UNITED STATES INTERNATIONAL TRADE COMMISSION
WASHINGTON, D.C.
Before the Honorable David P. Shaw
Administrative Law Judge
In the Matter of
CERTAIN WIRELESS DEVICES WITH
3G CAPABILITIES AND
COMPONENTS THEREOF
Investigation No. 337-TA-800
COMPLAINANTS’ AMENDED IDENTIFICATION OF EXPERT WITNESSES
Complainants InterDigital Communications, LLC; InterDigital Technology
Corporation; and IPR Licensing, Inc. (collectively “InterDigital�) hereby identify the following
individuals as experts that InterDigital currently believes may testify on behalf of InterDigital in
this Investigation.
1. Richard A. Chandler
Mr. Chandler is an expert in the field of wireless communications. A copy of Mr.
Chandler’s curriculum vitae is attached hereto as Exhibit A. Mr. Chandler may be called on to
testify regarding matters relating to, at least, the technical background of the asserted patents;
the interpretation of the claims in those patents; the design, structure, function, and operation of
the accused products and any article asserted to be infringed by the patents; the knowledge of a
person of ordinary skill in the art; the scope of the prior art; other issues in connection with
infringement, validity, enforceability, and any other technical issue that may arise. Mr. Chandler
may also be called to rebut the testimony of Respondents’ experts or fact witnesses, should any
be presented, regarding the same.
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2. Dr. Benjamin F. Goldberg
Dr. Goldberg is an expert in the field of source code, including source code
relating to wireless communications. A copy of Dr. Goldberg’s curriculum vitae is attached
hereto as Exhibit B. Dr. Goldberg may be called on to testify regarding matters relating to, at
least, the technical background of the asserted patents; the design, structure, function, and
operation of the accused products and any article asserted to be infringed by the patents; the
knowledge of a person of ordinary skill in the art; other issues in connection with infringement,
validity, and/or enforceability; and any other technical issue that may arise. Dr. Goldberg may
also be called to rebut the testimony of Respondents’ experts or fact witnesses, should any be
presented, regarding the same.
3. Dr. Charles L. Jackson
Dr. Jackson is an expert in the field of wireless communications. A copy of Dr.
Jackson’s curriculum vitae is attached hereto as Exhibit C. Dr. Jackson may be called on to
testify regarding matters relating to, at least, the technical background of the asserted patents; the
interpretation of the claims in those patents; the design, structure, function, and operation of the
accused products and any article asserted to be infringed by the patents; the knowledge of a
person of ordinary skill in the art; the scope of the prior art; other issues in connection with
infringement, validity, enforceability, and any other technical issue that may arise. Dr. Jackson
may also be called to rebut the testimony of Respondents’ experts or fact witnesses, should any
be presented, regarding the same.
4. Dr. Paul R. Prucnal
Dr. Prucnal is an expert in the field of wireless communications. A copy of Dr.
Prucnal’s curriculum vitae is attached hereto as Exhibit D. Dr. Prucnal may be called on to
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testify regarding matters relating to, at least, the technical background of the asserted patents; the
interpretation of the claims in those patents; the design, structure, function, and operation of the
accused products and any article asserted to be infringed by the patents; the knowledge of a
person of ordinary skill in the art; the scope of the prior art; other issues in connection with
infringement, validity, enforceability, and any other technical issue that may arise. Dr. Prucnal
may also be called to rebut the testimony of Respondents’ experts or fact witnesses, should any
be presented, regarding the same.
5. Dr. Jonathan D. Putnam
Dr. Putnam is an expert in the licensing and economic aspects of intellectual
property. A copy of Dr. Putnam’s curriculum vitae is attached hereto as Exhibit E. He may be
called on to testify regarding, at least, licensing and the economic aspects of intellectual
property; the meaning of FRAND obligations and FRAND terms and conditions, including
royalty rates and other terms; industry practice in licensing with respect to FRAND terms and
conditions; and the domestic industry. Dr. Putnam may also be called to rebut the testimony of
any Respondent expert or fact witnesses, should any be presented, regarding the same.
