STEPTOE &}oHNsoNm=
`ATTORNEYS AT LAW
`
`Charles F. Schill
`
`202.429.8162
`c5chll|@steptoe.com
`
`May 20, 201 1
`
`I330 Connecticut Avenue. NW
`
`Washington. DC 20036-I795
`Tel 202.429.3000
`Fax 202.429.3902
`sreptoe.com
`
`VIA ELECTRONIC FILING
`The Honorable James Holbein
`
`Secretary
`U.S. International Trade Commission
`
`500 E Street, SW
`Washington, D.C. 20436
`
`Re:
`
`Certain Mobile Devices and Related Software
`Inv. No. 33 7-TA-750
`
`Dear Secretary Holbein:
`
`Enclosed for submission in the above-referenced investigation please find Respondents’
`
`Identification of Expert Witnesses filed electronically on behalf of Motorola, Inc., n/lr/a
`
`Motorola Solutions, Inc., and Motorola Mobility, Inc.
`
`Please do not hesitate to contact me directly at 202.429.8162 should you have any
`
`questions.
`
`Respectfully submitted,
`
`
`
`Charles F. Schill
`
`STEPTOE & JOHNSON LLP
`
`1330 Connecticut Avenue, NW
`Washington, DC 20036
`Tel: 202.429.3000
`
`Fax: 202.429.3902
`
`Counselfor Motorola, Inc.,
`n/k/a Motorola Solutions, Inc, and
`
`Motorola Mobility, Inc.
`
`WASHINGTON I NEWYORK 0 CHICAGO 4
`
`PHOENIX '
`
`LOS ANGELES
`
`' CENTURY CITY 0
`
`LONDON '
`
`BRUSSELS
`
`I BEIIING
`
`

`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, D.C.
`
`Before The Honorable Theodore R. Essex
`
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN MOBILE DEVICES AND
`
`RELATED SOFTWARE
`
`Investigation No. 337-TA-750
`
`
`
`RESPONDENTS' IDENTIFICATION OF EXPERT WITNESSES
`
`Pursuant to Procedural Order No. 4 and Ground Rule 6, Respondents Motorola, Inc.,
`
`n/k/a Motorola Solutions, Inc., and Motorola Mobility, Inc. (collectively, "Motorola") provide
`
`the following identification of expert witnesses who may testify on their behalf. Discovery in
`
`this investigation is ongoing and expected areas of testimony and expert opinion are based on the
`
`information produced in this investigation to date. Motorola reserves the right to supplement its
`
`identification of experts and/or areas of testimony and expert opinion based on further discovery,
`
`review of new or yet-to-be-produced documents or depositions, or other developments in this
`
`investigation.
`
`Peter Alexander
`
`Peter Alexander's areas of expertise include computer science, software and hardware
`
`engineering, and operating systems. Peter Alexander is expected to testify regarding matters
`
`relating to, at least and without limitation, technology embodied or claimed in the Asserted
`
`Patents, technology disclosed in the prior art, technology embodied in the accused products,
`
`claim construction, non-infringement, lack of domestic industry, invalidity, and/or
`
`02426.51 764."4l 5093 1 . l
`
`

`
`unenforceability of the asserted claims of one or more of U.S. Patent Nos. 7,812,828; 7,663,607;
`
`and 5,379,430 (collectively, the "Asserted Patents").
`
`A copy of his curriculum vitae is attached hereto as Exhibit A.
`
`Robert Dezmelyk
`
`Robert Dezmelyk's areas of expertise include software and hardware engineering, design
`
`and development of input devices, and touch technology. Robert Dezmelyk is expected to testify
`
`regarding matters relating to, at least and without limitation, technology embodied or claimed in
`
`the Asserted Patents, technology disclosed in the prior art, technology embodied in the accused
`
`products, claim construction, non-infringement, lack of domestic industry, invalidity, and/or
`
`unenforceability of the asserted claims of one or more of the Asserted Patents.
`
`A copy of his curriculum vitae is attached hereto as Exhibit B.
`
`Charles R. Donohoe
`
`Charles Donohoe's areas of expertise include licensing of patents and technology, and
`
`patent prosecution practices and procedures including the practices and procedures used in the
`
`United States Patent and Trademark Office ("USPTO"). Charles Donohoe is expected to testify
`
`regarding matters relating to, at least and without limitation, issues of patent licensing including
`
`but not limited to, the licensing of the Asserted Patents; non-infringement; lack of domestic
`
`industry; unenforceability with respect to one or more of the Asserted Patents; and the practices
`
`and procedures used in prosecuting patent applications.
