throbber

`
` UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Monica Bhattacharyya
`Administrative Law Judge
`
`
`
`In the Matter of
`
`CERTAIN PHOTOVOLTAIC
`CONNECTORS AND COMPONENTS
`THEREOF
`
`
`
`
`
`
`Investigation No. 337-TA-1365
`
`
`
`
`RESPONDENTS’ DISCLOSURE OF EXPERT WITNESSES
`
`Pursuant to the Procedural Schedule (Order No. 7), Respondents Hikam America, Inc.,
`
`Hikam Electronica De Mexico, S.A. DE C.V., Hikam Technologia De Sinaloa, Hewtech
`
`Philippines Corp., Hewtech Philippines Electronics Corp., and Hewtech (Shenzhen) Electronics
`
`Co., Ltd., (collectively, “Hikam”) and Voltage, LLC and Ningbo Voltage Smart Production Co.
`
`(collectively “Voltage”) (all collectively, “Respondents”), submit their identification of potential
`
`expert witnesses, including their expertise and curriculum vitae, for the evidentiary hearing: John
`
`C. Jarosz, Andrew T. Clarke, Julia Rowe, Todd Schoettelkotte, Dr. Mark Ehsani, Dr. Seth Miller,
`
`Dr. Hamid A. Toliyat, Dr. Mark Horenstein, Dr. Thomas Kenny, and Dr. Kimberly Cameron.
`
`Some or all of these experts may be called to testify at the hearing for this Investigation,
`
`either live, through witness statements, or by deposition, and may submit Expert Reports and/or
`
`Rebuttal Expert Reports. Curricula vitae of each named person are included as Exhibits A through
`
`J to this document. Respondents reserve the right to supplement and amend this identification of
`
`expert witnesses as appropriate, including the right to identify further rebuttal experts if necessary.
`
`Respondents further reserve the right to call and/or examine any expert witness(es) identified by
`
`Complainant Shoals Technologies Group, LLC (“Complainant” or “Shoals”) or the Office of
`
`Unfair Import Investigations.
`
`
`
`

`

`
`
`A.
`
`JOHN C. JAROSZ
`
`John C. Jarosz has expertise in the areas set forth in his curriculum vitae, including
`
`microeconomics and industrial organization and valuations of intellectual property and other
`
`business assets. Mr. Jarosz may offer expert testimony regarding economics, secondary
`
`considerations of non-obviousness (including without limitation any alleged commercial success
`
`of Shoal’s inventions), and investments by Shoals into Shoals’ asserted domestic industry
`
`products, including how Shoals has failed to satisfy the economic prong of the domestic industry
`
`requirement. Mr. Jarosz may also opine on the propriety and scope of the remedies sought by
`
`Shoals as well as the appropriate amount of bond, if any, to be posted during the presidential review
`
`period. Mr. Jarosz may further offer opinions and/or testimony in rebuttal to Complainant’s expert
`
`testimony and/or other issues asserted by Complainants. A copy of Mr. Jarosz’s curriculum vitae
`
`is attached as Exhibit A.
`
`B.
`
`ANDREW T. CLARKE
`
`Andrew T. Clarke has expertise in the areas set forth in his curriculum vitae, including
`
`economics and finance, applying economic and financial theory to complex business disputes, and
`
`analyzing domestic industry, injury, remedy, bonding, commercial success, and enforcement
`
`issues at the ITC. Mr. Clarke may offer expert testimony regarding economics, secondary
`
`considerations of non-obviousness (including without limitation any alleged commercial success
`
`of Shoal’s inventions), and investments by Shoals into Shoals’ asserted domestic industry
`
`products, including how Shoals has failed to satisfy the economic prong of the domestic industry
`
`requirement. Mr. Clarke may also opine on the propriety and scope of the remedies sought by
`
`Shoals as well as the appropriate amount of bond, if any, to be posted during the presidential review
`
`period. Mr. Clarke may further offer opinions and/or testimony in rebuttal to Complainant’s expert
`
`2
`
`

