UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`In the Matter of
`
`CERTAIN CRAFTING MACHINES AND
`COMPONENTS THEREOF
`
`Inv. No. 337-TA-1426
`
`RESPONDENTS HUNAN SIJIU TECHNOLOGY, CO. LTD., HUNAN SIJIU
`ELECTRONIC TECHNOLOGY, CO. LTD. AND GUANGDONG RONGTU
`TECHNOLOGY CO., LTD.’S IDENTIFICATION OF EXPERT WITNESSES
`
`Pursuant to the Procedural Schedule (Order No. 6), Respondents Hunan Sijiu
`
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology, Co. Ltd.1 and Guangdong Rongtu
`
`Technology Co., Ltd. (“HTVRONT” or “Respondents”), by and through counsel, hereby submit
`
`this identification of expert witnesses, including their expertise and curriculum vitae.
`
`HTVRONT may present the witnesses at the hearing, either live, or by deposition, by affidavit,
`
`or by witness statement. This identification of experts and expected areas of testimony is
`
`preliminary and is based on HTVRONT’s current understanding of the evidence and issues to be
`
`decided at the hearing. Discovery is ongoing and HTVRONT reserves the right to supplement
`
`this identification as appropriate, including by identifying additional expert witnesses,
`
`designating additional topics that the below-listed witnesses or any additional expert witnesses
`
`may opine on, and/or addressing new issues that may arise in discovery and in the expert
`
`disclosure(s) of Complainant Cricut, Inc. (“Cricut” or “Complainant”). HTVRONT further
`
`1 Respondent Hunan Sijiu Technology, Co. Ltd. was formerly known as Hunan Sijiu Electronic
`Technology Co., Ltd. Pending Commission approval of Order No. 10, Hunan Sijiu Electronic
`Technology Co., Ltd. will be terminated from the Investigation and HK Sijiu International Share
`Co., Ltd. (“HK Sijiu”) will be added as a respondent.
`1
`
`

`

`reserves its right to call any expert witness that a party deposes; to call expert witnesses
`
`identified or called to testify at the hearing by Cricut; and to call impeachment witnesses not
`
`identified below.
`
`1. Dr. Kimberly Cameron, Ph.D.
`
`Dr. Cameron is a Principal for Engineering Systems Inc. (ESi) in the Mechanics and
`
`Materials practice. She received her Ph.D. and M.S. in Mechanical Engineering from Stanford
`
`University and her B.S.E. in Mechanical and Aerospace Engineering from Princeton University.
`
`Dr. Cameron has conducted hundreds of investigations on a wide variety of engineering
`
`structures, including consumer products and electronics. Further, she specializes in metallurgy,
`
`materials selection, and product design, among other fields. Dr. Cameron has served as a
`
`consulting and testifying expert in over thirty cases, including testifying in four International
`
`Trade Commission Section 337 proceedings. Dr. Cameron’s qualifications are set forth in her
`
`curriculum vitae, attached as Exhibit 1.
`
`The general nature of Dr. Cameron’s testimony is presently expected to relate to technical
`
`matters related to the Asserted Patents; the subject matter of the Asserted Patents; the invalidity
`
`and/or unenforceability of the Asserted Patents; the construction of claims and claim terms of the
`
`Asserted Patents; the functionality, structure, design, and operation of products at issue in this
`
`Investigation; non-infringement of the Asserted Patents; technical analysis on the lack of a
`
`technical domestic industry; and any other issues relevant to HTVRONT’s defenses for which
`
`the expert testimony within the scope of her expertise is required or useful. Additionally, Dr.
`
`Cameron may rebut expert witness testimony of Cricut’s experts.
`
`2. Joel Delman
`
`2
`
`

