`36619
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`Exhibit 3
`Public Redacted Version
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 2 of 117 PageID#
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`36620
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`INTENSITY
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`INTENSITY, LLC
`intensity.com
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
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`Case No. 1:20-cv-00393-LMB-WEF
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`DECLARATION OF
`RYAN SULLIVAN, Ph.D.
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`PHILIP MORRIS PRODUCTS S.A.,
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`Plaintiff,
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`R.J. REYNOLDS VAPOR COMPANY,
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`Defendant.
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`v.
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`CONFIDENTIAL BUSINESS INFORMATION – SUBJECT TO PROTECTIVE ORDER
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 3 of 117 PageID#
`36621
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 4 of 117 PageID#
`36622
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 5 of 117 PageID#
`36623
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 6 of 117 PageID#
`36624
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 7 of 117 PageID#
`36625
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 8 of 117 PageID#
`36626
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 9 of 117 PageID#
`36627
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 10 of 117 PageID#
`36628
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 11 of 117 PageID#
`36629
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 12 of 117 PageID#
`36630
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 13 of 117 PageID#
`36631
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 14 of 117 PageID#
`36632
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 15 of 117 PageID#
`36633
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 16 of 117 PageID#
`36634
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 17 of 117 PageID#
`36635
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 18 of 117 PageID#
`36636
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 19 of 117 PageID#
`36637
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 20 of 117 PageID#
`36638
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 21 of 117 PageID#
`36639
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 22 of 117 PageID#
`36640
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 23 of 117 PageID#
`36641
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 24 of 117 PageID#
`36642
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 25 of 117 PageID#
`36643
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 26 of 117 PageID#
`36644
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 27 of 117 PageID#
`36645
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`Attachment A-1
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 28 of 117 PageID#
`36646
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`1111!®
`iiil INTENSITY
`
`Ryan Sullivan, Ph.D.
`President
`
`INTENSITY, LLC
`www.intensity.com
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`September 2022
`
`Ryan Sullivan, Ph.D. is President of Intensity, LLC and provides expertise in economics, finance,
`and statistics. He applies his expertise to solve complex and challenging issues that
`organizations face in the competitive marketplace and the courtroom.
`■ Litigation & Disputes. Dr. Sullivan has wide-ranging experience with the economics of
`intellectual property and technology, technically demanding analyses of antitrust and
`competition, robust statistical modeling for labor and employment issues, and detailed
`quantitative analyses for securities and finance disputes.
`
`■ Business Analytics. Dr. Sullivan develops and implements state-of-the-art predictive models
`that provide reliable, evidence-based insights into business outcomes. These predictive
`models are implemented across a spectrum of business challenges, including price
`optimization, promotional programs, business strategy, forecasting, and investing.
`
`Dr. Sullivan is a recognized top U.S. economic expert by Intellectual Asset Management in each
`year from 2014 to 2021. Dr. Sullivan was rated at the top gold-band level reserved for those
`professionals highest among their peers in the field. According to IAM, "Ryan Sullivan uses
`sophisticated economic models to solve the trickiest damages conundrums."
`1AM further
`commented that the "outstanding academician is celebrated for his creative but rigorous, data
`driven approach and deep engagement with the questions at hand."
`
`Dr. Sullivan is often retained to provide expert testimony in high-stakes commercial litigation.
`He has provided expert testimony in more than a dozen cases that each had more than $1 billion
`in controversy. Dr. Sullivan has testified at trial in more than 25 cases and provided expert
`reports and deposition testimony in more than 100 cases. Dr. Sullivan's litigation-related work
`includes the following cases:
`
`■ Juno Therapeutics v. Kite Pharma. Dr. Sullivan worked on behalf of Juno Therapeutics and
`Sloan Kettering in patent litigation involving cancer immunotherapy. Juno, a subsidiary of
`Bristol-Myers Squibb, and Sloan Kettering claimed that Kite Pharma, a subsidiary of Gilead
`Sciences, infringed their patent. The technology at issue involved genetically engineering T
`cells to fight cancer, which is known as CAR-T therapy. Economic issues included the
`contribution of the patented technology to Kite's allegedly infringing product, availability of
`potential non-infringing alternatives, stage of development of licensed technology,
`competitive relationship between Juno and Kite, financial harms and benefits from use of
`the patented technology by Kite, and market analysis of related license agreements.
