Qualcomm Trial Witness List

Case 3:17-cv-00108-GPC-MDD Document 1054-21 Filed 03/25/19 PageID.
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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.
7
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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JOINT WITNESS LIST -1- CASE NO. 3:17-CV-0108-GPC-MDD

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1 APPLE CURRENT AND FORMER EMPLOYEES

2 WITNESS PARTY TIME TIME DESCRIPTION OF
CALLING EST./ EST./ TESTIMONY
3 THE DIRECT CROSS
WITNESS EXAM EXAM1
4
Blevins, Tony Apple/CMs 60 minutes 70 minutes Apple and the CMs expect Mr.
5 Contact through Blevins to testify about
Apple’s business relationship
6 counsel for Apple with and agreements with
One Apple Park Way, Qualcomm, the negotiation of
7 Cupertino, CA 95014 said agreements, and their
competitive effects in the
8 (408) 996-1010 relevant markets; baseband
chipset supply issues and the
9 resulting leverage Qualcomm
gained during contract
10 negotiations; Apple’s business
relationship with and
11 agreements with the CMs and
the manufacturing of Apple
12 cellular products; Apple’s lack
of interference in the CMs’
13 relationships with Qualcomm;
withholdings of payments in
14 2016 and 2017; the
anticompetitive effects of
15 Qualcomm’s conduct and
business practices; the absence
16 of any justification for
exclusivity with Apple;
17 Qualcomm’s competition in
the relevant markets for
18 baseband processor chipsets
and the effects of Qualcomm’s
19 agreements on that market;
Apple’s relationship with Intel
20 and other potential and actual
baseband processor chipset
21 suppliers; Apple’s attempts to
dual-source and the reasons
22 therefor; Apple’s cooperation
with competition agencies’
23 investigations of Qualcomm;
topics discussed at deposition;
24 and matters relating to
Qualcomm’s counterclaims.
25
Mr. Blevins will testify live.
26
27 1
Apple and the CMs’ estimated cross-examination times listed for entries where
28 Qualcomm is the party calling the witness do not include time for direct

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WITNESS PARTY TIME TIME DESCRIPTION OF

1 CALLING EST./ EST./ TESTIMONY
THE DIRECT CROSS
2 WITNESS EXAM EXAM1
3 Cook, Tim Apple/CMs 30 minutes 50 minutes Qualcomm expects Mr. Cook
will testify about Apple’s
Contact through
4 business strategy, Apple’s
counsel for Apple mobile devices, Apple’s sales
5 One Apple Park Way, and financial performance,
Cupertino, CA 95014 Apple’s business relationship
6 (408) 996-1010 with Qualcomm and the CMs,
and Apple’s agreements with
7 Qualcomm relating to modem
chips.
8
Mr. Cook will testify live.
9 Qualcomm 50 minutes 15 minutes Mr. Cook will testify about
Apple’s business practices and
10 strategy; Apple’s agreements
with and business strategy
11 concerning cellular network
carriers; industry practice of
12 licensing cellular SEPs and/or
other patents; Apple’s mobile
13 devices and technologies;
Apple’s sales, financial
14 performance, and pricing;
Apple’s business relationships
15 and agreements or potential
agreements with others,
16 including Qualcomm and the
CMs; and subject matter about
17 which he was asked during his
deposition. Mr. Cook will
18 provide live testimony.
19
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28 examination or redirect examination (for witnesses called by both sides) or direct
deposition designations (for witnesses designated by both sides).
of 69

THE DIRECT CROSS
3 Cooper, Kim Qualcomm 10 minutes 1 minute Ms. Cooper will testify about
Contact through
4 with Qualcomm; Apple’s
counsel for Apple agreements with and business
5 One Apple Park Way, strategy concerning cellular
Cupertino, CA 95014 network carriers; Apple’s
6 (408) 996-1010 agreements with Qualcomm
relating to baseband processor
7 chipsets; Apple’s business
relationship with contract
8 manufacturers; industry
practice of licensing cellular
9 SEPs and/or other patents;
Apple’s licensing practices;
10 and subject matter about which
she was asked during her
11 deposition. Ms. Cooper will
provide testimony by
12 deposition designations.
Denney, Deborah Apple/CMs 10 minutes 10 minutes Apple and the CMs expect Ms.
13 Contact through Denney to testify about
14 counsel for Apple with and agreements with the
One Apple Park Way, CMs and manufacturing of
15 Cupertino, CA 95014 Apple cellular products;
Apple’s lack of interference in
(408) 996-1010
16 the CMs’ relationships with
Qualcomm; the manufacturing
17 of Apple cellular products;
Qualcomm; audits of the CMs
19 by Qualcomm’s auditors;
withholdings of payments in
20 2016 and 2017; Apple’s
operational, finance, and
21 financial records; topics
discussed at deposition; and
22 matters relating to
23
Ms. Denney will testify live.
24
25
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THE DIRECT CROSS
3 Lutton, Richard Qualcomm 35 minutes 30 minutes Mr. Lutton will testify about
(Chip) Apple’s business practices and
4 strategy; Apple’s relationship
Contact through with Qualcomm; industry
5 counsel for Apple practice of licensing cellular
One Apple Park Way, SEPs and/or other patents;
6 Cupertino, CA 95014 Apple’s patent acquisition and
licensing practices; and subject
7 (408) 996-1010 matter about which he was
asked during his deposition.
8 Mr. Lutton will provide
testimony by deposition
9 designations.
Mansfield, Bob Qualcomm 15 minutes 10 minutes Mr. Mansfield will testify
10 about Apple’s technical
Contact through engineering requirements for
counsel for Apple
11 its devices’ cellular
One Apple Park Way, capabilities; Apple’s business
12 Cupertino, CA 95014 relationship with Qualcomm;
competition in the modem chip
13 (408) 996-1010 industry; and subject matter
about which he was asked
14 during his deposition. Mr.
Mansfield will provide
15 testimony by deposition
designations.
16 Risher, Jeff Qualcomm 20 minutes 15 minutes Mr. Risher will testify about
Apple’s business and licensing
17 Contact through practices and strategy; Apple’s
counsel for Apple patent and licensing positions,
18 One Apple Park Way, including with regulators and
Cupertino, CA 95014 in litigation; Apple’s business
19 relationship with Qualcomm;
(408) 996-1010 industry practice of licensing
20 cellular SEPs and/or other
patents; and subject matter
21 about which he was asked
during his deposition. Mr.
22 Risher will provide testimony
by deposition designations.
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THE DIRECT CROSS
3 Sauer, Matthias Qualcomm 30 minutes 9 minutes Mr. Sauer will testify about
Apple’s technical engineering
Contact through
4 requirements for its devices’
counsel for Apple cellular capabilities; Apple’s
5 One Apple Park Way, business relationship with
Cupertino, CA 95014 Qualcomm; competition in the
6 (408) 996-1010 modem chip industry; and
subject matter about which he
7 was asked during his
deposition. Mr. Sauer will
8 provide testimony by
deposition designations.
9 Schafer, Aaron Apple/CMs 10 minutes 15 minutes Apple and the CMs expect Mr.
Schafer to testify about
Contact through
10 Apple’s business relationship
counsel for Apple with and agreements with
11 One Apple Park Way, Qualcomm, the negotiation of
Cupertino, CA 95014 said agreements, and their
12 (408) 996-1010 competitive effects in the
relevant markets; ; the dispute
13 between Apple and Qualcomm
related to carrier aggregation
14 payments pursuant to the Mav
7/8, 10, and 13 Statement of
15 Work; Apple’s business
relationship with and
16 agreements with the CMs and
manufacturing of Apple’s
17 cellular products; Apple’s lack
of interference in the CMs’
18 relationships with Qualcomm;
baseband chipset supply issues
19 and the resulting leverage
Qualcomm gained during
20 contract negotiations;
competition in the relevant
21 markets for baseband
processor chipsets and the
22 anticompetitive effects of
Qualcomm’s conduct and
23 business practices; Apple’s
attempts to dual-source and the
24 reasons therefor; Apple’s
relationship with Intel and
25 other actual and potential
baseband processor chipset
26 suppliers; topics discussed at
deposition; and matters
27 relating to Qualcomm’s
counterclaims.
28
Mr. Schafer will testify live.

of 69

THE DIRECT CROSS
3 Schiller, Phil Apple/CMs 20 minutes 30 minutes Apple and the CMs expect Mr.
Schiller to testify about
Contact through
4 Apple’s marketing efforts in
counsel for Apple connection with devices that
5 One Apple Park Way, use baseband processor
Cupertino, CA 95014 chipsets; the myriad factors
6 (408) 996-1010 unrelated to cellular
connectivity or performance
7 that drive demand for iPhone,
iPad, and Apple Watch; the
8 dispute between Apple and
Qualcomm related to carrier
9 aggregation payments pursuant
to the Mav 7/8, 10, and 13
10 Statement of Work; topics
11 matters relating to
12
Mr. Schiller will testify live.
13 Qualcomm 30 minutes 30 minutes Mr. Schiller will testify about
Apple’s business practices and
14 strategy; Apple’s mobile
devices and technologies;
15 Apple’s sales, financial
performance, and pricing;
16 Apple’s marketing efforts in
connection with Apple devices
17 that use baseband processor
chipsets; the features and
18 attributes of those devices; and
subject matter about which he
19 was asked during his
deposition. Mr. Schiller will
Sebeni, Johnson Apple/CMs 15 minutes 10 minutes Apple and the CMs expect Mr.
21 Sebeni to testify about
Contact through technical details relating to
22 counsel for Apple cellular functionality within
One Apple Park Way, baseband processor chipsets;
23 Cupertino, CA 95014 Apple cellular products’
support for one or more 3GPP
24 (408) 996-1010 standards including LTE and
UMTS; topics discussed at
25 deposition; and matters
relating to Qualcomm’s
26 counterclaims.
27 Mr. Sebeni will testify live.
28

