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10 UNITED STATES DISTRICT COURT
11 SOUTHERN DISTRICT OF CALIFORNIA
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IN RE: Case No. 3:17-CV-00108-GPC-MDD
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QUALCOMM LITIGATION [Consolidated with Case No. 3:17-CV-01010-
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GPC-MDD]
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JOINT WITNESS LIST
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17 Judge: Gonzalo P. Curiel
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JOINT WITNESS LIST CASE NO. 3:17-CV-0108-GPC-MDD
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1 Pursuant to the Court’s December 19, 2018 Trial Preparation and Scheduling
2 Order (Dkt. 749), Apple Inc. (“Apple”), Compal Electronics, Inc. (“Compal”); FIH
3 Mobile LTD. (“Foxconn”); Hon Hai Precision Industry Co., LTD. (“Foxconn”);
4 Pegatron Corporation (“Pegatron”); and Wistron Corporation (“Wistron”) (together,
5 the “Contract Manufacturers” or the “CMs”), and Qualcomm Incorporated
6 (“Qualcomm”) hereby submit the following joint witness list.
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8 Table of Contents
9 Apple Current and Former Employees.........................................................................2
10 Qualcomm Current and Former Employees...............................................................12
11 CM Current and Former Employees...........................................................................25
12 Third-Party Witnesses................................................................................................34
13 Apple/CM Experts.....................................................................................................41
14 Qualcomm Experts.....................................................................................................55
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1 THIRD-PARTY WITNESSES
2 WITNESS PARTY TIME TIME DESCRIPTION OF
CALLING EST./ EST./ TESTIMONY
3 THE DIRECT CROSS
WITNESS EXAM EXAM
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Blumberg, Ira Apple/CMs 30 minutes 10 minutes Apple and the CMs expect Mr.
5 Lenovo Blumberg to testify about
Lenovo’s inability to challenge
6 1009 Think Pl, Qualcomm’s supra-FRAND
Morrisville, NC royalty demands due to supply
7 27560 threats from Qualcomm;
licensing practices in the
8 (850) 253-6686 cellular industry; competition in
the relevant markets for
9 baseband processor chipsets;
Qualcomm’s policies and
10 practices relating to the sale and
licensing of baseband processor
11 chipsets and the competitive
effects thereof; the
12 anticompetitive effects of
Qualcomm’s practices on
13 Lenovo; and topics discussed at
deposition.
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Mr. Blumberg will testify by
15 deposition designations.
Blaylock, Richard Apple/CMs 10 minutes 10 minutes Apple and the CMs expect Mr.
16 Pillsbury Winthrop Blaylock to testify about
Shaw Pittman LLP Qualcomm’s licensing practices
17 12255 El Camino and threats to cut off supply of
18 Real #300, San baseband processor chipsets to
Diego, CA customers who do not sign
19 92130
licenses; licensing practices in
(585) 509-4000 the cellular industry;
20 competition in the relevant
21 markets for baseband processor
chipsets; Qualcomm’s policies
22 and practices relating to the sale
and licensing of baseband
23 processor chipsets and the
competitive effects thereof, the
24 anticompetitive effects of
25 Qualcomm’s practices on ZTE;
and topics discussed at
26 deposition.
1 APPLE/CM EXPERTS
2 WITNESS PARTY TIME TIME DESCRIPTION OF
CALLING EST./ EST./ TESTIMONY
3 THE DIRECT CROSS
WITNESS EXAM EXAM
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Akl, Robert Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
5 (rebuttal)2 Akl to provide rebuttal
Contact through testimony, to the extent that
counsel for Apple
6 Qualcomm’s expert William
and the CMs Michalson is permitted to and
7 Harvard University, does testify, regarding Dr.
33 Oxford St., Michalson’s failure to show that
8 Cambridge, MA 16 Qualcomm “exemplary
02138 patents” related to the area of
9 (617) 495-4390 location tracking and location-
based services provide Apple,
10 the CMs and consumers any
value, including because Dr.
11 Michalson has not shown that
Apple, the CMs, or any
12 consumers use the technology
of the 16 Qualcomm
13 “exemplary patents” and
because the 16 “exemplary
14 patents” are likely invalid.
15 Apple and the CMs further
expect Dr. Akl to provide
16 rebuttal testimony, to the extent
that Qualcomm’s expert Jeffrey
17 Andrews is permitted to and
does testify, regarding Dr.
18 Andrews’s failure to show that
34 Qualcomm “exemplary
19 patents” related to the areas of
waveform, carrier aggregation,
20 heterogeneous networks, and
unlicensed spectrum are
21 particularly fundamental and/or
important to any
22 telecommunications standard,
including because Dr. Andrews
23 has not shown that the
technology of the Qualcomm
24 “exemplary patents” are
essential to any portion of any
25 telecommunications standard,
because the 34 “exemplary
26 patents” are invalid, and/or
because patents owned by other
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28 Witnesses identified as rebuttal witnesses may or may not testify, depending on
Qualcomm’s case-in-chief.
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1 QUALCOMM EXPERTS
2 WITNESS PARTY TIME TIME DESCRIPTION OF
CALLING EST./ EST./ TESTIMONY
3 THE DIRECT CROSS
WITNESS EXAM EXAM
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Andrews, Jeff Qualcomm 30 minutes 10 minutes Dr. Andrews is an expert in
5 c/o Qualcomm electrical engineering, and is a
professor at the University of
6 Incorporated Texas-Austin. He holds a B.S.
5775 Morehouse in Engineering from Harvey
7 Drive, San Diego, CA Mudd College and a M.S. and
92121 Ph.D. in Electrical Engineering
8 from Stanford University.
9 Dr. Andrews will testify
regarding the subject matter of
10 his expert report and subject
matter about which he was
11 asked during his deposition,
including the importance of
12 certain Qualcomm
technologies, as well as certain
13 standard essential patents
(“SEPs”) related to the UMTS,
14 LTE and 5G NR standards.
Dr. Andrews will provide live
15 testimony.
Chipty, Tasneem Qualcomm 30 minutes 30 minutes Dr. Chipty is an expert
16 c/o Qualcomm economist specializing in
marketplace behaviors with a
17 Incorporated focus on issues of antitrust and
5775 Morehouse regulatory policy. She holds a
18 Drive, San Diego, CA B.A. in Economics and
92121 Mathematics from Wellesley
19 College and a Ph.D. in
Economics from the
20 Massachusetts Institute of
Technology.
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Dr. Chipty will testify
22 regarding the subject matter of
her expert reports and subject
23 matter about which she was
asked during her deposition,
24 including competition for
modem chips; market
25 definition; market power; and
certain contracts entered into
26 between Qualcomm and
Apple, as well as in rebuttal to
27 Apple and the CMs’ experts.
Dr. Chipty will provide live
28 testimony.