`
`Richard G. Zech, Ph.D.
`Curriculum Vitae
`
`
`
`
`
`Intellectual Ventures Ex. 2011
`Canon v. IV
`IPR2014-00757
`
`
`
`Professional Summary
`
`
`
`
`
`Dr. Dick Zech has over 49 years of optical data storage, novel computer storage technologies, and
`photonics experience (including holography, flat panel displays and digital image processing and
`cameras). His academic focus was on modern optics, electromagnetic theory, communications and
`information theory, and advanced mathematics. Starting in 1965 at the University of Michigan, Dr. Zech
`began a lifetime of research and development in the highly specialized areas of optical data and image
`storage, processing/computing, and communications and image-capture and display. He studied under E.
`N. Leith, A. Kozma, A. Vander Lugt, and Dennis Gabor (1971 Nobel laureate in physics), leading
`modern optical sciences pioneers. Dr. Zech is a well-known expert in the field of advanced data storage,
`holography, photonics, digital image capture and processing, and small computer systems.
`
`Dr. Zech’s main areas of interest are optical storage (CD, DVD, and Blu-ray/Blue-laser-disc formats), 3D
`holographic memories, lasers, flat panel displays, digital imaging/cameras, renewable energy, fiber optics,
`LEDs, materials science, nanotechnology, control and processing of light beams, and photonic
`components and their integration into fully functional systems. He has significant engineering, product
`and business development, and sales & marketing management experience. Finally, he has been a
`consultant for over 25 years and an expert witness for over 23 years.
`
`Dr. Zech opened a test and forensics lab in October 2004. The lab is focused on test and evaluation of
`CD/DVD, Blu-ray Disc, other optical storage, flat panel displays, digital imaging/cameras, small
`computer systems, and related storage and consumer electronics products. The capabilities of the lab
`have been successfully used for patent infringement and class action litigations.
`
` 1
`
`
`
`
`
`Areas of Expertise
`
` CCD and CMOS Image Sensors
`
` Solar Energy/Photovoltaics
`
`
`
`
`
` Video Data Storage and Transmission
`
` 2
`
`
`
` CD, DVD, and Blu-ray Technologies,
`Processes and Engineering
`
` Computer Storage (magnetic optical, and
`semiconductor)
`
` Consumer Electronic Products
`
` Digital Imaging and Cameras
`
` Document Management Systems
`
` Flat Panel Displays and TVs
`
` Fiber Optic/Optical Communications
`
` Holographic Optical Elements (HOEs)
`
` Holographic Displays
`
` Holographic Memories
`
` Lasers and Laser Technology
`
` LEDs
`
` Materials Science
`
` Nanotech/MEMS
`
` Optical Data Storage (specializing in
`read/write channel, storage media,
`read/write heads, and applications)
`
` Opto-Electronic/Electro-Optical Systems
`
` Photonic Components & Technology
`
` Rewritable Optical Drives and Media
`Technologies
`
`
`
`Education
`
`
`
`
`
`Year College or University
`
`1974
`
`University of Michigan
`
`1966
`
`University of Michigan
`
`Degree
`
`Ph.D. (EE; computer science and photonics
`minors)
`M.S.E.E.
`
`1965
`
`Lawrence Institute of Technology
`
`B.S.E.E.
`
` Post graduate studies in computer science, optical communications, electronics, optical systems
`design, and infrared technology and systems.
` Career advancement and MBA courses (off campus) in general management (Harvard University),
`international marketing (Columbia University), advanced financial analysis, managing interpersonal
`relationships, and product development.
`
`Professional Experience
`
`
`
`From:
`
`To:
`
`1992
`
`Present
`
`Organization:
`
`The ADVanced ENTerprises (ADVENT) Group
`
`Title:
`
`President, Managing Principal
`
`Summary:
`
`The ADVENT Group provides forensic consumer electronics test & evaluation, market
`research, product development, R&D/engineering, and technology assessment services
`in the areas of optical/computer storage, holography, flat panel displays, digital
`cameras, nanotechnology/MEMS, and photonics. Main areas of expertise include
`photonics-enabled
`information
`storage/processing/display, new and evolving
`technologies, and consumer electronics technologies. Examples include:
` CD, DVD, and Blu-ray and other rewritable optical drive and media technologies
`and optical storage-enabled applications.