`
`A copy of his curriculum vitae is attached hereto as Exhibit C.
`
`Marc D. Foodman
`
`Marc Foodman's area of expertise include licensing of patents and technology, and patent
`
`prosecution practices and procedures including the practices and procedures used in the United
`
`02426.5 I 764i4 I 5093] .l
`
`2
`
`

`
`States Patent and Trademark Office ("USPTO"). Marc Foodman is expected to testify regarding
`
`matters relating to, at least and without limitation, issues of patent licensing including but not
`
`limited to, the licensing of the Asserted Patents; non-infringement; lack of domestic industry;
`
`unenforceability with respect to one or more of the Asserted Patents; and the practices and
`
`procedures used in prosecuting patent applications.
`
`A copy of his curriculum vitae is attached hereto as Exhibit D.
`
`Michael S. Kogan
`
`Michael Kogan's areas of expertise include computer science, hardware and software
`
`engineering, operating systems and system software. Michael Kogan is expected to testify
`
`regarding matters relating to, at least and without limitation, technology embodied or claimed in
`
`the Asserted Patents, technology disclosed in the prior art, technology embodied in the accused
`
`products, claim construction, non-infringement, lack of domestic industry, invalidity, and/or
`
`unenforceability of the asserted claims of one or more of the Asserted Patents.
`
`A copy of his curriculum vitae is attached hereto as Exhibit E.
`
`C. Douglass Locke
`
`C. Douglass Locke's areas of expertise include computer science, hardware and software
`
`engineering, operating systems, and distributed systems. C. Douglass Locke is expected to
`
`testify regarding matters relating to, at least and without limitation, technology embodied or
`
`claimed in the Asserted Patents, technology disclosed in the prior art, technology embodied in
`
`the accused products, claim construction, non-infringement, lack of domestic industry, invalidity,
`
`and/or unenforceability of the asserted claims of one or more of the Asserted Patents.
`
`A copy of his curriculum vitae is attached hereto as Exhibit F.
`
`02426.5 l 764/4I5093l .1
`
`3
`
`

`
`Carla S. Mulhern
`
`Carla Mulhem's areas of expertise include economics, intellectual property valuation and
`
`licensing. Carla Mulhem is expected to testify regarding matters relating to, at least and without
`
`limitation, lack of domestic industry, remedy, public interest, bonding, and licensing with respect
`
`to one or more of the Asserted Patents.
`
`A copy of her curriculum vitae is attached hereto as Exhibit G.
`
`Andrew Wolfe
`
`Andrew Wolfe's areas of expertise include semiconductors, computer systems, software
`
`and hardware engineering, input devices, and touch technology. Andrew Wolfe is expected to
`
`testify regarding matters relating to, at least and without limitation, technology embodied or
`
`claimed in the Asserted Patents, technology disclosed in the prior art, technology embodied in
`
`the accused products, claim construction, non-infringement, lack of domestic industry, invalidity,
`
`and/or unenforceability of the asserted claims of one or more of the Asserted Patents.
`
`A copy of his curriculum vitae is attached hereto as Exhibit H.
`
`02426.5 l 764/4 1 5093 I .1
`
`4
`
`

`
`Dated: May 20, 2011
`
`Respectfully submitted,
`
` Charles F. Schill
`
`Steptoe & Johnson LLP
`1330 Connecticut Avenue, N.W.
`Washington, DC 20036
`Phone No. (202) 429-8162
`
`Charles K. Verhoeven
`
`David Eiseman
`
`Quinn Emanuel Urquhart & Sullivan LLP
`50 California Street, 22nd Floor
`
`San Francisco, CA 94111
`Phone No. (415) 875-6600
`
`Edward J. DeFranco
`
`Stephen T. Straub
`Quinn Emanuel Urquhart & Sullivan LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Phone No. (212) 849-7000
`
`David A. Nelson
`
`Quinn Emanuel Urquhart & Sullivan LLP
`500 West Madison Street, Ste. 2450
`Chicago, IL 60661
`Phone No. (312) 705-7400
`
`Attorneysfor Respondents Motorola, Inc.,
`n/Ir/a Motorola Solutions, Inc. and Motorola
`
`Mobility, Inc.
