throbber
UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C. 20436
`
`Before the Honorable MaryJoan McNamara
`Administrative Law Judge
`
`
`In the Matter of
`
`CERTAIN CELLULAR BASE STATION
`COMMUNICATION EQUIPMENT,
`COMPONENTS THEREOF, AND
`PRODUCTS CONTAINING SAME
`
`
`
`Investigation No. 337-TA-1388
`
`COMPLAINANT MOTOROLA MOBILITY LLC’S
`IDENTIFICATION OF EXPERT WITNESSES
`
`the Procedural Schedule, Complainant Motorola Mobility LLC
`
`to
`
`Pursuant
`
`
`
`
`
`
`
`
`(“Complainant” or “Motorola”) hereby provides its identification of Expert Witnesses, including
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`a statement of expertise and curriculum vitae for each expert witness. This identification of experts
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`(including their expected areas of testimony) is based on Motorola’s current understanding of the
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`evidence produced during discovery to date. Discovery is ongoing, and Motorola reserves the
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`right to supplement this identification as additional information becomes available. In addition to
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`the expert witnesses identified below, Motorola reserves the right to proffer testimony from any
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`expert identified by Respondents Ericsson AB, Telefonaktiebolaget LM Ericsson, and Ericsson
`
`Inc (collectively, Respondents” or “Ericsson”) or the Staff in this Investigation.
`
`I.
`
`Pallavi Seth
`
`Dr. Pallavi Seth is an expert in economics, including intellectual property and economic
`
`policy. She specializes in a range of economic issues including domestic industry, remedy,
`
`bonding, commercial success, public interest, and economic injury. She earned a Doctor of
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`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
`INV. NO. 337-TA-1388
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`Philosophy (Ph.D.) in economics from Boston College with a focus in Industrial Organization,
`
`Applied Econometrics, and International Trade. She also holds a Bachelor of Arts in economics
`
`and a Bachelor of Arts in mathematics. Dr. Seth’s curriculum vitae, attached hereto as Exhibit A,
`
`sets forth her qualifications. If called upon to testify, the general nature of Dr. Seth’s testimony is
`
`expected to relate to at least the economics of Motorola’s domestic industry, the appropriate
`
`remedy in this Investigation, and its effect on the public interest, bonding, and any other issues
`
`relevant to Motorola’s claims and Ericsson’ defenses for which expert testimony is required or
`
`useful. Dr. Seth may also testify in rebuttal to the issues, opinions, and evidence offered by
`
`Ericsson or its retained expert witnesses in this matter.
`
`II.
`
`Coleman Bazelon
`
`Dr. Bazelon is an expert in economics, including valuation and remedies issues relating to
`
`intellectual property rights. He specializes in regulation, strategy, and valuation of the wireless,
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`wireline, and video sectors, as well as intellectual property matters at the ITC. He earned a Doctor
`
`of Philosophy (Ph.D.) in Agricultural and Resource Economics from the University of California,
`
`Berkeley. He also holds a Master of Science in Agricultural and Resource Economics, a Diploma
`
`in Economics from the London School of Economics, and a Bachelor of Arts in Social Studies.
`
`Dr. Bazelon’s curriculum vitae, attached hereto as Exhibit B, sets forth his qualifications. If called
`
`upon to testify, the general nature of Dr. Bazelon’s testimony is expected to relate to at least the
`
`economics of Motorola’s domestic industry, the appropriate remedy in this Investigation, and its
`
`effect on the public interest, bonding, and any other issues relevant to Motorola’s claims and
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`Ericsson’ defenses for which expert testimony is required or useful. Dr. Bazelon may also testify
`
`in rebuttal to the issues, opinions, and evidence offered by Ericsson or its retained expert witnesses
`
`in this matter.
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`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
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`III. Thomas Vander Veen
`
`Dr. Vander Veen is an expert in economics, including valuation and remedies issues
`
`relating to intellectual property rights. He specializes in, without limitation, the application of
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`economics and valuation to intellectual property, international trade, and complex commercial
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`disputes, including evaluation of economic damages related to patent infringement, and economic
`
`analysis in section 337 intellectual property matters before the Commission. He earned a Doctor
`
`of Philosophy (Ph.D.) in economics from Brown University in 1998. He also holds a Master of
`
`Arts in economics, a Bachelor of Arts in economics, and a Bachelor of Arts in mathematics. Dr.
`
`Vander Veen’s curriculum vitae, attached hereto as Exhibit C, sets forth his qualifications. If
`
`called upon to testify, the general nature of Dr. Vander Veen’s testimony is expected to relate to
`
`at least the economics of Motorola’s domestic industry, the appropriate remedy in this
`
`Investigation, and its effect on the public interest, bonding, and any other issues relevant to
`
`Motorola’s claims and Ericsson’ defenses for which expert testimony is required or useful. Dr.
`
`Vander Veen may also testify in rebuttal to the issues, opinions, and evidence offered by Ericsson
`
`or its retained expert witnesses in this matter.
`
`IV. Matthew Valenti
`
`Professor Matthew Valenti has a Ph.D. in Electrical Engineering from the Virginia
`
`Polytechnic Institute & State University. He received a Bachelor of Science in Electrical
`
`Engineering from the Virginia Polytechnic Institute & state University, and a Master of Science in
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`Electrical Engineering from Johns Hopkins University. Professor Valenti is currently a Professor
`
`in West Virginia University’s Lane Department of Computer Science and Electrical Engineering.
`
`Professor Valenti’s CV, attached as Exhibit D, sets forth his additional qualifications and
`