` Consumer electronics products such as flat panel displays, digital cameras and
`imaging, and small computer systems and components.
`
` 3
`
`
`
`
`
` New and evolving technologies such as LEDs, solar energy, and nanotechnology.
`Clients range from new ventures to Fortune 500 giants. Extensive contacts with major
`Asian companies provide early access to new technologies and leading edge
`components.
`
`Expert witness/technology consultant to law firms; primarily, patent infringement and
`validity, class action, and breach of contract litigation (1990 to present).
`
`Served as CIO/MIS Director for a financial services company from 19995-2000.
`
`
`
`
`
`From:
`
`To:
`
`1988
`
`1991
`
`Organization:
`
`Independent Consultant, Temporary Executive
`
`Summary:
`
`
`
`Vice President Engineering, Optimem, Inc.
`President & COO, New Interfile Corporation
`Vice President Strategic Planning, Optimem, Inc.
`Vice President Marketing & Sales, LaserDrive, Ltd.
`Vice President Marketing & Sales, Optimem, Inc.
`
`1987
`
`1988
`
`1991
`1990
`1989
`1989
`1988
`
`
`
`From:
`
`To:
`
`Organization: Rothchild Consultants, Inc.
`
`Title:
`
`Senior Industry Analyst
`
`Summary:
`
` Responsible for new business development and functioned as chief technology
`expert for optical and magnetic storage and computer information systems.
` Provided new product development, technology transfer, market research,
`forecasting, and manufacturing strategy support to both domestic and international
`clients.
`
` 4
`
`
`
`
`
` Met 1-year contract goals of tripling sales and profits and diversifying product line.
`
`
`
`
`
`From:
`
`To:
`
`1985
`
`1986
`
`Organization: Rugged Optical Storage Systems
`
`Title:
`
`President
`
`Summary:
`
`Responsible for the general management and principal founder of a new venture to
`develop and manufacture high-performance, high-reliability 2" and 3.5" form factor,
`fixed-erasable optical disk drives for military, factory floor/industrial, and portable
`computer markets. Advanced engineering and design features included a two-laser
`optical head, a sub-20 ms track accessing mechanism, and an optical media hypervisor
`subsystem (MEAD: Media Error Analysis and Detection). An innovative subsystem
`architecture featured the optical drive and its controller mounted on the same PC board
`and packaged in a removable, secure metal enclosure (an industry first).
`
`1984
`
`1985
`
`
`
`From:
`
`To:
`
`Organization:
`
`Information Storage, Inc. (ISi)
`
`Title
`
`Vice President, Marketing & Sales
`
`Summary:
`
` Responsible for all elements of marketing and sales for the world's first 5.25"
`optical disk drive startup.
` Developed prospect base and made sales presentations to all major computer and
`office automation OEMs, system integrators, computer chains, and distributors in
`the US and Europe.
` Created a complete product line of systems and services, including ISiDOS (the
`world's first integrated optical I/O driver and file manager).
` Positioned ISi as the number one OEM manufacturer of optical storage products
`for small computer systems through a multi-media PR campaign based on direct
`mailings, telemarketing, trade shows, magazine articles, advertising, and symposia.
` Recruited and trained an international sales force. Sold over 200 evaluation
`systems at $5,000 each to major prospects to finance the transition to
`
`
`
` 5
`
`
`
`
`
`manufacturing, and developed an OEM book of business with an estimated 18-
`month revenue potential of over $20M.
` Reported to the President and CEO; member of the Executive Committee.
`
`
`
`
`
`From:
`
`To:
`
`1979
`
`1984
`
`Organization: McGraw-Hill, Inc. (Information Systems Company)
`
`Title:
`
`Vice President for Technology, Business Systems, and Manufacturing
`
`Summary:
`
`
`
`From:
`
`To:
`
` Responsible for new
`technology (including electronic editing, CD-ROM
`publishing, and advanced networking for on-line services), computer systems and
`applications software development, manufacturing operations, technology transfer,
`strategic planning, and electronically-delivered product development for a $350-
`million business unit of McGraw-Hill, Inc. Primary corporate mission as functional
`chief technology officer was to design and build a 21st-century computer and
`communications architecture.