`
`02426.5 1 764/41 5093 l .1
`
`5
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that, on May 20, 2011, he caused
`RESPONDENT'S IDENTIFICATION OF EXPERT WITNESSES
`
`to be served upon the following parties as indicated below:
`
`The Honorable James Holbein
`
`El Via First Class Mail
`
`Secretary
`U.S. International Trade Commission
`
`500 E Street, SW, Room 112-F
`Washington, DC 20436
`
`E] Via Hand Delivery
`(Original plus six)
`IZI Via Electronic Filing (EDIS)
`El Via Overnight Courier
`El Via Facsimile
`
`El Via Email (PDF)
`
`The Honorable Theodore R. Essex
`
`I] Via First Class Mail
`
`Administrative Law Judge
`U.S. International Trade Commission
`
`500 E Street, SW
`Washington, DC 20436
`
`Anne Goalwin, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`
`500 E Street, SW
`Washington, DC 20436
`
`Mark Davis, Esq.
`Weil, Gotshall & Manges LLP
`1300 Eye Street, NW, Suite 900
`Washington, DC 20005
`
`Counselfor Complainant. Apple Inc.
`
`IZI Via Hand Delivery
`Two Copies
`El Via Overnight Courier
`III Via Facsimile
`
`Cl Via E-mail (PDF)
`
`III Via First Class Mail
`
`El Via Hand Delivery
`El Via Overnight Courier
`III Via Facsimile
`
`El Via E-mail (PDF)
`Anne. Goalwin@usz'tc. gov
`
`E] Via First Class Mail
`
`IZI Via Hand Delivery
`CI Via Overnight Courier
`CI Via Facsimile
`
`IZI Via E-mail (PDF)
`appIe.moto.750@wez'I.com
`applecov I cov.c0m
`
`
`
`0242651764/4l5093l .1
`
`

`
` Exhibit A
`
`Exhibit A
`
`

`
`PETER ALEXANDER, Ph.D.
`
`501 ½ Larkspur Avenue
`Corona del Mar, CA 92625
`Office (949) 760 9990 Cell (949) 689 8692
`email: peter.alexander@roadrunner.com
`
`EDUCATION
`
`Ph. D., Electrical Engineering, Massachusetts Institute of Technology, 1971
`MS, Electrical Engineering, University of Illinois, 1967
`BS, Electrical Engineering, University of Canterbury, New Zealand, 1965
`
`PROFESSIONAL AFFILIATIONS & AWARDS
`
`Fulbright Scholar, 1965
`National Science Foundation – Small Business Innovation Research, 1988
`Dept. of Energy – Small Business Innovation Research, 1988
`Member Association of Computing Machinery (ACM)
`Member IEEE Computer Society
`
`PROFESSIONAL EXPERIENCE - SUMMARY
`
`Technical Expertise - Computer software design, development & deployment
`x Forensic data acquisition and analysis
`x Microsoft Visual Studio component and application design
`x Web integration of authentication services, streaming media services, ad displays,
`content feeds
`x
`Implementation of real-time and media streaming systems
`x Architecture and design of complex business systems involving database back ends
`x Oracle 8i, 9i, SQL Server 2000, and DB2 database technology.
`x
`Java, C, C++, Visual Basic, assembly language programming
`x Embedded microprocessor designs
`x Network equipment design and manufacture (LAN cards, routers, bridges)
`x Security, authentication, networking, firewalls, hacking countermeasures, backups,
`archives and service level agreements for customer-outsourced data.
`
`x
`
`Domain Expertise - Client-server and web-based software applications
`x ERP systems – financial, distribution, manufacturing, SF automation applications
`(Platinum Software)
`eCommerce - Secure web transactions, authentication (InfrastructureWorld.com,
`Syntricity, Inc.)
`x Semiconductor manufacturing – yield analysis, semiconductor defect analysis
`(Syntricity, Inc.)
`
`LITIGATION RELATED EXPERIENCE
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 2.
`
`x Patent Litigation. Contributions made to numerous patent infringement cases, three
`of which required participation in claim construction for Markman hearings,
`including courtroom assistance to attorneys during claim construction. Authored three
`infringement and three validity rebuttal reports in support of plaintiffs, as well as
`numerous non-infringement and invalidity reports on behalf of defendants. Testified
`in deposition as an expert in patent cases regarding claim construction, infringement
`and invalidity.
`x Software contract disputes. Analysis of desktop, Internet, and client-server software
`projects to determine adherence to industry-standard software development
`processes, and to evaluate architectural design decisions. Contributions made to
`numerous cases, including court testimony in two, and deposition testimony in four
`others.