`

`
`
`testimony and/or other issues asserted by Complainants. A copy of Mr. Clarke’s curriculum vitae
`
`is attached as Exhibit B.
`
`C.
`
`JULIA ROWE
`
`Julia Rowe has expertise in the areas set forth in her curriculum vitae, including accounting,
`
`valuation of intellectual property, and analyzing domestic industry, cease and desist, and bonding
`
`issues at the ITC. Ms. Rowe may offer expert testimony regarding economics, secondary
`
`considerations of non-obviousness (including without limitation any alleged commercial success
`
`of Shoal’s inventions), and investments by Shoals into Shoals’ asserted domestic industry
`
`products, including how Shoals has failed to satisfy the economic prong of the domestic industry
`
`requirement. Ms. Rowe may also opine on the propriety and scope of the remedies sought by
`
`Shoals as well as the appropriate amount of bond, if any, to be posted during the presidential review
`
`period. Ms. Rowe may further offer opinions and/or testimony in rebuttal to Complainant’s expert
`
`testimony and/or other issues asserted by Complainants. A copy of Ms. Rowe’s curriculum vitae
`
`is attached as Exhibit C.
`
`D.
`
`TODD SCHOETTELKOTTE
`
`Todd Schoettelkotte has expertise in the areas set forth in his curriculum vitae, including
`
`accounting, valuation of intellectual property, and analyzing domestic industry, cease and desist,
`
`and bonding issues at the ITC. Mr. Schoettelkotte may offer expert testimony regarding
`
`economics, secondary considerations of non-obviousness (including without limitation any alleged
`
`commercial success of Shoal’s inventions), and investments by Shoals into Shoals’ asserted
`
`domestic industry products, including how Shoals has failed to satisfy the economic prong of the
`
`domestic industry requirement. Mr. Schoettelkotte may also opine on the propriety and scope of
`
`the remedies sought by Shoals as well as the appropriate amount of bond, if any, to be posted
`
`during the presidential review period. Mr. Schoettelkotte may further offer opinions and/or
`
`3
`
`

`

`
`
`testimony in rebuttal to Complainant’s expert testimony and/or other issues asserted by
`
`Complainants. A copy of Mr. Schoettelkotte’s curriculum vitae is attached as Exhibit D.
`
`E.
`
`DR. MARK EHSANI
`
`Dr. Mark Ehsani has expertise in the areas set forth in his curriculum vitae, including
`
`electrical engineering, high voltage direct current power transmission, electrical failures and
`
`hazards, sustainable energy, and specialized power systems. Dr. Ehsani may offer expert testimony
`
`regarding the technical background and state of the art relevant to the asserted claims of Shoals’
`
`Asserted Patents, the qualifications of a person of ordinary skill in the art, the interpretation of the
`
`asserted claims of Shoals’ Asserted Patents, non-infringement and invalidity of the Asserted
`
`Patents, Shoals’ failure to satisfy the technical prong of the domestic industry requirement, and the
`
`technical details regarding the accused products and functionalities as they relate to the Asserted
`
`Patents. Dr. Ehsani may further offer opinions and/or testimony in rebuttal to Complainant’s expert
`
`testimony and/or other issues asserted by Complainant. A copy of Dr. Ehasani’s curriculum vitae
`
`is attached as Exhibit E.
`
`F.
`
`DR. SETH MILLER
`
`Dr. Seth Miller has expertise in the areas set forth in his curriculum vitae, including
`
`materials and device technologies, nanostructured materials, and material science. Dr. Miller may
`
`offer expert testimony regarding the technical background and state of the art relevant to the
`
`asserted claims of Shoals’ Asserted Patents, the qualifications of a person of ordinary skill in the
`
`art, the interpretation of the asserted claims of Shoals’ Asserted Patents, non-infringement and
`
`invalidity of the Asserted Patents, Shoals’ failure to satisfy the technical prong of the domestic
`
`industry requirement, and the technical details regarding the accused products and functionalities
`
`as they relate to the Asserted Patents. Dr. Miller may further offer opinions and/or testimony in
`
`4
`
`

