UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before the Honorable Thomas B. Pender
`Administrative Law Judge
`
`Inv. No. 337-TA-1057
`
`
`In the Matter of
`
`CERTAIN ROBOTIC VACUUM
`CLEANING DEVICES AND
`COMPONENTS THEREOF SUCH AS
`SPARE PARTS
`
`
`RESPONDENTS’ IDENTIFICATION OF EXPERT WITNESSES
`
`Pursuant to Ground Rule 10 and the Procedural Schedule in this Investigation (Order No.
`
`
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`14), Respondents Shenzhen Zhiyi Technology Co., Ltd., BISSELL Homecare, Inc., Matsutek
`
`Enterprises Co., Ltd., Black & Decker Corporation, Black & Decker (U.S.) Inc., Shenzhen
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`Silver Star Intelligent Technology Co., Ltd., bObsweep, Inc., bObsweep USA, Hoover Inc.,
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`Royal Appliance Manufacturing Co. d/b/a TTI Floor Care North America, Inc., and Suzhou Real
`
`Power Electronic Appliance Co., Ltd. (collectively, “Respondents”) hereby identify the
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`following experts from whom they may offer opinions or testimony in this Investigation.
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`Respondents may offer the testimony of one or more of these experts at the hearing for
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`this Investigation either live, through witness statements, or by deposition, as the Administrative
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`Law Judge permits. The identification of experts and expected areas of testimony are based on
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`Respondents’ ongoing investigation of evidence produced in this matter as of the date of this
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`disclosure. Because discovery is still in an early stage, Respondents reserve the right to
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`supplement its identification of experts and areas of testimony for the identified experts as
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`additional information becomes available or as new issues arise.
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`Respondents also reserve the right to supplement or amend this list if an objection to one
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`or more of these experts is raised by Complainant iRobot Corporation (“Complainant”) and/or
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`1
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`IROBOT 2016
`Shenzhen Silver Star v. iRobot
`IPR2018-00897
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`

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`sustained by the Administrative Law Judge. Respondents further reserve the right to (i) call at the
`
`hearing any expert witness that a party deposes; (ii) call at the hearing any expert witness
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`identified by, or called to testify at the hearing by, Complainant; and (iii) call at the hearing
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`impeachment witnesses not identified herein.
`
`1. Richard M. Goodin
`Goodin & Associates, Inc.
`Apex, North Carolina
`
`Mr. Goodin earned his Bachelor’s degree in Electrical Engineering from the University of
`
`Delaware. Mr. Goodin is currently President and Chief Consultant for Goodin & Associates,
`
`Inc. Mr. Goodin may be called on to testify regarding the source code involved in this
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`Investigation; the technical background of the Asserted Patents; the interpretation of claims in
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`the Asserted Patents; the design, structure, function, and operation of the Accused Products and
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`alleged Domestic Industry Products; the scope of the prior art; the invalidity, non-infringement,
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`and unenforceability of the Asserted Patents as well as Complainant’s positions on validity,
`
`enforceability, and/or infringement; and other related issues raised in connection with the claims
`
`and defenses raised in this Investigation. Mr. Goodin is expected to provide testimony at the
`
`hearing for this Investigation live and/or via deposition, as the Administrative Law Judge
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`permits. Mr. Goodin is also expected to provide testimony in form of declarations in response to
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`various pleadings and motions that may be filed in this Investigation addressing subject matter
`
`falling within Mr. Goodin’s expertise, including any motions for summary determination. Mr.
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`Goodin may also rebut the expert witness report(s) and testimony of Complainant’s expert(s) as
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`to the subject matter within Mr. Goodin’s expertise. A copy of Mr. Goodin’s curriculum vitae is
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`attached hereto as Exhibit A.
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`
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`2
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`2. Dr. Stephen Heppe
`Telenergy, Inc.
`Hood River, Oregon
`
`
`
`Dr. Heppe earned his B.S.E.E. degree from Princeton University and M.S. and D.Sc.
`
`
`
`
`
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`degrees in Electrical Engineering/Communications from George Washington University. Dr.
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`Heppe is currently President of Telenergy, Inc. Dr. Heppe may be called on to testify regarding
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`the technical background of the Asserted Patents; the interpretation of claims in the Asserted
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`Patents; the design, structure, function, and operation of the Accused Products and alleged
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`Domestic Industry Products; the scope of the prior art; the invalidity, non-infringement, and
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`unenforceability of the Asserted Patents as well as Complainant’s positions on validity,
`
`enforceability, and/or infringement; and other related issues raised in connection with the claims
`
`and defenses raised in this Investigation. Dr. Heppe is expected to provide testimony at the
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`hearing for this Investigation live and/or via deposition, as the Administrative Law Judge
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`permits. Dr. Heppe is also expected to provide testimony in form of declarations in response to
`
`various pleadings and motions that may be filed in this Investigation addressing subject matter
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`falling within Dr. Heppe’s expertise, including any motions for summary determination. Dr.