`x Forensic analysis. Provided forensic analysis of Internet and computer hard drive
`technology to recover deleted computer data and determine algorithms. Performed
`analysis of peer-to-peer file sharing servers for government agencies.
`
`Jury Testimony
`WhitServe LLC, v. Computer Packages, Inc.
`US District Court, Southern District of Connecticut.
`Civil Action No.
`3:06CV01935 (AVC)
`Matter:
`Patent infringement - web document services.
`Technical Issues: Analysis of MS Access VBA, ASP, .NET code and web technology.
`Responsibilities: Prepare non-infringement and invalidity reports on behalf of defendant
`Computer Packages, Inc. Testified in deposition regarding invalidity
`and non-infringement reports, Sept. 2007. Testified in jury trial May,
`2010 regarding invalidity and non-infringement.
`Fitzpatrick, Cella, Harper & Scinto, New York, for defendant CPI.
`Law Firm:
`Opposing counsel: St. Onge Steward Johnson & Reens, CT
`Data TreasuryCorporation v. Wells Fargo, The Clearing House Payments Co., et al.
`U.S. District Court, Eastern District of Texas, Marshall Division
`Civil Action No.
`Civil Action No. 2:06-CV-72 (Hon. David Folsom)
`Matter:
`eCommerce patent litigation.
`Technical Issues: eCommerce software; data encryption and authentication technology
`including IPSec, PGP, SSL, key exchange and Message
`Authentication Codes; TCP/IP networking.
`Responsibilities: Invalidity report, non-infringement report. Deposition testimony
`December, 2009.
`Testified in jury trial on behalf of defendant. The Clearing House
`March 24, 2010 regarding non-infringement.
`Fitzpatrick, Cella, Harper & Scinto, New York, and Sullivan &
`Cromwell LLP for defendant Clearing House Payments.
`Opposing counsel: Ostrow Kaufman Frankl, New York, Ward & Smith, TX, Nix
`Patterson Roach, TX.
`Work completed March 2010. The Court ruled in favor of The
`Clearing House regarding the post trial motions as to non-infringement
`and joint liability with Viewpointe. The jury found joint infringement
`
`Disposition:
`
`
`
`Law Firm:
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 3.
`
`
`
`Disposition:
`Law Firms:
`
`Disposition:
`
`for US Bank and The Clearing House as joint defendants, which was
`upheld by the Court.
`epicRealm Licensing, LLC (Parallel Networks) v. Autoflex Leasing, Franklin
`Covey, Clark Consulting, Herbalife of America, Various Inc.
`U.S. District Court, Eastern District of Texas, Marshall Division
`Civil Action Nos.
`5:07-CV-125, 5:07-CV-126, 5:07-CV-135 (Hon. David Folsom)
`Matter:
`Web technology patent litigation.
`Technical Issues: Web site implementation
`Responsibilities: Retained by Franklin Covey, Co., Clark Consulting, Inc., Herbalife of
`America, Various, Inc. Researched specific non-infringement issues;
`wrote declaration on support of motion to dismiss, and testified in
`deposition Dec., 2007 regarding that declaration. Testified in
`deposition regarding non-infringement by Herbalife (June 2008) and
`Various Inc., (July 2008).
`Testified in jury trial on behalf of defendant FriendFinder in the jury
`trial Parallel Networks v. Various, FriendFinder August 20, 2008
`regarding non-infringement and non-infringing alternatives.
`Work completed November, 2008.
`Vedder Price, Chicago, IL; Jones Day, New York, NY; Pepper
`Hamilton, Boston, MA, Fenwick & West, San Francisco, for
`defendants.
`Opposing counsel: Baker Botts.
`Dell USA, LP v. Lucent Technologies, Inc
`US District Court, Eastern District of Texas, Sherman Division
`Civil Action No.
`C.A. 4:03-cv-347. (Hon. Richard A. Schell.)
`Matter:
`Patent infringement - configurator applications for manufacturing.
`Technical Issues: Analysis of configurator algorithms, software automation.
`Responsibilities: Invalidity and non-infringement report on behalf of defendant Lucent
`Technologies. Testified in deposition regarding non-infringement and
`invalidity, Sept. 2007. Testified in jury trial on Jan. 29-30, 2008
`regarding non-infringement and invalidity.
`Jury returned a verdict in favor of Lucent Technologies for non-
`infringement.
`Kirkland & Ellis, LLP, New York, NY, for defendant.
`Law Firm:
`Opposing counsel: Haynes & Boone, Dallas, TX.