`

`
`
`rebuttal to Complainant’s expert testimony and/or other issues asserted by Complainant. A copy
`
`of Dr. Miller’s curriculum vitae is attached as Exhibit F.
`
`G.
`
`DR. HAMID A. TOLIYAT
`
`Dr. Hamid A. Toliyat has expertise in the areas set forth in his curriculum vitae, including
`
`electrical and computer engineering and power electronics. Dr. Toliyat may offer expert testimony
`
`regarding the technical background and state of the art relevant to the asserted claims of Shoals’
`
`Asserted Patents, the qualifications of a person of ordinary skill in the art, the interpretation of the
`
`asserted claims of Shoals’ Asserted Patents, non-infringement and invalidity of the Asserted
`
`Patents, Shoals’ failure to satisfy the technical prong of the domestic industry requirement, and the
`
`technical details regarding the accused products and functionalities as they relate to the Asserted
`
`Patents. Dr. Toliyat may further offer opinions and/or testimony in rebuttal to Complainant’s
`
`expert testimony and/or other issues asserted by Complainant. A copy of Dr. Toliyat’s curriculum
`
`vitae is attached as Exhibit G.
`
`H.
`
`DR. MARK N. HORENSTEIN
`
`Dr. Mark N. Horenstein has expertise in the areas set forth in his curriculum vitae, including
`
`power electronics, analog and digital circuits, electric power systems, and green energy. Dr.
`
`Horenstein may offer expert testimony regarding the technical background and state of the art
`
`relevant to the asserted claims of Shoals’ Asserted Patents, the qualifications of a person of
`
`ordinary skill in the art, the interpretation of the asserted claims of Shoals’ Asserted Patents, non-
`
`infringement and invalidity of the Asserted Patents, Shoals’ failure to satisfy the technical prong
`
`of the domestic industry requirement, and the technical details regarding the accused products and
`
`functionalities as they relate to the Asserted Patents. Dr. Horenstein may further offer opinions
`
`and/or testimony in rebuttal to Complainant’s expert testimony and/or other issues asserted by
`
`Complainant. A copy of Dr. Horenstein’s curriculum vitae is attached as Exhibit H.
`
`5
`
`

`

`
`
`I.
`
`DR. THOMAS KENNY
`
`Dr. Thomas Kenny has expertise in the areas set forth in his curriculum vitae, including
`
`mechanical engineering and micromechanical structures. Dr. Kenny may offer expert testimony
`
`regarding the technical background and state of the art relevant to the asserted claims of Shoals’
`
`Asserted Patents, the qualifications of a person of ordinary skill in the art, the interpretation of the
`
`asserted claims of Shoals’ Asserted Patents, non-infringement and invalidity of the Asserted
`
`Patents, Shoals’ failure to satisfy the technical prong of the domestic industry requirement, and the
`
`technical details regarding the accused products and functionalities as they relate to the Asserted
`
`Patents. Dr. Kenny may further offer opinions and/or testimony in rebuttal to Complainant’s expert
`
`testimony and/or other issues asserted by Complainant. A copy of Dr. Kenny’s curriculum vitae is
`
`attached as Exhibit I.
`
`J.
`
`DR. KIMBERLY CAMERON
`
`Dr. Kimberly Cameron has expertise in the areas set forth in her curriculum vitae, including
`
`mechanical engineering and materials science engineering. Dr. Cameron may offer expert
`
`testimony regarding the technical background and state of the art relevant to the asserted claims of
`
`Shoals’ Asserted Patents, the qualifications of a person of ordinary skill in the art, the interpretation
`
`of the asserted claims of Shoals’ Asserted Patents, non-infringement and invalidity of the Asserted
`
`Patents, Shoals’ failure to satisfy the technical prong of the domestic industry requirement, and the
`
`technical details regarding the accused products and functionalities as they relate to the Asserted
`
`Patents. Dr. Cameron may further offer opinions and/or testimony in rebuttal to Complainant’s
`
`expert testimony and/or other issues asserted by Complainant. A copy of Dr. Cameron’s
`
`curriculum vitae is attached as Exhibit J.
`
`
`
`
`
`6
`
`