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`Heppe may also rebut the expert witness report(s) and testimony of Complainant’s expert(s) as to
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`the subject matter within Dr. Heppe’s expertise. A copy of Dr. Heppe’s curriculum vitae is
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`attached hereto as Exhibit B.
`
`3. Dr. John Martens
`Exponent Engineering & Scientific Consulting
`Chicago, Illinois
`
`Dr. Martens earned his Ph.D. degree in Electrical Engineering and Computer Science
`
`
`
`
`
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`from Case Western Reserve University. Dr. Martens is currently a Principal Engineer at
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`Exponent Engineering & Scientific Consulting. Dr. Martens may be called on to testify regarding
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`the technical background of the Asserted Patents; the interpretation of claims in the Asserted
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`3
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`

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`Patents; the design, structure, function, and operation of the Accused Products and alleged
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`Domestic Industry Products; the scope of the prior art; the invalidity, non-infringement, and
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`unenforceability of the Asserted Patents as well as Complainant’s positions on validity,
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`enforceability, and/or infringement; and other related; and other related issues raised in
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`connection with the claims and defenses raised in this Investigation. Dr. Martens is expected to
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`provide testimony at the hearing for this Investigation live and/or via deposition, as the
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`Administrative Law Judge permits. Dr. Martens is also expected to provide testimony in form of
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`declarations in response to various pleadings and motions that may be filed in this Investigation
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`addressing subject matter falling within Dr. Martens’s expertise, including any motions for
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`summary determination. Dr. Martens may also rebut the expert witness report(s) and testimony
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`of Complainant’s expert(s) as to the subject matter within Dr. Martens’ expertise. A copy of Dr.
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`Martens’ curriculum vitae is attached hereto as Exhibit C.
`
`4. Dr. William Messner
`Tufts University
`Department of Mechanical Engineering
`Medford, Massachusetts
`
`Dr. Messner earned his Ph.D. degree in Mechanical Engineering from University of
`
`
`
`
`
`
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`California, Berkeley. Dr. Messner is currently a Professor in the Department of Mechanical
`
`Engineering at Tufts University. Dr. Messner may be called on to testify regarding the technical
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`background of the Asserted Patents; the interpretation of claims in the Asserted Patents; the
`
`design, structure, function, and operation of the Accused Products and alleged Domestic Industry
`
`Products; the scope of the prior art; the invalidity, non-infringement, and unenforceability of the
`
`Asserted Patents as well as Complainant’s positions on validity, enforceability, and/or
`
`infringement; and other related issues raised in connection with the claims and defenses raised in
`
`this Investigation. Dr. Messner is expected to provide testimony at the hearing for this
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`4
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`

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`Investigation live and/or via deposition, as the Administrative Law Judge permits. Dr. Messner is
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`also expected to provide testimony in form of declarations in response to various pleadings and
`
`motions that may be filed in this Investigation addressing subject matter falling within Dr.
`
`Messner’s expertise, including any motions for summary determination. Dr. Messner may also
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`rebut the expert witness report(s) and testimony of Complainant’s expert(s) as to the subject
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`matter within Dr. Messner’s expertise. A copy of Dr. Messner’s curriculum vitae is attached as
`
`Exhibit D.
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`5. Dr. James L. Olivier
` Olivier Consulting, Inc.
` Dallas, Texas
`
`
`Dr. Olivier is an expert inthe field of electronical engineering, including computer and
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`
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`communication systems design . Dr. Olivier earned his B.S., M.S. and Ph.D. degrees in
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`Electrical Engineering from Ohio State University. Dr. Olivier is currently Owner and
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`Consultant for Oliver Consulting, Inc. and a Consultant for McAlexander Sound, Inc. Dr. Olivier
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`may be called on to testify regarding the source code involved in this Investigation; technical
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`background of the Asserted Patents; the interpretation of claims in the Asserted Patents; the
`
`design, structure, function, and operation of the Accused Products and alleged Domestic
`
`Industry Products;
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`the scope of
`
`the prior art;
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`the
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`invalidity, non-infringement, and
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`unenforceability of the Asserted Patents as well as Complainant’s positions on validity,
`
`enforceability, and/or infringement; and other related issues raised in connection with the claims
`
`and defenses raised in this Investigation. Dr. Olivier is expected to provide testimony at the
`
`hearing for this Investigation live and/or via deposition, as the Administrative Law Judge
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`permits. Dr. Olivier is also expected to provide testimony in form of declarations in response to
`
`various pleadings and motions that may be filed in this Investigation addressing subject matter
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`5
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`falling within Dr. Olivier’s expertise, including any motions for summary determination. Dr.