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THE DIRECT CROSS
3 Sewell, Bruce Apple/CMs 30 minutes 30 minutes Apple and the CMs expect Mr.
Sewell to testify about Apple’s
4 Contact through business relationship with
counsel for Apple Qualcomm, including the
5 One Apple Park Way, negotiation of the BCPA and
Cupertino, CA 95014 other agreements with
6 (408) 996-1010 Qualcomm; the dispute
between Apple and Qualcomm
7 over carrier aggregation
payments related to the Mav
8 7/8, 10, and 13 Statement of
Work; Apple’s business
9 relationship with and
agreements with the CMs;
10 Apple’s lack of interference in
the CMs’ relationships with
11 Qualcomm; licensing of
cellular SEPs or other patents;
12 topics discussed at deposition;
and matters relating to
13 Qualcomm’s counterclaims.
14 Mr. Sewell will testify live.
Teksler, Boris Qualcomm 1 hour 33 minutes Mr. Teksler will testify about
15 Apple’s business and licensing
(Formerly of Apple practices and strategy; Apple’s
16 Inc.) patent and licensing positions,
Conversant including with regulators and
17 Intellectual Property in litigation; Apple’s
Management relationship with Qualcomm;
18 2441 Park Blvd Suite industry practice of licensing
cellular SEPs and/or other
19 104, Palo Alto, CA
94036 patents; and subject matter
Teksler will provide testimony
21 by deposition designations.
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THE DIRECT CROSS
3 Watrous, B.J. Apple/CMs 20 minutes 45 minutes Apple and the CMs expect Mr.
Watrous to testify about
Contact through
relevant markets; Apple’s
7 inbound and outbound
licensing framework for both
8 SEPs and NEPs; Apple’s
licensing negotiations with
9 other cellular patent holders;
10 with and agreements with the
CMs and manufacturing of
11 Apple cellular products;
Qualcomm; withholdings of
13 payments in 2016 and 2017;
licensing of cellular SEPs or
14 other patents; topics discussed
at deposition; and matters
15 relating to Qualcomm’s
counterclaims.
16
Mr. Watrous will testify live.
17 Qualcomm 1 hour 25 minutes Mr. Watrous will testify about
18 practices and strategy; Apple’s
patent and licensing positions,
19 including with regulators and
in litigation; Apple’s
20 relationship with Qualcomm,
including actual and potential
21 agreements; Apple’s licensing
negotiations; Apple’s business
22 relationships with contract
manufacturers; industry
23 practice of licensing cellular
SEPs and/or other patents; and
24 subject matter about which he
was asked during his
25 deposition. Mr. Watrous will
provide live testimony.
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27
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THE DIRECT CROSS
3 Whitt, Jayna Qualcomm 15 minutes None Ms. Whitt will testify about
Contact through
4 practices and strategy; Apple’s
counsel for Apple patent and licensing positions,
5 One Apple Park Way, including with regulators and
Cupertino, CA 95014 in litigation; Apple’s licensing
6 negotiations; Apple’s business
(408) 996-1010 relationship with Qualcomm;
7 Apple’s agreements with
Qualcomm relating to
8 baseband processor chipsets;
9 with contract manufacturers;
industry practice of licensing
10 cellular SEPs and/or other
patents; and subject matter
11 about which she was asked
during her deposition. Ms.
12 Whitt will provide live
testimony and/or testimony by
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THE DIRECT CROSS
3 Williams, Jeff Apple/CMs 60 minutes 40 minutes Apple and the CMs expect Mr.
Williams to testify about
Contact through
relevant markets; Apple’s
7 compliance with the BCPA;
8 with and agreements with the
CMs and manufacturing of
9 Apple cellular devices;
Qualcomm; withholdings of
11 payments in 2016 and 2017;
Apple’s decision to commence
12 litigation against Qualcomm;
the anticompetitive effects of
13 Qualcomm’s conduct and
business practices; the absence
14 of any justification for
exclusivity with Apple;
15 baseband supply issues and the
resulting leverage Qualcomm
16 gained during contract
negotiations; competition in
17 the relevant markets for
baseband processor chipsets
18 and the anticompetitive effects
of provisions in Qualcomm
19 agreements; Apple’s
cooperation with competition
20 agencies’ investigations of
Qualcomm; topics discussed at
21 deposition; and matters
relating to Qualcomm’s
22 counterclaims.
23 Mr. Williams will testify live.
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of 69
1 QUALCOMM CURRENT AND FORMER EMPLOYEES

3 THE DIRECT CROSS
WITNESS EXAM EXAM
4
Aberle, Derek Qualcomm 1 hour 45 minutes Mr. Aberle will testify about
5 c/o Qualcomm Qualcomm’s business and
licensing practices and strategy;
6 Incorporated Qualcomm’s patent portfolio
5775 Morehouse Dr., and innovations; Qualcomm’s
7 San Diego, CA 92121 business relationships with
original equipment
8 manufacturers (“OEMs”);
Qualcomm’s business
9 relationships with Apple and
the CMs, including licensing
10 negotiations; and subject matter
Aberle will provide live
12 testimony.
Achour, Baaziz Apple/CMs 5 minutes 5 minutes Apple and the CMs expect Mr.
13 5775 Morehouse Dr., Achour to testify about
San Diego, CA 92121 Qualcomm’s modem chip
14
(858) 845-4100 engineering; competition in the
15 relevant markets for baseband
processor chipsets; alleged
16 business justifications for
Qualcomm’s conduct and
17 contractual provisions,
18 including the absence of any
justification for exclusivity with
19 Apple; Qualcomm’s “no
license, no chips” policy;
20 competitive effects and
causation; topics discussed at
21 deposition; and matters relating
22 to Qualcomm’s counterclaims.
23 Mr. Achour will testify live or

24 Amon, Cristiano Apple/CMs 45 minutes 30 minutes Apple and the CMs expect Mr.
5775 Morehouse Dr., Amon to testify about
25 Qualcomm’s business model,
San Diego, CA 92121
26 (858) 845-4100 practices, procedures,
operations, revenues, profits
27 and costs; Qualcomm’s “no
28 Qualcomm’s use of marketing

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 funds, strategic funds, incentive
funds, and other rebates;
4 Qualcomm’s concerns about
5 Intel and other potential and
actual competitors as a
6 competitive threat, and
measures taken in response to
7 that threat; Qualcomm’s
attempts to evade patent
8 exhaustion; Qualcomm’s sales
9 and business practices relating
to baseband processor chipsets
10 and licensing; the relationship
between Qualcomm Inc. and
11 other Qualcomm entities;
12 markets for baseband processor
13 chipsets; Qualcomm’s sales or
licensing agreements with
14 licensees, Apple, or other
device manufacturers; the
15 dispute between Apple and
Qualcomm over carrier
16 aggregation payments; topics
17 discussed at deposition; and
topics related to Qualcomm’s
18 counterclaims.
19 Mr. Amon will testify live.
Blecker, Marvin Apple/CMs 15 minutes 15 minutes Apple and the CMs expect Mr.
20
12824 Silver Acacia Blecker to testify about the
21 Place, San Diego negotiation of agreements with
92130 Apple, including the Marketing
22 Telephone number Incentive Agreement;
unknown Qualcomm’s business practices
23 and objectives regarding
24 WiMAX; Qualcomm’s “no
25 Qualcomm’s use of marketing
funds, strategic funds, incentive
26 funds, and other rebates;
Qualcomm’s licensing of
27 cellular SEPs and other patents,
28 and its views on licensing and
FRAND; Qualcomm’s attempts

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THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 to evade patent exhaustion; the
relationship between
4 Qualcomm Inc. and other
5 Qualcomm entities;
Qualcomm’s relationships with
6 Authorized Purchasers;
Qualcomm’s sales or licensing
7 agreements with licensees,
Apple, or other device
8 manufacturers; Qualcomm’s
9 threats to cut off supply to
unlicensed customers; topics
topics related to Qualcomm’s
11 counterclaims.
12 Mr. Blecker will testify live or
13 by deposition designations.
Casaccia, Lorenzo Qualcomm 15 minutes 10 minutes Mr. Casaccia is Qualcomm’s
14 Vice President, Technical
c/o Qualcomm Standards, responsible for
Incorporated
15 leading Qualcomm’s
5775 Morehouse Dr., engineering delegation at the
16 San Diego, CA 92121 3GPP cellular standards
development organization
17 (“SDO”). Mr. Casaccia was
disclosed as a fact witness who
18 may render expert opinions that
rebut Apple and the CMs’
19 experts who rely on counting
document submissions to 3GPP
20 (so-called “contribution
counting”) as a proxy for the
21 quantity or quality of a firm’s
patent portfolio. Mr. Casaccia
22 is an expert in 3GPP cellular
standards, how the standards
23 are made, and contributions.
Mr. Casaccia has more than 18
24 years of experience drafting,
presenting, and overseeing
25 Qualcomm’s thousands of
3GPP contributions. He has
26 attended hundreds of 3GPP
meetings and analyzed tens of
27 thousands of 3GPP
contributions from other
28 companies as part of his job
responsibilities. Mr. Casaccia