`

`Mr. Delman is a Design Director at Informed Innovation, a consulting agency focused on
`
`assisting clients with design thinking. He also serves as an Associate Professor at the ArtCenter
`
`College of Design. He has a Master of Industrial Design from the Pratt Institute, a J.D. from
`
`Harvard Law School, and a B.S. in Economics from New York University. He has also received
`
`the IDSA 20/20 and the CES Innovation Awards, among many others. He has served as a
`
`consultant or testifying expert in two dozen design patent infringement cases, including in two
`
`International Trade Commission Section 337 proceedings involving design patents. Mr.
`
`Delman’s qualifications are set forth in his curriculum vitae, attached as Exhibit 2.
`
`The general nature of Mr. Delman’s testimony is presently expected to relate to technical
`
`matters related to the Asserted Patents; the subject matter of the Asserted Patents; the invalidity
`
`and/or unenforceability of the Asserted Patents; the functionality, structure, and design, of
`
`products at issue in this Investigation; noninfringement of the Asserted Patents; and any other
`
`issues relevant to HTVRONT’s defenses for which the expert testimony within the scope of his
`
`expertise is required or useful. Additionally, Mr. Delman may rebut expert witness testimony of
`
`Cricut’s experts.
`
`3. Julia Rowe
`
`Ms. Rowe is the Vice President of Charles River Associates. She is a Certified Public
`
`Accountant. She received her M.A. in Accountancy from DePaul University and her B.A. in
`
`Business Administration from the University of Michigan. She has given numerous speeches,
`
`presentations, and publications about economic issues at the International Trade Commission,
`
`including “ITC Investigations: Legal Issues” and “The Growing Role of Economics In IP-based
`
`Investigations At the ITC.” She has served as a consultant or testifying expert in over thirty trials
`
`and arbitrations, including over a dozen International Trade Commission Section 337
`
`3
`
`

`

`proceedings. Ms. Rowe’s qualifications are set forth in her curriculum vitae, attached as Exhibit
`
`3.
`
`The general nature of Ms. Rowe’s testimony is presently expected to relate to Cricut’s
`
`lack of an economic domestic industry and the appropriate remedy and/or bond rate if the
`
`Commission finds a violation of Section 337. Ms. Rowe’s testimony is also presently expected to
`
`relate to any other issues relevant to Complainant’s claims for which the expert testimony within
`
`the scope of her expertise is required or useful. Additionally, Mr. Rowe may rebut expert witness
`
`testimony of Cricut’s experts.
`
`Dated: March 11, 2025
`
`Respectfully submitted,
`
`/s/ Helena Kiepura
`Helena Kiepura
`DLA Piper LLP (US)
`500 Eighth Street, NW
`Washington, DC 20004
`Tel: 202.799.4000
`Fax: 202.799.5000
`
`Matthew Satchwell
`Paulina Starostka
`DLA Piper LLP (US)
`444 West Lake Street, Suite 900
`Chicago, IL 60606
`Tel: 312.368.4000
`
`Shaobin Zhu
`DLA Piper LLP (US)
`701 Fifth Avenue
`Suite 6900
`Seattle, WA 98104
`Tel: 206.839.4894
`
`Benjamin Yaghoubian
`DLA Piper LLP (US)
`2000 Avenue of the Stars
`Suite 400 North Tower
`
`4
`
`

`

`Los Angeles, CA 90067
`Tel: 310.595.3000
`
`Claire Schuster
`DLA Piper LLP (US)
`33 Arch Street, 26th Floor
`Boston, MA 02110
`Tel: 617.406.6000
`
`Peter VandeVort
`DLA Piper LLP (US)
`555 Mission St, Suite 2400
`San Francisco, CA 94105
`Tel: 415.836.2500
`
`Counsel for Hunan Sijiu Technology, Co.
`Ltd., Hunan Sijiu Electronic Technology, Co.
`Ltd. and Guangdong Rongtu Technology Co.,
`Ltd.
`
`5
`
`

`

`
`
`
`
`
`
`EXHIBIT 1
`EXHIBIT 1
`
`
`

`

`EXPERT WITNESS AGENCY
`
`1370 Broadway
`15th Hloor
`New York, NY 10018
`
`\ 212-235-2747
`@ 212-235-2701
`® wWrtlegal.com
`
`KIMBERLY K. CAMERON, Ph.D., P.E.
`PRINCIPAL
`
`Dr. Kimberly Cameronis a Principal for ESi in the Mechanics and Materials practice. She specializes in
`design, failure analysis, and risk assessments of engineering structures and components. She has
`conducted hundreds of investigations on a wide variety of engineering structures, from miniature
`biomedical devices to large scale process equipment. She has also taught classes for engineers
`preparing to take the fundamentals of engineering exam and the professional engineering licensing
`examination in both Civil Engineering and Mechanical Engineering.
`
`Dr. Cameron has performed design and damagetolerance evaluations on biomedical devices, pipelines,
`consumer electronics, consumer products, aircraft structures,
`industrial machinery, power-plant
`components, solar panels, pressure vessels, and vehicle components. Dr. Cameron also has extensive
`experience evaluating pipe-soil interactions, mechanical and welded joints, welding procedures,in-line
`inspection tools, regulatory compliance, and the overall integrity of pipeline systems. She has evaluated
`operating and maintenance procedures, control room management programsand pipeline leak detection
`plans. The commonthread in each of Dr. Cameron’s investigations is the application of the fundamentals
`of metallurgy, materials science, engineering physics, computational mathematics, and engineering
`mechanics to help understand and solve complex problems.
`
`Dr. Cameronis a registered patent agent, with experience in both the patent application process, as well
`as intellectual property disputes. In particular, she has experience in biomedical, automotive, electrical,
`mechanical, and materials science fields and has provided numerousinvalidity and infringement reports.
`She hastestified in federal and state court as well as in front of the ITC andin arbitration.
`
`Areas of Specialization
`
`Metallurgy
`Plastics & Composites
`Corrosion
`Materials Selection
`Mechanical Engineering
`Intellectual Property Matters
`
`Education
`
`Product Design
`Structural Engineering
`Product Recalls
`Root Cause Investigations
`Regulatory Compliance
`Failure Analysis
`
`Oil & Gas
`Energy & Power
`Biomedical Devices
`ConsumerProducts & Electronics
`Automotive & Aviation
`Electrical Equipment
`
`Ph.D. Mechanical Engineering, minor Materials Science & Engineering, Stanford University, CA, 2004
`M.S. Mechanical Engineering, Stanford University, CA, 2000
`B.S.E. Mechanical and Aerospace Engineering. Certificates: Engineering Physics, Applied &
`Computational Mathematics, Materials Science & Engineering, Woodrow Wilson School of
`Public Policy & International Affairs, Princeton University, NJ, 1999
`
`