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`Olivier may also rebut the expert witness report(s) and testimony of Complainant’s expert(s) as
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`to the subject matter within Dr. Olivier’s expertise. A copy of Dr. Olivier’s curriculum vitae is
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`attached as Exhibit E.
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`6. W. Christopher Bakewell
`Duff & Phelps, LLC
`Houston, Texas
`
`
`
`
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`Christopher Bakewell is an expert in economics and accounting. Dr. Bakewell earned his
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`M.B.A. from the University of Maryland at College Park. Mr. Bakewell is currently a Managing
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`Director of Duff & Phelps, LLC. Mr. Bakewell may be called on to testify regarding the
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`economic prong of Complainant’s domestic industry contentions. Mr. Bakewell may also be
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`called to testify regarding any alleged economic injury; domestic injury; public interest; remedy;
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`and any other relief sought by Complainant, including, but not limited to, whether an exclusion
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`order is appropriate and whether a bond during the presidential review period is appropriate. Mr.
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`Bakewell is also expected to address any other economic issues that may arise out of
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`Complainant’s allegations against Respondents. Mr. Bakewell is expected to provide testimony
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`at the hearing for this Investigation live and/or by deposition, as the Administrative Law Judge
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`permits. Mr. Bakewell is also expected to provide testimony in the form of declarations in
`
`response to various pleadings and motions that may be filed in this Investigation addressing the
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`subject matter falling within Mr. Bakewell’s expertise, including any motions for summary
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`determination. . Mr. Bakewell may also rebut the expert witness report(s) and testimony of
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`Complainant’s expert(s) as to the subject matter within Mr. Bakewell’s expertise. A copy of Mr.
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`Bakewell’s curriculum vitae is attached as Exhibit F.
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`
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`6
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`7. Dr. Hagen Schempf
`ICON Consultants, LLC
`Pittsburgh, Pennsylvania
`
`Dr. Schempf earned his Ph.D. degree in Mechanical and Oceanographic Engineering
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`
`
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`
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`from Massachusetts Institute of Technology and Woods Hole Oceanographic Institution. Dr.
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`Schempf is currently Co-Founder and Senior Partner of ICON Consultants, LLC. Dr. Schempf
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`may be called on to testify regarding the technical background of the Asserted Patents; the
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`interpretation of claims in the Asserted Patents; the design, structure, function, and operation of
`
`the Accused Products and alleged Domestic Industry Products; the scope of the prior art; the
`
`invalidity, non-infringement, and unenforceability of the Asserted Patents as well as
`
`Complainant’s positions on validity, enforceability, and/or infringement; and other related issues
`
`raised in connection with the claims and defenses raised in this Investigation. Dr. Schempf is
`
`expected to provide testimony at the hearing for this Investigation live and/or via deposition, as
`
`the Administrative Law Judge permits. Dr. Schempf is also expected to provide testimony in
`
`form of declarations in response to various pleadings and motions that may be filed in this
`
`Investigation addressing subject matter falling within Dr. Schempf’s expertise, including any
`
`motions for summary determination. Dr. Schempf may also rebut the expert witness report(s)
`
`and testimony of Complainant’s expert(s) as to the subject matter within Dr. Schempf’s
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`expertise. A copy of Dr. Schempf’s curriculum vitae is attached as Exhibit G.
`
`8. Dr. Khalid Sorensen
`PaR Systems
`PaR Material Handling Business Unit
`Atlanta, Georgia
`
`Dr. Sorensen earned his Ph.D. degree in Mechanical Engineering from the Georgia
`
`
`
`
`
`
`
`Institute of Technology. Dr. Sorensen is currently the CTO of PaR System’s Material Handling
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`Business Unit. Dr. Sorensen may be called on to testify regarding the technical background of
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`7
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`the Asserted Patents; the interpretation of claims in the Asserted Patents; the design, structure,
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`function, and operation of the Accused Products and alleged Domestic Industry Products; the
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`scope of the prior art; the invalidity, non-infringement, and unenforceability of the Asserted
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`Patents as well as Complainant’s positions on validity, enforceability, and/or infringement; and
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`other related issues raised in connection with the claims and defenses raised in this Investigation.
