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`David L. Lyon
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` Rancho Santa Fe, CA 92067-3450
` Email: dll@prodigy.net
` Mobile: +1.619.246.5966
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`1996 - Present CEO, Sage Strategies®
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`Founded and have continuously operated this technology consulting firm from its inception.
`Assignments have included targeted technical projects, interim executive management and long term
`Board roles at growth oriented companies, as well as testifying expert witness assignments and
`technology consulting in intellectual property litigations.
`
`A partial list of current and past non-litigation clients follows: Cohere Technologies, Libit Signal
`Processing (pioneers in DOCSIS), Ozmo Devices (pioneers in Wi-Fi Direct), Orca Systems,
`Quantance , RFAxis, RFMD (now Qorvo), Sansay (pioneers in specialized security gateways for
`VoIP), and Sidense (best of class OTP IP). A listing of recent consulting relationships can be found
`further below.
`
`Patent litigation firms that have retained me as testifying witness or technical consultant on behalf of
`their clients include Alston & Bird, Baker & McKenzie, Kramer Levin Naftalis & Frankel,
`McDonnell Boehnen Hulbert & Berghoff, Quinn Emanuel, and Steptoe & Johnson. A list of cases
`can be found further below.
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`The firm’s websites can be found at www.sagestrategies.net and at www.sagepatents.net.
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`2004 – 2008
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`VP/GM , RF MicroDevices, Inc.
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`Negotiated the acquisition of Silicon Wave by RF MicroDevices in May of 2004. Silicon Wave (see
`below) then became the Wireless Personal Area Networking (WPAN) product line within RFMD’s
`Wireless Connectivity Business Unit (WCBU). In December of 2006 I helped to negotiate the sale of
`RFMD’s WPAN assets to Qualcomm which consequently brought them the Bluetooth technology
`which they have subsequently integrated into their broader IC product lines.
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`1
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`Samsung Exhibit 1010, Page 1
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`Served as general manager of RFMD’s WCBU from 2005 through 2007. The unit was comprised of
`three growth stage product lines: WPAN, GPS IC solutions, and radio front end components for
`WLAN & WiMax. Average annual revenue of the unit climbed to approximately $50M and the
`revenue growth rate was over 50% per year. Subsequently served as VP of corporate business
`development.
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`1997 – 2004
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` CEO, Silicon Wave Inc.
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`Having served Silicon Wave as a technical and management consultant during its formative stages, I
`became Chairman of the Board in October of 1997 upon initiation of operations. A year later the
`Board recruited me to become the company’s CEO. Subsequently staffed all of the senior operating
`management positions, led all subsequent funding rounds, and helped to establish key relationships
`with customers and foundry partners. The company was an established technology leader in the field
`of wireless personal area networking, in particular the Bluetooth standard.
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`1987-1996
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`CEO, PCSI
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`Co-founded PCSI (Pacific Communication Sciences Inc), was employee #1, and the chief executive
`from inception through merger/acquisition with Cirrus Logic (Nasdaq:CRUS) in 1993 and for three
`years thereafter while it operated as a wholly owned subsidiary. Served on the Cirrus Logic Board of
`Directors from 1993 through 1996.
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`PCSI was known for its technology leadership in digital telecommunications systems and was a
`leading provider of packetized voice multiplexer systems, radio frequency and digital chipsets for
`Japanese Personal Handyphone Systems. PCSI helped to pioneer the first packet data designs and
`standards for mobile cellular systems (CDPD) and also developed some of the first mobile data base
`stations (MDBS) and “smartphones” to use those digital packet data networks. In early 1993 when
`PCSI was acquired by Cirrus Logic annual revenue was ~$25Million and headcount was ~150
`people. Revenue in FY96 had grown to ~$140Million, headcount was ~500 and the subsidiary was
`operating profitably.
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`1982-1987
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`VP/GM, Linkabit Div of M/A-Com Inc.
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`Having been recruited by Dr. Andy Viterbi, I initially served as assistant vice president of
`engineering responsible for the commercial engineering staff of Linkabit (a group numbering about
`400). At the same time managed the initial product development of the industry’s first successful
`Ku-Band very small aperture satellite communication system (VSAT), which was delivered to
`Schlumberger Oil Field Services. Later combined the Schlumberger production work into a broader
`product group spread across all of M/A-Com and led the creation of the Personal Earth Station (PES)
`product line. Subsequently in late 1987 the PES business unit was sold by M/A-Com to Hughes and
`was an integral part of Hughes Network Systems.