`
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`36647
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` Lucent v. Microsoft. Dr. Sullivan worked on behalf of Microsoft in patent litigation involving
`video coding technology. Lucent Technologies and Multimedia Patent Trust claimed that
`the Microsoft Windows operating system and Xbox 360 infringed their patent. Dr. Sullivan
`evaluated the contribution of the patented technology to Microsoft’s products and the effects
`of licensing through patent pools. Economic issues included patent pools, cross licensing,
`FRAND rates, software cost structure, and reasonable royalties.
`
` Abbott Cardiovascular v. Edwards Lifesciences. Dr. Sullivan worked on behalf of Edwards
`Lifesciences in patent litigation involving devices used to treat mitral regurgitation, where
`the leaflets of the mitral valve do not close tightly and allow blood to backfill into the heart.
`Abbott claimed that Edwards’ PASCAL device violated several of its patents and was harming
`sales of its competing MitraClip product. Abbott sought injunctive relief and economic
`damages. Economic issues included an examination of products in the structural heart
`device marketplace, market definition, competition, pricing dynamics, existing license
`agreements, and product substitution patterns at the customer level.
`
` Ritz v. SanDisk. Dr. Sullivan worked on behalf of plaintiffs in antitrust litigation involving
`NAND flash memory and related patent licensing. Dr. Sullivan’s evaluation of price injury
`included analysis of licensing revenue, apportionment of licensing revenue to disputed
`patents, and implementation of an econometric model relating product pricing to competitor
`costs and other factors. Economic issues included market definition, market power, class
`definition, apportionment, and pass-through of costs.
`
` T-Mobile v. Huawei. Dr. Sullivan worked on behalf of T-Mobile in trade secret litigation
`involving Huawei’s misappropriation of T-Mobile’s robot testing system for mobile devices.
`Dr. Sullivan evaluated T-Mobile’s actual losses and Huawei’s unjust enrichment resulting
`from Huawei’s misappropriation of trade secrets and breach of contract. Economic issues
`included the technology’s contribution to profits, supply agreements, product sales, and
`product costs.
`
`Dr. Sullivan served as an invited member of the Economics Leadership Council at the University
`of California, San Diego. In this role, he provided guidance to the Department of Economics
`faculty on the application of economic science in private industry.
`
`Dr. Sullivan served as the Treasurer and an officer on the Board of Trustees for San Diego Zoo
`Global, now known as the San Diego Zoo Wildlife Alliance, which is an international, nonprofit
`conservation organization with two front doors: the San Diego Zoo and the San Diego Zoo Safari
`Park.
`
`Dr. Sullivan earned his B.A., M.A., and Ph.D. in economics from the University of California, San
`Diego. While at UC San Diego, Dr. Sullivan used advanced statistical methods to evaluate the
`predictive ability of econometric models. He has published economic research in top-tier, peer-
`reviewed academic journals—including the Journal of Finance, the Journal of Econometrics, and
`the International Journal of Forecasting—as well as articles on the economics of intellectual
`assets.
`
`
`CV of Ryan Sullivan, Ph.D.
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`Dr. Sullivan has provided professional economic services since 1992. He established Quant
`Economics, Inc. in 2006 and Intensity in 2014.
`
`Education
`Ph.D., Economics, University of California, San Diego
`
`M.A., Economics, University of California, San Diego
`
`B.A., Economics, University of California, San Diego
`
`Employment
`Intensity, LLC. President, 2014 to present.
`
`Quant Economics, Inc. President, 2006 to 2014.
`
`Bates White, LLC. Manager, 2001 to 2003. Principal, 2003 to 2006.
`
`Econ One Research, Inc. Economist, 2000 to 2001.
`
`Economic Analysis, LLC. Economist, 1998 to 2000.
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`INDETEC International, Inc. Economic Analyst, 1992 to 1998.
`
`Professional Experience
`
` Litigation & Disputes
` Dr. Sullivan has wide-ranging experience with the economics of intellectual property and
`technology across life sciences, consumer electronics, and other industries. In one example,
`he calculated the profits lost by a branded drug company as a result of an “at-risk” launch
`of generic versions of a blockbuster drug by generic drug suppliers, including reconstruction
`of the market but for the alleged infringement and detailed analysis of price effects. In
`another example, he calculated reasonable royalties in litigation involving video coding
`technology used in personal computers and gaming devices, including investigation of
`standard-essential patents, reasonable and non-discriminatory licensing practices, and the
`impact of patent licensing pools.