`

`EXPERT WITNESS AGENCY
`
`1370 Broadway
`15th Hloor
`New York, NY 10018
`
`\ 212-235-2747
`@ 212-235-2701
`® wWrtlegal.com
`
`Kimberly K. Cameron, Ph.D., P.E.
`June 2022
`
`Licensed Professional Engineer(P.E.)
`
`Mechanical Engineer, State of California ..........License No. 33732
`Metallurgical Engineer, State of California..........License No. 1969
`
`ProfessionalAffiliations/Honors
`
`American Society of Mechanical Engineers
`Member
`
`The Minerals, Metals & Materials Society
`Member
`
`Department of Defense
`Fellowship
`
`National Science Foundation
`Fellowship
`
`Lucent Technologies
`Graduate Fellowship
`
`Positions Held
`
`Engineering SystemsInc., Sunnyvale, California
`Principal, Mechanics, 2011 — Present
`
`Exponent, Menlo Park, California
`Senior Engineer, Mechanics & Metallurgy, 2004 — 2011
`
`Publications/Presentations
`
`“Crack Growth and Arrest in Steam Turbine Casings,” EPRI 3002003504, EPRI, Palo Alto, CA, December
`2014.
`
`M. H. Anderson, D. Cislo, J. Saavedra, and K. Cameron, Why International Inventors Might Want to
`Consider Filing Their First Patent Application at the United States Patent Office & the
`Convergence of Patent Harmonization and E-Commerce, 30 Santa Clara High Tech. L.J. 555
`(2014).
`
`“Increasing Reliability of Small Punch Fracture Toughness Testing with Acoustic Emission Monitoring,”
`Proceedings, 3rd International Conference on Small Sample Test Techniques, September 2014.
`(with D. Purdy and J. Foulds).
`
`“Small Punch Fracture Toughness Evaluation of Combustion Turbine Materials,” EPRI 3002001468,
`EPRI, Palo Alto, CA, December 2013. (with D. Purdy, J. Foulds and J. Rodgers).
`
`Page 2 of 5
`
`