`experience. Professor Valenti is expected to testify regarding technical matters related to the
`
`Asserted Patents, the subject matter of the Asserted Patents, the state of the art at the time of the
`3
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`alleged invention of the Asserted Patents, qualifications of a person of ordinary skill in the art, the
`
`invalidity and/or unenforceability of the Asserted Patents, the construction of claims and claim
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`terms of the Asserted Patents, the structure, design, functionality, and operation of the accused
`
`products and domestic industry products at issue in this Investigation, other issues in connection
`
`with Motorola’s defenses, and any other technical issues that may arise. Professor Valenti may
`
`also testify in rebuttal to the issues, opinions, and evidence offered by Ericsson or its retained
`
`expert witnesses in this matter.
`
`V.
`
`Paul S. Min
`
`Professor Paul S. Min has a Ph.D. in Electrical Engineering from the University of
`
`Michigan in Ann Arbor. He received a Bachelor of Science and Master of Science in Electrical
`
`Engineering from University of Michigan. Professor Min is currently a Senior Professor at
`
`Washington University in St. Louis McKelvey School of Engineering. Professor Min’s CV,
`
`attached as Exhibit E, sets forth his additional qualifications and experience. Professor Min is
`
`expected to testify regarding technical matters related to the Asserted Patents, the subject matter
`
`of the Asserted Patents, the state of the art at the time of the alleged invention of the Asserted
`
`Patents, qualifications of a person of ordinary skill in the art, the invalidity and/or unenforceability
`
`of the Asserted Patents, the construction of claims and claim terms of the Asserted Patents, the
`
`structure, design, functionality, and operation of the accused products and domestic industry
`
`products at issue in this Investigation, other issues in connection with Motorola’s defenses, and
`
`any other technical issues that may arise. Professor Min may also testify in rebuttal to the issues,
`
`opinions, and evidence offered by Ericsson or its retained expert witnesses in this matter.
`
`VI. Harry Bims
`
`Dr. Harry V. Bims has a Ph.D. in Electrical Engineering from Stanford University. He
`
`received a Bachelor of Science in Computer and Systems Engineering from Rensselaer
`4
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`Polytechnic Institute and a Master of Science in Electrical Engineering from Stanford University.
`
`Dr. Bims currently holds a number of roles, including as CEO of CUPP Cybersecurity, LLC,
`
`Founder of BoughtStuff, Inc., and Technical Lead Developer at Access Network Protocol
`
`Development. Dr. Bim’s CV, attached as Exhibit F, sets forth his additional qualifications and
`
`experience. Dr. Bim is expected to testify regarding technical matters related to the Asserted
`
`Patents, the subject matter of the Asserted Patents, the state of the art at the time of the alleged
`
`invention of the Asserted Patents, qualifications of a person of ordinary skill in the art, the
`
`invalidity and/or unenforceability of the Asserted Patents, the construction of claims and claim
`
`terms of the Asserted Patents, the structure, design, functionality, and operation of the accused
`
`products and domestic industry products at issue in this Investigation, other issues in connection
`
`with Motorola’s defenses, and any other technical issues that may arise. Dr. Bims may also testify
`
`in rebuttal to the issues, opinions, and evidence offered by Ericsson or its retained expert witnesses
`
`in this matter.
`
`VII. Richard M. Goodin
`
`Mr. Richard M. Goodin is a technical consultant in software design and development. He
`
`holds a Bachelor of Science in Electrical Engineering with a Minor in Mechanical Engineering
`
`from the University of Delaware. Mr. Goodin’s CV, attached as Exhibit G, sets forth his additional
`
`qualifications and experience. Mr. Goodin’s expertise includes but is not limited to source code
`
`and software development, and analysis and interpretation of the same. If called upon to testify,
`
`the general nature of Mr. Goodin’s testimony is expected to relate to the technical matters of this
`
`case, including the source code concerning the accused products, technical domestic industry
`
`products, infringement, and validity. Mr. Goodin may also testify in rebuttal to the issues,
`
`opinions, and evidence offered by Ericsson or its retained expert witnesses in this matter.
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`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
`INV. NO. 337-TA-1388
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`5
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`VIII. Walter Overby
`
`
`
`Mr. Walter Overby is a technical consultant in software design and development. He holds
`
`a Bachelor of Science in Computer Science from Duke University. Mr. Overby’s CV, attached as
`
`Exhibit H, sets forth his additional qualifications and experience. Mr. Overby’s expertise includes
`
`but is not limited to source code and software development, and analysis and interpretation of the
`
`same. If called upon to testify, the general nature of Mr. Overby’s testimony is expected to relate
`
`to the technical matters of this case, including the source code concerning the accused products,
`
`technical domestic industry products, infringement, and validity. Mr. Overby may also testify in
`
`rebuttal to the issues, opinions, and evidence offered by Ericsson or its retained expert witnesses
`
`in this matter.
`
`IX. Dave Djavaherian
`
`Mr. Dhavaherian has expertise in the areas of licensing and standards in a wide range of
`
`industries including telecommunications. Mr. Djavaherian’s CV, attached as Exhibit I, sets forth
`
`his additional qualifications and experience. Mr. Djavaherian may testify regarding how members
`
`in the industry would conduct themselves in negotiations toward a FRAND license; and how an
`
`exclusion order would affect the public interest, including, but not limited to, an assessment of the
`
`statutory factors considered by the Commission and FRAND issue and any other issues relevant
`
`to Motorola’s claims and Ericsson’ defenses for which expert testimony is required or useful. Mr.
`
`Djavaherian may testify as part of Motorola’s case-in-chief as well as in rebuttal to address
`
`Ericsson’s expert testimony.
`
`X.
`
`Christian Dippon