`Orion IP LLC v. Mercedes-Benz USA et al
`US District Court, Eastern District of Texas, Tyler Division.
`Civil Action No.
`6:05-cv-322 (Hon. Leonard Davis)
`Matter:
`Patent Infringement – automated proposal generation.
`Technical Issues: Technology and analysis for web sites.
`Responsibilities: Wrote non-infringement report regarding Hyundai Motor America
`web sites. Testified in deposition regarding non-infringement report.
`Testified in jury trial, May 24, 2007 regarding non-infringement,
`primarily for the ‘342 patent.
`For the contested ‘342 patent the jury found in favor of Hyundai
`Motor Corporation for non-infringement.
`Jackson Walker L.L.P., Dallas, TX for defendant
`
`
`
`Disposition:
`
`Law Firm:
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 4.
`
`Disposition:
`
`Opposing counsel: Williams, Morgan & Amerson, P.C., and Wong, Cabello, Lutsch,
`Rutherford & Brucculeri, LLP, Houston, TX.
`Amer Jneid et al v. Novell Inc., Tripole Corporation
`Superior Court of State of California, County of Orange
`Civil Action No.
`02CC00182 (Hon. David C. Velasquez)
`Matter:
`Breach of contract.
`Technical Issues: Networking technology code analysis
`Responsibilities: Analysis of source code for Novell product implementations.
`Testified at deposition on behalf of defendant Tripole Corp.
`Testified in Jury trial, November 2006.
`Completed work November, 2006. Jury awarded $13.5M damages to
`client Tripole Corporation. The jury ruled against licensee Novell
`Corp. As the IP licensor, Tripole Corporation was awarded
`approximately $13.5M damages.
`Waldron & Olson, Newport Beach, CA, for Tripole Corp.
`Law Firm:
`Opposing counsel: Workman Nydegger, UT.
`CyberNET Engineering v. Con-Way Transportation
`Circuit Court of the State of Oregon, for the County of Multnomah
`Case No. 0107-07220, April 7-8, 2003
`Matter:
`Contract dispute.
`Technical issues: Local area network design and implementation for 300 service centers.
`Responsibilities: Researched relevant networking issues and testified at jury trial on
`behalf of plaintiff.
`Martin Bischoff Templeton Langslet, Portland, OR, for plaintiff
`Law Firm:
`Jury verdict in favor of plaintiff. 2003.
`Disposition:
`International Trade Commission testimony:
`Nokia Corporation v. Apple, Inc.
`United States International Trade Commission, Washington, DC.
`Investigation No. 337-TA-701 (Hon. E.J. Gildea)
`Matter:
`Mobile phone and music player software technology.
`Technical Issues: Software implementation for Apple iPhone, iPad and iMac telephony,
`camera architecture and user interface functionality.
`Responsibilities: Research infringement issues, review source code for iPhone. Wrote
`infringement and validity rebuttal reports for two patents and
`infringement report for camera architecture patent. Testified in
`deposition Oct. 5-6, 2010. Testified in ITC Hearing Dec. 1-2, 2010.
`Completed work in December 2010.
`Disposition:
`Alston-Bird, Washington DC, for Complainant Nokia Corp.
`Law Firm:
`Opposing counsel: Wilmer Hale, Palo Alto, CA.
`Pioneer Electronics (USA), Inc. v. Garmin Corporation
`United States International Trade Commission, Washington, DC.
`Investigation No. 337-TA-694 (Hon. C.C. Charneski)
`Matter:
`Computerized navigation using GPS.
`Technical Issues: Source code analysis for Garmin GPS navigation devices.
`Responsibilities: Research non-infringement issues, review source code. Wrote
`infringement reports for three patents. Testified in deposition
`regarding infringement in June, 2010. Testified in open court hearing
`Sept. 16-17, 2010 regarding infringement and claim construction.
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 5.
`
`Disposition:
`Law Firm:
`
`Completed work in Sept. 2010.
`Finnegan Henderson Farabow Garrett & Dunner, Washington DC, for
`Complainant Pioneer.
`Opposing counsel: Adduci, Mastriani & Schaumbert LLP, Washington DC.
`Honeywell International Inc. v. Pioneer Corporation, Pioneer Electronics et al.
`United States International Trade Commission, Washington, DC.
`Investigation No. 337-TA-657 (Hon. Theodore R. Essex)
`Matter:
`Computerized navigation using GPS and inertial systems.
`Technical Issues: Source code for GPS signal processing.