` Controlled over $80M of operating expenses through budget/expenditure review
`and approval.
` Managed a staff of 15 senior information system professionals and 20 applications
`programmers.
` Created the strategic business plan for a market focus organizational structure to
`rationalize product lines.
`Introduced office automation and microcomputer systems to all business units.
` Automated the production operations of the major divisions, resulting in
`annualized cost savings of over $8M and the ability to market competitive
`electronic information products.
` Reported to the President; member of Executive and Operations Committees; Chair
`of the Corporate Technology, Product Assurance, and Project Evaluation
`Committees.
`
`
`
`
`1978
`
`1979
`
`Organization:
`
`TRW Space and Defense Systems Group
`
`Title:
`
`Director, Business Development/Product Line Manager
`
` 6
`
`
`
`
`
` Responsible for the marketing/sales and technology/product development for the
`optical processing systems product line (C3I and ECM applications) comprised of
`acousto-optic Bragg-cell spectrum analyzers,
`time and space
`integrating
`correlators, and ultra-wideband scanner and recorder systems.
` Marketed programs to defense and intelligence agencies, including CIA, DIA,
`Hanscomb AFB, MIRADCOM, NASA, NSA, NWL, RADC, and WPAFB.
`Formulated 1-year and 5-year business plans. Initiated marketing efforts that lead
`to $3M in new business in less than one year, including a classified agency
`program for an optical drum memory system with 1 TB capacity and a 1 Gbps data
`rate.
` Managed eight senior scientists and engineers and two marketing specialist.
` Reported to the Division VP/General Manager.
`
`1969
`
`1978
`
`
`
`Summary:
`
`
`
`From:
`
`To:
`
`Organization: Harris Corporation, Government Systems Sector, Electro-Optics Division
`
`Title:
`
`Research Manager/Principal Engineer
`
` Responsible for R&D and advanced programs/product development in the areas of
`optical/electronic data recording, processing, storage, and communications using
`state-of-the-art electronic and laser systems (high-density disk storage, holographic
`memories, wideband data acquisition and processing, optical computers, and fiber
`optics).
` Held assignments in research and systems (de facto corporate R&D manager),
`program management, and marketing. Marketed R&D and systems development
`programs to DoD, NASA, and other Federal government agencies.
` Developed the technology and sold to NASA the world's largest optical mass
`storage program (for archiving LandSAT and other remote sensing data; a 1,000
`terabyte system with a potential contract value of over $150M).
` Finished all managed programs successfully on schedule and on/under budget for 9
`years.
` Managed 15 engineers, scientists, and programmers.
`
` 7
`
`
`
`1967
`
`1969
`
`Summary:
`
`
`
`From:
`
`To:
`
`
`
`
`
`Organization: McDonnell Douglas Corporation, Electronic Systems (Conductron) Division
`
`Title:
`
`Section Head/Research Manager
`
`
`
` Responsible for R&D and business acquisition in the areas of optical data storage,
`optical data processing (terminal guidance, feature extraction, synthetic aperture
`radar, and simulators), large displays, laser systems, light-sensitive media, and
`holography.
`Invented the “projected real-image” white light hologram, the universal type used
`for displays and art.
` Functioned as project engineer and business manager for the largest-ever industrial
`effort to commercialize CW and pulsed laser holography for display, information
`storage, and non-destructive testing applications.
` Developed profitable technology and manufacturing methods to achieve these
`goals, and sold nearly 1 million holograms.
` Managed 25 scientists, engineers, and manufacturing technicians.
`
`1965
`
`1967
`
`Summary:
`
`
`
`From:
`
`To:
`
`Organization: University of Michigan, Institute of Science and Technology
`
`Electro-Optical Sciences Laboratories
`
`Title:
`
`Laboratory Supervisor/Research Engineer
`
`Summary:
`
`
`
` Responsible for basic research supported by National Science Foundation (NSF)
`and Office of Naval Research (ONR) grants in the areas of holography, optical data
`processing and storage, light-sensitive materials, lasers, and grating ruling engines.