`
` Dr. Sullivan develops technically demanding analyses of antitrust and competition in the
`context of merger evaluation, antitrust claims, and related issues, such as alleged unfair
`competition and breach of contract. In one example, he examined allegations of tying,
`exclusive dealing, and other anticompetitive conduct in the aerospace equipment industry.
`His market power inquiry included defining the relevant market and directly determining
`competitive effects of the alleged conduct. In another example, Dr. Sullivan developed
`sophisticated statistical models of product sales to estimate economic damages. In addition
`
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`CV of Ryan Sullivan, Ph.D.
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`36649
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`to measuring the effect of the alleged conduct, his models included a scientific test to assess
`the fact of damages.
`
` Dr. Sullivan applies robust statistical analyses to evaluate labor and employment issues. In
`one example, he evaluated a statistical sampling methodology for estimating the amount of
`time spent by managers performing non-exempt duties, which informed class certification.
`In another example, Dr. Sullivan evaluated the economic impact of an employee raid
`between two large insurance companies, using an econometric model that accurately
`separated the effects of the alleged conduct from unrelated factors, including the 2008
`financial crisis.
`
` Dr. Sullivan implements detailed quantitative analyses for securities and finance disputes.
`In one example, he developed a probabilistic model of distressed equity and drivers of value,
`and advised on reliable trading strategies. In another example, he conducted detailed
`statistical analysis of stock options to test whether the pattern of observed option grants
`utilized unfair hindsight or sound foresight. In a third example, Dr. Sullivan implemented
`sophisticated event-study analyses and stock trading models to calculate economic damages
`to investors resulting from alleged accounting misstatements and other fraudulent claims.
`
` Business Analytics
` Dr. Sullivan develops and implements state-of-the-art predictive models that provide
`reliable, evidence-based insights into business outcomes. These predictive models are
`implemented across a spectrum of business challenges, including price optimization,
`promotional programs, business strategy, and forecasting.
`
` Dr. Sullivan designs and develops price optimization programs that systematically improve
`business performance. In one example, he designed a price improvement program for a
`high-traffic online retailer that sells a diverse set of products that have widely varying
`consumer price sensitivity. His approach combined scientific testing that measures
`consumer response with adaptive pricing models that continuously update prices as market
`conditions change. In another example, Dr. Sullivan developed high-frequency price
`updating strategies that optimize a specialized statistic of business performance that
`includes revenue per order, profit per order, conversion rate, and repurchase rate.
`
` Dr. Sullivan designs and implements scientifically valid analyses that directly guide
`promotional activity and demonstrably improve customer engagement. For example, he
`performed analysis for pharmaceutical companies to determine which physicians should be
`visited, when they should be detailed, and how many samples should be provided at each
`visit. In another example, Dr. Sullivan designed a promotional testing and optimization
`program that combined individual customer attributes and dynamic market factors to
`deliver unique communications to each customer, including variation among types of
`discounts, featured products, and messaging.
`
` Dr. Sullivan applies real-world economic expertise to solve challenging problems facing
`sports franchises, player associations, and entertainment companies. In one example, he
`performed extensive economic analysis of digital video recorder technology, its effect on
`
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`CV of Ryan Sullivan, Ph.D.
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`36650
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`consumer viewing behavior, and corresponding impacts on the value of live sports content.
`In another example, Dr. Sullivan
`investigated compensation mechanisms, player
`constraints, and strategic bargaining in the context of professional sports leagues, including
`a combination of economic theory and detailed data analysis to identify means of
`improvement for both players and teams.
`
` Dr. Sullivan employs predictive analytics that target a collection of performance metrics for
`determining reliable investments, including equity selection, trade timing, position size,
`duration of entry, and duration of exit. Select performance metrics include company
`revenue, company earnings, trade volume, and returns. Dr. Sullivan also incorporates
`state-of-the-art business cycle forecasts that quantify high-dimensional, time-varying
`relationships, as well as risk management techniques that limit downside movements.
`
` Dr. Sullivan implements methods that avoid data snooping, spurious correlations, look-
`ahead bias, and overfitting. Early in his career, Dr. Sullivan pioneered the application of
`advanced statistical methods that quantify data-snooping biases, which occur when a given
`set of data is used more than once for purposes of inference or model selection. When such
`data reuse occurs, there is a possibility that any seemingly positive model performance may
`simply be due to chance rather than any merits of the model. Through more than two
`decades of hands-on work in predictive modeling, Dr. Sullivan developed methodologies that
`effectively combine statistical techniques to reduce data-snooping biases and deliver reliable
`results.