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 has bachelor’s and master’s
degrees in electrical engineering
4 and telecommunication
engineering and is the named
5 inventor on about 50 granted
U.S. Patents and hundreds of
6 patents worldwide. Mr.
Casaccia has given
7 presentations and seminars to
both academic and professional
8 audiences on cellular
communications and, more
9 recently, on 3GPP’s
standardization of 5G.
10
Mr. Casaccia will testify
11 regarding the subject matter of
his disclosure pursuant to Rule
12 26(a)(2)(C) and subject matter
13 during his deposition, including
the 3GPP standards
14 development process;
Qualcomm’s role in the
15 development and
standardization of cellular
16 communications technologies;
the flaws of contribution
17 counting, including the varied
technical significance of
18 contributions; and the reasons
why contribution counting is
19 not a proxy for the quantity or
quality of a firm’s patent
20 portfolio. Mr. Casaccia will
21 Cathey, James Qualcomm 25 minutes 20 minutes Mr. Cathey will testify about
22 Qualcomm relationships with its licensees,
Incorporated including the CMs’
23 5775 Morehouse Dr., performance under certain
San Diego, CA 92121 contracts and Apple’s
24 interference with the CMs’
contract performance; and
26 deposition. Mr. Cathey will
27
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THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Chen, Liren Qualcomm 20 minutes 10 minutes Mr. Chen will testify about the
nature, makeup and scope of
Qualcomm
4 Qualcomm’s patent portfolio,
Incorporated including its SEPs, non-cellular
5 5775 Morehouse Dr., SEPs and non-SEPs;
San Diego, CA 92121 Qualcomm’s approach to
6 research; Qualcomm’s
preparation and presentation of
7 technical claim charts provided
to Apple during licensing
8 negotiations; the nature of any
materials presented in licensing
9 discussions; Qualcomm’s
interactions with government
10 agencies; and subject matter
Chen will provide live
12 testimony.
Chen, Victoria Qualcomm 30 minutes 15 minutes Ms. Chen will testify about
13 Qualcomm’s modem chip sales;
Qualcomm Qualcomm’s business
14 Incorporated relationship with Apple,
5775 Morehouse Dr., including the negotiation,
15 San Diego, CA 92121 terms, and/or performance of
certain contracts or potential
16 contracts; and subject matter
about which she was asked
17 during her deposition. Ms.
Chen will provide live
18 testimony.
Dwight, Deborah Qualcomm 15 minutes 10 minutes Ms. Dwight will testify about
19 Qualcomm’s business
Qualcomm relationships with the CMs,
20 Incorporated including Qualcomm’s
negotiations with the CMs for
21 5775 Morehouse Dr., their license agreements with
San Diego, CA 92121 Qualcomm; Qualcomm’s
22 business and licensing
practices; and subject matter
23 about which she was asked
during her deposition. Ms.
24 Dwight will provide live
testimony.
25
26
27
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THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Gonell, Fabian Qualcomm 15 minutes 15 minutes Mr. Gonell will testify about
Qualcomm’s licensing business
4 Qualcomm and practices; cellular SDOs
Incorporated and intellectual property rights
5 (“IPR”) policies; Qualcomm’s
5775 Morehouse Dr., business relationships with
6 San Diego, CA 92121 Apple and the CMs, including
the negotiation, terms, and/or
7 performance of certain contracts
or potential contracts; and
9 deposition. Mr. Gonell will
10 Hartogs, Michael Qualcomm 15 minutes 15 minutes Mr. Hartogs will testify about
11 c/o Qualcomm relationship with Apple,
Incorporated including the negotiation,
12 terms, and/or performance of
5775 Morehouse Dr., certain contracts or potential
13 San Diego, CA 92121 contracts; Qualcomm’s
licensing business and
14 practices; Qualcomm’s business
relationships with the CMs,
15 including the negotiations,
terms, and/or performance of
16 certain contracts or potential
contracts, including the CMs’
17 SULAs; Qualcomm’s business
and licensing practices; and
19 deposition. Mr. Hartogs will
20 Jacobs, Irwin Qualcomm 30 minutes 25 minutes Dr. Jacobs will testify about the
founding and early years of
21 c/o Qualcomm Qualcomm; Qualcomm’s
Incorporated contributions to cellular
22 technology and standardized
5775 Morehouse Dr., cellular technologies;
23 San Diego, CA 92121 Qualcomm’s business and
licensing practices and strategy;
24 Qualcomm’s modem chip sales;
and subject matter about which
25 he was asked during his
deposition. Dr. Jacobs will
27
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THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Malladi, Durga Qualcomm 50 minutes 15 minutes Dr. Malladi will testify about
Qualcomm’s approach to
4 Qualcomm research and internal
Incorporated development efforts, including
5 5775 Morehouse Dr., prototyping; Qualcomm’s
San Diego, CA 92121 leadership and contributions to
6 cellular technologies, cellular
SDOs and cellular standards;
7 Qualcomm’s outlook regarding
5G; Qualcomm’s product
8 development and customer
support, including reference
9 designs; and subject matter
10 during his deposition. Dr.
Malladi will provide live
11 testimony.
Mollenkopf, Steven Apple/CMs 60 minutes 30 minutes Apple and the CMs expect Mr.
12 Qualcomm Mollenkopf to testify about
Qualcomm’s business model,
13 Incorporated practices, procedures,
5775 Morehouse Dr., operations, revenues, profits
14 San Diego, CA 92121 and costs; Qualcomm’s “no
license, no chips” policy; the
15 uniqueness of Qualcomm’s
business model; Qualcomm’s
16 use of marketing funds,
strategic funds, incentive funds,
17 and other rebates; the allocation
of these funds between QTL
18 and QCT; Qualcomm’s
attempts to evade patent
19 exhaustion; Qualcomm’s
concerns about Intel and other
20 potential and actual competitors
as a competitive threat, and
21 measures taken in response to
that threat; Qualcomm’s
22 licensing of cellular SEPs and
other patents, and its views on
23 licensing and FRAND;
Qualcomm’s sales and business
24 practices relating to baseband
processor chipsets and
25 licensing; Qualcomm’s
negotiations with Apple and its
26 motivations and goals in those
negotiations; Qualcomm’s
27 withholding of BCP Payments
to Apple; the relationship
28 between Qualcomm Inc. and
other Qualcomm entities and

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Qualcomm’s decision to
maintain a one-company
4 structure; competition in the
relevant markets for baseband
5 processor chipsets;
Qualcomm’s relationships with
6 Authorized Purchasers;
8 manufacturers; Qualcomm’s
patents; Qualcomm’s threats to
9 cut off supply to unlicensed
customers; topics discussed at
10 deposition; and topics related to
11
Mr. Mollenkopf will testify
12 live.
Qualcomm 30 minutes 15 minutes Mr. Mollenkopf will testify
13 about Qualcomm’s business
strategy and practices;
14 Qualcomm’s patent portfolio
and innovations; Qualcomm’s
15 modem chip sales and
competition for modem chip
16 sales; Qualcomm’s business
relationships with Apple and
17 the CMs, including the
negotiation, terms, and/or
18 performance of certain contracts
or potential contracts; and
20 deposition. Mr. Mollenkopf
will provide live testimony.
21
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2 WITNESS EXAM EXAM
3 Pilgram, Ryan Apple/CMs 25 minutes 15 minutes Apple and the CMs expect Mr.
Qualcomm Pilgram to testify about the
4 Incorporated terms of Qualcomm SULA
5 5775 Morehouse Dr., licenses with the CMs;
San Diego, CA 92121 Qualcomm’s calculation of
6 royalties under those licenses;
Qualcomm’s royalty
7 investigations of the CMs and
any royalty inspection or
8 royalty disputes or findings;
9 communications with
Qualcomm’s royalty inspectors,
10 employees, and/or the CMs
regarding the previous items;
and topics related to
12 Qualcomm’s counterclaims.
13
Mr. Pilgram will testify live.
14
15
16
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20
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23
24
25
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THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Reifschneider, Eric Apple/CMs 60 minutes 40 minutes Apple and the CMs expect Mr.
Reifschneider to testify about
Marconi Group
1717 McKinney practices, procedures,
5 Ave., Dallas, TX operations, revenues, profits
75202 and costs; Qualcomm’s “no
6 license, no chips” policy;
Telephone number Qualcomm’s use of marketing
7 unknown funds, strategic funds, incentive
funds, and other rebates;
8 Qualcomm’s licensing of
cellular SEPs and other patents,
9 and its views on licensing and
FRAND; Qualcomm’s
10 negotiations with Apple and its
motivations and goals in those
11 negotiations; the relationship
between Qualcomm Inc. and
12 other Qualcomm entities;
Qualcomm’s decision to
13 maintain a one-company
structure; Qualcomm’s
14 relationships with Authorized
Purchasers; Qualcomm’s sales
15 or licensing agreements with
licensees, Apple, or other
16 device manufacturers;
Qualcomm’s threats to cut off
17 supply to unlicensed customers;
18 and topics related to
19
Mr. Reifschneider will testify
20 live.
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Rogers, Alex Qualcomm 30 minutes 45 minutes Mr. Rogers will testify about
Qualcomm’s business and
4 Qualcomm licensing practices and strategy;
Incorporated Qualcomm’s patent portfolio
5 5775 Morehouse Dr., and innovations; Qualcomm’s
San Diego, CA 92121 business relationships with
6 original equipment
manufacturers (“OEMs”);
7 regulatory investigations of
Qualcomm and Apple’s
8 inducement thereof;
9 relationships with Apple and
the CMs, including licensing
10 negotiations; and subject matter
Rogers will provide live
12 testimony.
Samimi, Abbaseh Qualcomm 15 minutes 10 minutes Ms. Samimi will testify about
13 Qualcomm’s business and
Qualcomm licensing practices;
Incorporated
14 Qualcomm’s business
5775 Morehouse Dr., relationships with the CMs,
15 San Diego, CA 92121 including the performance of
certain contracts; Apple’s
16 interference with the CMs’
contract performance; and
17 subject matter about which she
was asked during her
18 deposition. Ms. Samimi will
19 Skiver, Gerald Apple/CMs 20 minutes 20 minutes Topics discussed at deposition.
20 Qualcomm Mr. Skiver may testify live or
Incorporated by deposition designations.
21 5775 Morehouse Dr.,
San Diego, CA 92121
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Thompson, James Qualcomm 30 minutes 20 minutes Dr. Thompson will testify about
Qualcomm’s business practices;
Qualcomm
4 Qualcomm’s product
Incorporated development and competitive
5 5775 Morehouse Dr., landscape; Qualcomm’s
San Diego, CA 92121 business and engineering
6 relationship with Apple;
Qualcomm’s Research and
7 Development, including its
development of consumer and
8 mobile device technologies;
Qualcomm’s chipset
9 engineering; Qualcomm’s
customer support; and subject
10 matter about which he was
asked during his deposition.
11 Dr. Thompson will provide live
testimony.
12 Wise, David Apple/CMs 45 minutes 10 minutes Apple and the CMs expect Mr.
Wise to testify about
Qualcomm
Incorporated practices, procedures,
14 5775 Morehouse Dr., operations, revenues, profits
San Diego, CA 92121 and costs; Qualcomm’s “no
Qualcomm’s licensing of
and its views on licensing and
17 FRAND; Qualcomm’s sales
and business practices relating
18 to baseband processor chipsets
and licensing; the relationship
19 between Qualcomm Inc. and
other Qualcomm entities and
20 Qualcomm’s decision to
maintain a one-company
21 structure; competition in the
24 manufacturers; topics discussed
at deposition; and topics related
25 to Qualcomm’s counterclaims.
26 Mr. Wise will testify live.
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Qualcomm 10 minutes 5 minutes Mr. Wise will testify about
Qualcomm’s corporate strategy;
he was asked during his
5 deposition. Mr. Wise will
6 Wyatt, William Apple/CMs 10 minutes 10 minutes Apple and the CMs expect Mr.
Wyatt to testify about
Qualcomm
Incorporated practices, procedures,
8 5775 Morehouse Dr., operations, revenues, profits
San Diego, CA 92121 and costs; Qualcomm’s “no
(858) 845-4100 Qualcomm’s licensing of
and its views on licensing and
11 FRAND; Qualcomm’s sales
and business practices relating
12 to baseband processor chipsets
and licensing; competition in
baseband processor chipsets;
14 Qualcomm’s sales or licensing
agreements with licensees,
15 Apple, or other device
manufacturers; topics discussed
16 at deposition; and topics related
to Qualcomm’s counterclaims.
17
Mr. Wyatt will testify live.
18
19
20
21
22
23
24
25
26
27
28

of 69
1 CM CURRENT AND FORMER EMPLOYEES

3 THE DIRECT CROSS
WITNESS EXAM EXAM
4
Chang, Rick Qualcomm 5 minutes 2 minutes Mr. Chang will testify about
5 Compal’s product development
Compal Electronics and manufacturing activities;
Co., Ltd.
6 Compal’s chip procurement
c/o Gibson, Dunn & activities; Compal’s corporate
7 Crutcher LLP history and structure; and
333 South Grand subject matter about which he
8 Avenue, 54th Fl., Los was asked during his
Angeles, CA 90071 deposition. Mr. Chang will
9 provide testimony by deposition
designations.
10 Chao, Lily Apple/CMs 15 minutes 30 minutes Apple and the CMs expect Ms.
Chao to testify about Pegatron’s
11 Contact through negotiation of and the terms of
counsel for the CMs patent licenses and other
12 Pegatron Corporation agreements, including the
SULA and other agreements
13 5F, No. 76, Ligong with Qualcomm, and related
Street, Beitou issues and activities (including
14 District, Taipei City royalties, audits, and
112, Taiwan negotiation or renegotiation of
15 such license); Pegatron’s
product development and
16 manufacturing activities;
Pegatron’s interactions with
17 governmental agencies
investigating Qualcomm;
18 Pegatron’s corporate history
and structure; Pegatron’s
19 business relationship and
interactions with its customers
20 and other entities; topics
21 matters relating to Qualcomm’s
claims.
22
Ms. Chao will testify live.
23 Qualcomm 20 minutes 15 minutes Ms. Chao will testify about
Pegatron’s license and other
24 agreements (including with
Qualcomm); Pegatron’s royalty
25 payments and reporting;
Qualcomm’s audit disputes with
26 Pegatron; Pegatron’s product
development and manufacturing
27 activities; Pegatron’s
interactions with governmental
28 agencies investigating