` Pioneered new recording and processing systems for optical storage and image
`correction and enhancement. Managed four engineers, three technicians, and two
`R&D laboratories.
`
` 8
`
`
`
`
`
`Litigation Support Experience
`
`
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Digital implementation of servo controls for tracking and
`focusing.
`
`Law Firm:
`
`Case Name:
`
`DLA Piper LLC
`
`Optical LLC v. Toshiba
`
`Services Provided:
`
`Consulting expert for Defendant Toshiba on digital optical disc drive servos.
`Wrote three declarations in support for IPR.
`
`Disposition:
`
`TBD
`
`August – present 2014
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Retroreflectors and optical disc drive controllers.
`
`Law Firm:
`
`Case Name:
`
`O’Melveny & Meyers
`
`Optical LLC v. Samsung
`
`Services Provided:
`
`Consulting expert for Defendant Samsung on optical components/systems based
`on a submarined patent and a recent patent on a fully digital optical disc drive
`controllers.
`
`Disposition:
`
`TBD
`
`October - December 2013
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Blu-ray Disc player hardware and firmware.
`
`Law Firm:
`
`O’Melveny & Meyers
`
` 9
`
`
`
`
`
`
`
`Case Name:
`
`Walker Digital v. Samsung, et. al.
`
`Services Provided:
`
`Consulting expert for Defendant Samsung on Blu-ray Disc player operation and
`extensions.
`
`Disposition:
`
`TBD
`
`March - June 2012
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. LCD displays.
`
`Law Firm:
`
`Case Name:
`
`O’Melveny & Meyers
`
`Samsung v. AU Optronics
`
`Services Provided:
`
`Consulting expert for Plaintiff Samsung on LCD displays, including wide angle
`viewing, TFT substrates, and manufacturing processes.
`
`Disposition:
`
`Settled
`
`June 2011 – November 2011
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Digital cameras, firmware.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Perkins Coie LLP
`
`FlashPoint Technology v. HTC, et al
`
`Lead expert witness for the Defendant HTC on validity. Wrote omnibus
`invalidity report for three patents related to digital camera image processing.
`Testified at deposition. This was a litigation before the ITC.
`
`Disposition:
`
`TBD
`
`November 2010 – April 12, 2011
`
`Date:
`
`
`
`Expert Engagement:
`
`
`
`10
`
`
`
`
`
`Type of Matter:
`
`Patent Infringement. Writing to and reading from multiple types of optical discs.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Paul, Hastings, Janofsky & Walker LLP
`
`LaserDynamics v. Quanta Computer Inc., Quanta Storage Inc.
`
`Lead expert witness for the Defendant Quanta Computer Inc., Quanta Storage
`Inc. Wrote opinion and rebuttal expert reports. Testified at deposition. Trial on
`damages in Eastern District of Texas on January 31, 2011.
`
`Disposition:
`
`Verdict for Plaintiff, but limited damages significantly.
`
`November 2010 – January 2011
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Lens designs, digital cameras, and cell phones.
`
`Law Firm:
`
`Case Name:
`
`Perkins Coie LLP
`
`Fujinon Corp. v. HTC and Largon
`
`Services Provided:
`
`Lead expert witness for the Defendants HTC and Largon.
`
`Disposition:
`
`Trial at ITC; result unknown. Some patents before the PTO for reexamination
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Litigation:
`
`August 2010 – April 2011
`
`Patent Infringement. LCD flat panel displays and TVs. Optics and materials,
`electronics design and architecture.
`
`Law Firm:
`
`Case Name:
`
`Fish & Richardson
`
`Sharp v. Samsung II
`
`Services Provided:
`
`Consulting expert witness for the Defendant Samsung. Wrote expert report
`(declaration).
`
`Disposition:
`
`Settled
`
`Date:
`
`December 2009 – February 2010
`
`
`
`11
`
`
`
`
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Phase change optical discs and CD-RW.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Paul, Hastings, Janofsky & Walker LLP
`
`Ricoh Company, Ltd. (Ricoh) v. Quanta Computer Inc., QSI, AsusTek Inc., et al
`
`Lead expert witness for the Defendant Quanta and QSI (Quanta Storage Inc.).