`

`
`
`
`
`Dated: September 5, 2023
`
`By: /s/ Sid V. Pandit
`Timothy J. Maier
`Michael R. Casey
`Daniel J. Ehrlich
`Siddhesh V. Pandit
`Maier & Maier PLLC
`345 S. Patrick Street
`Alexandria, VA 22314
`HikamITC1365@maierandmaier.com
`
`
`Counsel for Hikam Respondents
`
`
`
`
`By: /s/ Philip Ou
`Yar R. Chaikovsky
`Philip Ou
`Jonathan Lamberson
`Bruce Yen
`Michael Costello-Caulkins
`Yolanda Xu
`WHITE & CASE LLP
`3000 El Camino Real
`2 Palo Alto Square, Suite 900
`Palo Alto, CA 94306-2109
`
`Colleen Tracy James
`WHITE & CASE LLP
`1221 Avenue of the Americas
`New York, New York 10020-1095
`
`Counsel for Voltage Respondents
`
`7
`
`

`

`EXHIBIT A
`EXHIBIT A
`
`

`

`JOHN C. JAROSZ
`Managing Principal
`
`
`Phone: 202 530 3980
`Mobile: 202 251 1992
`Fax: 202 530 0436
`john.jarosz@analysisgroup.com
`
`
`
`John Jarosz, a Managing Principal of Analysis Group, Inc., specializes in applied microeconomics and
`industrial organization. He has performed research, given economic testimony, and provided strategy
`consultation in intellectual property, licensing, and commercial damages matters, including:
`
`Analysis Group, Inc.
`800 17th Street, NW
`Suite 400
`Washington, DC 20006
`
` 
`
`
`
`
`
`
`evaluation of damages in patent, copyright, trade secret, trademark, and unfair competition cases
`(including lost profits, reasonable royalties, price erosion, unjust enrichment, accelerated market
`entry, and prejudgment interest);
`evaluation of injunctive relief and commercial success in a variety of intellectual property cases;
`strategy consultation regarding the nature and value of technology, methods to share technology, and
`reasonable compensation terms;
`analysis of compliance with FRAND/RAND commitments; and
`
` general commercial damages testimony in a variety of cases and across numerous industries.
`
`Mr. Jarosz has been recognized for many years as among the top economic experts for IP matters by
`Intellectual Asset Management (IAM) in the IAM Patent 1000, which identifies leading patent
`professionals around the globe.
`
`Prior to joining Analysis Group, Mr. Jarosz was a Director with Putnam, Hayes & Bartlett, Inc. Before
`that, he was a Senior Analyst with Richard J. Barber Associates, a Section Supervisor with Mutual of
`Omaha Insurance, and a Research Analyst with the Center for the Study of American Business.
`
`EDUCATION
`
`J.D.
`
`
`M.A. & Ph.D. candidate
`B.A., Summa Cum Laude
`
`University of Wisconsin
`Economics, Washington University, St. Louis
`Economics and Organizational Communication, Creighton University
`
`
`
`

`

`
`
`John C. Jarosz, page 2
`
`PROFESSIONAL ASSOCIATIONS/MEMBERSHIPS
` American Economic Association
` American Law and Economics Association
` American Bar Association (Sections: Intellectual Property, Antitrust and Litigation)
` State Bar of Wisconsin (Section: Intellectual Property)
` American Intellectual Property Law Association (Sections: Federal Litigation, Licensing, Trade
`Secrets and Antitrust)
` Licensing Executives Society
`- Former Chair, Valuation and Taxation Committee
`- Former Member, Certified Licensing Professional Exam Writing Team
` Former Advisory Board - The IP Litigator
` Former Columnist (Damage Awards) - The IP Litigator
` Omicron Delta Epsilon (International Honor Society in Economics)
` Association of University Technology Managers
` Certified Licensing Professional
`Intellectual Property Owners Association (Committee: Damages and Injunctions)
`
` 2011 Presidential Rank Review Board
` Referee, Journal of Forensic Economics
` The Sedona Conference (Sections: Best Practices in Patent Litigation, Patent Damages and Remedies)
`IAM Patent 1000 (2014, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022): The World’s Leading
`
`Patent Practitioners - Economic Experts
`IP Law360: Voices of the Bar
`
`
`
`TESTIMONIAL EXPERIENCE
`
`Patent Cases – Damages
`
`
`
`Invacare Corporation v. Sunrise Medical (US) LLC
`United States District Court, District of Delaware (Case No. 21-823 (JPM))
`Deposition testimony and expert report: reasonable royalty damages involving patents directed to
`power wheelchair technology.
` Bel Power Solutions, Inc. v. Monolithic Power Systems, Inc.
`United States District Court, Western District of Texas, Waco Division (Case No. 6:21-cv-655-ADA)
`Deposition testimony and expert reports: reasonable royalty damages involving patents directed to
`integrated circuit power converters.
`
`
`
`
`
`