`

`EXPERT WITNESS AGENCY
`
`1370 Broadway
`15th Hloor
`New York, NY 10018
`
`\ 212-235-2747
`@ 212-235-2701
`® wWrtlegal.com
`
`Kimberly K. Cameron, Ph.D., P.E.
`June 2022
`
`“Small Punch Testing for Fracture Toughness” by J. Foulds, J. Rodgers, K. Cameron and P.Sullivan,
`EPRI, Palo Alto, CA: 2013. 3002000250.
`
`“The Effect of Low Sulfur Content on the Weldability of Linepipe Steel” by K. Cameron and A.M.
`Pettinger, Proceedings of the 9th International Pipeline Conference, September 2012.
`
`“Effectiveness of Hydrostatic Testing for High Strength Pipe Material” by K.K. Cameron & A.M.Pettinger,
`Proceedings,8th International Pipeline Conference, October 2010.
`
`“Axial Loads from Soil Movement Challenge Pipeline Integrity’ by K.K. Cameron & A.M. Pettinger,
`PipeLine Gas Technology, November 2009.
`
`“Assessing Pipeline Integrity Using Fracture Mechanics and Currently Available Inspections Tools” by
`K.K. Cameron & A.M.Pettinger, Journal of Pipeline Engineering, October 2009.
`
`“Assessing Pipeline Integrity Using Fracture Mechanics and Currently Available Inspections Tools” by
`K.K. Cameron & A.M. Pettinger, Proceedings, 2008 Evaluation and Rehabilitation of Pipelines
`Conference, Clarion Technical Conferences, Scientific Surveys Ltd., Prague, Czech Republic,
`October 2008.
`
`“Fatigue Damage in Bulk Metallic Glass |: Simulation” by K.K. Cameron & R. Dauskardt, Scripta
`Materialia 2006; 54(3):349-353.
`
`“Fundamentals of Engineering in a Flash” by K.K. Cameron, PPI, August 2006.
`
`“Transmission Electron Microscopy Structure and Platinum-like Temperature Coefficient of Resistance
`in a Ruthenate-Based Thick Film Resistor with Copper Oxide” by K.K. Cameron, G.Crosbie, J.
`Jiang, & X. Pan, J. Appl. Phys. 2000; 88:1124—1128.
`
`Selected Project Experience
`
`Medical Devices
`
`Failure analysis, design analysis, material selection, mechanicaltesting, finite element analysis, fatigue
`and fracture evaluation, and development of various
`implantable medical devices
`including
`cardiovascular implants (heart valves, stents, catheters, pacemakers), orthopedic implants (screws,
`plates, pins, hip implants, spinal implants), cranial implants, etc.
`
`Design andfailure analysis of variousfluid and drug delivery systemsincluding implantable pumps, drug
`eluting stents, syringes, patches, microneediles, CPAP machines, anesthesia machines,insulin and other
`drug delivery pumps,balloon respirators, etc.
`
`Design andfailure analysis of other types of medical devices including surgical tools, scooters, hospital
`beds, physical therapy equipment, etc.
`
`Performed analyses to support FDA submissions.
`
`Page 3 of 5
`
`

`

`EXPERT WITNESS AGENCY
`
`Pipelines
`
`1370 Broadway
`15th Hloor
`New York, NY 10018
`
`\ 212-235-2747
`@ 212-235-2701
`® wWrtlegal.com
`
`Kimberly K. Cameron, Ph.D., P.E.
`June 2022
`
`Evaluated the design, pipeline integrity management program, in-line inspection tools, leak detection
`systems, control room management and operation and maintenance practices, of both liquid and gas
`pipeline systems under both 49 CFR 195 and 192.
`
`Evaluated pipeline construction practices of various pipeline systems and performed pipeline failure
`investigations after various landslide events.
`
`Assisted the Inter-American Development Bankwith a pipeline integrity study and with the supervision of
`the implementation of a pipeline integrity management program for a pipeline operator. The investigation
`integrated geotechnical site investigations, metallurgical investigations, in-line inspection data, external
`pipe inspection data, and fracture mechanics to perform a root cause analysis.
`
`Evaluated welding procedures and determined the effect of welding defects and other construction
`factors on pipeline integrity.
`
`Investigated pipe soil interactions occurring during hydrostatic testing of pipelines and the evaluation of
`pipeline ruptures and leaks at weldedjoints.
`
`Investigated the operation and maintenance proceduresof pipelines that are located in close proximity
`to other infrastructure (electrical equipment, coal mines, waterdistribution, other pipelines, etc.)
`
`Failure analysis of various insulated steel oil and water pipeline systems, including behavior of the
`polyurethane foam and jacket materials.
`
`Design evaluation andfailure analyses of pipe couplings andfittings, including finite element analyses.
`
`Performed design and failure analyses of various gas distribution systems made of polyethylene and
`steel pipe,
`including the analysis of pipe-soil
`interactions, failure analysis of various components,
`evaluation of welding and construction practices, and performance evaluation of compression couplings.
`
`Performed failure analysis and finite element analyses of various waterdistribution systems including
`variousfire sprinkler systems, water supply systems and couplings, and a ten foot wide water main.
`
`Retained as an expert for the United States Patent and Trademark Office in the evaluation of a patent
`claim dispute relating to large diameterpipes.
`
`Energy & Power
`
`Assisted the general contractor of a nuclear power plant where a large pipe of the primary circuit was
`vibrating excessively, significantly reducing the allowable power production.
`
`Page 4 of 5
`
`