`On appeal, litigation on two patents was remanded to district court for trial.
`Testified on validity issues in Federal Court (Madison, WI) re: buffer underrun
`(“burn proof”) and zoned CLV. Originally wrote four invalidity reports that
`helped win summary judgments.
`
`Disposition:
`
`Verdict for the Plaintiff
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`September 2007 – November 2009
`
`Patent Infringement. LCD flat panel displays and TVs, optics and materials,
`electronics design and architecture.
`
`Law Firm:
`
`Case Name:
`
`Fish & Richardson
`
`Sharp v. Samsung
`
`Services Provided:
`
`Consulting expert witness for the Defendant Samsung.
`
`Disposition:
`
`Unknown
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`December 2007 – February 2008
`
`Patent Infringement. Multi-layer disk optical storage, DVD buffering, spherical
`aberration correction.
`
`Law Firm:
`
`Case Name:
`
`Connolly Bove Lodge & Hutz LLP
`
`U.S. Philips v. International Norcent Technology, et. al.
`
`
`
`12
`
`
`
`
`
`Services Provided:
`
`Lead expert witness for the Defendant International Norcent Technology. Wrote
`invalidity and rebuttal reports and testified at deposition and in Federal District
`Court.
`
`Disposition:
`
`Jury decision in favor of the Plaintiff
`
`Date:
`
`March – November 2007
`
`Patent Infringement. CD-R, CD-RW, DVD±R re background formatting, “burn
`proof” technology, phase change optical discs, write strategies.
`
`Paul, Hastings, Janofsky & Walker LLP
`
`Ricoh Company, Ltd. (Ricoh) v. AsusTek Computer Inc. (ASUS), et. al.
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Lead expert witness for the Defendant Quanta Computer Inc. Wrote four
`invalidity reports.
`
`Disposition:
`
`Summary judgment in favor of Defendant Quanta Computer Inc. for all four
`patents in litigation; one major patent invalidated.
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Litigation:
`
`Law Firm:
`
`Case Name:
`
`February – June 2007
`
`Patent Infringement. DVD media, DVD-9, thin films, metal alloys, phase change
`media.
`
`Cooper & Dunham LLP
`
`Target Technology v. Williams Advanced Materials, Cinram International, et al
`
`Services Provided:
`
`Consulting expert witness for the Defendant Cinram International.
`
`Disposition:
`
`Date:
`
`Settled
`
`2006
`
`
`
`13
`
`
`
`
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. DVD parental control mechanisms.
`
`Law Firm:
`
`Case Name:
`
`Monts & Ware LLP
`
`Digital Choice v. Toshiba, Yamaha, et al
`
`Services Provided:
`
`Lead expert witness for the Plaintiff Digital Choice
`
`Disposition:
`
`Settled
`
`2005 – 2007
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Class Action. DVD players.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Heller Erhman White & McAuliffe LLP
`
`Morris et al v. Sony Electronics Inc.
`
`Lead expert witness for the Defendant Sony Electronics Inc. Designated
`testifying and consulting expert witness. Forensic evaluation of claimed
`defective DVD player products, disproved the Plaintiff’s claims. Wrote expert
`report, testified at deposition.
`
`Disposition:
`
`Settled
`
`2005 – 2006
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. DVD technology.
`
`Law Firm:
`
`Case Name:
`
`Fish & Richardson
`
`U.S. Philips v. MRT Technology (Ritek)
`
`Services Provided:
`
`Consulting expert witness for the Defendant MRT Technology (Ritek) .
`
`
`
`14
`
`
`
`
`
`Disposition:
`
`Date:
`
`
`
`Settled
`
`2005
`
`Expert Engagement:
`
`Type of Matter:
`
`Class Action. DVD players.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Heller Erhman White & McAuliffe LLP
`
`Scafuri et al v. Sony Electronics Inc.
`
`Co-Lead expert witness for the Defendant Sony Electronics Inc. (SEL).