`

`
`
`John C. Jarosz, page 3
`
` Collision Communications, Inc. v. Nokia Corporation, Nokia Solutions and Networks OY, and
`Nokia of American Corporation
`United States District Court, Eastern District of Texas, Marshall Division (Case No. 2:21-cv-00308)
`Deposition testimony and expert reports: reasonable royalty damages involving patents directed to
`mobile telecommunication technologies.
` Collision Communications, Inc. v. Telefonaktiebolaget LM Ericsson and Ericsson Inc.
`United States District Court, Eastern District of Texas, Marshall Division (Case No. 2:21-cv-00327)
`Deposition testimony and expert report: reasonable royalty damages involving patents directed to
`mobile telecommunication technologies.
` Panasonic Corporation v. Getac Technology Corporation and Getac, Inc.
`United States District Court, Central District of California (Case No. 8:19-cv-01118-DOC-DFM)
`Trial and deposition testimony and expert reports: monopolization/attempted monopolization
`counterclaim and design patent damages directed to market for rugged 2-in-1 portable computers.
` Carnegie Institution of Washington and M7D Corporation v. Pure Grown Diamonds, Inc. and
`IIA Technologies PTE. Ltd d/b/a IIA Technologies
`United States District Court, Southern District of New York (Case No. 1:20-cv-00189-JSR)
`Deposition testimony and expert report: reasonable royalty damages covering patents directed to
`methods and apparatus used for producing lab-grown diamonds.
` Carnegie Institution of Washington and M7D Corporation v. Fenix Diamonds LLC
`United States District Court, Southern District of New York (Case No. 1:20-cv-00200-JSR)
`Deposition testimony and expert report: reasonable royalty damages covering patents directed to
`methods and apparatus used for producing lab-grown diamonds.
` BASF Plant Science, LP v. Commonwealth Scientific and Industrial Research Organisation;
`and Commonwealth Scientific and Industrial Research Organisation, Grains Research and
`Development, Corp., and Nuseed Pty Ltd. v. BASF Plant Science, LP and Cargill, Inc.
`United States District Court, Eastern District of Virginia (Case No. 17-cv-503-HCM)
`Trial and deposition testimony and expert report: reasonable royalty damages and injunctive relief
`covering patents directed to the production of plant-derived omega-3 oils.
` Riddell, Inc. v. Kranos Corporation, d/b/a Schutt Sports
`United States District Court, Northern District of Illinois (Case No. 1:16-cv-04496)
`Trial testimony and expert report: lost profits, reasonable royalty, and prejudgment interest involving
`patents covering football helmet technology.
` Cedars-Sinai Medical Center v. Quest Diagnostics Inc. and Quest Diagnostics Nichols Institute
`United States District Court, Central District of California, Western Division (Case No. 17-cv-5169-
`GW-FFM)
`Deposition testimony and expert report: damages associated with alleged misappropriation of trade
`secrets, breach of contract, and patent infringement involving diagnostic testing for irritable bowel
`syndrome (IBS).
` Roche Diagnostics Corporation v. Meso Scale Diagnostics, LLC and Meso Scale Diagnostics,
`LLC v. Roche Diagnostics Corporation and BioVeris Corporation
`United States District Court, District of Delaware (Case No. 17-189 (LPS)(CJB))
`Trial and deposition testimony and expert report: reasonable royalty damages related to alleged patent
`infringement involving electrochemiluminescent detection technology used in immunoassay kits.
` Kranos IP Corporation, Kranos IP II Corporation, and Kranos Corporation d/b/a Schutt
`Sports v. Riddell, Inc.
`United States District Court, Northern District of Illinois (Case No. 1:17-cv-06802)
`Deposition testimony and expert report: reasonable royalty damages and prejudgment interest
`involving patents covering football helmet technology.
`
`
`
`
`
`