`

`EXPERT WITNESS AGENCY
`
`1370 Broadway
`15th Hloor
`New York, NY 10018
`
`\ 212-235-2747
`@ 212-235-2701
`® wWrtlegal.com
`
`Kimberly K. Cameron, Ph.D., P.E.
`June 2022
`
`Evaluated the design of a hydrogenerator system. Performed a finite element analysis and fatigue
`analysis of the rotors, thrust bridge, and head cover to assess the design.
`
`Developed a three-dimensional modelof the control rod drive mechanism nozzle penetration in a nuclear
`reactor pressure vessel head. Evaluated welding-induced residual and operational stresses.
`
`Evaluated the design of various pumps,rotors, bearings, seals and insulation systems.
`
`Performed stress analysis of various solar panel system components andassisted in design changesto
`meet standardized safety testing.
`
`Performed a stress analysis to evaluate the effects of tightening torques on a ton containervalve.
`
`Performed numerical simulation and small punch testing to evaluate fracture toughness and tensile
`behavior of miniature surface samples from a steam turbine rotor bore and from medical device plastics.
`
`ConsumerProducts and Electronics
`
`Developed testing protocols, and conducted failure analyses and design reviews for various consumer
`electronic devices and accessories, electrical connectors, power cords, and jacket sleeves.
`
`Evaluated the material selection and performance for various components of several consumerelectronic
`devicesincluding phones, tablets, and computers.
`
`Design and failure analyses of various electronic components.
`
`including washing machines,
`Design evaluation and stress analysis of various consumer products,
`refrigerators, baby chairs and other child containment products, hand tools, security and display systems,
`microwave ovens, coffee machines, exercise machines,etc.
`
`Automotive and Aviation
`
`Performed fracture and fatigue analysesof aircraft structures.
`
`Performed welding and structural evaluation of various automotive componentsincluding semitrailers.
`
`Investigated the manufacturing proceduresof electromagnetic latches used in aerospace applications.
`
`Evaluated the design of a diode on a solar panel and various other components for space applications.
`
`Performed fitness for service and design evaluations for welds in various applications, including in fuel
`storage tanks, process reactor vessels, scaffoldings, semitrailers, and other automotive components.
`
`Page 5 of 5
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`

`

`
`
`
`
`
`
`
`KIMBERLY K. CAMERON, Ph.D., P.E.
`PRINCIPAL
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PROJECT
`2023
`
`International Medical Devices, Inc. v. Robert Cornell, M.D., et al
`Case No. 2:20-cv-03503-CBM (RAOx)
`United States District Court
`Central District of California – Western Division
`
`
`
`
`
`STATE
`
`CA
`
`(trial)
`
`
`In the Matter of Certain Compact Wallets and Components Thereof D.C.
`Investigation No. 337-TA-1355
`United States International Trade Commission
`Washington, D.C.
`
`
`EIS Inc. v. IntiHealth Ger GmbH, Wow Tech USA, Ltd.;
`WOW Tech Canada, Ltd.; Novoluto GmbH; Novoluto
`GmbH; Triple A Import GmbH; and Triple A Marketing GmbH
`Civil Action No. 19-CV-12279 (GBW)(MPT)
`United States District Court for the District of Delaware
`
`(deposition)
`
`DE
`
`(deposition)
`
`D.C.
`
`(deposition)
`
`DE
`
`(trial)
`
`CA
`
`(deposition)
`
`
`Envirotainer AB v. Doubleday Acquisitions, LLC
`
`Case No. IPR2022-00864
`Case No. IPR2022-00851
`United States Patent and Trademark Office Before the
`Patent Trial and Appeal Board
`
`
`
`
`
`
`Victualic v. ASC Engineered Solutions, LLP
`
`Case No. 1-20-CV-00887-CFC
`United States District Court for the District of Delaware
`
`
`
`
`
`
`
`
`
`
`
`Echologics, LLC, Mueller International, LLC, and Mueller
`Canada, LTD. d/b/a Echologics v. Orbis Intelligent Systems, Inc.
`Case No. 3:21-cv-01147-RBM-AHG
`United States District Court Southern District of California
`
`
`Wonderland Switzerland AG v. Evenflo Company, Inc.
`Civil Action No. 1:20-cv-00727-JPM
`United States District Court for the District of Delaware
`
`2022
`
`In the Matter of Certain Playards and Strollers
`Investigation No. 337-TA-1288
`United States International Trade Commission
`
`
`EIS Inc. v. IntiHealth Ger GmbH, Wow Tech USA, Ltd.;
`WOW Tech Canada, Ltd.; Novoluto GmbH; Novoluto
`GmbH; Triple A Import GmbH; and Triple A Marketing GmbH
`Civil Action No. 19-cv-1227-VAC
`
`
`
`DE
`
`(trial)
`
`D.C.
`
`(trial)
`
`DE
`
`(trial)
`
`