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Qualcomm; Pegatron’s
corporate history and structure;
5 deposition. Ms. Chao will
provide testimony by deposition
6 designations.
Chiang, Michael Apple/CMs 15 minutes 15 minutes Apple and the CMs expect Mr.
7 Hon Hai Precision Chiang to testify about
Foxconn’s corporate history and
Industry Co., Ltd.
8 structure; Foxconn’s
c/o Gibson, Dunn & manufacturing and product
9 Crutcher LLP development activities,
333 South Grand including for Apple; Foxconn’s
10 Avenue, 54th Fl., Los business relationship and
Angeles, CA 90071 interactions with its customers
11 and other entities; Foxconn’s
license agreements, including
12 its patent license agreement
with Qualcomm, and related
13 issues and activities (including
royalties, audits, and
14 negotiation or renegotiation of
such license); topics discussed
15 at deposition; and matters
relating to Qualcomm’s claims.
16
Mr. Chiang will testify live.
17 Qualcomm 10 minutes 10 minutes Mr. Chiang will testify about
Foxconn’s business relationship
18 with Apple; Foxconn’s business
relationship with Qualcomm;
19 Foxconn’s payment and non-
payment of royalties to
20 Qualcomm; Foxconn’s
meetings with Apple regarding
21 royalties owed to Qualcomm;
deposition. Mr. Chiang will
designations.
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Chih, Calvin Qualcomm 5 minutes 4 minutes Mr. Chih will testify about
Foxconn’s license agreements
4 Hon Hai Precision with cellular patent holders;
Industry Co., Ltd. Foxconn’s meetings with Apple
5 c/o Gibson, Dunn & regarding royalties owed to
Crutcher LLP Qualcomm; and subject matter
6 333 South Grand about which he was asked
Avenue, 54th Fl., Los during his deposition. Mr. Chih
7 Angeles, CA 90071 will provide testimony by
8 Chong, Brian Apple/CMs 25 minutes 25 minutes Apple and the CMs expect Mr.
Chong to testify about
Contact through
9 Wistron’s negotiation and terms
counsel for the CMs of patent licenses and other
10 Wistron Corporation agreements, including the
SULA and agreements with
21F, No. 88, Sec. 1,
11 Qualcomm; Wistron’s audit
Hsintai 5th Rd., disputes with Qualcomm and
12 Hsichih, New Taipei audit-related activities;
City 22181, Taiwan Wistron’s interactions with
13 governmental agencies
investigating Qualcomm;
14 Wistron’s R&D with respect to
mobile devices; Wistron’s
15 manufacturing and product
development activities, and
16 relationships with customers;
Wistron’s corporate structure
17 and history; topics discussed at
deposition; and matters relating
18 to Qualcomm’s claims.
19 Mr. Chong will testify live.
20
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Huang, Eric Apple/CMs 15 minutes 15 minutes Apple and the CMs expect Mr.
Huang to testify about
Contact through
4 Wistron’s patent license and
counsel for the CMs other agreements, including
5 Wistron Corporation with Qualcomm, and related
issues (including negotiation of
21F, No. 88, Sec. 1,
6 Wistron’s patent license
Hsintai 5th Rd., agreement with Qualcomm and
Hsichih, New Taipei
7 other agreements); Wistron’s
City 22181, Taiwan manufacturing and product
8 development activities;
discussions regarding choice of
9 modem chips for cellular
devices; Wistron’s chip
10 procurement activities;
Wistron’s R&D with respect to
11 cellular mobile devices;
Wistron’s business relationship
12 and interactions with its
customers and other entities;
13 Wistron’s audit disputes with
Qualcomm and audit-related
14 activities; Wistron’s corporate
structure and history; topics
matters relating to Qualcomm’s
16 claims.
17 Mr. Huang will testify live.
Lam, Joe Apple/CMs 25 minutes 30 minutes Apple and the CMs expect Mr.
18 Lam to testify about Foxconn’s
Contact through product development and
19 counsel for the CMs manufacturing activities,
Hon Hai Precision including for Apple; Foxconn’s
20 Industry Co., Ltd. and business relationship and
FIH Mobile Ltd. interactions with its customers
21 and other entities; Foxconn’s
No. 66, Zhongshan patent license and other
22 Road, Tucheng agreements, including with
Industrial Zone, Qualcomm, and related issues;
Tucheng District,
23 Qualcomm’s audit disputes with
New Taipei City, Foxconn; Foxconn’s
24 Taiwan interactions with governmental
agencies investigating
25 Qualcomm; Foxconn’s
27 Qualcomm’s claims.
28 Mr. Lam will testify live.

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Qualcomm 30 minutes 5 minutes Mr. Lam will testify about
Foxconn’s product development
4 and manufacturing activities;
Foxconn’s patent license
5 agreement and other agreements
with Qualcomm; Foxconn’s
6 audit disputes with Qualcomm;
Foxconn’s interactions with
7 government agencies;
Foxconn’s corporate history and
8 structure; and subject matter
9 during his deposition. Mr. Lam
will provide live testimony.
10 Lee, Jessica Qualcomm 5 minutes 1 minute Ms. Lee will testify about
Compal’s patent license
11 Compal Electronics agreement with Qualcomm;
Co., Ltd. Qualcomm’s royalty audits of
12 c/o Gibson, Dunn & Compal; and subject matter
Crutcher LLP about which she was asked
13 333 South Grand during her deposition. Ms. Lee
Avenue, 54th Fl., Los will provide testimony by
14 Angeles, CA 90071 deposition designations.
15 Liu, Brenda Qualcomm 10 minutes 1 minute Ms. Liu will testify about
Pegatron’s product
Pegatron Corporation
16 development and manufacturing
c/o Gibson, Dunn & activities; Pegatron’s license
Crutcher LLP
17 agreement and other agreements
333 South Grand with Qualcomm; Pegatron’s
18 Avenue, 54th Fl., Los audit disputes with Qualcomm;
Angeles, CA 90071 Pegatron’s interactions with
19 government agencies; and
subject matter about which she
20 was asked during her
deposition. Ms. Liu will
designations.
22 Ma, Eric Apple/CMs 6 minutes 0 minutes Topics discussed at deposition.
Former Wistron
23 Mr. Ma will testify by
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Peng, Eric Apple/CMs 20 minutes 30 minutes Apple and the CMs expect Mr.
Peng to testify about Compal’s
4 Contact through corporate history and structure;
counsel for the CMs Compal’s manufacturing and
5 Compal Electronics, product development activities,
Inc. including for Apple; Compal’s
6 Nos. 581 & 581-1, business relationship and
interactions with its customers
Ruiguang Road,
7 and other entities; Compal’s
Neihu District, Taipei license agreements, including
8 City, 11492, Taiwan its patent license agreement
with Qualcomm, and related
9 issues and activities (including
royalties, audits, and
such license); topics discussed
11 at deposition; and matters
relating to Qualcomm’s claims.
12
Mr. Peng will testify live.
13 Qualcomm 30 minutes 10 minutes Mr. Peng will testify about
Compal’s license and other
Qualcomm); Compal’s product
15 development and manufacturing
activities; Compal’s corporate
16 history and structure; Compal’s
business relationship with
17 Apple; Compal’s business
18 Compal’s payment and non-
payment of royalties to
19 Qualcomm; Compal’s meetings
with Apple regarding royalties
20 owed to Qualcomm; and subject
matter about which he was
21 asked during his deposition.
Mr. Peng will provide live
22 testimony.
Shen, David Apple/CMs 20 minutes 30 minutes Apple and the CMs expect Mr.
23 Shen to testify about Wistron’s
Contact through product development and
24 counsel for the CMs manufacturing activities;
Wistron Corporation Wistron’s business relationship
21F, No. 88, Sec. 1, customers and other entities,
26 Hsintai 5th Rd., including Apple; Wistron’s
Hsichih, New Taipei
City 22181, Taiwan patent license agreement with
27 Qualcomm and related issues
and activities (including
28 royalties, audits, and