`

`
`
`John C. Jarosz, page 4
`
`
`
` Nichia Corporation v. Vizio, Inc.
`United States District Court, Central District of California (Case No. 8:16-cv-00545)
`Deposition testimony and expert report: reasonable royalty damages and commercial success
`involving patents directed to light emitting diodes (LEDs).
` Syngenta Crop Protection, LLC v. Willowood, LLC, Willowood USA, LLC, Willowood
`Azoxystrobin, LLC, and Willowood Limited
`United States District Court, Middle District of North Carolina (Case No. 1:15-cv-274)
`Trial and deposition testimony and expert report: damages and prejudgment interest related to alleged
`patent and copyright infringement involving crop fungicide.
`Integra Lifesciences Corporation, Integra Lifesciences Sales, LLC, Confluent Surgical, Inc.,
`and Incept, LLC v. Hyperbranch Medical Technology, Inc.
`United States District Court, District of Delaware (Case No. 15-cv-00819)
`Trial and deposition testimony and expert reports: lost profits, price erosion, reasonable royalty,
`prejudgment interest, preliminary relief, and commercial success involving patents directed to cranial
`and spinal dural repair sealants.
` Blue Spike, LLC v. Toshiba America, Inc., and Toshiba Corporation
`United States District Court, Eastern District of Texas, Tyler Division (Case No. 6:16-CV-430-RWS-
`JDL)
`Damages hearing and early expert report: damages related to alleged patent infringement involving
`address space layout randomization (ASLR) technology.
` Audio MPEG, Inc., U.S. Philips Corporation, TDF SAS, and Institut Für Rundfunktechnik
`GmbH v. Dell, Inc.
`United States District Court, Eastern District of Virginia, Norfolk Division (Case No. 1:15-CV-1674
`AJT/TCB)
`Deposition testimony and expert report: analysis of patent pool compliance with FRAND
`commitments and determination of FRAND-compliant royalties involving patents directed to the
`transmission and storage of digital audio files.
` Koninklijke Philips Electronics N.V. and Philips Electronics North America Corporation v.
`ZOLL Medical Corporation
`United States District Court, District of Massachusetts (Case No. 1:10-cv-11041)
`Trial and deposition testimony and expert report: lost profits, reasonable royalty damages, and
`prejudgment interest related to alleged patent infringement involving external defibrillators.
` Erfindergemeinschaft UroPep GbR v. Eli Lilly and Company and Brookshire Brothers, Inc.
`United States District Court, Eastern District of Texas, Marshall Division (Case No. 2:15-cv-1202-
`WCB)
`Trial and deposition testimony and expert report: reasonable royalty damages related to alleged patent
`infringement directed to phosphodiesterase (PDE) V inhibitor(s) indicated for the treatment of benign
`prostatic hyperplasia.
` Koninklijke Philips Electronics N.V. and Philips Electronics North America Corporation v.
`ZOLL Lifecor Corporation
`United States District Court, Western District of Pennsylvania (Case No. 2:2012-cv-01369)
`Deposition testimony and expert report: damages related to alleged patent infringement involving
`wearable defibrillators.
`
`
`
`
`
`
`
`
`
`