`
`Dr. Christian Dippon has expertise in the areas set forth in his CV, attached as Exhibit J,
`
`including economic issues relating to telecommunications and intellectual property, and
`
`competition-related issues. Dr. Dippon may testify regarding how an exclusion order would affect
`6
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`the public interest, including, but not limited to, an assessment of the statutory factors considered
`
`by the Commission: public health and welfare, competitive conditions in the United States
`
`economy, production of like or directly competitive articles in the United States, United States
`
`consumers and any other issues relevant to Motorola’s claims and Ericsson’ defenses for which
`
`expert testimony is required or useful. Dr. Dippon may testify as part of Motorola’s case-in-chief
`
`as well as in rebuttal to address Ericsson’s expert testimony.
`
`XI.
`
`Paul Meyer
`
`Mr. Paul Meyer has experience in the areas of economic and financial issues in litigation,
`
`valuation of both business and intellectual property, economic damages, corporate operations,
`
`finance, accounting, and fair, reasonable, and nondiscriminatory licensing. Mr. Meyer’s CV,
`
`attached as Exhibit K, sets forth his additional qualifications and experience. Mr. Meyer may
`
`testify regarding how an exclusion order would affect the public interest, including, but not limited
`
`to, an assessment of the statutory factors considered by the Commission: public health and welfare,
`
`competitive conditions in the United States economy, production of like or directly competitive
`
`articles in the United States, United States consumers and any other issues relevant to Motorola’s
`
`claims and Ericsson’ defenses for which expert testimony is required or useful. Mr. Meyer may
`
`also testify regarding standard setting organizations, ETSI IPR undertakings, FRAND licensing,
`
`and whether Ericsson has complied with its FRAND obligations. Mr. Meyer may also testify about
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`secondary considerations of nonobviousness. Mr. Meyer may also testify regarding the
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`appropriate remedy and bond, if any, I the event a violation of Section 337 is found. Mr. Meyer
`
`may testify as part of Motorola’s case-in-chief as well as in rebuttal to address Ericsson’s expert
`
`testimony.
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`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
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`XII. Philippe Stoffel-Munck
`
`Dr. Philippe Stoffel-Munck has expertise in the area of French civil law applied in business
`
`life, including the law of contracts, liability, and security. Dr. Stoffel-Munck’s CV, attached as
`
`Exhibit L, sets forth his additional qualifications and experience. Dr. Stoffel-Munck may testify
`
`regarding the standards at issue in this litigation, including, but not limited to, the interpretation of
`
`ETSI IPR Policy and the enforceability, effect, construction of ETSI FRAND undertakings under
`
`French law and any other issues relevant to Motorola’s claims and Ericsson’ defenses for which
`
`expert testimony is required or useful. Dr. Stoffel-Munck may testify as part of Motorola’s case-
`
`in-chief as well as in rebuttal to address Ericsson’s expert testimony.
`
`XIII. Vince Thomas
`
`Mr. Vince Thomas has expertise in the areas of economic, accounting, financial, and
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`valuation analysis
`
`in several
`
`industries,
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`including computer
`
`technology, electronics,
`
`telecommunications, retail, manufacturing, and life sciences. Mr. Thomas’s CV, attached as
`
`Exhibit M, sets forth his additional qualifications and experience. If called upon to testify, the
`
`general nature of Mr. Thomas’s testimony is expected to relate to at least the economics of
`
`Motorola’s domestic industry, the appropriate remedy in this Investigation, and its effect on the
`
`public interest, bonding, and any other issues relevant to Motorola’s claims and Ericsson’ defenses
`
`for which expert testimony is required or useful. Mr. Thomas may also testify in rebuttal to the
`
`issues, opinions, and evidence offered by Ericsson or its retained expert witnesses in this matter.
`
`XIV. Christopher Floyd
`
`Sir Christopher Floyd has expertise in the area of UK civil law as applied in business,
`
`including the law of contracts, and patent law. Sir Floyd’s CV, attached as Exhibit N, sets forth
`
`his additional qualifications and experience. Sir Floyd may opine regarding provisions binding
`
`the parties’ choice of forum, the applicability of UK law in the parties’ prior private agreements,
`8
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`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
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`UK civil procedure for FRAND rate-setting disputes and any other issues relevant to Motorola’s
`
`claims and Ericsson’ defenses for which expert testimony is required or useful. Sir Floyd may
`
`testify as part of Motorola’s case-in-chief as well as in rebuttal to address Ericsson’s expert
`
`testimony.
`
`XV. Trevor Smedley
`
`Dr. Trevor Smedley is a technical consultant in software design and development. He also
`
`received a Doctor of Philosophy (Ph.D.) in Computer Science from the University of Waterloo,
`
`Canada, and a Master of Science in Computer Science from University of Waterloo, Canada. He
`
`also holds a Bachelor of Science in Computer Science and a Bachelor of Science in Math from the
`
`University of Waterloo, Canada. Dr. Smedley’s CV, attached as Exhibit O, sets forth his additional
`
`qualifications and experience. Dr. Smedley’s expertise includes but is not limited to source code
`
`and software development, and analysis and interpretation of the same. If called upon to testify,
`
`the general nature of Dr. Smedley’s testimony is expected to relate to the technical matters of this
`
`case, including the source code concerning the accused products, technical domestic industry
`
`products, infringement, and validity. Dr. Smedley may also testify in rebuttal to the issues,
`
`opinions, and evidence offered by Ericsson or its retained expert witnesses in this matter.
`
`.
`
`
`
`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
`INV. NO. 337-TA-1388
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`9
`
`