`
`Publications and Papers
`Sullivan, Ryan, DeForest McDuff, and Justin Skinner: “Downgrade to ‘Neutral’: A Diminishing
`Role of the Georgia-Pacific Factors in Reasonable Royalty Analyses,” (2015) les Nouvelles 50(3),
`134-137.
`
`Sullivan, Ryan and John Scherling: “Reincarnation of Reasonable Royalty Damages,” (2015)
`Intellectual Property Magazine, May 2015, 58-60.
`
`Sullivan, Ryan and DeForest McDuff: “AstraZeneca and Damages In ‘At-Risk’ Generic Drug
`Launches” (2015) Law360, April 28, 2015.
`
`Schayes, Danny, Mickey Ferri, and Ryan Sullivan: “One and Done: A Data-Driven Analysis”
`(2014) Intensity Corporation.
`
`Schayes, Danny and Ryan Sullivan: “How Much are the Atlanta Hawks Worth?” (2014) Sheridan
`Hoops, September 11, 2014.
`
`Sullivan, Ryan and John Scherling: “Rational Reasonable Royalty Damages: A Return to the
`Roots,” (2011) Landslide 4(2), 55–58.
`
`Sullivan, Ryan: “A Holistic Approach to Patent Damages Analysis,” (2006) in Daniel Slottje, ed.,
`Economic Damages in Intellectual Property: A Hands-On Guide to Litigation, John Wiley & Sons.
`
`Sullivan, Ryan, Allan Timmermann, and Halbert White: “Forecast Evaluation with Shared Data
`Sets,” (2003) International Journal of Forecasting 19(2), 217-227.
`
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`CV of Ryan Sullivan, Ph.D.
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`Page 5 of 18
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`36651
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`Sullivan, Ryan, Allan Timmermann, and Halbert White: “Dangers of Data-Mining: The Case of
`Calendar Effects in Stock Returns,” (2001) Journal of Econometrics 105(1), 249-286.
`
`Sullivan, Ryan, Allan Timmermann, and Halbert White: “Data-Snooping, Technical Trading Rule
`Performance, and the Bootstrap,” (1999) Journal of Finance 54(5), 1647-1691.
`
`Sullivan, Ryan, and Halbert White: “Finite Sample Properties of the Bootstrap Reality Check for
`Data-Snooping: A Monte Carlo Assessment,” (1999) UCSD manuscript.
`
`Sullivan, Ryan: “Instability and Prediction Error in Model Selection,” (1996) UCSD manuscript.
`
`Sullivan, Ryan: “A Neural Network Forecast of the S&P 500,” (1995) UCSD manuscript.
`
`Speaking Engagements
`“Applied Economics and Business Analytics,” Rady School of Management, University of
`California, San Diego, March 2020.
`
`“Applied Economics and Business Analytics,” ECONference, University of California, San Diego,
`April 2019.
`
`“Feedback Loop of Licensing and Royalties,” San Diego Intellectual Property Law Association,
`October 2018.
`
` “A Brave New World of Patent Damages,” San Diego Intellectual Property Law Association, April
`2016.
`
`Keynote address, “Perfecting the Science of Professional Success,” 7th Annual Winter Business
`Leadership Conference, Rady School of Management, University of California, San Diego,
`January 2015.
`
` “Application of Economic Science in Private Industry,” MicroMBA, Rady School of Management,
`University of California, San Diego, June 2014.
`
`“Asset Valuation for Patent Monetization: A review of valuation methods and transaction
`structures,” Best Practices in Patent Monetization, San Francisco, California, March 2014.
`
`Keynote address, “Perfecting the Science of Personal Achievement,” Financial Horizons
`Conference, Rady School of Management, University of California, San Diego, March 2013.
`
`“Reasonable Royalty Damages: A Return to the Roots,” American Bar Association, February
`2012.
`
`“Patent Damages: Economic Perspectives on Lucent, ResQNet, and Uniloc,” San Diego
`Intellectual Property Law Association, February 2011.
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`“Economics in Patent Litigation,” University of San Diego, School of Law, February 2010.