`

`
`
`John C. Jarosz, page 5
`
` Luminara Worldwide, LLC v. Shenzhen Liown Electronics Co., Ltd, Central Garden and Pet
`Co., et al.; Shenzhen Liown Electronics Co., Ltd, Central Garden and Pet Co. v. Luminara
`Worldwide, LLC, et al. ; and Luminara Worldwide, LLC v. Shenzhen Liown Electronics Co.,
`Ltd and Central Garden and Pet Co., et al.
`United States District Court, District of Minnesota (Case Nos. 14-cv-03103 (SRN/FLN) and 15-cv-
`03028 (SRN/FLN))
`Deposition testimony and expert reports: damages associated with alleged patent infringement and
`breach of contract, and unjust enrichment associated with breach of non-disclosure agreement and use
`of trade secrets, related to flameless candle technology and distribution.
` MobileMedia Ideas LLC v. Apple, Inc.
` United States District Court, District of Delaware (Case No. 10-258-SLR)
`Trial and deposition testimony and expert report: reasonable royalty involving patents directed to
`incoming call, playlist, and location detection features used in smartphones, tablets, and portable
`media players.
` MAZ Encryption Technologies LLC v. Blackberry Corporation
` United States District Court, District of Delaware (Case No. 1:13-cv-00304-LPS)
`Deposition testimony and expert report: reasonable royalty involving a patent directed to
`encryption/decryption methods used in smartphone and tablet operating systems.
` BroadSoft, Inc. v. Callwave Communications, LLC
`United States District Court, District of Delaware (Case No. 13-cv-0711-RGA)
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving patents
`directed to telecommunications call processing.
` Advanced Video Technologies, LLC v. Blackberry, LTD. and Blackberry Corporation
` United States District Court, Southern District of New York (Case No. 1:11-cv-06604-CM-RLE)
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving a
`patent directed to video compression and decompression.
` Drone Technologies, Inc. v. Parrot S.A. and Parrot, Inc.
`United States District Court, Western District of Pennsylvania (Case No. 2:14-cv-0111)
`Trial and deposition testimony and expert report: reasonable royalty and prejudgment interest
`involving a patent directed to drone technology.
` Bayer CropScience AG and Bayer CropScience NV v. Dow AgroSciences LLC, Mycogen Plant
`Science Inc., Agrigenetics, Inc. d/b/a Mycogen Seeds LLC, and Phytogen Seed Company, LLC
`International Chamber of Commerce (Case No. 18892/VRO/AGF)
`Arbitration hearing testimony and expert report: damages associated with alleged breach of contract
`and patent infringement involving genetically modified seed.
` CertusView Technologies, LLC v. S &N Locating Services LLC and S & N Communications,
`Inc.
`United States District Court, Eastern District of Virginia, Norfolk Division (Case No. 2:13-cv-346
`(MSD/LRL))
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving patents
`directed to creation of electronic sketches for utility location purposes.
` Ecolab USA Inc. and Kleancheck Systems, LLC v. Diversey, Inc.
`United States District Court, District of Minnesota (Civil Action No. 12-cv-1984 (SRN/JJG))
`Deposition testimony and expert report: lost profits, reasonable royalty, and prejudgment interest
`involving products covering the monitoring of hospital cleaning.
`
`
`
`
`
`
`
`
`

`

`
`
`John C. Jarosz, page 6
`
` Everlight Electronics Co. Ltd., and Emcore Corporation v. Nichia Corporation and Nichia
`America Corporation v. Everlight Americas, Inc.
`United States District Court, Eastern District of Michigan, Southern Division (Case No. 4:12-cv-
`11758 GAD-MKM)
`Trial and deposition testimony, expert report and declaration: commercial success, lost profits,
`reasonable royalty, and prejudgment interest involving patents directed to LEDs.
` Source Search Technologies, LLC v. Kayak.com, Inc.
`United States District Court, District of New Jersey (Case No. 2:11-cv-03388-FSH-MAH)
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving a
`patent directed to online exchanges.
` Universal Electronics, Inc. v. Universal Remote Control, Inc.
`United States District Court, Central District of California, Southern Division (Case No. SACV12-
`329AG (JPRx))
`Trial and deposition testimony and expert report: reasonable royalty and prejudgment interest
`involving patents directed to universal remotes.
` Prowess, Inc. v. RaySearch Laboratories AB, et al.
`United States District Court, District of Maryland (Case No. 11 CV 1357 (WDQ))
`Deposition testimony and expert report: lost profits, reasonable royalty and prejudgment interest
`involving patents directed to treatment planning software for radiation therapy.
` JDS Therapeutics, LLC and Nutrition 21, LLC v. Pfizer Inc., Wyeth LLC, Wyeth Consumer
`Healthcare Ltd., and Wyeth Consumer Healthcare LLC
`United States District Court, Southern District of New York (Case No. 1:12-cv-09002-JSR)
`Deposition testimony and expert report: commercial success, reasonable royalty, and unjust
`enrichment involving patents and trade secrets directed to the use of chromium picolinate in multi-
`vitamins.
`comScore, Inc. v. Moat, Inc.
`United States District Court, Eastern District of Virginia, Norfolk Division (Case No. 2:12CV695-
`HCM/DEM, Lead Case 2:12CV351-HCM/DEM)
`Deposition testimony and expert report: lost profits, reasonable royalty and prejudgment interest
`involving patents directed to online analytics.
`Impulse Technology Ltd. v. Microsoft Corporation, Electronic Arts, Inc., Ubisoft Holdings,
`Inc., and Konami Digital Entertainment Inc.
`United States District Court, District of Delaware (Case No. 11-586-RGA-CJB)
`Deposition testimony and expert report: reasonable royalty involving patents directed to video game
`motion detection functionalities.
` LendingTree, LLC v. Zillow, Inc., NexTag, Inc., and Adchemy, Inc.
`United States District Court, Western District of North Carolina, Charlotte Division (Case No. 3:10-
`cv-439-FDW-DCK)
`Trial and deposition testimony and expert report: lost profits, reasonable royalty and prejudgment
`interest involving patents directed to internet loan matching systems.
` Network Protection Sciences, LLC v. Fortinet, Inc.
`United States District Court, Northern District of California (Case No. 3:12-cv-01106-WHA)
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving patents
`directed to network security systems.
` Shurtape Technologies, LLC and Shurtech Brands, LLC v. 3M Company
`United States District Court, Western District of North Carolina (Case No. 5:11-cv-00017)
`Deposition testimony and expert report: lost profits, reasonable royalty and prejudgment interest
`involving patents directed to painter’s tape.
`
`
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`
`
`
`
`
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`