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`Date: March 20, 2024
`
`
`
`
`
`Respectfully submitted,
`
`FISH & RICHARDSON P.C
`
`By: Adam R. Shartzer
`Ruffin B. Cordell
`Adam R. Shartzer
`Richard A. Sterba
`Jenna Kuh
`FISH & RICHARDSON P.C.
`1000 Maine Ave., SW
`Washington, DC 20024
`Telephone: (202) 783-5070
`Fax: (202) 783-2331
`
`Benjamin C. Elacqua
`Kate Quisenberry
`Eli Svetlov
`FISH & RICHARDSON P.C.
`909 Fannin Street, Suite 2100
`Houston, TX 77010
`Telephone: (713) 654-5300
`Fax: (713) 713-652-0109
`
`Christopher O. Green
`Charles N. Reese, Jr.
`Jacqueline Tio
`Wonjoon Chung
`FISH & RICHARDSON P.C.
`1180 Peachtree Street, NE
`21st Floor
`Atlanta, GA 30309
`Telephone: (404) 892-5005
`Fax: (404) 892-5002
`
`James Huguenin-Love
`FISH & RICHARDSON P.C.
`60 South 6th Street
`Ste. 3200
`Minneapolis, MN 55402
`Telephone: (612) 335-5070
`Fax: (612) 288-9696
`
`Aleksandr Gelberg
`FISH & RICHARDSON P.C.
`12860 El Camino Real
`Ste. 400
`
`10
`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
`INV. NO. 337-TA-1388
`
`

