Free Redacted Document - District Court of Delaware - Delaware

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

POLAROID CORPORATION,
Plaintiff and Counterclaim Defendant,

C.A. No. 06-738-SLR
V. HEWLETT-PACKARD COMPANY, Defendant and Counterclaim Plaintiff.

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AFFIDAVIT OF DR. ROBERT L. STEVENSON I, Robert L. Stevenson, affirm and declare as follows:
1. I have been retained by counsel for Hewlett-Packard Company ("HP") to

serve as a technical expert witness. 2. On April 18, 2008, I submitted an Expert Report on non-infringement of

U.S. Patent No. 4,829,381 (the "'381 patent"). This declaration summarizes certain statements and opinions set forth in my expert report. 3. I have a Bachelors degree in Electrical Engineering from the University of

Delaware and a Ph.D. degree in Electrical Engineering from Purdue University. My Ph.D. research was in the area of communications and signal processing. 4. I am presently a Professor in the Department of Electrical Engineering and

in the Department of Computer Science and Engineering at the University of Notre Dame. I first joined the faculty at the University of Notre Dame as an Assistant Professor in the Department of Electrical Engineering in 1990. I was granted tenure and promoted to the rank of Associate Professor in August 1996. I attained the rank of Professor in the Department of Electrical Engineering in August 2002, and I continue to serve in that

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capacity. I have served concurrently as a Professor in the Department of Computer Science and Engineering at the University of Notre Dame since January 2003. 5. I spent the summer of 1992 at the Air Force Research Lab in Rome, New

York and I spent the summer of 1993 at the Intel® Corporation in Hillsboro, Oregon. Several leading computing companies, including Intel®, Sun Microsystems®' Apple® Computer, and Microsoft®, have supported my research at Notre Dame. During the past 20 years, I have published over 100 technical papers related to the field of image processing and digital systems. 6. I am a member of the Institute of Electronics and Electrical Engineers, The

International Society for Optical Engineering, and the Society for Imaging Science and Technology. I am a member of the academic honor societies Eta Kappa Nu, Tau Beta Pi, and Phi Kappa Phi. 7. For the past 20 years my work has focused on the design of techniques,

hardware, and software for the processing of digital signals using digital computing devices. As an academic researcher I attempt to develop novel ideas for systems, then publish and present those ideas to the technical community. My success as an academic is directly related to the insights and techniques which provide the basis for new generations of products. My early work on digital techniques for printing and image capture devices led to significant interaction with companies developing desktop computers products in the early 1990's as they tried to incorporate those ideas into their products. 8. My interaction with Apple's Imaging Group focused on various imaging

devices such as digital cameras, scanners, and printers and how to best support those

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devices on desktop computers. Similarly, my interaction with Sun Microsystem's group examined how advanced signal processing techniques could be best implemented using Sun's new Visual Instruction Set on the SPARC architecture. 9. I have also received significant support for my research from several U.S.

Department of Defense Agencies. The Air Force Research Laboratory has funded my work to develop advanced parallel processing algorithms which exploited an ad-hoc network of mixed computers to achieve significant computational advantages over their previously implemented techniques. Other Department of Defense agencies have supported my work in image and video enhancement. 10. I have published 27 journal articles, written six book chapters, edited the

proceedings of eight SPIE conferences and one other conference, presented 73 papers at professional conferences, and presented five papers at undergraduate research conferences. 11. Additional information concerning my background, qualifications,

publications, conferences, honors, and awards are described in my Curriculum Vitae, a copy of which is attached hereto as Exhibit A.

12.

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CERTIFICATE OF SERVICE
I hereby certify that on June 5, 2008, I electronically filed with the Clerk of Court the foregoing document using CM/ECF which will send electronic notification of such filing(s) to the following counsel:

Via Email Jack B. Blumenfeld (#1014) Julia Heaney (#3052) Morris, Nichols, Arsht & Tunnell, LLP

Attorneys for Plaintiff and Counterclaim-Defendant Polaroid Corporation

1201 North Market Street Wilmington, DE 19899-1347 Phone: 302-658-9200 Fax: 302-658-3989
Emails: [email protected]; [email protected] Via Email Russell E. Levine, P.C. Michelle W. Skinner/David W. Higer Maria A. Meginnes/Courtney Holohan/C. Beasley Attorneys for Plaintiff and Counterclaim-Defendant Polaroid Corporation

Kirkland & Ellis LLP 200 East Randolph Drive Chicago, IL 60601 Phone: 312-861-2000 Fax: 312-861-2200
Emails: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]

Courtesy Copy Via Federal Express Michelle W. Skinner

Kirkland & Ellis LLP 200 East Randolph Drive Chicago, IL 60601 Phone: 312-861-2000 Fax: 312-861-2200

lsl Raymond N. Scott, Jr. Raymond N. Scott, Jr.

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