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
such license); Wistron’s
4 corporate history and structure;
5 and matters relating to
Qualcomm’s claims.
6
Mr. Shen will testify live.
7 Qualcomm 30 minutes 14 minutes Mr. Shen will testify about
Wistron’s business relationship
8 with Apple; Wistron’s business
9 Wistron’s payment and non-
payment of royalties; Wistron’s
10 meetings with Apple regarding
royalties owed to Qualcomm;
he was asked during his
12 deposition. Mr. Shen will
13 designations.
Tien, Shawn Apple/CMs 10 minutes 5 minutes Topics discussed at deposition.
14
Compal Electronics Mr. Tien will testify by
15 Co., Ltd. deposition designations.
c/o Gibson, Dunn &
Crutcher LLP Qualcomm 5 minutes 2 minutes Mr. Tien will testify about
16 Compal’s product marketing,
333 South Grand design, development and
17 Avenue, 54th Fl., Los manufacturing activities;
Angeles, CA 90071 discussions regarding choice of
18 modem chips for cellular
devices; Compal’s license
Qualcomm); Compal’s royalty
20 reporting; Qualcomm’s audit
disputes with Compal;
21 Compal’s corporate history and
structure; and subject matter
during his deposition. Mr. Tien
23 will provide testimony by
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Wang, Renee Qualcomm 5 minutes 1 minute Ms. Wang will testify about
Pegatron’s license agreement
4 Pegatron Corporation and other agreements with
c/o Gibson, Dunn & Qualcomm; Pegatron’s royalty
5 Crutcher LLP payments and reporting;
333 South Grand Pegatron’s audit disputes with
6 Avenue, 54th Fl., Los Qualcomm; Pegatron’s
Angeles, CA 90071 interactions with government
7 agencies; and subject matter
about which she was asked
8 during her deposition. Ms.
Wang will provide testimony by
Wang, Selena Qualcomm 10 minutes 1 minute Ms. Wang will testify about
10 Wistron’s relationship with
Wistron Corporation Apple; Wistron’s royalty
11 c/o Gibson, Dunn & reporting and royalty payments
Crutcher LLP to Qualcomm; Wistron’s
12 333 South Grand payment and non-payment of
royalties; and subject matter
13 Avenue, 54th Fl., Los about which she was asked
Angeles, CA 90071 during her deposition. Ms.
14 Wang will provide testimony by
15 Yang, Monica Apple/CMs 45 minutes 30 minutes Apple and the CMs expect Ms.
Yang to testify about Pegatron’s
16 Contact through negotiation of and the terms of
counsel for the CMs patent licenses and other
17 Pegatron Corporation agreements, including the
SULA and other agreements
18 5F, No. 76, Ligong with Qualcomm; Pegatron’s
Street, Beitou interactions with governmental
19 District, Taipei City agencies investigating
112, Taiwan Qualcomm; Pegatron’s
20 corporate structure and history;
Pegatron’s business relationship
customers and other licensees;
24 Ms. Yang will testify live.
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Qualcomm 30 minutes 10 minutes Ms. Yang will testify about
Pegatron’s patent license and
4 other agreements (including
with Qualcomm); Pegatron’s
5 interactions with governmental
agencies investigating
6 Qualcomm; Pegatron’s
corporate structure and history;
8 deposition. Ms. Yang will
9 Yao, Denese Apple/CMs 15 minutes 10 minutes Apple and the CMs expect Ms.
Yao to testify about Pegatron’s
10 Contact through product development and
counsel for the CMs manufacturing activities,
11 Pegatron Corporation including for Apple; Pegatron’s
business relationship and
12 5F, No. 76, Ligong interactions with its customers
Street, Beitou and other entities; Pegatron’s
13 District, Taipei City license agreements, including
112, Taiwan its patent license agreement
14 with Qualcomm, and related
issues and activities (including
15 royalties and audits); Pegatron’s
18 Ms. Yao will testify live.
Qualcomm 5 minutes 4 minutes Ms. Yao will testify about
19 Pegatron’s business relationship
with Apple; Pegatron’s
20 meetings with Apple regarding
royalties owed to Qualcomm;
22 deposition. Ms. Yao will
23 designations.
24
25
26
27
28

of 69
1 THIRD-PARTY WITNESSES
3 THE DIRECT CROSS
WITNESS EXAM EXAM
4
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
Qualcomm’s policies and
10 practices relating to the sale and
licensing of baseband processor
11 chipsets and the competitive
effects thereof; the
Qualcomm’s practices on
13 Lenovo; and topics discussed at
deposition.
14
Mr. Blumberg will testify by
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
chipsets; Qualcomm’s policies
22 and practices relating to the sale
and licensing of baseband
23 processor chipsets and the
competitive effects thereof, the
25 Qualcomm’s practices on ZTE;
and topics discussed at
26 deposition.
27 Mr. Blaylock may testify live or

28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Cho, Hwi-Jae Apple/CMs 15 minutes 5 minutes Apple and the CMs expect Mr.
Cho to testify concerning
4 LGE licensing practices in the
cellular industry; competition in
6 Qualcomm’s policies and
practices relating to the sale and
7 licensing of baseband processor
chipsets and the competitive
8 effects thereof; the
9 Qualcomm’s practices on LGE;
and topics discussed in his
10 written testimony.
11 Mr. Cho will testify through the
reading of his written
12 testimony.
Constantine, Kevin Qualcomm 15 minutes 15 minutes Mr. Constantine will testify
13 Intel Corporation about competition in the
modem chip industry; Intel’s
14 2200 Mission College business relationship with
Blvd, Santa Clara, Apple; Apple’s technical
15 CA 95054 requirements for its chip
suppliers; technical
16 specifications of Intel chips;
deposition. Mr. Constantine
18 will provide testimony by
19 Davis, Mark Apple/CMs 30 minutes 25 minutes Apple and the CMs expect Mr.
Davis to testify about licensing
20 Intel practices in the cellular
Contact through industry; baseband processor
21 counsel chipset engineering;
22 Mark A. Ford markets for baseband processor
WilmerHale chipsets; Qualcomm’s policies
23 60 State Street
and practices relating to the sale
Boston, MA 02109 and licensing of baseband
24 (617) 526-6423 processor chipsets and the
competitive effects thereof; the
Qualcomm’s practices on VIA
26 and Intel; and topics discussed
at deposition.
27
Mr. Davis will testify live.
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Evans, Aichatou Apple/CMs 45 minutes 45 minutes Apple and the CMs expect Ms.
Evans to testify about Intel’s
4 Former Intel baseband processor chipset
Contact through engineering efforts; competition
5 counsel in the relevant markets for
Joseph J. Mueller
6 Qualcomm’s policies and
WilmerHale practices relating to the sale and
7 60 State Street licensing of baseband processor
Boston, MA 02109 chipsets and the competitive
8 (617) 526-6396 effects thereof; the
9 Qualcomm’s practices on Intel;
10 deposition.
11 Ms. Evans will testify live.
Grubbs, John Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Mr.
12 BlackBerry Grubbs to testify about
Qualcomm’s licensing
13 5030 Riverside Dr., negotiations with Blackberry;
Irving, TX 75039 the supra-FRAND terms of
14 Blackberry’s SULA;
(972) 373-1700 Blackberry’s valuation of
15 Qualcomm’s SEPs; licensing
practices in the cellular
16 industry; competition in the
21 Blackberry; and topics
discussed at deposition.
22
Mr. Grubbs will testify by
Hill, Arthur Apple/CMs 15 minutes 15 minutes Topics discussed at deposition.
24
Sony Mobile Mr. Hill will testify by
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Hong, Eushuk Apple/CMs 7 minutes 15 minutes Topics discussed at deposition.
4 Samsung Mr. Hong will testify by
129 Samsung-Ro, deposition designations.
5 Yeongtong-gu,
Suwon-si, Gyeonggi-
6 do, South Korea
16677
7 82-32-279-0962
8 Keddy, Asha Apple/CMs 4 minutes 7 minutes Topics discussed at deposition.
9 Intel Corporation Ms. Keddy will testify by
2200 Mission College deposition designations.
10 Blvd, Santa Clara,
CA 95054
11 Kim, Yooseok Apple/CMs 10 minutes 10 minutes Topics discussed at deposition.
12 Samsung Mr. Kim will testify by
129 Samsung-Ro, deposition designations.
13 Yeongtong-gu,
Suwon-si, Gyeonggi-
14 do, South Korea
16677
15
82-32-279-0962
16 Lee, Injung Apple/CMs 20 minutes 30 minutes Apple and the CMs expect Mr.
Lee to testify about
17 Samsung Qualcomm’s refusal to provide
129 Samsung-Ro, Samsung a chipset-level license
18 Yeongtong-gu, and its impact on Samsung’s
Suwon-si, Gyeonggi- modem development; licensing
19 do, South Korea practices in the cellular
16677 industry; baseband processor
20 chipset engineering;
82-32-279-0962 competition in the relevant
22 and practices relating to the sale
23 processor chipsets and the
25 Samsung; and topics discussed
at deposition.
26
Mr. Lee will testify by
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Madderom, Todd Apple/CMs 20 minutes 35 minutes Apple and the CMs expect Mr.
Madderom to testify about
Motorola Mobility
4 Motorola’s inability to
222 West challenge Qualcomm’s supra-
5 Merchandise Mart FRAND royalty demands
Plaza #1800, because of the fear of supply
6 Chicago, IL 60654 threats from Qualcomm;
licensing practices in the
7 (800) 668-6765 cellular industry; competition in
12 Motorola; and topics discussed
at deposition.
13
Mr. Madderom will testify by
McGregor, Scott Apple/CMs 15 minutes 15 minutes Apple and the CMs expect Mr.
15 Former Broadcom McGregor to testify about
16 Peppertree Bend markets for baseband process
17 San Juan Capistrano and practices relating to the sale
18 pressor chipsets and the
20 Broadcom; and topics discussed
at deposition.
21
Mr. McGregor will testify live
22 or by deposition designations.
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Moynihan, Finbarr Apple/CMs 30 minutes 40 minutes Apple and the CMs expect Mr.
(John) Moynihan to testify about
4 MediaTek baseband processor chipset
engineering; competition in the
5 120 Presidential Way relevant markets for baseband
# 100, Woburn, MA processor chipsets;
6 01801 Qualcomm’s policies and
practices relating to the sale and
7 (781) 503-8000 licensing of baseband processor
chipsets and the competitive
8 effects thereof; the
9 Qualcomm’s practices on
MediaTek, including
10 MediaTek’s delayed entry into
the 3G, LTE, and premium LTE
11 markets; and topics discussed at
deposition.
12
Mr. Moynihan will testify live
13 or by deposition designations.
Petersson, Christina Apple/CMs 14 minutes 30 minutes Apple and the CMs expect Ms.
14 Ericsson Petersson to testify about
18 Ericsson; and topics discussed
at deposition.
19
Ms. Petersson will testify by
Varadarajan, Qualcomm 10 minutes 10 minutes Mr. Varadarajan will testify
21 Godavarthi about Boston Consulting
Group’s work relating to
22 Boston Consulting strategic alternatives under
Group, Inc. consideration by a special
23 2501 North Harwood committee of Qualcomm’s
Suite 2200, Dallas, Board of Directors in and
24 TX 75201 around 2015; and subject matter
25 during his deposition.
Mr. Varadarajan will provide
26 live testimony.
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Weiler, Dirk Qualcomm 20 minutes 19 minutes Mr. Weiler will testify about
industry licensing practices;
Nokia Technologies
4 Nokia’s business relationship
200 South Mathilda with Qualcomm; and subject
5 Ave, Sunnyvale, CA matter about which he was
94086 asked during his deposition.
6 Mr. Weiler will provide live
testimony and/or testimony by
Yu, Nanfen (Nancy) Apple/CMs 15 minutes 25 minutes Apple and the CMs expect Ms.
8 Yu to testify about Qualcomm’s
Huawei policies and practices relating to
9 the sale and licensing of
baseband processor chipsets
10 and the competitive effects
thereof; the anticompetitive
11 effects of Qualcomm’s practices
on Huawei; and topics
12 discussed at deposition.
13 Ms. Yu will testify by
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

of 69
1 APPLE/CM EXPERTS
3 THE DIRECT CROSS
WITNESS EXAM EXAM
4
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,
26 patents” are invalid, and/or
because patents owned by other
27
2
28 Witnesses identified as rebuttal witnesses may or may not testify, depending on
Qualcomm’s case-in-chief.
of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 companies are comparably
fundamental and/or important
4 to the same areas of
telecommunications standards
5 identified by Dr. Andrews.
6 Dr. Akl will testify live.
Bernheim, Douglas Apple/CMs 70 minutes 45 minutes Apple and the CMs expect
7 Contact through Professor Bernheim to testify
regarding economic principles
8 counsel for Apple for antitrust analysis in this
and the CMs case, the economics of standard
9 Department of setting, the meaning and
Economics, Stanford purpose of FRAND
10 University, Stanford, commitments, the industry and
CA, 94305-6072 relevant markets, Qualcomm’s
11 market power, Qualcomm’s
(650) 725-8732 anticompetitive conduct, the
12 effects of Qualcomm’s conduct
on competition, to evaluate
13 alleged business justifications
for Qualcomm’s conduct, to
14 rebut Qualcomm experts, and
topics discussed at deposition.
15
Professor Bernheim will testify
16 live.
Bims, Harry Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
17 Bims to testify, as an
Contact through
18 counsel for Apple independent expert and person
and the CMs of skill in the relevant art,
19 1314 Chilco Street, regarding the technical
Menlo Park, CA background and the state of the
20 94025 art relevant to the claims of
(650) 283-4174 exemplary patents including
21 U.S. Patent No. 9,137,822; the
22 interpretation of the claims of
exemplary patents including
23 U.S. Patent No. 9,137,822; the
invalidity and/or
24 unenforceability of the claims
of one or more exemplary
25 patents including U.S. Patent
26 No. 9,137,822; secondary
indicia of non-obviousness as
27 they relate to one of more
28 U.S. Patent No. 9,137,822; the