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`Dr. Sorensen is expected to provide testimony at the hearing for this Investigation live and/or via
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`deposition, as the Administrative Law Judge permits. Dr. Sorensen is also expected to provide
`
`testimony in form of declarations in response to various pleadings and motions that may be filed
`
`in this Investigation addressing subject matter falling within Dr. Sorensen’s expertise, including
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`any motions for summary determination. Dr. Sorensen may also rebut the expert witness
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`report(s) and testimony of Complainant’s expert(s) as to the subject matter within Dr. Sorensen’s
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`expertise. A copy of Dr. Sorensen’s curriculum vitae is attached as Exhibit H.
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`Dated: August 4, 2017
`
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`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`By: /s/ Patrick J. McCarthy
`Mark G. Davis
`Ronald J. Pabis
`Patrick J. McCarthy
`Myomi T. Coad
`Greenberg Traurig, LLP
`2101 L Street, N.W., Suite 1000
`Washington, D.C. 20037
`Telephone: (202) 331-3100
`Facsimile: (202) 331-3101
`ShenzhenZhiyiITCAll@gtlaw.com
`
`Nicholas A. Brown
`Greenberg Traurig LLP
`4 Embarcadero Center
`Suite 3000
`San Francisco CA 94111
`Telephone: (415) 655-1271
`Facsimile: (415) 520-5609
`brownn@gtlaw.com
`
`8
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`
`Jonathan Ball
`Greenberg Traurig, LLP
`MetLife Building
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 801-9200
`Facsimile: (212) 801-6400
`ballj@gtlaw.com
`
`Stephen M. Ullmer
`Greenberg Traurig LLP
`The Tabor Center
`1200 17th Street, Suite 2400
`Denver, CO 80202
`Telephone: (303) 572-6500
`Facsimile: (303) 572-6540
`
`Ping Gu
`Zhong Lun Law Firm
`31, 33, 36, 37/F, SK Tower, 6A
`Jianguomenwai Avenue, Chaoyang District
`Beijing 100022, P.R.China
`Telephone: 86-10-5957228
`Facsimile: 86-10-59571022/1838
`guping@zhonglun.com
`
`ATTORNEYS FOR RESPONDENT
`SHENZHEN ZHIYI TECHNOLOGY CO.,
`LTD.
`
`9
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`

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`Dated: August 4, 2017
`
`
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`
`
`/s/ Kecia J. Reynolds
`Kecia J. Reynolds
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`1200 Seventeenth St. NW
`Washington, DC 20036
`Tel: (202) 663-8025
`Fax: (202) 663-8007
`
`William P. Atkins
`Jack S. Barufka
`Bryan P. Collins
`Sean M. Weinman
`Michael K. Heins
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`1650 Tysons Blvd., 14th Floor
`McLean, Virginia 22102
`Tel: (703) 770-7900
`Fax: (703) 770-7901
`
`Jack Ko, Ph.D.
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`Suite 4201, Bund Center,
`222 Yan An Road East
`Shanghai 200002 China
`Tel: (86) 21-6137-7999
`Fax: (86) 21-6137-7900
`
`COUNSEL FOR RESPONDENTS HOOVER,
`INC., ROYAL APPLIANCE
`MANUFACTURING CO., INC. D/B/A TTI
`FLOOR CARE NORTH AMERICA INC., THE
`BLACK & DECKER CORPORATION,
`BLACK & DECKER (U.S.) INC., SHENZHEN
`SILVER STAR INTELLIGENT
`TECHNOLOGY CO., LTD., BOBSWEEP,
`INC., AND BOBSWEEP USA
`
`10
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`

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`Dated August 4, 2017
`
`
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`
`
`/s/ Rachel E. Burnim
`Harold H. Davis, Jr.
`Rachel E. Burnim
`K&L GATES LLP
`4 Embarcadero Center, Ste. 1200
`San Francisco, CA 94111
`Tel: (415) 882-8200
`Fax: (415) 882-8220
`
`Jay C. Chiu
`K&L GATES LLP
`1 Park Plaza
`Twelfth Floor
`Irvine, CA 92614
`
`Eric C. Rusnak
`K&L Gates LLP
`1601 K Street, NW
`Washington, DC 20006
`
`COUNSEL FOR RESPONDENTS BISSELL
`HOMECARE, INC. AND MATSUTEK
`ENTERPRISES CO., LTD.