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`2
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`Samsung Exhibit 1010, Page 2
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`1981-1982
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`Director of Engineering, Novation Inc.
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`Managed all product engineering and R&D activities for this southern California company which had
`pioneered telephone line modems for personal computers. Helped to capture design wins and
`production orders from both Apple Computer and IBM’s PC Division for internally integrated
`modems.
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`1972-1981
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`Director of Research & Product Management, Intertel Inc.
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`Joined the company upon completing my education at MIT, and then led the research and
`development of state-of-the-art telephone line modems and network control systems. My team
`perfected the design of a series of equalized modems which were integrated into a comprehensive
`automated control system that was geared to meet the needs of enterprises such as banks, airlines, and
`package delivery companies. Invented a number of novel techniques in both modem and network
`control designs that were awarded five US patents. The company was later acquired by Teleglobe, the
`international record carrier of Canada.
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`1967-1969
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`Technical Staff, AT&T Bell Laboratories
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`Three work assignments as part of the VI-2-A cooperative study program of MIT’s EE department
`brought me to the Indian Hill, Holmdel, and Murray Hill sites of Bell Labs. The project at Indian Hill
`was focused on software synthesis of automated test programs for telephone switching systems. The
`project at Holmdel was related to long haul data communications systems over copper lines. At
`Murray Hill I worked on problems related to laser pulse sources for future optical fiber
`communication networks.
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`3
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`Samsung Exhibit 1010, Page 3
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`Education
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`Massachusetts Institute of Technology
`PhD(’72), MS(’70), BS(’70); all in Electrical Engineering
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`Doctoral thesis entitled ‘Collisional Relaxation Mechanisms Governing Operation of High Pressure
`CO2 Lasers’; September, 1972. Primary thesis advisor: Professor Hermann Haus. Software
`simulations of these laser systems confirming theoretical modeling of the mechanisms governing
`their optical output and achievable efficiency.
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`Master of Science thesis entitled ‘Transitions Between Mode-Locked States in Phase-Modulated
`Lasers’; written while on cooperative study assignment at AT&T Bell Labs and submitted October,
`1969. Thesis advisors: Dr. Tracy Kinsel (Bell Labs) and Professor Hermann Haus (MIT).
`Characterization and mathematical modeling of a problematic phenomenon in mode-locked laser
`light sources.
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`Hertz Foundation Fellowship (1969-1972), Scott Fellowship (1968-1970).
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`Teaching Experience
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`2002
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`2001
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`1997
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`Lecture on The Lessons Learned in Startup Companies delivered at the Wharton
`School’s west coast MBA program in San Francisco
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`Lecture on Telecom Ventures across the Pacific at University of California (Berkeley)
`Haas Business School as part of special MBA course on Asian IT and Entrepreneurship.
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`Lecture on Wireless Communication Chip Development and International Collaboration
`as part of Stanford University School of Engineering’s series in Topics in International
`Technology Management
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`1995-97 Lecturer on wireless technologies for the MIT Sloan School Executive short course for
`CNOs: Managing the IT Infrastructure for Global Competitiveness
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`1994
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`1983
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`Video taped lecture on What Digital Engineers Need To Know About Wireless
`Communications; produced and distributed by University Video Communications as
`part of their Lecture Series VII.
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`Co-wrote and co-taught extension course Digital Communications and Satellite Systems
`(X498.2) with Dr. Paul Moroney in the University of California (San Diego) Electrical
`Engineering & Computer Science Department
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`1974-5
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`Taught graduate level course Principles of Communication (6.451) in the MIT Electrical
`Engineering & Computer Science Department. Wrote original class notes describing
`application of theory to the practical design of high speed data communication devices
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`1970-72 Teaching assistant and lecturer in MIT EE department’s Applied Optics Lab.
`Recognized with EE department outstanding teaching award in 1972
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`Samsung Exhibit 1010, Page 4
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`Litigation Experience
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`June 2010 to February 2011
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`Consultant to Sony Electronics
`Retained by Quinn Emanuel Urquhart & Sullivan, LLP
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`Case: Bandspeed, Inc. vs Sony Electronics Inc. et al
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`Western District of Texas; Civil Action No. A09CA593 LY
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`July to September 2010
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`Consultant to 724 Solutions, Inc.