`Responsibilities: Research non-infringement issues, review source code. Wrote Non-
`infringement reports for two patents. Testified in deposition April,
`2009 and June 10, 2009. Testified in open court hearing June 11, 2009
`regarding non-infringement of ‘132 and ‘286 patents by Pioneer Corp.
`Work completed June 2009. The Court ruled for non-infringement for
`both the ‘132 and ‘286 patents.
`Finnegan Henderson Farabow Garrett & Dunner, DC, for Respondent
`Pioneer.
`Opposing counsel: Robbins, Kaplan, Miller, Ciresi, Los Angeles.
`
`Disposition:
`
`Law Firm:
`
`Markman Hearing testimony:
`Finisar Corporation v. XM Satellite Radio, Inc. & Sirius Satellite Radio, Inc.
`US District Court, Eastern District of Texas, Lufkin Division.
`Civil Action No.
`No. 9:07-CV-99 (Clark) (Hon. Ron Clark)
`Matter:
`Patent litigation concerning satellite content distribution.
`Technical Issues: Indexing of data, scheduled data delivery via satellite
`Responsibilities: Research claim construction issues. Testified briefly in claim.
`construction hearing, February, 2008.
`Work completed 2008.
`Disposition:
`Kilpatrick Stockton for plaintiff.
`Law Firm:
`Opposing counsel:
`Fish & Richardson, Washington, DC, and Kramer Levin Naftalis
`& Frankel, New York.
`Auction Management Solutions Inc. v. Manheim Auctions Inc. et al
`U.S. District Court, Northern District of Georgia, Atlanta Division
`Civil Action No.
`05-CV-0639 (RWS)
` (Hon. Richard W. Story)
`Matter:
`Online auction technology patent litigation.
`Technical Issues: Communications protocols and streaming media
`Responsibilities: Research claim construction issues. Testified in deposition regarding
`claim construction in May, 2006. Provided a declaration to the Court.
`regarding construction terms for the asserted patent claims. Testified
`in court during claim construction hearing, August, 2006.
`Wrote infringement report, validity report and testified in deposition
`May 2008 on behalf of AMS as plaintiff.
`Markman Order issued Oct. 2007. Defendant stipulated to non-
`infringement in cross suit. Inactive.
`Finnegan Henderson Farabow Garrett & Dunner for plaintiff.
`Law Firm:
`Opposing counsel: Ropes & Gray LLP, Morris Manning & Martin, Covington &
`Burling, Dow Lohnes & Albertson
`
`Disposition:
`
`
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 6.
`
`McKesson Information Solutions v. Epic Systems Corp.
`U.S. District Court, Northern District, Georgia, Atlanta Division
`Civil Action No. 1:06-cv-2965
`(Hon. Jack T. Camp)
`Matter:
`Patent infringement - web-based services.
`Technical Issues: Analysis of web technology.
`Responsibilities: Assist in claim construction. Testified in deposition regarding
`contributions to claim construction, Sept. 2007. Provided assistance
`with technology tutorial entered into evidence at Markman Hearing,
`July 2, 2008. Testified in deposition regarding infringement, February,
`2009.
`Motion For Summary Judgment regarding non-infringement in favor
`of defendant Epic Systems. Work completed March 2009.
`Kilpatrick Stockton LLP, Atlanta, GA, for defendant Epic.
`Law Firm:
`Opposing counsel: Womble Carlyle Sandridge & Rice PLLC, Charlotte, NC
`
`Disposition:
`
`Deposition Testimony
`Augme/Modavox, Inc. v. Tacoda Inc., AOL .
`U.S. District Court, Southern District of New York
`07-CV-7088 (CM)(CWG) Judge Colleen McMahon.
`Civil Action No.
`Matter:
`eCommerce patent litigation.
`Technical Issues: Implementation of Internet browser and server technology.
`Responsibilities: Research JavaScript and web page tracking non-infringement issues,
`assist with claim construction. Testified in support of Tacoda motion
`for summary judgment, April, 2011.
`Active.
`Disposition:
`Orrick, Herrington & Sutcliffe LLP, New York, for defendant.
`Law Firm:
`Opposing counsel:
`Shaub & Williams LLP, LA, Goodwin Procter, New York.
`
`Juxtacomm Technologies v. Ascential Software, Microsoft Corp., IBM Corporation
`United States District Court, Eastern District Texas.
`Civil Action No. 2:07-CV-359 LED
`Matter:
`Data Warehouse patent dispute.
`Technical Issues: SOA software implementation, ETL database technology.