`
`11
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`Dated August 4, 2017
`
`
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`
`
`/s/ Jason Xu
`Shamita Etienne-Cummings
`Jason Xu
`WHITE & CASE LLP
`701 Thirteenth Street, NW
`Washington, DC 20005-3807
`Telephone: (202) 626-3600
`Facsimile: (202) 639-9355
`
`Bijal V. Vakil
`Eric E. Lancaster
`Allen W. Wang
`WHITE & CASE LLP
`3000 El Camino Real
`5 Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`Telephone: (650) 213-0300
`Facsimile: (650) 213-8158
`
`Jonathan K. Waldrop
`Jack Shaw
`Kevin M. Pasquinelli
`John W. Downing
`Kasowitz Benson Torres LLP
`jwaldrop@kasowitz.com
`jshaw@kasowitz.com
`kpasquinelli@kasowitz.com
`jdowning@kasowitz.com
`333 Twin Dolphin Drive, Suite 200
`Redwood Shores, CA 94065
`Telephone: (650) 453-5410
`Facsimile: (650) 453-5171
`
`Drew B. Hollander
`Kasowitz Benson Torres LLP
`dhollander@kasowitz.com
`1633 Broadway
`New York, NY 10019
`Telephone: (212) 506-1700
`Facsimile: (212) 506-1800
`
`Henry Brownstein
`Kasowitz Benson Torres LLP
`hbrownstein@kasowitz.com
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`12
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`1399 New York Avenue, Suite 201
`Washington, DC 20005
`Telephone: (202) 760-3400
`
`COUNSEL FOR RESPONDENT SUZHOU
`REAL POWER ELECTRIC APPLIANCE CO.,
`LTD.
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`CERTIFICATE OF SERVICE
`
`Via Email and Hand Delivery
`
`Via Email
`
`Via EDIS and Hand Delivery (2 copies)
`
`
`I, Colleen Sphar, hereby certify that on this 4th day of August, 2017, copies of the
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`foregoing were served upon the following parties as indicated:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 112-A
`Washington, D.C.
`The Honorable Thomas B. Pender
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W., Room 317
`Washington, D.C. 20436
`michael.turner@usitc.com
`
`Ruffin B. Cordell, Esq.
`FISH & RICHARDSON P.C.
`The McPherson Building
`901 15th Street NW, 7th Floor
`Washington, DC 20005
`ServiceiRobotITC@fr.com
`
`Counsel for Complainant
`Harold H. Davis, Jr.
`K&L Gates LLP
`Four Embarcadero Center, Suite 1200
`San Francisco, CA 94111
`BISSELL_MATSUTEK@klgates.com
`
`Counsel for Bissell Homecare, Inc. and
`Matsutek Enterprises Co., Ltd.
`Kecia J. Reynolds, Esq.
`PILLSBURY WINTHROP SHAW
`PITTMAN LLP
`1200 Seventeenth St. NW
`Washington, DC 20036
`Pillsbury-1057@pillsburylaw.com
`
`Counsel for Respondents Hoover Inc. and
`Royal Appliance Manufacturing Co. d/b/a
`TTI Floor Care North America, Inc., Black
`& Decker Corporation, Black & Decker
`(U.S.) Inc., and Shenzhen Silver Star
`Intelligent Technology Co., Ltd, bObsweep,
`
`Via Email
`
`Via Email
`
`14
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`Inc. and bObsweep USA
`Shamita Etienne-Cummings
`Jason Xu
`WHITE & CASE LLP
`701 Thirteenth Street, NW
`Washington, DC 20005-3807
`
`Bijal V. Vakil
`Eric E. Lancaster
`Allen W. Wang
`WHITE & CASE LLP
`3000 El Camino Real
`5 Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`WCiRobotTeam@whitecase.com
`
`Jonathan K. Waldrop
`Jack Shaw
`Kevin M. Pasquinelli
`John W. Downing
`Kasowitz Benson Torres LLP
`333 Twin Dolphin Drive, Suite 200
`Redwood Shores, CA 94065
`
`Drew B. Hollander
`Kasowitz Benson Torres LLP
`dhollander@kasowitz.com
`1633 Broadway
`New York, NY 10019
`
`Henry Brownstein
`Kasowitz Benson Torres LLP
`hbrownstein@kasowitz.com
`1399 New York Avenue, Suite 201
`KBT_RealPower_1057@kasowitz.com
`
`Counsel for Respondent Suzhou Real
`Power Electric Appliance Co., Ltd.
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`/s/ Colleen Sphar
`Colleen Sphar
`Paralegal
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`15
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