`Retained by Quinn Emanuel Urquhart & Sullivan, LLP
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`Case: Openwave Systems, Inc. vs 724 Solutions, Inc.
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`Northern District of California; Case No. 09-CV-03511 (RS, HRL)
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`January 2011 to October 2012
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`Consultant to EON Corporation IP Holdings, LLC
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`Retained by Reed & Scardino LLP
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`Case: EON vs T-Mobile USA, Inc. et al
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`Eastern District of Texas; Case No 6:10-cv-00379-LED
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`Filed expert reports and gave deposition testimony
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`March 2011 to March 2012
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`Consultant to Ceres Communications Technologies, LLC
`Retained by Russ August & Kabat, PLC
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`Ceres v Atlantic Broadband et al; Case No. 1:10-cv-01062-UNA
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`Ceres v 8X8, Inc et al; Case No. 1:10-cv-00855-JCJ
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`September 2011 to December 2011
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`Consultant to Tramontane IP, LLC
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`Retained by Russ August & Kabat, PLC
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`Case in the Eastern District of Virginia, Alexandria Division
` Tramontane v Garmin et al; Case No: 1:11-cv-00918-LMB-TCB
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`October 2011 to January 2012
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`Consultant to RFMD Inc.
`Retained by Womble Carlyle Sandridge & Rice, PLLC
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`Case in the Eastern District of Texas
`Inductive Design, Inc. v Broadcom et al; Case No. 1:11-cv-00421
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`July 2012 to August 2012
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`Consultant to MediaTek, Inc. and Ralink Technology Corp.
`Retained by Quinn Emanuel Urquhart & Sullivan, LLP
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`Case before the US International Trade Commission
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`LSI Corp & Agere Systems Inc v Funai et al; Inv. No. 337-TA-837
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`5
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`Samsung Exhibit 1010, Page 5
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`October 2012 to January 2014
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`Consultant to British Telecommunications
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`Retained by McDonnell Boehnen Hulbert & Berghoff LLP
`Cases in the District of Delaware
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`BT v CoxCom et al (#10-658-SLR), Comcast et al v BT (#11-843-SLR)
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`Filed expert reports and gave deposition testimony
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`February 2013 to present
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`Consultant to Prism Technologies LLC
`Retained by Kramer Levin Naftalis & Frankel LLP
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`Cases in the District of Nebraska
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`Prism v AT&T, Prism v Sprint, Prism v T-Mobile, Prism v USCellular, Prism v Verizon
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`Civil Action Nos. 8:12-cv-122 to 8:12-cv-126
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`Filed expert reports, gave deposition testimony,
` and have testified at three trials (Prism v AT&T, Prism v Sprint, Prism v T-Mobile)
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`April 2013 to May 2015
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`Consultant to EON Corporation IP Holdings, LLC
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`Retained by Reed & Scardino LLP
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`Case: EON vs Aruba Networks, et al
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`Northern District of California; Case No 12-cv-01011-JST
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`Filed expert reports and gave deposition testimony
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`December 2013 to January 2014
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`Consultant to British Telecommunications
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`Retained by McDonnell Boehnen Hulbert & Berghoff LLP
`Case in the Northern District of Texas
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`Comcast Cable Communications, LLC et al. v. BT Americas, Inc., Civil Action No. 12-1712
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`Filed expert report
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`May 2014 to July 2015
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`Consultant to Mediatek
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`Retained by Quinn Emanuel
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`Case: CSIRO v Mediatek et al
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`Eastern District of Texas; Case 6:12-cv-00578-LED
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`Filed expert report and gave deposition testimony
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`June 2014 to present
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`Consultant to VTech Communications, Inc. and Uniden Corporation
`Retained by Steptoe & Johnson and Baker & McKenzie
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`Cases: Spherix v VTech and Spherix v Uniden
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`Northern District of Texas; Cases 13-cv-3494 (VTech) and 13-cv-3496 (Uniden)
` PTAB Inter partes review, Case IPR2014-01431
` Filed declarations and gave deposition testimony
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`November 2014 to July 2015
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`Consultant to Finjan, Inc.