`Designated testifying and consulting expert witness. Performed research and
`analysis and testified about the design, technology and manufacture of DVD
`hardware, firmware, and DVD-Video discs. Determined and categorized the
`modes of DVD-Video product failure by hardware, media and consumer. Used
`statistical analysis of customer service/repair data to show that product failures
`after infant mortality were well below industry norms. Provided expertise on
`consumer electronics products and markets, including service and support
`strategies. Wrote detailed expert report in response to the Plaintiff’s claims and
`expert report. Testified at deposition.
`
`Disposition:
`
`Settled
`
`2003 – 2005
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement before the ITC. Laptop computers.
`
`Law Firm:
`
`Case Name:
`
`Dewey Ballantine LLC
`
`Gateway v. HP
`
`Services Provided:
`
`Lead expert witness for the Plaintiff Gateway. Subject matter included laptop
`computers, CD and DVD drives, and Windows and Linux operating systems.
`Wrote expert and rebuttal reports.
`
`Disposition:
`
`Litigation terminated
`
`Date:
`
`2004 – 2005
`
`
`
`15
`
`
`
`
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Optical mice.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Keker & Van Ness LLC
`
`PixArt Technology v. Agilent Technologies
`
`Lead expert witness for the Plaintiff PixArt Technology in the following
`technologies: Optical mouse, photodetector arrays, image processing, optical
`navigation, LEDs and lasers, and optics.
`
`Settled
`
`2004
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Class Action. DVD players.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Heller Erhman White & McAuliffe LLP
`
`Zeigler et al v. Sony Electronics Inc.
`
`Lead expert witness for the Defendant Sony Electronics Inc. Designated
`testifying and consulting expert witness. Wrote expert report that responded in
`detail to and disproved the Plaintiff’s litigation claims re DVD.
`
`Disposition:
`
`Settled
`
`2004 – 2006
`
`Date:
`
`
`
`Expert Engagement
`
`Type of Matter:
`
`Patent Infringement. Digital and analog cameras.
`
`Law Firm:
`
`Case Name:
`
`Lerner, David, Littenberg, Krumholz & Mentlik, LLP
`
`Sony v. Eastman Kodak
`
`Services Provided:
`
`Consulting expert witness for the Plaintiff Sony. Subject matter included digital
`
`
`
`16
`
`
`
`
`
`and film cameras and processing methods and equipment.
`
`Disposition:
`
`Settled
`
`2004 – 2006
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. DVD manufacturing.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Weil Gotshal & Manges LLP
`
`Matsushita Electric Industrial (MEI) v. Cinram International
`
`Lead expert witness for the Plaintiff MEI (now Panasonic). Designated testifying
`and consulting expert witness. Performed research and analysis and testified
`about bonding and substrate molding processes, materials, equipment and
`manufacturers. Provided expertise on the technology and processes used to
`design and manufacture DVD discs. Rebutted the Defendant’s claims that the
`patents in litigation lacked validity. Wrote both infringement and validity expert
`reports. Testified at deposition twice in defense of these reports.
`
`Disposition:
`
`Settled
`
`Date:
`
`2003 – 2004
`
`Expert Engagement:
`
`Type of Matter:
`
`Copyright Infringement.
`
`Law Firm:
`
`Case Name:
`
`Hogan & Hartson LLP
`
`ESS Technology Inc. v. MediaTek Inc.
`
`Services Provided:
`
`Consulting expert witness for the Defendant MediaTek Inc.. Subject matter
`included DVD drives and firmware. Submitted initial expert report.
`
`
`
`17
`
`Settled
`
`2003
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`
`
`
`
`Type of Matter:
`
`Patent Infringement. Xbox related technologies.
`
`Law Firm:
`
`Case Name:
`
`Klaquist Sparkman LLP
`
`Media Optik v. Microsoft
`
`Services Provided:
`
`Consulting expert witness for the Defendant Microsoft in the following
`technologies; Xbox games, DVD-ROM; optical card systems; virtual memory
`architectures and bus structures, displays, and image processing.
`
`Settled
`
`2003
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. DVD hardware and firmware.
`
`Law Firm:
`
`Case Name:
`
`Fulbright & Jaworski
`
`LaserDynamics v. Acer, et al
`
`Services Provided:
`
`Consulting expert witness for the Defendant Acer in the following technologies:
`DVD-Video and DVD-Recordable, file structures, data access methods, DVD
`applications software, and displays.