`Responsibilities: Analyze IBM products in preparation for non-infringement report.
`Wrote invalidity comparison report regarding IBM’s prior art data
`warehouse products. Wrote non-infringement report. Testified in
`deposition July, 2009 regarding non-infringement and prior art
`products.
`Case settled October 2009.
`Fitzpatrick, Cella, Harper & Scinto, New York, Kirkland & Ellis, LLP,
`New York, NY, for defendant IBM.
`Opposing counsel: Akin Gump Straus Hauer and Feld, LLP. Ward & Smith, TX.
`Madison Tyler Holdings, LLC., et al v. Financial Asset Trading & Technology of
`California, LLC, et al.
`JAMS Arbitration
`JAMS Ref. No. 1220038462 (Justice Richard Neal)
`Matter:
`Misappropriation of Trade Secrets, financial market trading software.
`
`Disposition:
`Law Firms:
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 7.
`
`Disposition:
`Law Firms:
`
`Disposition:
`Law Firm:
`
`Technical Issues: Examine code and algorithms in Java application re-write of market-
`maker trading functionality for similarity with original Python code
`base.
`Responsibilities: Perform duties as a neutral, Court-appointed technical expert. Review
`Java and Python code bases for similarities. Perform automated and
`manual code comparisons. Wrote technical report on findings and
`testified in deposition June, 2009.
`Settled July 2009. Work completed July 2009.
`LathamWatkins, Los Angeles, Storch Amini & Munves, PC, Paul,
`Weiss, Rifkind, Wharton & Garrison LLP, New York, Skadden Arps,
`Los Angeles, Bird, Marella, Boxer, Wolpert, Nessim, Century City,
`CA, Irell & Manella, Los Angeles.
`Irise v. Axure Software Solutions, Inc., Integrated Electrical Services, Inc.
`U.S. District Court, Central District of California, Western Division.
`Case No.
`08-CV-03601 SJO (JWJx) Hon. S. James Otero.
`Matter:
`Patent litigation regarding rapid software prototyping tools
`Technical Issues: Microsoft .NET source code implementation analysis.
`Responsibilities: Research non-infringement issues, review source code. Wrote
`Invalidity and Non Infringement reports; testified in deposition June,
`2009.
`Case settled Sept., 2009.
`Disposition:
`Orrick, Herrington & Sutcliffe, LLP, Irvine CA, for defendant Axure.
`Law Firm:
`Opposing counsel: Knobbe, Martens, Olson & Bear, LLP.
`Constellation IP, LLC v. Avis Budget Group, FedEx Corporation.
`United States District Court, Eastern District of Texas, Texarkana Division.
`Civil Action No. 5:07-cv-00038-DF-CMC
`Matter:
`Patent infringement - computer based customized presentations.
`Technical Issues: Analysis of FedEx web sites. Delivery of web pages to web browsers.
`Responsibilities: Wrote non-infringement report. Testified in deposition regarding non-
`infringement, June, 2008.
`Settled. Work completed 2008.
`Finnegan Henderson Farabow Garrett & Dunner, Reston, VA, for
`defendant FedEx.
`Opposing counsel:
`Sedona Corporation v. Open Solutions, Inc..
`United States District Court, District of Connecticut.
`Index No. 3:07CV171 (TPS)
`Matter:
`Contract dispute regarding porting of source code from Java platform
`to Microsoft .NET platform.
`Technical Issues: Java and C# source code analysis and comparisons for a large
`application concerned with data warehouses/data marts for the banking
`industry.
`Responsibilities: Wrote expert report regarding similarities of code. Testified in
`deposition, September, 2008.
`Completed work September 2008.
`Schiff Hardin LLP, San Francisco, CA for plaintiff Sedona
`Corporation.
`Opposing counsel: Pullman & Comley, LLC, Bridgeport, CT.
`
`Disposition:
`Law Firm:
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 8.
`
`Disposition:
`
`Law Firm:
`
`Taurus IP, LLC v. DaimlerChrysler and Mercedes Benz USA, Inc.
`United States District Court, Western District of Wisconsin
`Civil Action No. 07-C-0158-C
`Matter:
`Patent infringement - computer based management of data models
`used for managing sales information.
`Technical Issues: Analysis of source code used to implement DaimlerChrysler and
`Mercedes Benz web sites.
`Responsibilities: Wrote non-infringement report. Testified in deposition regarding non-
`infringement, Dec. 2007.
`Court awarded summary judgment of non-infringement and invalidity
`on 2 claims.