`

`United States District Court for the District of Delaware
`
`
`
`
`Envirotainer AB v. Doubleday Acquisitions, LLC
`
`Case No. IPR2022-00292
`Case No. IPR2022-00293
`United States Patent and Trademark Office Before the
`Patent Trial and Appeal Board
`
`
`
`
`Kimberly K. Cameron, Ph.D., P.E.
`Rule 26 Expert Testimony List
`Page 2 of 4
`
`
`
`
`
`D.C.
`
`(deposition)
`
`D.C.
`
`CA
`
`NC
`
`(deposition)
`
`(trial)
`
`(deposition)
`
`
`
`
`In the Matter of Certain Playards and Strollers
`
`Investigation. No. 337-TA-1288
`
`United States International Trade Commission
`
`Timothy Johnson v. LA Fitness; Fitness International LLC
`
`Case No. 30-2019-01059520
`
`Superior Court for the State of California for the County of Orange
`
`
`Ultra-Mek, Inc. v. United Furniture Industries, Inc.; Oiseys
`International, Inc.; Taizhou Chenguang Vehicle Co., LTD; Man
`Wah (USA), Inc.; Man Wah Holdings LTD; Remarco Machinery
`Technology Co., LTD; and Jiangsu Yulong Smart Technology
`Co., LTD
`
`Case No. 1:18-cv-281-WO-JEP
`United States District Court for the Middle District of North Carolina
`
`
`Victualic v. ASC Engineered Solutions, LLP
`
`Case No. 1-20-CV-00887-CFC
`United States District Court for the District of Delaware
`
`
`
`
`
`
`
`DE
`
`(deposition)
`
`
`Unirac, Inc. v. Ecofasten Solar, LLC and ESDEC, Inc.
`
`Case No. 1:21-CV-000058
`
`Case No. 1:21-CV-000059
`
`United States District Court for the District of Delaware
`
`Transcontinental Gas Pipe Line Company LLC v Latex
`Construction Company
`
`Case No. CJ-2019-3611
`
`In the District Court in and for Tulsa County
`
`State of Oklahoma
`
`Antonio Barrera and Martha Barrera v. Southern California
`Edison Company, Robert K. Laird and Rebecca F. Clark
`
`Case No. CIVDS1700188
`
`Superior Court of the State of California
`
`County of San Bernardino, San Bernardino District
`
`
`Regeneron Pharmaceuticals, Inc. v. Novartis Pharma AG,
`Novartis Technology LLC, Novartis Pharmaceuticals Corporation
`
`Case No. IPR2021-00816
`United States Patent and Trademark Office Before the
`Patent Trial and Appeal Board
`
`
`
`
`
`
`
`DE
`
`(deposition)
`
`OK
`
`(deposition)
`
`CA
`
`(deposition)
`
`D.C.
`
`(deposition)
`
`
`Wonderland Switzerland AG v. Evenflo Company Inc.
`
`Case No. 20-727-RGA
`United States District Court for the District of Delaware
`
`
`
`
`DE
`
`(deposition)
`
`Updated June 29, 2023 – Based on information available
`
`

`

`
`Wonderland Switzerland AG v. Evenflo Company Inc.
`
`Case No. 20-727-RGA
`United States District Court for the District of Delaware
`
`
`Wonderland Switzerland AG v. Evenflo Company Inc.
`
`Case No. 20-727-RGA
`
`United States District Court for the District of Delaware
`
`Timothy Johnson v LA Fitness; Fitness International LLC
`
`Case No. 30-2019-01059520
`Superior Court for the State of California for the County of Orange
`
`
`
`
`Kimberly K. Cameron, Ph.D., P.E.
`Rule 26 Expert Testimony List
`Page 3 of 4
`
`
`
`
`
`
`
`
`
`DE
`
`DE
`
`CA
`
`(deposition)
`
`(deposition)
`
`(deposition)
`
`
`
`DE
`
`(deposition)
`
`
`2021
`
`Novo Nordisk Inc. and Novo Nordisk AS v. Sandoz Inc.
`
`Case No. 20-747-CFC
`United States District Court for the District of Delaware
`
`
`International Medical Devices, Inc. v. Robert Cornell, M.D., et al
`Case No. 2:20-cv-03503-CBM (RAOx)
`United States District Court
`Central District of California – Western Division
`
`
`Marathon Pipe Line LLC. v. Energy Transfer L.P, et al
`
`Case No. 2021CH14
`
`In The Circuit Court Fourth Judicial Circuit
`
`Marion County, Illinois
`
`In The Matter Of Certain Electrical Connectors and Cages,
`Components Thereof, And Products Containing The Same
`
`Investigation No. 337-TA-1241
`
`United States International Trade Commission
`
`
`
`Hoya Corporation and Hoya Surgical Optics, Inc. v.
`Alcon Inc., Alcon Laboratories, Inc., and Alcon Research, LLC
`
`Case No. 3:20-cv-03629
`5th Circuit, US District Court for the Northern District of Texas
`
`
`
`
`
`CA
`
`(deposition)
`
`IL
`
`(deposition)
`
`D.C.
`
`(trial)
`
`TX
`
`(deposition)
`
`
`In the Matter of Certain Electrical Connectors and Cages,
`Components Thereof, and Products Containing the same
`
`Investigation No. 337-TA-1241
`United States International Trade Commission
`
`
`
`D.C.
`
`(deposition)
`
`
`Cherelus (Genicia) vs Columbia Hospital Corporation
`of South Broward D/B/A Westside Regional Medical Center;
`Ravishankar Shivashankar, M.B.B.S.; Envision Healthcare
`Corporation; Radiology Physician Solutions of Florida, LLC;
`and Penumbra, Inc
`
`
`
`
`
`Case No. CACE-19-002780
`Circuit Court of the 17th Judicial Circuit, Broward County, Florida
`
`
`In the Matter of: Certain Blowers and Components Thereof
`
`Investigation No. 337-TA-1217
`
`
`
`
`
`FL
`
`(deposition)
`
`MO
`
`(trial)
`
`Updated June 29, 2023 – Based on information available
`
`