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 non-essentiality to the relevant
standard of one or more of
4 exemplary patents including
5 U.S. Patent No. 9,137,822; the
design and operation of the
6 accused products as they relate
to one or more exemplary
No. 9,137,822; noninfringement
8 of the claims of one or more
U.S. Patent No. 9,137,822;
10 noninfringing alternatives to the
extent any of the accused
11 products are deemed to infringe
claims of one or more of the
13 U.S. Patent No. 9,137,822;
whether claims of Qualcomm
14 patents, if practiced, would be
substantially embodied in a
15 Qualcomm baseband processor
chipset, other components of a
16 mobile device, and/or the
17 network infrastructure; wireless
communication technologies
18 and associated standards;
technical comparability of
19 licensing agreements; ex ante
alternatives to technologies
20
embodied in relevant cellular
21 SEPs; and topics discussed at
deposition.
22
Additionally, to the extent that
23 Qualcomm’s experts Dr.
24 Andrews, Dr. Gitlin and Dr.
Jayant are permitted to and do
25 testify, Apple and the CMs
expect Dr. Bims to testify
26 regarding their failure to show
that certain of Qualcomm’s SEP
27 are essential to any cellular
28 standard and are invalid and/or
not important. Apple also

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 experts Dr. Bims to rebut
testimony from Dr. Williams
4 regarding the technical
5 capabilities of Qualcomm’s
baseband chipset.
6
Dr. Bims will testify live.
7 Choi, David Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
(rebuttal) Choi to provide rebuttal
8 Contact through testimony, to the extent that
counsel for Apple
Qualcomm’s expert Massoud
9 and the CMs Pedram is permitted to and does
2706 Winding Trail testify, regarding Dr. Pedram’s
10 Place, Boulder, CO failure to show that 68
80304. Qualcomm “exemplary patents”
11 related to the area of power
(858) 352-8889 management provide Apple, the
12 CMs or consumers any value,
including because Dr. Pedram
13 has not shown that Apple, the
CMs, or any consumers use the
14 technology of the 68 Qualcomm
“exemplary patents” and
15 because the 68 “exemplary
patents” are likely invalid.
16
Dr. Choi will testify live.
17 Lanning, Mark Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Mr.
(rebuttal) Lanning to provide rebuttal
counsel for Apple Qualcomm’s experts Dr. Gitlin
19 and the CMs and Dr. Jayant are permitted to
4 Eagles Nest, and do testify, regarding Dr.
20 Greenville, TX Gitlin’s and Dr. Jayant’s failure
75402-9027 to show that certain of
21 Qualcomm’s SEP are essential
(903) 454-3399 to any cellular standard and are
22 invalid and/or not important.
23 Mr. Lanning will testify live.
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Leitzinger, Jeffrey Apple/CMs 75 minutes 45 minutes Apple and the CMs expect Dr.
Leitzinger to testify regarding
Contact through
4 issues relating to the CMs’ (and
counsel for the CMs each of their) causal injuries
5 EconOne Research, and damages (including but not
Inc. limited to overcharge damages,
6 550 South Hope restitution, and disgorgement)
in connection with their
7 Street, Suite 800, Los counterclaims and defenses in
Angeles, CA 90071 the above-captioned litigation,
8 (213) 624-9600 and other economic matters
relevant to assessing the injury
9 to competition as a result of
Qualcomm’s conduct; rebuttal
10 to Qualcomm’s experts; and
11
Dr. Leitzinger will testify live.
12 Libchaber, Remy Apple/CMs 15 minutes 15 minutes Apple and the CMs expect
(rebuttal) Professor Libchaber to testify
13 Contact through about the meaning under French
counsel for Apple law of Qualcomm’s IPR
14 and the CMs disclosure obligation under the
University of Paris I: ETSI IPR Policy and FRAND
15 Pantheon-Sorbonne, commitment to ETSI;
12 Place du timeliness of Qualcomm’s IPR
16 Panthéon, 75231 disclosures; and topics
Paris, France discussed at deposition.
17 +33 1 44 07 80 00 Professor Libchaber will testify
18 live.
19
20
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Meyer, Paul Apple/CMs 45 minutes 45 minutes Apple and the CMs expect Mr.
Meyer to testify regarding the
4 Contact through economic issues implicated by
counsel for Apple the claims of this lawsuit,
5 and the CMs including the disgorgement of
TM Financial royalties paid by Apple and/or
6 Forensics, LLC Two the CMs, whether the royalty
Embarcadero Ctr., rates and related fees paid by
7 Suite 2510, San Apple/or and the CMs adhere to
Francisco, CA 94111 FRAND, the restitution owed to
8 (415) 692-6350 Apple and/or the CMs for
excessive license fees, and
9 secondary indicia of non-
obviousness; issues surrounding
10 FRAND licensing, including
Apple’s, the CMs’, and
11 Qualcomm’s licensing
practices, as well as the royalty
12 that would apply to making,
using, selling, offering for sale
13 and/or importing products
encompassed by any valid,
14 standard-essential, non-
exhausted, and infringed patent
15 claims at issue in this lawsuit;
16 deposition.
17 Mr. Meyer will testify live.
Rodermund, Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Mr.
18 Friedhelm (rebuttal) Rodermund to testify regarding
the meaning of Qualcomm’s
19 Contact through
counsel for Apple FRAND commitment to ETSI;
the history and proper
20 and the CMs interpretation of ETSI policies,
IOTECC GmbH Am including its intellectual rights
21 Steiner Graben 18, policy; industry practice as it
56077 Koblenz, relates to the FRAND
22 Germany commitment; rebuttal to
Qualcomm’s experts on these
23 +49 172 2606489
topics, to the extent
Qualcomm’s experts are
24 permitted to and do testify
about them; and topics
25 discussed at deposition.
26 Mr. Rodermund will testify
live.
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Scott Morton, Fiona Apple/CMs 70 minutes 45 minutes Apple and the CMs expect
Professor Scott Morton to
4 Contact through testify regarding economic
counsel for Apple principles for antitrust analysis
5 and the CMs in this case, the economics of
Charles River standard setting, the meaning
6 Associates and purpose of FRAND
commitments, the industry and
200 Clarendon Street
7 relevant markets, Qualcomm’s
Boston, MA 02116 market power, the
8 (617) 425-3000 anticompetitive nature of
Qualcomm’s conduct, the
9 effects of Qualcomm’s conduct
on competition, to rebut
10 Qualcomm experts, and topics
11
Professor Scott Morton will
12 testify live.
Sears, Andrew Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
13 Contact through (rebuttal) Sears to provide rebuttal
testimony, to the extent that
counsel for Apple
14 Qualcomm’s expert Daniel
and the CMs Wigdor is permitted to and does
15 332 Information testify, regarding Dr. Wigdor’s
Sciences and failure to show that 22
16 Technology Building Qualcomm “exemplary patents”
University Park, PA related to the area of user
17 16802 interfaces and mobile device
software provide Apple, the
18 (410) 802-5045 CMs and consumers any value,
including because Dr. Wigdor
“exemplary patents” and
21 because the 22 “exemplary
patents” are likely invalid.
22
Dr. Sears will testify live.
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Simcoe, Timothy Apple/CMs 45 minutes 45 minutes Apple and the CMs expect
Professor Simcoe to testify
4 Contact through regarding the process and
counsel for Apple economics of standard setting,
5 and the CMs the meaning and purpose of
Boston University FRAND commitments,
6 595 Commonwealth economic principles for
assessing FRAND terms,
Avenue, Boston, MA
7 whether Qualcomm’s royalties,
02215 license terms, and offers to
8 (617) 353-2000 Apple comport with FRAND,
the value of Qualcomm’s SEPs,
9 to rebut Qualcomm experts, and
10
Professor Simcoe will testify
11 live.
Simonson, Itamar Apple/CMs 15 minutes 15 minutes Apple and the CMs expect
12 Contact through (rebuttal) Professor Simonson to provide
rebuttal testimony, to the extent
counsel for Apple
13 that Qualcomm’s expert Jeffrey
and the CMs Prince is permitted to and does
14 Graduate School of testify, regarding research
Business, Stanford methods, design and analysis of
15 University consumer surveys and common
survey mistakes, and human
16 655 Knight Center, judgment and decision-making.
Stanford, CA 94305
17 (650) 725-8981 Professor Simonson will testify
live.
18 Stark, Wayne Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
Stark to testify, as an
19 Contact through independent expert and person
counsel for Apple of skill in the relevant art,
20 and the CMs regarding the technical
EECS Department, background and the state of the
21 The University of art relevant to the claims of one
Michigan, Ann or more of exemplary patents
22 Arbor, MI 48109- including U.S. Patent Nos.
2122 7,095,725 and 6,556,549; the
(734) 763-0390 one or more exemplary patents
24 including U.S. Patent Nos.
7,095,725 and 6,556,549; the
25 invalidity and/or
unenforceability of the claims
26 of one or more exemplary
patents including U.S. Patent
27 Nos. 7,095,725 and 6,556,549;
secondary indicia of non-
28 obviousness as they relate to

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 one of more exemplary patents
including U.S. Patent Nos.
4 7,095,725 and 6,556,549; the
non-essentiality to the relevant
5 standard of one or more of
6 U.S. Patent Nos. 7,095,725 and
6,556,549; the design and
7 operation of the accused
products as they relate to one or
8 more exemplary patents
9 7,095,725 and 6,556,549;
noninfringement of the claims
11 Nos. 7,095,725 and 6,556,549;
noninfringing alternatives to the
12 extent any of the accused
products are deemed to infringe
13 one or more exemplary patents
14 7,095,725 and 6,556,549;
whether claims of Qualcomm
15 patents, if practiced, would be
substantially embodied in a
16 Qualcomm baseband processor
chipset, other components of a
17 mobile device, and/or the
network infrastructure; wireless
18 communication technologies
and associated standards,
19 technical comparability of
licensing agreements; ex ante
20 alternatives to technologies
embodied in relevant cellular
21 SEPs; and topics discussed at
deposition.
22 Additionally, to the extent that
Qualcomm’s experts Dr.
expect Dr. Stark to testify
standard and are invalid and/or
27 not important.
28 Dr. Stark will testify live.

