Free Declaration - District Court of Delaware - Delaware

_._ 28 HPR 3®§se1$@cv-OOGFI 6*-tHl$RJBI>o'€1?1*ik§l1t 18 Filed O4/28/2005 Page 1 of 3 P- 3
N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
NOKIA CORPORATION and NOKIA,
INC.
Plaintiffs,
No. 05»l6—JIF
v.
HQTERDIGITAL COMMUNICATIONS
CORPORATION and INTERDIGI'l`A.L
TECHNOLOGY CORPORATION
Defendants.
_ DECLARATION OF JU SSI NUMIVHNEN IN SUPPORT OF NOKIA’S
OPPOSITION TO INTER¥}IGI'I`AL’S MOTION T0 DISMISS
_ I, Jessi Numminen, pursuant to 28 U.S.C. § 1746, declare and say as
follows:
E 1. My name is Jussi Nnmminen. I presently hold the title Principal Technologist
l for Noida Corporation in Salo, Finland.
2. I understand this declaration will be submitted in support ofNokia’s Opposition
§ to Defendants Motion To Dismiss Pursuant to Federal Rules of Civil Procedure l2(B)(l),
Z 12{B)(6) and 12(H)(3). Except as otherwise stated, I have personal knowledge ofthe facts
I set forth in this declaration.
at 3G Wireless Standards
i 3. I understand there are two 3G wireless standards that will be used in the
e United States after 2006 that are of interest to this litigation: Wideband Code Division
i Multiple Access ("WCDMA") and CDMA2000. While a GSNUEDGE TDMA based
l system is sometimes considered to he s 3G system, I understand it is not at issue in this
litigation.
1
1

28 HF`? 2@§se‘~ $?Oi53cv-0061 6l—§l¥lE*iJlE)`E>o'@1¥1'i’é’r1t 18 Filed O4/28/2005 Page 2 of 3 P · 2
_ The WCDMA Standard
4. WCDMA is sometimes referred to s Universal Mobile
T clecommunications System or UMTS.
5. The tirst successful 3G WCDMA call through a public network was
e performed by Nokia in February of 1999. Attached hereto as Exhibit A is a true and
correct copy of a press release announcing that event.
6. Since then, WCDMA networks have been adopted in Europe and Asia. As
of J aneary l, 2005, there were approxiitcately 16 million WCDMA subscribers worldwide. - A
J 7. One anticipated upgrade to the WCDMA standard that may be implemented
in the United States during 2006 is High Speed Dcwnlink Pacst Access ("HSDZ£’A"). .
8. Release 5 of the WCDMA standard is completed such that commercial
products are under development in cornptianoe with this standard. While fixture WCDMA
it specification releases may contain additions.} functionality, it is anticipated that U
commercial products introduced in 2007 will be backwards compatible with release 5.
I declare under penalty of perjury under the laws ofthe United States of America
that the foregoing is true and correct.

Executed on this gk; day of April, 2905.
‘VW»~·»»~*~
E Jessi Numminen
-2·
E

Case 1:05-cv-00016-JJF Document 18 Filed O4/28/2005 Page 3 of 3
CERTIFICATE OF SERViCH
I, Jack B. Blumenfeld, hereby certify that on April 28, 2005 I electronically tiled
Deciaration of Jussi Nuniniinen in Support of Nol Dismiss with the Clerk ofthe Court using CM/ECF, which will send notification of such illing(s)
io the following:
Richard L. Horwitz
Potter Andersoon & Corroon LLP
[email protected]
I also certify that copies were caused to be served on April 28, 2005 upon the
following inthe manner indicated:
BY HAND
Richard L. Horwitz
Potter Anderson & Corroon LLP
1313 N. Market Street
Wilmington, DE 19801
BY FEDERAL EXPRESS
D. Dudley Oldham
Fulbright & Iaworski
1301 McKinney
Suite 5100
Houston, TX 77010
/s/ lack B. Blumenfeld g#10143
Morris, Nichols, Arsht & Tunnell
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899
(302) 658-9200
[email protected]