`

`
`
`
`Kimberly K. Cameron, Ph.D., P.E.
`Rule 26 Expert Testimony List
`Page 4 of 4
`
`
`
`Enforcement Proceeding
`United States International Trade Commission
`
`D.C.
`
`
`
`D.C.
`
`
`
`
`Novo Nordisk Inc. and Novo Nordisk AS v. Mylan Institutional LLC DE
`
`Case No. 19-01551-CFC
`
`United States District Court for the District of Delaware
`
`2020
`
`In the Matter of: Certain Portable Gaming Console Systems
`With Attachable Handheld Controllers and Components Thereof II
`
`Investigation No. 337-TA-197
`
`United States International Trade Commission
`
`In the Matter of: Certain Collapsible and Portable Furniture
`Investigation No. 337-TA-1178
`United States International Trade Commission
`
`
`
`
`
`
`
`(deposition)
`
`(trial)
`
`(trial)
`
`(deposition)
`
`(deposition)
`
`(deposition)
`
`
`
`In the Matter of: Certain Portable Gaming Console Systems
`With Attachable Handheld Controllers and Components Thereof II
`
`Investigation No. 337-TA-197
`
`United States International Trade Commission
`
`Ultra-Mek, Inc. v. United Furniture Industries, Inc.; Oiseys
`International, Inc.; Taizhou Chenguang Vehicle Co., LTD;
`Man Wah (USA), Inc.; Man Wah Holdings LTD.; Remarco
`Machinery Technology Co., LTD; and Jiangsu Yulong Smart
`Technology Co., LTD.
`
`
`
`
`
`Case No. 1:18-cv-281-WO-JEP
`
`United States District Court for the Middle District of North Carolina
`
`In the Matter of: Certain Collapsible and Portable Furniture
`Investigation No. 337-TA-1178
`United States International Trade Commission
`
`D.C.
`
`NC
`
`
`
`MO
`
`
`
`
`
`
`
`
`
`2019
`
`Andrews, et al v. Plains All American Pipeline, L.P. et al
`
`No. 2:15-cv-04113-PSG-JEM
`
`United States District Court, Central District of California
`
`Mobile Tech, Inc. v. Sennco Solutions, Inc.
`
`No. IPR2018-01218
`
`United States Patent and Trademark Office
`
`
`
`
`
`
`
`
`
`CA
`
`(deposition)
`
`MO
`
`(deposition)
`
`Updated June 29, 2023 – Based on information available
`
`