`Kilpatrick Stockton LLP, Atlanta, GA, for defendants
`DaimlerChrysler & Mercedes Benz.
`Opposing counsel: DeWitt, Ross and Stevens S.C., Madison, WI
`Telematics Corporation v. UPS, Inc., et al
`U.S. District Court, Northern District of Georgia, Atlanta Division
`Civil Action Nos.
`1:07-cv-0105-ODE
`Matter:
`Vehicle telematics technology patent litigation.
`Technical Issues: Computer implementation of GPS tracking system
`Responsibilities: Retained by Motorola, Ryder, and Verizon to address infringement
`allegations. Assist attorneys with claim construction issues; testified in
`deposition Jan., 2008 regarding claim construction.
`Work completed 2007.
`Kilpatrick Stockton, Atlanta, GA, for defendant Motorola Inc., and
`Roylance, Abrams, Berdo & Goodman, LLP, Washington, DC for
`defendants Ryder Truck Rental, Teletrac, Inc.
`Opposing counsel:
`Thomas, Kayden, Horstemeyer & Risley, LLP
`NetRatings, Inc. v. WebSideStory, Inc
`US District Court, Southern District of New York
`Civil Action No.
`06 Civ. 878 (LTS)(AJP)
`Matter:
`Patent infringement - web user tracking.
`Technical Issues: Analysis of web sites, client application software, and browser
`characteristics.
`Responsibilities: Wrote invalidity report on behalf of defendant WebSideStory.
`Testified in deposition regarding invalidity report, May 2007.
`Settled Aug., 2007.
`Disposition:
`Latham Watkins, LLP, New York, NY, for defendant.
`Law Firm:
`Opposing counsel: Dreier, LLP, New York, NY.
`Coupons Inc. v. Indian Harbor Insurance Company
`American Arbitration Association
`AAA Case No. 74 133 Y 91922 94 /DEAR
`Matter:
`Patent insurance contract dispute.
`Technical Issues: Web server software implementation and patent infringement issues.
`Responsibilities: Testify on technical issues analyzed during E-Centives v. Coupons
`Inc. patent litigation while representing Coupons. Testified at
`deposition on behalf of plaintiff, May 2006.
`Case settled, Aug. 2006.
`Farella Braun & Martel LLP, San Francisco, CA for plaintiff.
`
`Disposition:
`Law Firms:
`
`Disposition:
`Law Firm:
`
`

`
`Peter Alexander, Ph.D.
`Resume
`
`
`
`Page 9.
`
`Law Firm:
`
`Sonnenschein Nath & Rosenthal LLP, San Francisco, CA
`Opposing counsel:
`Lending Tree LLC v. LowerMyBills, Inc.
`United States District Court, Western District of North Carolina
`Charlotte Division
`3:05CV153-C
`Civil Action No.
`Patent Infringement – credit analysis.
`Matter:
`Technical Issues: Technology and code analysis for web sites
`Responsibilities: Wrote infringement and invalidity rebuttal reports. Testified in
`deposition regarding infringement, September 2006. Testified in
`deposition regarding Invalidity rebuttal report, November, 2006
`Settled 2006.
`Disposition:
`King & Spalding LLP, Atlanta, GA for plaintiff.
`Law Firm:
`Sky Technologies LLC v. IBM Corp. and i2 Inc.
`U.S. District Court, Eastern District of Texas, Marshall Division
`Civil Action No. 2:03CV454-DF Judge David Folsom.
`Matter:
`Supply-chain negotiation patent litigation.
`Technical Issues: Analysis of Java J2EE applications/ Enterprise Java Bean technology.
`Responsibilities: Conducted research concerning infringement position and claim
`construction. Testified in deposition regarding infringement and
`invalidity.
`Townsend Townsend and Crew, San Francisco, and Susman Godfrey
`LLP, Houston, TX for plaintiff.
`Opposing counsel:
`Fitzpatrick, Cella, Harper & Scinto
`Disposition:
`Settled. Completed work in Jan. 2006.
`Trilogy Software, Inc. v Selectica, Inc.
`U.S. District Court, Eastern District of Texas, Marshall Division
`Civil Action No. 2-04-CV-160 (TJW). Judge T. John Ward
`Matter:
`Internet eCommerce patent litigation.
`Technical Issues: Web server interaction with client browsers.
`Responsibilities: Research non-infringement issues in cross complaint. Testified at
`deposition regarding Trilogy’s proposed claim construction. Wrote
`expert declaration