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`Retained by Kramer Levin Naftalis & Frankel
`Case: Finjan v Blue Coat Systems
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`Northern District of California; Case 13-cv-03999-BLF
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`Filed expert report, gave deposition testimony, and testified at trial
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`Samsung Exhibit 1010, Page 6
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`August 2015 to present
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`Consultant to ASUSTEK
`Retained by Alston & Bird LLP
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`Case: Avago v ASUSTEK
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`Originally in Eastern District of Texas; Case 2:15-cv-00239-JRG
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`Since December 2015 in Northern District of California; Case 3:15-CV-04525-EMC
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`Also PTAB Inter Partes Review, Case IRP2016-00647
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`Have filed expert reports, given deposition testimony and filed declarations
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`September 2015 to May 2016
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`Consultant to Finjan, Inc.
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`Retained by Kramer Levin Naftalis & Frankel
`Case: Finjan v ProofPoint
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`Northern District of California; Case 3:13-CV-05808-HSG
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`Filed expert report and gave deposition testimony
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`November 2015 to September 2016
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`Consultant to Finjan, Inc.
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`Retained by Kramer Levin Naftalis & Frankel
`Case: Finjan v Sophos
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`Northern District of California; Case 14-CV-01197-WHO
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`Filed expert report, gave deposition testimony, and testified at trial
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`August 2016 to present
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`Consultant to Nokia
`Retained by Alston & Bird LLP
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`Case: Huawei v Nokia
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`Eastern District of Texas; Cases 2:16-CV-0055-JRG-RSP and
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`2:16-CV-0057-JRG-RSP
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`Also PTAB Inter Partes Reviews: Cases IPR2017-00590, 00591, 00660, 00661
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`Submitted declarations in support of IPR petitions
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`September 2016 to present
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`Consultant to Finjan, Inc.
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`Retained by Kramer Levin Naftalis & Frankel
`Case: Finjan v Blue Coat Systems
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`Northern District of California; Case 5:15-cv-03295-BLF-SVK
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`Samsung Exhibit 1010, Page 7
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`Other Recent Consulting Relationships
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`July 2003 to October 2012
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`Advisor and consultant to Amimon, Inc.
`Pioneers in WLAN technology for HD Video using OFMD and MIMO techniques
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`www.amimon.com
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`April 2008 to present
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`Member of Board of Directors, Sidense Corporation
`Designers of best of class One Time Programmable (OTP) memory
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`www.sidense.com
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`October 2008 to March 2010
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`Acting CEO & consultant to Ozmo, Inc.
` Pioneers in Wi-Fi Direct technology.
`http://ir.atmel.com/releasedetail.cfm?ReleaseID=727959
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`November 2008 to October 2009
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`Executive Chairman & consultant to Sand 9, Inc.
`MEMS technology for high accuracy timing sources
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`www.sand9.com
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`November 2009 to May 2010
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`Consultant to Quantance, Inc.
`High efficiency power supplies for RF amplifiers
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`www.quantance.com
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`May 2010 to May 2016
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`Advisor and consultant to RFaxis, Inc.
`Single chip CMOS RF front ends for Wi-Fi and cellular
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`www.rfaxis.com
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`June 2010 to September 2011
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`Advisor and consultant to Fusion Wireless, Inc.
`Communications modules for Internet of Things (IoT) applications
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`http://www.u-blox.com/en/fusion-wireless-joins-the-u-blox-family.html
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`November 2010 to September 2015
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`Advisor and consultant to Sansay, Inc.
`Pioneers of Session Border Controller technology for Voice over Internet Protocol (VoIP)
` networks. SBCs are specialized security gateways.
`www.sansay.com
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`Samsung Exhibit 1010, Page 8
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`January 2014 to present
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`Advisor and consultant to Cohere Technologies, Inc.
`Pioneers of advanced WAN RF data communication technology
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`www.cohere-technologies.com
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`September 2014 to present
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`Advisor and consultant to Orca Systems, Inc.
`High efficiency single chip solutions for Bluetooth and Wi-Fi
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`www.orcasystems.com
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`August 2016 to present
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`Advisor and consultant to China Entropy Ltd. Co.