`

`San Diego, CA 92130
`Telephone: (858) 678-5070
`Fax: (858) 678-5099
`
`Counsel for Complainant
`Motorola Mobility LLC
`
`11
`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
`INV. NO. 337-TA-1388
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`

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`CERTIFICATE OF SERVICE
`
`I hereby certify that true and correct copies of the foregoing document:
`
`COMPLAINANT MOTOROLA MOBILITY LLC’S IDENTIFICATION
`OF EXPERT WITNESSES
`
`have been filed and served on this 20th day of March, 2024, on the following:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`The Honorable MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W., Room 317
`Washington, D.C. 20436
`Email: mcnamara337@usitc.gov
`Michael Maas, Esq.
`Investigative Attorney
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`Email: michael.maas@usitc.gov
`
`Adam D. Swain
`Alston & Bird
`950 F Street, NW
`Washington, DC 20004
`Email: EricssonLenovo@alston.com
`
`Nicholas Mathews
`McKool Smith
`300 Crescent Court
`Suite 1200
`Dallas, TX 75201
`Email: Ericsson_Moto_1388@mckoolsmith.com
`
`
` Via First Class Mail
`□
` Via Hand Delivery
`□
` Via Federal Express
`□
` Via Electronic Filing
`~
`
` Via First Class Mail
`□
` Via Hand Delivery
`□
`(two double sided paper copies)
` Via Federal Express
`□
` Via Electronic Mail
`~
`
` Via First Class Mail
`□
` Via Hand Delivery
`□
` Via Federal Express
`□
` Via Electronic Mail
`~
` Via USITC Box Platform
`~
`
` Via First Class Mail
`□
` Via Hand Delivery
`□
` Via Federal Express
`□
` Via Electronic Mail
`~
`
` Via First Class Mail
`□
` Via Hand Delivery
`□
` Via Federal Express
`□
` Via Electronic Mail
`~
`
` /s/Tracy Haynes
`
`
`
`
`
`
`
`COMPLAINANT’S IDENTIFICATION OF EXPERT WITNESSES
`INV. NO. 337-TA-1388
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`