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Stevenson, Robert Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
(rebuttal) Stevenson to provide rebuttal
counsel for Apple Qualcomm’s expert Dr. Nikil
5 and the CMs Jayant is permitted to and does
1961 Camp Madron testify, regarding Dr. Jayant’s
6 Rd., Lot 38, failure to show that 13
Buchanan, MI 49107 Qualcomm “Evaluated Patents”
7 (574) 339-3514 related to the area of speech and
video coding provide Apple, the
8 CMs or consumers any value,
including because Dr. Jayant
“Evaluated Patents” and
11 because the 13 “Evaluated
Patents” are likely invalid.
12
Dr. Stevenson will testify live.
13 Valenti, Matthew Apple/CMs 45 minutes 30 minutes Apple and the CMs expect Dr.
Valenti to testify regarding
14 Contact through technical analysis of Qualcomm
counsel for Apple patents, including whether
15 and the CMs claims of Qualcomm patents, if
Lane Dept. of Comp. practiced, would be
16 Sci. & Electrical substantially embodied in a
Engineering, West Qualcomm baseband processor
17 Virginia University, chipset, other components of a
Morgantown, WV mobile device, and/or the
18 26506-6109 network infrastructure; and
19 (304) 293-9139
Dr. Valenti will testify live.
20 Wells, Jonathan Apple/CMs 30 minutes 30 minutes Apple and the CMs expect Dr.
Wells to testify, as an
533 Peters Ave, Suite background and the state of the
23 204, Pleasanton, CA art relevant to the claims of one
94566 or more exemplary patents
(925) 200-5124 7,246,242, 7,289,630,
25 8,867,494, and 9,059,819; the
interpretation of the claims of
26 one or more exemplary patents
27 7,246,242, 7,289,630,
8,867,494, and 9,059,819; the

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 unenforceability of the claims
of one or more exemplary
Nos. 7,246,242, 7,289,630,
5 8,867,494, and 9,059,819;
one of more exemplary patents
7,246,242, 7,289,630,
8 8,867,494, and 9,059,819; the
non-essentiality to the relevant
9 standard of one or more
10 U.S. Patent Nos. 7,246,242,
7,289,630, 8,867,494, and
11 9,059,819; the design and
operation of the accused
12 products as they relate to one or
more exemplary patents
7,246,242, 7,289,630,
14 8,867,494, and 9,059,819;
16 Nos. 7,246,242, 7,289,630,
8,867,494, and 9,059,819;
17 noninfringing alternatives to the
extent any of the accused
18 products are deemed to infringe
claims of one or more
U.S. Patent Nos. 7,246,242,
20 7,289,630, 8,867,494, and
9,059,819; whether claims of
21 Qualcomm patents, if practiced,
would be substantially
22 embodied in a Qualcomm
baseband processor chipset,
23 other components of a mobile
device, and/or the network
24 infrastructure; wireless
communication technologies
25 and associated standards,
including the counting of
26 contributions to one or more
standards; technical
27 comparability of licensing
agreements; ex ante alternatives
28 to technologies embodied in

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 relevant cellular SEPs; and
expect Dr. Wells to testify
9 not important.
10 Dr. Wells will testify live.
Welsch, Roy Apple/CMs 15 minutes 10 minutes Apple and the CMs expect Dr.
11 Contact through Welsch to testify regarding the
correct size of a statistical
counsel for Apple
12 sample of Qualcomm’s
and the CMs population of patents to
13 100 Main Street, estimate certain characteristics
E62-564, Cambridge, of the whole Qualcomm patent
14 MA 02139 population; and topics
15 (617) 253-6601
Dr. Welsch will testify live.
16 Wicker, Stephen Apple/CMs 30 minutes 30 minutes Apple and the CMs expect Dr.
Wicker to testify, as an
386 Rhodes Hall, background and the state of the
19 Cornell University, art relevant to the claims of one
Ithaca, NY 14853 or more exemplary patents
(607) 255-8817 6,694,469 and 7,096,021; the
one or more exemplary patents
6,694,469 and 7,096,021; the
unenforceability of the claims
25 Nos. 6,694,469 and 7,096,021;
one of more exemplary patents
6,694,469 and 7,096,021; the
28 non-essentiality to the relevant

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 standard of one or more of the
patents-in- suit including U.S.
4 Patent Nos. 6,694,469 and
7,096,021; the design and
5 operation of the accused
products as they relate to one or
6 more exemplary patents
7 6,694,469 and 7,096,021;
9 Nos. 6,694,469 and 7,096,021;
noninfringing alternatives to the
10 extent any of the accused
products are deemed to infringe
11 claims of one or more
12 U.S. Patent Nos. 6,694,469 and
7,096,021; whether claims of
13 Qualcomm patents, if practiced,
would be substantially
14 embodied in a Qualcomm
baseband processor chipset,
15 other components of a mobile
device, and/or the network
16 infrastructure; evolution of
wireless communication
17 technologies over time,
including the evolution of smart
18 phone technology and Apple
smart phone technology, and
19 associated standards; technical
comparability of licensing
20 agreements, and ex ante
alternatives to technologies
21 embodied in relevant cellular
SEPs; and topics discussed at
22 deposition.
expect Dr. Wicker to testify
28 not important.

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Similarly, Apple and the CMs
expect Dr. Wicker to provide
4 rebuttal testimony, to the extent
that Qualcomm’s expert Dr.
5 Madisetti is permitted to and
does testify, regarding Dr.
6 Madisetti’s failure to show that
certain Qualcomm “exemplary
7 patents” provide Apple, the
CMs or consumers any value,
8 including because Dr. Madisetti
has not shown that Apple, the
9 CMs, or any consumers use the
technology of the Qualcomm
because the “exemplary
Dr. Wicker will testify live.
12 Zickler, Todd Apple/CMs 20 minutes 20 minutes Apple and the CMs expect Dr.
(rebuttal) Zickler to provide rebuttal
counsel for Apple Qualcomm’s expert Ken
14 and the CMs Parulski is permitted to and
Harvard University does testify, regarding Mr.
15 Parulski’s failure to show that
33 Oxford St., 19 Qualcomm “exemplary
Cambridge, MA
16 patents” related to the area of
02138 digital image processing
17 (617) 495-4390 provide Apple, the CMs and
consumers any value, including
18 because Mr. Parulski has not
shown that Apple, the CMs, or
19 any consumers use the
technology of the 19 Qualcomm
22 Dr. Zickler will testify live.
23
24
25
26
27
28

of 69
1 QUALCOMM EXPERTS
3 THE DIRECT CROSS
WITNESS EXAM EXAM
4
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
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.
21
Dr. Chipty will testify
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.