`

` Abbott Biotechnology Ltd. and AbbVie, Inc. v. Centocor Ortho Biothech, Inc.
`United States District Court, District of Massachusetts (Case No. 09-40089-FDS)
`Deposition testimony and expert report: lost profits, reasonable royalty and prejudgment interest
`involving patents directed to the treatment of rheumatoid arthritis.
` Wi-LAN Inc. v. Alcatel-Lucent USA Inc.; Telefonaktiebolaget LM Ericsson; Ericsson Inc.;
`Sony Mobile Communications AB; Sony Mobile Communications (USA) Inc.; HTC
`Corporation; HTC America, Inc.; Exedea Inc.; LG Electronics, Inc.; LG Electronics
`Mobilecomm U.S.A., Inc.; and LG Electronics U.S.A., Inc.
`United States District Court, Eastern District of Texas (Case No. 6:10-CV-521-LED)
`Trial and deposition testimony, affidavit, and expert report: reasonable royalty and prejudgment
`interest involving patents directed to wireless telecommunication systems.
` Epos Technologies Ltd.; Dane-Elec S.A.; Dane-Elec Memory S.A.; and Dane-Elec Corporation
`USA v. Pegasus Technologies Ltd. and Luidia, Inc.
`United States District Court, District of Columbia (Case No. 07-cv-00416-WMN)
`Deposition testimony and expert report: lost profits, reasonable royalty and prejudgment interest
`involving patents directed to digital pen products.
` Life Technologies Corporation; Applied Biosystems, LLC; Institute for Protein Research;
`Alexander Chetverin; Helena Chetverina; and William Hone v. Illumina, Inc. and Solexa, Inc.
`United States District Court, Southern District of California (Case No. 3:11-cv-00703)
`Deposition testimony and expert report: lost profits, reasonable royalty and prejudgment interest
`involving patents directed to DNA amplification and sequencing technology.
` TomTom, Inc. v. Michael Adolph
`United States District Court, Eastern District of Virginia (Case No. 1:12-cv-528)
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving patents
`directed to automotive navigation systems.
` Carl B. Collins and Farzin Davanloo v. Nissan North America, Inc. and Nissan Motor Co., Ltd.
`United States District Court, Eastern District of Texas, Marshall Division (Case No. 2:11-cv-00428-
`JRG)
`Deposition testimony and expert report: reasonable royalty and prejudgment interest involving patents
`directed to automotive engines.
`I.E.E. International Electronics & Engineering, S.A. and IEE Sensing, Inc. v. TK Holdings, Inc.
`United States District Court, Eastern District of Michigan (Case No. 2:

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