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`Telecommunications infrastructure integrator and supplier
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`http://chinaentropy.com/EN_home.html
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`Samsung Exhibit 1010, Page 9
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`Issued Patents (USA)
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`3,955,141
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`D. L. Lyon, J. L. Holsinger, D. E. Williams; Synchronizing Circuit for Modems in a
` Data Communications Network; 4 May 1976
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`4,037,049
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`D. L. Lyon; Modulator and Demodulator for Data Communications Network;
`19 July 1977
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`4,055,808
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`J. L. Holsinger, D. L. Lyon, D. E. Williams, F. B. Lezotte, D. I. Falkenstein;
`Data Communications Network Testing System; 25 October 1977
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`4,545,011
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`D. L. Lyon, R. E. Huettner, J. L. Holsinger, D. I. Falkenstein, I. Piracha, D. T. Ching;
` Enhanced Communications Network Testing and Control System; 1 October 1985
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`4,545,013
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`D. L. Lyon, R. E. Huettner, J. L. Holsinger, D. I. Falkenstein, I. Piracha, D. T. Ching;
` Enhanced Communications Network Testing and Control System; 1 October 1985
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`5,838,727
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`D. L. Lyon, C. Poonpol, M. A. Montgomery, J. E. Neeley;
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`Method and Apparatus for Transmitting and Receiving Digital Data over a Bandpass
` Channel; 17 November 1998
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`6,175,599
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`D. L. Lyon, C. Poonpol, M. A. Montgomery, J. E. Neeley;
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`Method and Apparatus for Transmitting and Receiving Digital Data over a Bandpass
` Channel; 17 November 1998
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`Samsung Exhibit 1010, Page 10
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`Publications and Presentations (sole author unless noted)
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`‘Transitions between mode-locked states in intracavity phase-modulated lasers’; D. L. Lyon
`and T. Kinsel; Applied Physics Letters; February, 1970
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`‘Observation of spontaneous mode-locking in a high-pressure CO2 laser’; D. L. Lyon, E. V.
`George, and H. Haus; Applied Physics Letters; December, 1970
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`‘Digital simulation of transversely excited high-pressure CO2 laser operation’; Third
`Conference on Chemical and Molecular Lasers; May, 1972
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`‘Comparison of theory and experiment for a transversely excited high-pressure CO2 laser’;
`IEEE Journal of Quantum Electronics; January, 1973
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`‘Unified analysis of synchronous digital-modulation schemes’; D. L. Lyon and J. L.
`Holsinger; IEEE International Conference on Communications; June, 1973
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`‘Sampler timing recovery in equalized data communication systems’; IEEE International
`Conference on Communications; June, 1974
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`‘Practical signal space coding for the telephone channel’; National Electronics Conference;
`September, 1974 (served as organizer and moderator of session)
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` ‘Timing recovery in synchronous, equalized data communications’; IEEE Transactions on
`Communications; February, 1975
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`‘How to evaluate a high speed modem’; Telecommunications Magazine; October, 1975
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`‘Envelope derived timing recovery in QAM and SQAM systems’; IEEE Transactions on
`Communications; November, 1975
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` ‘Bell’s claims for DDS unsubstantiated’; Computerworld; November, 1975
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`‘Elimination of DC offset by MMSE adaptive equalizers’; IEEE Transactions on
`Communications; November, 1976
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`‘Diagnostics and the distributed intelligence network’; Communications International;
`December, 1976
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`‘Coping with the downtime dilemma in on-line networks’; IEEE Networks and
`Telecommunications Conference; December, 1976
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`‘Testing modem performance in polled operations’; Data Communications Magazine’ April,
`1977
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`Samsung Exhibit 1010, Page 11
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`‘Advanced techniques in real-time data networks’; IEEE Networks and Telecommunications
`Conference; December, 1977 (served as organizer and moderator of session)
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`‘The role of network control in data communications systems’; Communications Networks
`Conference; January, 1979
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`‘Telephone lines speak out for compatible modems’; Electronic Design; April, 1980
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`‘How network control curbs downtime’; Data Communications Magazine; July, 1980
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`‘Network control: a view from the DEC’; International Conference on Computer
`Communications’; October, 1980
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`‘Combining data base management and network control’; Communications Networks
`Conference; January, 1981
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`‘Network management systems’; Interface Conference; March, 1981