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Evans, David Qualcomm 25 minutes 15 minutes Dr. Evans is the Chairman of
the Global Economics Group.
4 c/o Qualcomm He has held faculty positions at
Incorporated the University of Chicago Law
5 5775 Morehouse School and the University
Drive, San Diego, CA College London, as well as a
6 92121 tenured professorship at
Fordham University School of
7 Law until 1995. He holds a
B.A, M.A., and Ph.D. in
8 Economics from the University
of Chicago.
9
Dr. Evans will testify
his expert reports and subject
asked during his deposition,
12 including the value of cellular
technologies for smartphone
13 users and device makers,
including Apple; and the
14 economic impact of certain
patent licensing structures, as
15 well as in rebuttal to Apple and
the CMs’ experts. Dr. Evans
16 will provide live testimony.
Gitlin, Richard Qualcomm 20 minutes 10 minutes Dr. Gitlin is an expert in
17 c/o Qualcomm electrical engineering, and
holds the Agere Endowed
18 Incorporated Chair in Electrical Engineering
5775 Morehouse at the University of South
19 Drive, San Diego, CA Florida. He holds a B.E.E.
92121 from the City College of New
20 York and a M.S. and Eng. Sc.
D. in Electrical Engineering
21 from Columbia University.
22 Dr. Gitlin will testify regarding
the subject matter of his expert
23 report and subject matter about
which he was asked during his
24 deposition, including the
importance of certain
25 Qualcomm technologies, as
well as certain SEPs related to
26 the UMTS, LTE and 5G NR
standards. Dr. Gitlin will
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Hart, Oliver Qualcomm 30 minutes 10 minutes Dr. Hart is a Nobel Prize-
winning economist who has
4 c/o Qualcomm held a tenured professorship at
Incorporated Harvard University since 1993
5 5775 Morehouse and focuses on contracting
Drive, San Diego, CA theory. He is also a Fellow of
6 92121 the Econometric Society, the
American Academy of Arts
7 and Sciences, the British
Academy and the American
8 Finance Association as well as
a member of the National
9 Academy of Sciences. Hart
earned his B.A. in
10 Mathematics from King’s
College at Cambridge
11 University before his M.A. in
Economics from Warwick
12 University and Ph.D. in
Economics from Princeton
13 University.
14 Dr. Hart will testify regarding
the subject matter of his expert
15 report and subject matter about
which he was asked during his
16 deposition, including the
parties’ contracting practices,
17 including the related
economics and welfare effects;
18 and the value of Qualcomm’s
licensing practices in
19 facilitating investment and
other productivity-enhancing
20 activities. Dr. Hart will
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Huber, Bertram Qualcomm 20 minutes 10 minutes Dr. Huber is a Principal of
IP*SEVA and is a Lecturer at
4 c/o Qualcomm the University of
Incorporated Tübingen/Germany on Laws of
5 5775 Morehouse IPRs, International IP Strategy
Drive, San Diego, CA and Management and License
6 92121 Agreements/Licensing Law.
He has extensive negotiation
7 and technology licensing
experience, and has
8 participated in the elaboration
of IPR/patent policies at ETSI.
9 He received his undergraduate
degrees from the Universities
10 of Münster and Tübingen in
Law and his Doctorate in Law
11 from the University of
Tübingen.
12
Dr. Huber will testify
15 including the development,
history and purposes animating
16 ETSI’s IPR policy; the
obligations of patent licensors
17 that have made fair, reasonable
and non-discriminatory
18 (“FRAND”) commitments to
ETSI, including whether
19 Apple’s behavior in licensing
negotiations is consistent with
20 that of a party negotiating in
good faith, as well as in
21 rebuttal to Apple and the CMs’
experts. Dr. Huber will
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Jayant, Nikil Qualcomm 15 minutes 10 minutes Dr. Jayant is a Professor
Emeritus at the Georgia
4 c/o Qualcomm Institute of Technology and an
Incorporated Adjunct Professor at the
5 5775 Morehouse University of California at
Drive, San Diego, CA Santa Barbara. He has held
6 92121 research positions at Stanford
University, Bell Laboratories
7 and the Georgia Institute of
Technology, and presently is a
8 Co-Founder and the CEO of
VQLink, a Georgia Institute of
9 Technology startup. He holds
a B.Sc. in Physics and
10 Mathematics from Mysore
University, India, and a B.E.
11 and Ph.D. in Electrical
Communications from the
12 Indian Institute of Science.
13 Dr. Jayant will testify
including the importance of
16 certain Qualcomm
technologies, as well as certain
17 SEPs related to the UMTS,
LTE and 5G NR standards.
18 Dr. Jayant will provide live
testimony.
19
20
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Knittel, Christopher Qualcomm 30 minutes 10 minutes Dr. Knittel holds a tenured
professorship at MIT in
4 c/o Qualcomm Applied Economics, and his
Incorporated research focuses on industrial
5 5775 Morehouse organization, environmental
Drive, San Diego, CA economics and applied
6 92121 econometrics. Dr. Knittel
holds a B.A. in Economics
7 from California State
University, Stanislaus, an M.A.
8 in Economics from the
University of California,
9 Davis, and a Ph.D. in
Economics from the University
10 of California, Berkeley.
11 Dr. Knittel will testify
including the value
14 enhancement of cellular
technology in mobile devices,
15 including Apple’s devices. Dr.
Knittel will provide live
16 testimony.
17
18
19
20
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Madisetti, Vijay Qualcomm 15 minutes 10 minutes Dr. Madisetti is a Professor in
Electrical and Computer
4 c/o Qualcomm Engineering at the Georgia
Incorporated Institute of Technology. He
5 5775 Morehouse holds a B. Tech (Hons) in
Drive, San Diego, CA Electronics and Electrical
6 92121 Communications Engineering
from the Indian Institute of
7 Technology and a Ph.D. in
Electrical Engineering and
8 Computer Sciences from the
University of California,
9 Berkeley.
10 Dr. Madisetti will testify
including the technical merit,
13 value for user experience, and
relevance to customers and
14 device makers of certain
Qualcomm patents. Dr.
15 Madisetti will provide live
testimony.
16 Michalson, William Qualcomm 15 minutes 10 minutes Dr. Michalson is a faculty
member of the Electrical and
17 c/o Qualcomm Computer Engineering
Incorporated Department at the Worcester
18 5775 Morehouse Polytechnic Institute in
Drive, San Diego, CA Massachusetts. He holds a
19 92121 B.S. in Electrical Engineering
from Syracuse University, and
20 a M.S. and Ph.D. in Electrical
Engineering from Worcester
21 Polytechnic.
22 Dr. Michalson will testify
27 Michalson will provide live
testimony.
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Nevo, Aviv Qualcomm 1 hour 50 minutes Dr. Nevo is an antitrust
economist who holds a tenured
4 c/o Qualcomm professorship in the Marketing
Incorporated Department at the Wharton
5 5775 Morehouse School of Business and in the
Drive, San Diego, CA Department of Economics at
6 92121 the University of
Pennsylvania. He is the
7 former Deputy Assistant
Attorney General for
8 Economic Analysis of the
Antitrust Division at DOJ
9 (2013-2014). Dr. Nevo holds a
Ph.D. and A.M. in Economics
10 from Harvard University and
his B.Sc. with Special Honors
11 in Mathematics and Economics
from Tel Aviv University.
12
Dr. Nevo will testify regarding
13 the subject matter of his expert
reports and subject matter
during his deposition,
15 including Qualcomm’s
licensing practices; and
16 Apple’s and the CMs’ theories
of antitrust harm, as well as in
17 rebuttal to Apple and the CMs’
experts. Dr. Nevo will provide
18 live testimony.
19
20
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Parulski, Kenneth Qualcomm 15 minutes 10 minutes Mr. Parulski is the Chief
Scientist and Managing
4 c/o Qualcomm Member of aKAP Innovation,
Incorporated LLC, which provides
5 5775 Morehouse innovation and digital
Drive, San Diego, CA photography-related consulting
6 92121 services. He holds a B.S. and
an M.S. in Electrical
7 Engineering from the
Massachusetts Institute of
8 Technology.
9 Mr. Parulski will testify
Qualcomm patents. Mr.
14 Parulski will provide live
testimony.
15 Pedram, Massoud Qualcomm 15 minutes 10 minutes Dr. Pedram is a Professor of
Electrical Engineering and the
16 c/o Qualcomm Charles Lee Powell Chair in
Incorporated Electrical Engineering and
17 5775 Morehouse Computer Science in the
Drive, San Diego, CA Viterbi School of Engineering,
18 92121 University of Southern
California. He holds a B.S. in
19 Electrical Engineering from
the California Institute of
20 Technology and an M.S. and
Ph.D. in Electrical Engineering
21 and Computer Sciences from
the University of California,
22 Berkeley.
23 Dr. Pedram will testify
28 Pedram will provide live
testimony.

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Prince, Jeffrey Qualcomm 15 minutes 10 minutes Dr. Prince is an empirical
researcher of industrial
4 c/o Qualcomm organization and applied
Incorporated econometrics, and holds a
5 5775 Morehouse tenured professorship at the
Drive, San Diego, CA Kelley School of Business at
6 92121 Indiana University. He has
published works focusing on
7 technology markets and
telecommunications. He holds
8 a Ph.D. and M.A. in
Economics from Northwestern
9 University and a B.A. in
Economics and B.S. in
10 Mathematics/Statistics from
Miami University.
11
Dr. Prince will testify
his expert report and subject
14 including the value of certain
Qualcomm technologies and
15 the price premium associated
with the features/feature
16 enhancements those
technologies enable in
17 smartphones. Dr. Prince will
18
19
20
21
22
23
24
25
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Putnam, Jonathan Qualcomm 50 minutes 20 minutes Dr. Putnam is the founder of
and principal at Competition
4 c/o Qualcomm Dynamics Inc. and previously
Incorporated was an assistant professor at
5 5775 Morehouse the Centre for Innovation Law
Drive, San Diego, CA and Policy at the University of
6 92121 Toronto until 2005, as well as
an adjunct assistant professor
7 and lecturer at other
universities. He holds a B.A.,
8 M.A. and Ph.D. in Economics
from Yale.
9
Dr. Putnam will testify
his expert report and subject
12 including FRAND patent
licensing agreements in the
13 cellular industry; and Apple’s
proffered comparable licenses,
14 as well as in rebuttal to Apple
and the CMs’ experts. Dr.
15 Putnam will provide live
testimony.
16 Salters, Ambreen Qualcomm 30 minutes 20 minutes Ms. Salters is an economic
expert and consultant involved
17 c/o Qualcomm primarily in intellectual
Incorporated property and complex
18 5775 Morehouse commercial disputes. She has
Drive, San Diego, CA participated in licensing
19 92121 negotiations, designed and
managed royalty audits, and
20 performed intellectual property
valuations for licensors and
21 licensees. Ms. Salters earned
her M.S. in Economics and
22 B.B.A. in Finance and
Economics from Baylor
23 University.
24 Ms. Salters will testify
25 her expert report and subject
matter about which she was
26 asked during her deposition,
including the damages suffered
27 by Qualcomm as a result of
Apple’s and the CMs’ conduct
28 at issue. Ms. Salters will

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Snyder, Edward Qualcomm 30 minutes 30 minutes Dr. Snyder is the Indra K.
Nooyi Dean and William S.
4 c/o Qualcomm Beinecke Professor of
Incorporated Economics and Management at
5 5775 Morehouse the Yale School of
Drive, San Diego, CA Management. Dr. Snyder
6 92121 began his professional career
as an economist with the U.S.
7 Department of Justice’s
Antitrust Division. He earned
8 a Ph.D. in Economics and an
M.A. in Public Policy from the
9 University of Chicago.
10 Dr. Snyder will testify
11 his expert reports and subject
including the modem chip
13 industry; and Apple’s and the
CMs’ theories of antitrust
14 harm, as well as in rebuttal to
Apple and the CMs’ experts.
15 Dr. Snyder will provide live
testimony.
16 Wigdor, Daniel Qualcomm 15 minutes 10 minutes Dr. Wigdor is an Associate
Professor of Computer Science
17 c/o Qualcomm at the University of Toronto.
Incorporated He holds a B.Sc., M.Sc., and
18 5775 Morehouse Ph.D. in Computer Science
Drive, San Diego, CA from the University of
19 92121 Toronto.
20 Dr. Wigdor will testify
25 Wigdor will provide live
testimony.
26
27
28

of 69

THE DIRECT CROSS
2 WITNESS EXAM EXAM
3 Williams, Tim Qualcomm 30 minutes 15 minutes Dr. Williams is an expert in
electrical engineering,
4 c/o Qualcomm specializing in cellular
Incorporated communications. He holds a
5 5775 Morehouse B.S. in Electrical Engineering
Drive, San Diego, CA from Michigan Technological
6 92121 University, a M.S. and Ph.D.
in Electrical Engineering from
7 the University of Texas at
Austin, as well as an M.B.A.
8 from the University of Texas at
Austin.
9
Dr. Williams will testify
12 including the cellular standards
development process in 3GPP
13 and its organizational partners,
such as ETSI; that cellular
14 standards define functionality
for complete mobile devices,
15 not modem chipsets; the
cellular modem chip industry;
16 and the viability of certain
modem chip suppliers to meet
17 Apple’s technical demands for
its mobile devices, as well as
18 responding to Apple and the
CMs’ experts regarding their
19 reliance on hypothetical
products. Dr. Williams will
21
22
23
24
25
26
27
28

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Case 3:17-cv-00108-GPC-MDD Document 1054-21 Filed 03/25/19 PageID.

JOINT WITNESS LIST -1- CASE NO. 3:17-CV-0108-GPC-MDD

1 APPLE CURRENT AND FORMER EMPLOYEES

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1 QUALCOMM CURRENT AND FORMER EMPLOYEES

23 Mr. Achour will testify live or

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1 CM CURRENT AND FORMER EMPLOYEES

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27 Mr. Blaylock may testify live or