`
`“The Evolution of Patent Damages,” Orange County Patent Law Association, November 2007.
`
`“Economics of Intellectual Property,” San Diego County Bar Association, Carmel Valley / UTC
`Section, March 2007.
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`CV of Ryan Sullivan, Ph.D.
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`Page 6 of 18
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`36652
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`Financial Horizons Conference, Undergraduate Investment Society, University of California, San
`Diego, March 2007.
`
`“Allocating Risk in Intellectual Property Licensing Agreements,” CommNexus San Diego,
`November 2006.
`
`“The Master Class on Licensing Agreements for the Financial Services Industry” and “Asserting
`Rights to Your Financial Services Innovation through Patent Litigation,” Optimizing Patents and
`IP in Financial Products & Services, New York, New York, June 2006.
`
`Keynote address, “Economics in Intellectual Property,” California Bar Association, 30th Annual
`Intellectual Property Institute, Napa Valley, California, November 2005.
`
`“Initial Analysis and Planning: Choosing the Expert and Getting Started,” Expert testimony in
`litigation: Capitalizing on expertise for success, Reston, Virginia, December 2004.
`
`“Initial Analysis and Planning: Choosing the Expert and Getting Started,” Effective financial
`expert testimony: Significant strategies and tactics, San Francisco, California, November 2004.
`
`“Applying Daubert Principles to the Use of Computer Simulation to Develop an Estimate of the
`‘But For’ World for Damages Calculations,” Calculating and proving patent damages: Beyond the
`usual courses of action for pursuit and defense, Seattle, Washington, November 2004.
`
`“Applying Daubert Principles to the Use of Computer Simulation to Develop an Estimate of the
`‘But For’ World for Damages Calculations,” Calculating and proving patent damages: Beyond the
`usual courses of action for pursuit and defense, Atlanta, Georgia, October 2004.
`
`“Taking a Holistic Approach to Patent Damages Analysis,” Calculating and proving patent
`damages: Recent developments and new tools for success, San Francisco, California, July 2004.
`
`Professional Services and Associations
`Referee, American Economic Review
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`Referee, Journal of Business
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`Referee, Journal of Econometrics
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`Referee, Journal of Financial Econometrics
`
`Referee, Journal of Financial Research
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`Referee, Journal of Forecasting
`
`Referee, Quantitative Finance
`
`Member, American Economic Association
`
`Member, American Finance Association
`
`Member, Econometric Society
`
`Member, Economics Leadership Council, University of California, San Diego
`
`
`CV of Ryan Sullivan, Ph.D.
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`36653
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`Member, Licensing Executives Society
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`Associate Member, American Bar Association, Intellectual Property and Antitrust Sections
`
`Treasurer, Board of Trustees, San Diego Zoo Global
`
`Expert Testimony
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`12.
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`District of Columbia v. NRA Foundation, Inc. and National Rifle Association of America.
`Superior Court for the District of Columbia, Case No. 2020 CA 003454 B. Expert report.
`
`PACT XPP Schweiz AG v. Intel Corporation. United States District Court, District of
`Delaware, Case No. 1:19-cv-01006. Expert report and deposition.
`
`Natera, Inc. v. ArcherDX, Inc., ArcherDX, LLC, and Invitae Corp. United States District
`Court, District of Delaware, Case No. 1:20-cv-00125. Expert report and deposition.
`
`Eolas Technologies Incorporated v. Google LLC. United States District Court, Northern
`District of California, Case No. 4:17-cv-01138. Expert report and deposition.
`
`J.R. Simplot Company v. McCain Foods USA, Inc. United States District Court, District of
`Idaho, Case No. 1:16-cv-00449. Expert report and deposition.
`
`Bio-Rad Laboratories, Inc. v. 10x Genomics, Inc. United States District Court, District of
`Massachusetts, Case No. 1:19-cv-12533. Expert report and deposition.
`
`RAI Strategic Holdings, Inc. and R.J. Reynolds Vapor Company v. Altria Client Services,
`LLC; Philip Morris USA, Inc.; and Philip Morris Products S.A. United States District Court,
`Eastern District of Virginia, Case No. 1:20-cv-00393. Expert report and deposition.
`
`VLSI Technology LLC v. Intel Corporation. United States District Court, District of
`Delaware, Case No. 1:18-cv-00966. Expert report and deposition.