`
`Disposition:
`
`Date:
`
`Settled
`
`2002
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. CD-R optical discs.
`
`Law Firm:
`
`Case Name:
`
`Sullivan & Cromwell
`
`Philips, et al v. Princo, et al
`
`Services Provided:
`
`Consulting expert witness for the Plaintiff Philips
`
`Disposition:
`
`Date:
`
`
`
`Settled
`
`2002
`
`
`
`18
`
`
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Non-imaging optics.
`
`Law Firm:
`
`Case Name:
`
`Workman, Nydegger & Seeley
`
`3COM v. Xircom
`
`Services Provided:
`
`Consulting expert witness for the Plaintiff 3COM on the following technologies:
`LEDs, fiber optic light pipes, and optical path analysis for laptop modems.
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Settled
`
`2001
`
`architecture, design
`included
`Infringement. Technology
`Patent
`implementation of EIDE controller with ATAPI extensions for CD-ROM
`
`and
`
`Law Firm:
`
`Case Name:
`
`Wilson, Sonsini, Goodrich & Rosati
`
`Oak Technologies v. UMC, et. al.
`
`Services Provided:
`
`Supporting expert witness for the Defendant UMC. Designated testifying and
`consulting expert witness about the product and market evolution of CD-ROM
`products, from their invention in 1978 until introduction of universal interface
`standards in 1995. Performed research and analysis, wrote an expert report, and
`testified about products, technology, markets, manufacturing, business practices,
`standards and trends. Testified at deposition and before the ITC.
`
`Disposition:
`
`Dr. Zech’s market and trends analyses were cited by the judge (Hon. Sidney
`Harris) in his decision in favor of the client.
`
`Date:
`
`
`
`1999
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Complex storage architectures.
`
`Law Firm:
`
`Chrisman Bynum Johnson
`
`
`
`19
`
`
`
`
`
`Case Name:
`
`Stuff Technology v. Storage Technology Corp.
`
`Services Provided:
`
`Lead expert witness for the Defendant Storage Technology Corp. Wrote detailed
`expert report refuting Plaintiff’s claims.
`
`Disposition:
`
`Summary judgment in favor of Defendant
`
`Date:
`
`
`
`1999
`
`Expert Engagement:
`
`Type of Matter:
`
`Theft of Trade Secrets
`
`Law Firm:
`
`Case Name:
`
`Oppenheimer Wolff & Donnelly
`
`Maxoptix v. TeraStor
`
`Services Provided:
`
`Lead expert witness for the Plaintiff Maxoptix. Subject matter included near
`field optical drives and media.
`
`Settled
`
`1999
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Advanced system for cinematic sound reproduction.
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Farella Braun & Martel
`
`Drexler Technology v. Dolby Laboratories.
`
`Lead expert witness for the Defendant Dolby Laboratories on the following
`technologies: CCD photodetector arrays, correlation detection, image processing
`and display, and optical storage for sound reproduction from photographic film.
`
`
`
`20
`
`Disposition:
`
`Settled
`
`1998 – 1999
`
`Date:
`
`
`
`Expert Engagement:
`
`
`
`
`
`Type of Matter:
`
`Patent Infringement. Optical disc mastering.
`
`Law Firm:
`
`Case Name:
`
`Brobeck Phleger & Harrison
`
`ODC v. Delmar Electronics
`
`Services Provided:
`
`Lead expert witness for the Defendant Delmar Electronics. Subject matter
`included CD-R optical discs and optimum write strategies.
`
`Settled
`
`1998
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Large optical disc system integration.
`
`Law Firm:
`
`Case Name:
`
`Gray Cary Ware & Freidenrich
`
`ASI v. DataWare
`
`Services Provided:
`
`Consulting expert witness for the Defendant DataWare . Subject matter included
`WORM 12- and 14-inch optical disc drives and media and applications.
`
`Settled
`
`1998
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Breach of Contract. Design and performance of a thermal transfer device.
`
`Law Firm:
`
`Case Name:
`
`Sidley & Austin
`
`BE Aerospace v. NCR
`
`Services Provided:
`
`Consulting expert witness for the Defendant NCR; submitted expert report.
