`Jeffrey T. Lindgren
`Eric W. Benisek
`Robert S. McArthur
`VASQUEZ BENISEK & LINDGREN, LLP
`1550 Parkside Drive, Suite 130
`Walnut Creek, CA 94596
`Telephone: (925)627-4250
`rvasquez@vbllaw.com
`jlindgren@vbllaw.com
`ebenisek@vbllaw.com
`mcarthur@vbllaw.com
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`/s/ Sherri Mills
`Sherri Mills
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`US 173407706
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`EXHIBIT A
`EXHIBIT A
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`R. JACOB (JAKE) BAKER, PH.D., P.E.
`Professor Pristinus of Electrical and Computer Engineering
`Independent Consultant
`
`6775 Agave Azul Court
`Las Vegas, NV 89120
`
`(208) 850-0517 (Cell)
`
`Email: rjacobbaker@gmail.com
`Website: http://CMOSedu.com/jbaker/jbaker.htm
`
`
`PROFESSIONAL SUMMARY
`Russel Jacob (Jake) Baker, Ph.D., P.E. (IEEE Student Member 1983, Member 1988, Senior Member 1997, and Fellow
`2013) was born in Ogden, Utah, on October 5, 1964. He received the B.S. and M.S. degrees in electrical engineering
`from the University of Nevada, Las Vegas, in 1986 and 1988. He received the Ph.D. degree in electrical engineering
`from the University of Nevada, Reno in 1993. His Google Scholar profile is here and his ResearchGate profile is
`here.
`From 1981 to 1987 he served in the United States Marine Corps (from September of 1982 in the Reserves, Fox
`Company, 2nd Battalion, 23rd Marines, 4th Marine Division). From 1985 to 1993 he worked for E. G. & G. Energy
`Measurements and the Lawrence Livermore National Laboratory designing nuclear diagnostic instrumentation for
`underground nuclear weapons tests at the Nevada Test Site. During this time, he designed, and oversaw the
`fabrication and manufacture of, over 30 electronic and electro-optic instruments including high-speed cable and
`fiber-optic receiver/transmitters, PLLs, frame- and bit-syncs, data converters, streak-camera sweep circuits,
`Pockels cell drivers, micro-channel plate gating circuits, and analog oscilloscope electronics. From 1991-1992 he
`was an adjunct faculty member in the department of electrical engineering at the University of Nevada, Las Vegas
`(UNLV). From 1993 to 2000 he served on the faculty in the department of electrical engineering at the University
`of Idaho (UI), first as an untenured Assistant Professor and then from 1998 as a tenured Associate Professor. In
`2000 he joined a new electrical and computer engineering (ECE) program at Boise State University (BSU) where
`he was promoted to Full Professor in 2002. He then served as the ECE department chair at BSU from 2004 to 2007.
`At BSU he helped establish graduate programs in ECE including, in 2006, the university’s second PhD degree. In
`2012 he re-joined the faculty at UNLV as a tenured Full Professor of ECE. During his service at the UI, BSU, and
`UNLV he has been the major professor to more than 100 graduate students. In addition to this industry and
`academic experience, he has done consulting, both technical and expert witness, for over 200 companies.
`Over the last 35+ years his research/development interests and publications have been, or currently are, focused on:
`analog-to-digital/digital-to-analog data conversion and transmission, optoelectronics (imagers, displays, LIDARs,
`APDs, SiPMs, and associated electronics), analog and digital integrated circuit design and fabrication, design of
`diagnostic electrical and electro-optic instrumentation for scientific research, integrated electrical/biological
`circuits and systems, array (memory, imagers, and displays) fabrication and design, CAD tool development and
`online tutorials,
`low-power
`interconnect and packaging (electrical and optical) techniques, design of
`wired/wireless communication and interface circuits, circuit design for the use and storage of renewable energy,
`power electronics and power supply design, and the delivery of online engineering education.
`Dr. Baker is the named inventor on over 150 US patents. He is a member of the honor societies Eta Kappa Nu and Tau
`Beta Pi, a licensed Professional Engineer, a popular lecturer that has delivered over 50 invited talks around the
`world, an IEEE Fellow, and the author of the books CMOS Circuit Design, Layout, and Simulation, CMOS Mixed-
`Signal Circuit Design, and a coauthor of DRAM Circuit Design: Fundamental and High-Speed Topics. He received
`the 2000 Best Paper Award from the IEEE Power Electronics Society, the 2007 Frederick Emmons Terman Award,
`
`R. JACOB BAKER, PH.D., P.E.
`
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`Page 1
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`the 2011 IEEE Circuits and Systems Education Award and the 2021 Wiley-IEEE Press Textbook Award for the 4th
`Edition of his book CMOS Circuit Design, Layout, and Simulation.
`His service activities include the IEEE Press Editorial Board (1999-2004), editor for the Wiley-IEEE Press Book Series on
`Microelectronic Systems (2010-2018), the Technical Program Chair of the 2015 IEEE 58th International Midwest
`Symposium on Circuits and Systems (MWSCAS 2015), the IEEE Solid-State Circuits Society (SSCS) Administrative
`Committee (2011-2016), Distinguished Lecturer for the SSCS (2012-2015), Technology Editor (2012-2014) and
`Editor-in-Chief (2015-2020) for the IEEE Solid-State Circuits Magazine, IEEE Kirchhoff Award Committee (2020-
`2023), and advisor for the student branch of the IEEE at UNLV (2013-2023).
`INDUSTRY EXPERIENCE
`2008 - present: Expert witness in intellectual property disputes in electrical, electro-optic, and computer engineering
`matters for: 1) district court and ITC patent disputes, 2) inter partes reviews at the PTAB, and 3) arbitrations and
`mediations.
`2013 - 2022: Worked with Freedom Photonics, Santa Barbara, CA, on the integration, fabrication and design, of
`optoelectronics with

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