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`‘Second order equalizer training methods’; J. Liu and D. L. Lyon; IEEE Communications
`Conference; June, 1981
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`‘Data base management streamlines network management’; Data Communications
`Magazine; July, 1981
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`‘Personal computer standards for dial network communications’; IEEE Conference on
`Consumer Electronics; June, 1982
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`‘Networking over the space channel’; Infocomm Conference; April, 1983
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`‘The technology of small aperture satellite systems’; IEEE Information Theory Workshop;
`June, 1984
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`‘VSAT technology readiness’; VSATCOM Conference; April, 1985
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`‘Personal computer communications via Ku-band small earth stations’; IEEE Journal on
`Selected Areas in Communications; May, 1985
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`‘Ku-Band earth stations for data communications’; Ninth Data Communications
`Symposium; September, 1985
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`‘Interference issues affecting Ku-band small-aperture satellite systems’; F. Mohamadi and
`D.L.Lyon; AIAA 11th Communication Satellite Systems Conference; March, 1986
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`‘VSAT technology at M/A-Com Linkabit’; VSATCOM Conference; April, 1986
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`‘Design features of a VSAT network’; EASCON Conference; September, 1986
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`‘Effects of solar transit in Ku-band VSAT systems’; F. Mohamadi and D.L.Lyon; IEEE
`Global Telecommunications Conference; December, 1986
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`Samsung Exhibit 1010, Page 12
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`‘Effects of solar transit in Ku-band VSAT systems’; F. Mohamadi and D.L.Lyon; IEEE
`Transactions on Communications; July, 1988
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`‘Case Study: Pacific Communication Sciences, Inc.”; MIT Enterprise Forum (San Diego);
`13 June 1990
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`‘Technical Advances and Challenges in Wireless Communications’; M. Lubin and D. Lyon;
`Telecommunications; December, 1990
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`‘Digital Voice and Mobile Systems”; IEEE Communication Society Meeting (San Diego);
`25 June 1991
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`‘A survey of data communications techniques’; Schlumberger Systems Lecture Series;
`April, 1992
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` ‘Telecommunications technology overview’; UCSD Connect Conference on Issues
`Affecting the Growing Communications Company; March, 1993
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`‘Voice compression technologies’; DDI (Japan) Seminar Series; May, 1993
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` ‘Cellular digital packet data’; IEEE Hot Interconnects Conference; 1994
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`‘Smartphones and CDPD’; CTIA Conference opening plenary session; March, 1994
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`‘What digital engineers need to know about wireless communications’; University Video
`Communications Distinguished Lecture Series VII; May, 1994
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` ‘The convergence of wireless and the Internet’; panel discussion at CTIA Conference
`plenary session; March, 1995
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`‘Launch of the Personal Handy Phone System in Japan’; IEEE Conference on Personal,
`Indoor, and Mobile Radio Communications; September, 1995 (invited keynote speaker)
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` ‘Telewars: the battle for the telephone market’; Emerging Markets in Telecommunications
`Conference; May, 1996 (moderator)
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`‘Trends in digital wireless communications’; Device Research Conference; June, 1996
`(Plenary speaker)
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`‘Overview of digital wireless communication’; Proceedings of SPIE; October, 1996
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`‘What is required to meet wireless consumer demands’; Dataquest Conference on the
`Wireless Future; January, 1997
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`‘Select topics in telecommunications technology’; MIT Executive Short Course for Chief
`Network Officers; May, 1995, 1996, & 1997
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`‘Personal networking: integrating smart devices’; UCSD Connect & SDTC Conference on
`Evolving Markets in Telecommunications; June, 1999 (moderator, organizer and speaker)
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`13
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`Samsung Exhibit 1010, Page 13
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`‘Introduction to the Bluetooth standard’; SD IEEE Communications Society; March, 2000
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`‘Comparing short range wireless technologies’; panel discussion at Futuretech Forum at the
`University of Michigan Business School; January, 2001
`
` “Wireless LANs and PANs’; panel discussion at the Headliner event of the San Diego
`Telecom Council; July, 2001
`
`‘The future of wireless personal area networking’; Pervasive Computing Outlook;
`December, 2001
`
`‘The Lessons Learned in Startup Companies’; Executive Speaker Series – Wharton
`Executive MBA West Program; January, 2002
`
`‘Bluetooth – Standard, products, and applications’; Joint session of the SD IEEE
`Communications Society and Signal Processing Society; February, 2002
`
`‘What is Bluetooth?’; Albuquerque IEEE chapter invited speaker; March, 2002
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`14
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`Samsung Exhibit 1010, Page 14
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