`

`EXHIBIT A
`EXHIBIT A
`
`

`

`PALLAVI SETH
`Principal
`Co-Chair Intellectual Property Practice
`
`+1.202.955.5050
`
`Washington, DC
`
`Pallavi.Seth@brattle.com
`
`
`Dr. Pallavi Seth has extensive experience in the areas of intellectual property and economic policy. She
`has assisted counsel for leading technology companies; trade associations; and government agencies.
`
`She has provided expert testimony in intellectual property matters involving allegations of patent
`infringement, false advertising, and misappropriation of trade secrets. She has served as an expert witness
`on damages issues in district courts and in Section 337 investigations at the United States International
`Trade Commission (ITC). Before the ITC, Dr. Seth has testified on a range of economic issues, such as
`domestic industry, remedy, bonding, commercial success, public interest, and economic injury. She has
`aided leading companies in over 50 Section 337 investigations. She has also supported leading academic
`experts, including Nobel Laureate Joseph Stiglitz, in these matters.
`
`Dr. Seth has assisted counsel for government agencies, trade associations, and leading technology
`companies, including Intel, Apple, Hewlett-Packard, Samsung, Sony, Nokia, Macronix, LG, and Garmin.
`Her industry expertise includes high-tech and consumer products—such as semiconductors, flash memory
`devices, liquid crystal display (LCD) panels, smartphones, computers, and medical devices—as well as
`financial institutions and the automotive, pharmaceutical, commercial machinery and heavy equipment,
`and gaming industries.
`
`In addition to her expertise in intellectual property matters, Dr. Seth is experienced in applying the tools
`of economic analysis to policy questions and has performed numerous policy analyses across various
`industries. She assisted the Office of the Governor of Massachusetts in evaluating the proposed plan for
`hosting the Olympic Games and the economic impacts of hosting the Games on the Commonwealth.
`
`She is the Former Chair of the ABA-IPL ITC Committee and a frequent speaker at conferences and CLE
`events. She is the Co-Chair of Brattle’s Intellectual Property Practice.
`
`She received her Ph.D. in Economics from Boston College, with a focus in Industrial Organization,
`Applied Econometrics, and International Trade. She received an A.B. in Economics and Mathematics
`(double major) magna cum laude from Mount Holyoke College.
`
`AREAS OF EXPERTISE
`
`
`•
`Intellectual Property
`• Economic Impact Analysis
`• Technology and Telecommunications
`
`
`
`
`THE Bratt le GROUP
`
`
`
`
`
`

`

`PALLAVI SETH
`
`EXPERIENCE
`
`Intellectual Property - ITC
`
`
`• Certain Vaporizer Devices, Cartridges Used Therewith, and Components Thereof, Inv. No. 337-
`TA-1372. NJOY LLC v. JUUL Labs, Inc. Retained by Respondent to opine on economic matters
`related to public interest.
`• Certain Power Converter Modules and Computing Systems Containing the Same, Inv. No. 337-
`TA-1370. Vicor Corporation v. Delta Electronics; Cyntec Co.; Quanta Computer; Hon Hai
`Precision Industry; Foxconn Industrial Internet Co; and Ingrasys Technology. Retained by
`Complainant to opine on economic matters related to domestic industry and remedy. Provided
`expert report and deposition testimony.
`• Certain Active Matrix Organic Light-Emitting Diode Display Panels and Modules for Mobile
`Devices, and Components Thereof, Inv. No. 337-TA-1351. Samsung Display Co. Ltd. v. Apt-
`Ability, LLC; DFW Imports LLC; Electronics Universe, Inc.; eTech Parts Plus, LLC; Gadgetfix
`Corp.; Injured Gadgets, LLC; LCTech International Inc.; Parts4Cells, Inc., Parts4LCD and Phone
`LCD Parts LLC; Wholesale Gadget Parts, Inc; and Mianyang BOE Optoelectronics Co., Ltd.
`Retained by Complainant to opine on economic matters related to public interest.
`• In the Matter of Certain Automated Retractable Vehicle Steps and Components Thereof, Inv. No.
`337-TA-1345. Lund Motion Products, Inc. v. Anhui Aggeus Auto Tech; Parts Co. Lt.; Rough
`Country LLC; Southern Truck LLC; Meyer Distributing Inc; and Earl Owen Company. Designated
`as an expert to opine on economic matters related to domestic industry and remedy.
`• Certain Cabinet X-Ray and Optical Camera Systems and Components Thereof, Inv. No. 337-TA-
`1348. KUB Technologies, Inc. v. Dilon Technologies, Inc.; CompAI Healthcare (Shenzhen) Co.,
`Ltd. et al. Retained by Complainant. Designated as an expert to opine on economic matters related
`to domestic industry and remedy.
`• Certain Rotating 3-D Lidar Devices, Components Thereof, and Sensing Systems Containing the
`Same, Inv. No. 337-TA-1322. Velodyne Lidar USA, Inc. v. Ouster, Inc. and Benchmark Electronics
`Inc. Retained by Complainant. Designated as an expert to opine on economic matters related to
`domestic industry and remedy.
`• Certain Interactive Fitness Products Including Stationary Exercise Bikes, Treadmills, Elliptical
`Machines, and Rowing Machines and Components Thereof, Inv. No. 337-TA-1310. Peloton
`Interactive Inc. v. ICON Fitness Corp; IHF Holdings Inc., iFIT Inc., NoridcTrack Inc., Free Motion
`Fitness Inc. Retained by Complainant. Designated as an expert to opine on economic matters
`related to domestic industry.
`
`
`
`2
`
`