`Subject matter included thermal analysis and characterization methods and
`processes.
`
`Disposition:
`
`Date:
`
`Settled
`
`1998
`
`
`
`21
`
`
`
`
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Breach of Contract. Allegations of the failure of PLMS to deliver in quantity and
`on time 2x-speed CD-ROM drives for Atari’s Jaguar game product
`
`Law Offices of Adron Beene
`
`JTS/Atari v. Philips Laser Magnetic Storage (PLMS)
`
`Lead expert witness for the Plaintiff JTS/Atari . Designated testifying and
`consulting expert witness. Performed research and analysis and testified about
`technology, product development, project management, components and
`manufacturing. Deconstructed production model of litigated 2x-speed CD-ROM
`reader. Determined mechanical, optical, and electronic (including R/W channel,
`ECC, and interface) design aspects. Showed in expert report that (i) Atari’s
`electronics design was stable and manufacturable, and that all components were
`available and usable and (ii) PLMS had the capability to perform. Testified at
`deposition
`
`Disposition:
`
`Date:
`
`Settled
`
`1997
`
`
`
`Expert Engagement:
`
`Type of Matter:
`
`Patent Infringement. Optical disc mastering.
`
`Law Firm:
`
`Case Name:
`
`Morgan, Lewis & Bockius
`
`DiscoVision Associates v. DMI
`
`Services Provided:
`
`Consulting expert for the Plaintiff DiscoVision Associates. Subject matter
`included CD-R discs and master disc formatting.
`
`
`
`22
`
`Settled
`
`1997
`
`Disposition:
`
`Date:
`
`
`
`Expert Engagement:
`
`
`
`
`
`Type of Matter:
`
`Law Firm:
`
`Case Name:
`
`Services Provided:
`
`Breach of Contract regarding the development, manufacturing and marketing of
`a 4 GB 14” WORM disk optical storage product line, comprising drives, disks,
`and libraries for IBM mainframe computers.
`
`Rothgerber, Appel, Johnson, & Powers
`
`Storage Tech Partners II v. Storage Technology Corp. (STC)
`
`Lead expert witness for the Defendant Storage Technology Corp. (STC) .
`Designated testifying and consulting expert witness. Performed research and
`analysis and
`testified about
`technology, product development, project
`management, manufacturing, computer storage, markets and applications, and
`market potential. Interviewed key managers. Analyzed sales forecasts. Testified
`at deposition
`
`Disposition:
`
`Date:
`
`
`
`Settled
`
`1990
`
`
`
`23
`
`
`
`Non‐Litigation Patent Consulting Projects
`
`
`
`
`
`Consulting Engagement:
`
`Client:
`
`Luminoz, LLC
`
`Services Provided:
`
`Patent application support. Wrote a report responding to patent examiner’s
`objections, refined claims, re-wrote abstract.
`
`Date:
`
`
`
`2006
`
`Consulting Engagement:
`
`Client:
`
`AC Troner LP (Melbourne, FL)
`
`Services Provided:
`
`Consulting expert regarding technology and potential economic value of IP.
`Wrote detailed report outlining areas of potential infringement and licensing
`opportunities.
`
`Date:
`
`
`
`2002 – Present
`
`Consulting Engagement:
`
`Client:
`
`Knobbe, Martens, Olson & Bear
`
`Services Provided:
`
`Consulting expert regarding technology/economic value of IP. Wrote detailed
`report with recommendations for product development/infringement research.
`
`Date:
`
`
`
`1998
`
`
`
`24
`
`
`
`Professional Affiliations, Achievements & Awards
`
`
`
`
`
` Founder's Scholar, Lawrence Institute of Technology (1960-1965)
` NASA Science and Technology Award for the invention of the DIGIMEM Terabyte Optical Memory
`System (1982)
` Member, Committee on Preservation for the U.S. National Archives (1981-85)
` Member, Consultants Network of Silicon Valley (CNSV)
` Fellow, Society for Imaging Science and Technology (1983; formerly SPSE)
` Member, DVD Association
` Life Member, IEEE (Institute of Electrical and Elec
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