`

`
`
`
`
`
`
`EXHIBIT 2
`EXHIBIT 2
`
`
`

`

`
`
`
`
`
`
`
`
`JOEL DELMAN | InformedInnovation
`2176 W. 24th Street, Los Angeles, CA 90018 773.517.1862 joel@informedinnovationinc.com
`
`
`Formerly a corporate lawyer, I graduated Harvard Law School and later earned a Master's in
`Industrial Design at Pratt Institute. From toys to complex medical devices, I've spent nearly 30
`years guiding innovation through strategic product development, and have helped hundreds of
`clients bridge the gap between creative insight and commercial success.
`
`
`EDUCATION Pratt Institute Master of Industrial Design, 1995
`Harvard Law School J.D. 1991
`
`
`
`New York University B.S. Economics, 1988
`
`
`
`
`PROFESSIONAL EXPERIENCE
`
`Design
`Director
`
`Informed Innovation Inc.
`Los Angeles, CA 2018 – Present
`• Strategic consulting agency focused on the application of design thinking to clients’
`most challenging business opportunities
`
`
`Product Development Technologies LLC
`Los Angeles, CA 1999 – 2018
`• Promoted effective user-centered design processes in a fast-paced, multidisciplinary
`consulting environment
`• Managed all issues related to intellectual property, licensing of technology, and the many
`legal facets of design and development
`• Founded and directed PDT’s Informed Innovation division, charged with generating
`proprietary products for license to leading manufacturers; delivered over 300% ROI
`• Responsible for multiple large scale programs for a diverse range of clients, from complex
`medical devices to mass market consumer electronics
`
`ArtCenter College of Design
`Pasadena, CA August 2019 – Present
`• Graduate level class in portfolio development and professional practice
`
`Metamason Inc.
`Pasadena, CA 2013 – Present
`• Healthcare focused startup capitalizing on 3D printing technologies to automate the
`creation of custom-fit medical devices
`• Engage, advise and take part in decisions impacting all aspects of corporate strategy,
`fundraising and governance
`
`
`Make in LA
`
`Los Angeles, CA 2016 – Present
`• Provide guidance to startups, from the perspective of product development and design
`strategy, at Los Angeles’ first dedicated hardware accelerator
`
`The Design Accelerator
`Pasadena, CA 2013 – Present
`• Partnership among Art Center College of Design, Caltech and Idealab implimenting
`low-cost management techniqes to help design-driven tech startups grow into scalable
`technology businesses
`
`
`
`
`
`Creative
`Director
`
`
`Associate
`Professor
`
`
`Board of
`Directors
`
`
`Mentor &
`Advisor
`
`Mentor &
`Advisor
`
`
`
`
`
`

`

`
`Principal
`
`
`
`
`Designer
`
`
`
`•
`
`Twenty Twenty Thinking Inc.
`Chicago, IL 1997 – 1999
`Invented, developed and licensed magical toy concepts, including the award-winning
`Bubble Bugstm and Exclamation! Pentm
`• Built successful licensing revenue stream, leveraging background in business, law and
`design to go head-to-head with established toy development firms
`
`Zenith Electronics Corp.
`Chicago, IL 1995 – 1997
`• Managed brand development through design of next gen televisions, remotes and media
`devices for giant American electronics manufacturer challenged by Asian competition
`
`
`Designer Cousins Design
`
`
`New York, NY 1993 – 1995
`• Responsible for all phases of design process at renowned boutique firm, from initial
`concept development through client presentations
`
`
`Attorney Gunster, Yoakley & Stewart
`
`
`West Palm Beach, FL 1991 – 1993
`• Creative problem solving for a variety of complex corporate, banking and securities
`matters, focused on the legal needs of entrepreneurial businesses
`
`
`HONORS
`
`
`Chair, IDSA Design Protection Committee
`(Industrial Designers Society of America)
`IDSA 20/20 Award
`Recognizing twenty designers who contributed to the advancement
`of the design profession in 2020
`40+ US Patents and Patents Applied For
`Dr. Toy Best New Toy, Gold Award
`
`ID 40 Award, ID Magazine
`Good Design Award, Chicago Athenaeum
`CES Innovation Award, Consumer Electronics Association
`Industrial Design Excellence Award (IDEA), Industrial Designers Society of America
`Wall Street Journal “Form + Function” Column, Featured Designer
`Becoming a Product Designer, Profiled by author and distinguished designer
`Bruce Hannah
`
`
`
`
`
`
`
`SELECT CLIENTS
`
`
`
`
`

`

`JOEL DELMAN | InformedInnovation
`2176 W. 24th Street, Los Angeles, CA 90018 773.517.1862 joel@informedinnovationinc.com
`
`
`
`Expert Witness Experience
`
`
`Under the Weather, LLC v. Alvantor Industry Company, Ltd. (Design Patent Infringement)
`Date of engagement: August, 2024
`California Central District Court, Case No. 2:23-cv-08343-MRA-E
`Expert for Plaintiff, engaged by Friedland Cianfrani LLP
`Patent evaluation, Expert Declaration
`
`SharkNinja, Inc. v. Dyson Technology Ltd. (Utility Patent IPR)
`Date of engagement: June, 2024
`Before the Patent Trial and Appeal Board, Case No. IPR2024-00219
`Expert for Paten