`

`PALLAVI SETH
`
`• Certain Knitted Footwear, Inv. No. 337-TA-1289. Nike, Inc. v. adidas AG, adidas North America,
`Inc., and adidas America, Inc. Retained by Respondents. Designated as an expert to opine on
`economic matters related to domestic industry, remedy, bond, and commercial success.
`• Certain Replacement Automotive Lamps, Inv. No. 337-TA-1291. Kia Corporation and Kia
`America, Inc. v. TYC Brothers Industrial Co., Ltd.; Genera Corporation d/b/a TYC Genera; LKQ
`Corporation; and Keystone Automotive Industries, Inc. Retained by Complainants. Designated as
`an expert to opine on economic matters related to domestic industry and commercial success.
`• Certain Replacement Automotive Lamps II, Inv. No. 337-TA-1292. Hyundai Motor Company and
`Hyundai Motor America, Inc. v. TYC Brothers Industrial Co., Ltd.; Genera Corporation d/b/a TYC
`Genera; LKQ Corporation; and Keystone Automotive Industries, Inc. Retained by Complainants.
`Designated as an expert to opine on economic matters related to domestic industry and commercial
`success.
`• Certain Silicon Photovoltaic Cells and Modules With Nanostructures, and Products Containing
`the Same, Inv. No. 337-TA-1271. Advanced Silicon Group Technologies, LLC v. Canadian Solar,
`Hanwha, Boviet et al. Retained by Complainant. Designated as an expert to opine on economic
`matters related to domestic industry, remedy, and bond.
`• Certain Automated Storage and Retrieval Systems, Robots, And Components Thereof, Inv. No.
`337-TA-1228. AutoStore Technology AS and AutoStore AS v. Ocado Group Plc et. al.; Tharsus
`Group Ltd.; and Printed Motorworks Ltd. Retained by Respondents. Designated as an expert to
`opine on economic matters related to domestic industry, remedy, and bond.
`• Certain Routers, Access Points, Controllers, Networks Management Devices, Other Networking
`Products, and Hardware and Software Components Thereof, Inv. No. 337-TA-1227. Q3
`Networking LLC v. CommScope Holding Company, Inc., CommScope, Inc.; ARRIS US Holdings,
`Inc.; RUCKU Wireless, Inc.; Hewlett Packard Enterprise Co; Aruba Networks, Inc.; and Netgear,
`Inc. Retained by Respondents to opine on economic matters related to domestic industry, remedy
`and bond.
`• Certain Filament Lightemitting Diodes and Products Containing Same (II), Inv. No. 337-TA-1220.
`The Regents of the University of California v. Feit Electric Company, Inc.; Home Depot et. al.;
`IKEA et.al.; Consumer Lighting (U.S.) LLC; Savant Systems, Inc.; General Electric; and Satco
`Products, Inc. Retained by Complainant. Submitted expert report on domestic industry. Provided
`deposition and trial testimony.
`• Certain Electronic Devices with Optical Filters and Optical Sensor Systems and Components
`Thereof, Inv. No. 337-TA-1187. Viavi Solutions, Inc. v. Optrontec Inc.; and LG Electronics, Inc.,
`
`
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`3
`
`