6. Dr. Wayne Eric Stark
Dr. Stark is an expert in the field of wireless communications. A copy of Dr.
Stark’s curriculum vitae is attached hereto as Exhibit F. Dr. Stark may be called on to testify
regarding matters relating to, at least, the technical background of the asserted patents; the
interpretation of the claims in those patents; the design, structure, function, and operation of the
accused products and any article asserted to be infringed by the patents; the knowledge of a
person of ordinary skill in the art; the scope of the prior art; other issues in connection with
infringement, validity, enforceability, and any other technical issue that may arise. Dr. Stark may
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also be called to rebut the testimony of Respondents’ experts or fact witnesses, should any be
presented, regarding the same.
7. Dr. Zygmunt Haas
Dr. Haas is an expert in the field of wireless communications. A copy of Dr.
Haas’s curriculum vitae is attached hereto as Exhibit G. Dr. Haas may be called on to testify
regarding matters relating to, at least, the technical background of the asserted patents; the
interpretation of the claims in those patents; the design, structure, function, and operation of the
accused products and any article asserted to be infringed by the patents; the knowledge of a
person of ordinary skill in the art; the scope of the prior art; other issues in connection with
infringement, validity, enforceability, and any other technical issue that may arise. Dr. Haas may
also be called to rebut the testimony of Respondents’ experts or fact witnesses, should any be
presented, regarding the same.
8. Bertrand Fages
Mr. Fages is an expert in French contract law. A copy of Mr. Fages’ curriculum
vitae is attached hereto as Exhibit H. Mr. Fages may be called on to testify regarding matters
relating to, at least, French contract law, including the enforceability, construction and effect of
the ETSI IPR policy and undertakings pursuant to that policy. Mr. Fages may also be called to
rebut the testimony of Respondents’ experts or fact witnesses, should any be presented,
regarding the same.
9. Dr. Bertram Huber
Mr. Huber is an expert on standard-setting organizations, licensing, and FRAND
obligations. A copy of Mr. Huber’s curriculum vitae is attached hereto as Exhibit I. Mr. Huber
may be called on to testify regarding matters relating to, at least, the ETSI IPR policy, including
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its original drafting and history of its adoption; licensing of patents including standards-essential
patents; and FRAND obligations. Mr. Huber may also be called to rebut the testimony of
Respondents’ experts or fact witnesses, should any be presented, regarding the same.
10. Kent Richardson
Mr. Richardson is an expert in licensing and the economic aspects of intellectual
property, including as they relate to domestic industry. A copy of Mr. Richardson’s curriculum
vitae is attached hereto as Exhibit J. Mr. Richardson may be called on to testify regarding matters
relating to, at least, licensing of patents, including standards-essential patents and FRAND
obligations; industry practice in licensing with respect to FRAND terms and conditions; and the
domestic industry issues in this investigation. Mr. Richardson may also be called to rebut the
testimony of Respondents’ experts or fact witnesses, should any be presented, regarding the
same.
11. Dr. Martin G. Walker
Dr. Walker is an expert in the field of source code, including source code relating
to wireless communications. A copy of Dr. Walker’s curriculum vitae is attached hereto as
Exhibit K. Dr. Walker may be called on to testify regarding matters relating to, at least, the
technical background of the asserted patents; the design, structure, function, and operation of the
accused products and any article asserted to be infringed by the patents; the knowledge of a
person of ordinary skill in the art; other issues in connection with infringement, validity, and/or
enforceability; and any other technical issue that may arise. Dr. Walker may also be called to
rebut the testimony of Respondents’ experts or fact witnesses, should any be presented,
regarding the same.
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InterDigital reserves the right to identify additional rebuttal expert witnesses in
response to Respondents’ expert disclosures, expert reports, and/or affirmative defenses.
InterDigital further reserves the right to call any expert witness that any party deposes, to call
expert witnesses identified by, or called to testify at the hearing by, Respondents, and to call
impeachment witnesses not identified above.