`
`VLSI Technology LLC v. Intel Corporation. United States District Court, Western District
`of Texas, Case Nos. 6:19-cv-00254, 6:19-cv-00255, and 6:19-cv-00256. Expert report,
`deposition, and trial.
`
`Evalve, Inc., Abbott Cardiovascular Systems, Inc., and Abbott Medical Ireland Limited v.
`Edwards Lifesciences Ireland Limited, Edwards Lifesciences Corp., and Edwards
`Lifesciences, LLC. The High Court Commercial, Record No. 2020/1219P. Expert report.
`
`CommScope, Inc. v. Rosenberger Technology (Kunshan) Co. Ltd., Rosenberger Asia Pacific
`Electronic Co., Ltd., Rosenberger Technology LLC, Rosenberger USA Corp., Rosenberger
`North America Pennsauken,
`Inc., Rosenberger Site Solutions, LLC, Rosenberger
`Hochfrequenztechnik GmbH & Co. KG, Northwest Instrument, Inc., CellMax Technologies
`AB, Janet Javier, and Robert Cameron. United States District Court, District of New
`Jersey, Case No. 2:19-cv-15962. Expert report and deposition.
`
`Dentsply Sirona, Inc. and Tulsa Dental Products LLC d/b/a Dentsply Sirona Endodontics
`v. Edge Endo, LLC and US Endodontics, LLC. United States District Court, District of New
`Mexico, Case No. 1:17-cv-01041. Expert report and deposition.
`
`CV of Ryan Sullivan, Ph.D.
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`Page 8 of 18
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`ClearPlay, Inc. v. DISH Network L.L.C. and EchoStar Technologies L.L.C. United States
`District Court, District of Utah, Central Division, Case No. 2:14-cv-00191. Expert report
`and deposition.
`
`Amgen Inc. and Amgen Manufacturing Limited v. Hospira, Inc. and Pfizer Inc. United States
`District Court, District of Delaware, Case No. 1:18-cv-01064. Expert report and
`deposition.
`
`Certain Botulinum Toxin Products, Processes for Manufacturing or Relating to Same and
`Certain Products Containing Same. United States International Trade Commission,
`Investigation No. 337-TA-1145. Expert report, deposition, and trial.
`
`Certain Digital Video Receivers, Broadband Gateways, and Related Hardware and
`Software Components. United States International Trade Commission, Investigation No.
`337-TA-1158. Expert report, deposition, and trial.
`
`Nike, Inc. v. Skechers U.S.A., Inc. United States District Court, Central District of
`California, Case No. 2:17-cv-08509. Expert report and deposition.
`
`Sumotext Corp. v. Zoove, Inc., Virtual Hold Technology LLC, StarSteve, LLC, and VHT
`StarStar LLC. United States District Court, Northern District of California, Case No. 5:16-
`cv-01370. Expert report, deposition, and trial.
`
`Juno Therapeutics, Inc., Memorial Sloan Kettering Cancer Center, and Sloan Kettering
`Institute for Cancer Research v. Kite Pharma, Inc. United States District Court, Central
`District of California, Case No. 2:17-cv-07639. Expert report, deposition, and trial.
`
`Abbott Cardiovascular Systems, Inc. and Evalve, Inc. v. Edwards Lifesciences Corp. and
`Edwards Lifesciences, LLC. United States District Court, District of Delaware, Case No.
`1:19-cv-00149. Expert report, deposition, and hearing.
`
`In the Matter of Certain LTE- and 3G- Compliant Cellular Communications Devices. United
`States International Trade Commission, Investigation No. 337-TA-1138. Expert report,
`deposition, and trial.
`
`Applied Invention, LLC v. E.I. DuPont De Nemours & Co. and Pioneer Hi-Bred International,
`Inc. American Arbitration Association, Case No. 01-18-0000-8614. Expert report.
`
`Fundamental Innovation Systems International LLC v. LG Electronics, Inc., LG Electronics
`U.S.A., Inc., LG Electronics Mobilecomm U.S.A. Inc., LG Electronics Mobile Research U.S.A.
`LLC, and LG Electronics Alabama, Inc. United States District Court, Eastern District of
`Texas, Case No. 2:16-cv-01425. Expert report and deposition.
`
`Fundamental Innovation Systems International LLC v. Huawei Device USA, Inc. and
`Huawei Device Co., Ltd. United States District Court, Eastern District of Texas, Case No.