`

`PALLAVI SETH
`
`and LG Innotek Co., Ltd.; LG Electronics U.S.A., Inc. Designated as an expert by Complainant to
`opine on economic matters related to domestic industry and remedy.
`• Certain Toner Cartridges, Components Thereof, and Systems Containing Same, Inv. No.337-TA-
`1174. Brother Industries, Ltd.; Brother International Corporation; and Brother Industries, Inc. v.
`Aster Graphics, Inc. et al. Designated as an expert by Complainant to opine on economic matters
`related to domestic industry and remedy.
`• Certain Rotating 3-D LiDAR Devices, Components Thereof, and Sensing Systems Containing the
`Same, Inv. No. 337-TA-1173. Velodyne lidar, Inc. v. Hesai Photonics Technology Co., Ltd. and
`Suteng Innovation Technology Co., Ltd. Designated as an expert by Complainant to opine on
`economic matters related to domestic industry and remedy. Submitted expert report on domestic
`industry, commercial success, and bonding.
`• Certain Child Carriers and Components Thereof, Inv. 337-TA-1154. LILLEbaby LLC v. BabyBjorn
`AB and BabyBjorn Inc.; Baby Tula a/k/a New Baby Tula LLC; The Ergo Baby Carrier Inc.; Blue Box
`OpCo LLC d/b/a Infantino. Retained by Respondents. Submitted rebuttal expert report on domestic
`industry and bonding. Provided deposition and trial testimony.
`• Certain Blood Separation and Cell Preparation Devices, Inv. No. 337-TA-1147. RegenLab USA v.
`Estar Technologies, Ltd. and Eclipse MedCorp., LLC. Designated as an expert by Respondents to
`opine on economic matters related to domestic industry.
`• Certain Botulinum Toxin Products, Processes for Manufacturing or Relating to Same and Certain
`Products Containing Same, Inv. No. 337-TA-1145. Medytox Inc.; Allergan plc; and Allergan, Inc.
`v. Daewoong Pharmaceuticals Co., Ltd., and Evolus, Inc. Designated as an expert by Respondents
`to opine on economic matters related to domestic industry and economic injury.
`• Certain Unmanned Aerial Vehicles and Components Thereof, Inv. No. 337-TA-1133. Autel
`Robotics USA LLC v. SZ DJI Technology Co. Ltd., DJI Europe B.V., DJI Technology Inc., iFlight
`Technology Co. Ltd., DJI Baiwang Technology Co. Ltd., DJI Research LLC, DJI Service LLC, and
`DJI Creative Studio LLC. Designated as an expert by Respondents to opine on economic matters
`related to domestic industry.
`• Certain Water Filters and Components Thereof, Inv. No. 337-TA-1126. Electrolux Home Products,
`Inc. and KX Technologies, LLC v. Ecolife Technologies, Inc.; Crystala Filters LLC; Shenzen Calux
`Purification technology Co.; Guangzhou Zhixun Xingyi Information; Ningbo Pureza Limited;
`JiangSu Angkua Environmental Technical Co., Ltd. Shenzen Dakon Purification tech Co., Ltd.; and
`HongKong Ecoaqua Co. Limited. Retained by Complainants. Designated as an expert to opine on
`economic matters related to domestic industry. Submitted expert affidavit on domestic industry
`and remedy (general exclusion order).
`
`
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`4
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`

`PALLAVI SETH
`
`• Certain Height-Adjustable Desk Platforms and Components Thereof, Inv. No. 337-TA-1125.
`Retained by Complainant Varidesk LLC. Designated as an expert to opine on economic matters
`related to domestic industry. Submitted expert report on domestic industry, and expert affidavit in
`support of motion for summary determination regarding economic domestic industry.
`• Certain Clidinium Bromide and Products Containing Same, Inv. No. 337-TA-1109. Valeant
`Pharmaceuticals North America LLC and Valeant Pharmaceuticals International, Inc. v. ECI
`Pharmaceuticals LLC; and Virtus 1.Pharmaceuticals, LLC, and Virtus Pharmaceutica

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