`2:16-cv-01424. Expert report and deposition.
`
`Rovi Guides, Inc. and TiVo Solutions, Inc. v. Telus Corporation, Telus Communications, Inc.,
`and Telus Communications Company. Federal Court of Canada, Case No. T-206-18.
`Expert report and deposition.
`
`Rovi Guides, Inc. and TiVo Solutions, Inc. v. BCE, Inc., Bell Canada, Bell Aliant Regional
`Communications, Inc., Bell MTS, Inc., and NorthernTel, L.P. Federal Court of Canada, Case
`No. T-113-18. Expert report and deposition.
`
`
`CV of Ryan Sullivan, Ph.D.
`
`
`
`
`Page 9 of 18
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`Case 1:20-cv-00393-LMB-WEF Document 1423-3 Filed 09/02/22 Page 37 of 117 PageID#
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`Fundamental Innovation Systems International, LLC v. Samsung Electronics Co., Ltd. and
`Samsung Electronics America, Inc. United States District Court, Eastern District of Texas,
`Case No. 2:17-cv-00145. Expert report and deposition.
`
`Egenera, Inc. v. Cisco Systems, Inc. United States District Court, District of
`Massachusetts, Case No. 1:16-cv-11613. Expert report, deposition, and trial.
`
`In the Matter of Certain Microfluidic Devices. United States International Trade
`Commission, Investigation No. 337-TA-1068. Expert report, deposition, and trial.
`
`Tecsec, Incorporated v. International Business Machines Corporation, SAS Institute, Inc.,
`SAP America, Inc., SAP, AG, Cisco Systems, Inc., Oracle America, Inc. (f/k/a Sun
`Microsystems, Inc.), Sybase, Inc., Software AG, Software AG, Inc., Adobe Systems
`Incorporated, eBay, Inc., PayPal, Inc., and Oracle Corporation. United States District
`Court, Eastern District of Virginia, Case No. 1:10-cv-00115. Expert report, deposition,
`and trial.
`
`Cave Consulting Group, Inc. v. OptumInsight, Inc. United States District Court, Northern
`District of California, Case No. 3:15-cv-03424. Expert report and deposition.
`
`Bio-Rad Laboratories, Inc. and The University of Chicago v. 10x Genomics, Inc. United
`States District Court, District of Delaware, Case No. 1:15-cv-00152. Expert report
`deposition and trial.
`
`Securus Technologies, Inc. v. Global Tel*Link Corporation. United States District Court,
`Northern District of Texas, Case No. 3:16-cv-01338. Expert report.
`
`Parsons Xtreme Golf, LLC v. Taylor Made Golf Company, Inc. United States District Court,
`District of Arizona, Case No. 2:17-cv-03125. Expert report.
`
`Rovi Guides, Inc., Rovi Technologies Corp., and Veveo, Inc. v. Comcast Corporation,
`Comcast Cable Communications, LLC, Comcast Communications Management, LLC,
`Comcast of Houston, LLC, Comcast Holdings Corporation, and Comcast Shared Services,
`LLC. United States District Court, Southern District of New York, Case No. 1:16-cv-
`09278. Expert report and deposition.
`
`Credit Suisse Securities (USA) LLC v. UBS Financial Services, Inc. Financial Industry
`Regulatory Authority, Claim No. 15-03186. Expert report and trial.
`
`Ethicon Endo-Surgery, Inc. and Ethicon Endo-Surgery, LLC v. Covidien LP, Covidien Sales,
`LLC, and Covidien AG. United States District Court, District of Massachusetts, Case No.
`1:16-cv-12556. Expert report, deposition, and trial.
`
`Illumina, Inc. v. Ariosa Diagnostics, Inc. and Verinata Health, Inc. v. Ariosa Diagnostics,
`Inc. United States District Court, Northern District of California, Case Nos. 3:15-cv-
`02216, 3:14-cv-01921, and 3:12-cv-05501. Expert report, deposition, and trial.
`
`Celltrion, Inc. v. Genentech, Inc. and Biogen, Inc. United States Patent and Trademark
`Office, Patent Trial and Appeal Board, Case IPR2016-01614. Expert report.
`
`IMAX Corporation v. Three-Dimensional Media Group, Ltd. and UNIPAT.org. American
`Arbitration Association, Case No. 50-133-T-00201-06. Expert report and trial.
`
`CV of Ryan Sulli