Free Redacted Document - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF

Document 532

Filed 09/10/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE POWER INTEGRATIONS, INC., a Delaware corporation, Plaintiff, v. FAIRCHILD SEMICONDUCTOR INTERNATIONAL, INC., a Delaware corporation, and FAIRCHILD SEMICONDUCTOR CORPORATION, a Delaware corporation, Defendants. DECLARATION OF KYLE WAGNER COMPTON IN SUPPORT OF POWER INTEGRATIONS, INC.'S APPLICATION TO EXCLUDE THE ADMISSION OF CERTAIN EVIDENCE RELATED TO FAIRCHILD'S FORENSIC TESTING FISH & RICHARDSON P.C. William J. Marsden, Jr. (#2247) ([email protected]) Kyle Wagner Compton (#4693) ([email protected]) 919 N. Market Street, Suite 1100 P.O. Box 1114 Wilmington, DE 19899-1114 Telephone: (302) 652-5070 Facsimile: (302) 652-0607 Frank E. Scherkenbach 225 Franklin Street Boston, MA 02110-2804 Telephone: (617) 542-5070 Facsimile: (617) 542-8906 Howard G. Pollack Michael R. Headley 500 Arguello Street, Suite 500 Redwood City, CA 94063 Telephone: (650) 839-5070 Facsimile: (650) 839-5071 Attorneys for Plaintiff POWER INTEGRATIONS, INC. C.A. No. 04-1371-JJF HIGHLY CONFIDENTIAL FILED UNDER SEAL PURSUANT TO COURT ORDER

DATED: August 31, 2007

Case 1:04-cv-01371-JJF

Document 532

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I, Kyle Wagner Compton declare as follows: 1. I am an attorney at Fish & Richardson P.C., counsel of record in this action for

Plaintiff Power Integrations, Inc. ("Power Integrations"). I am a member of the Bar of the State of Delaware and of this Court. I have personal knowledge of the matters stated in this declaration and would testify truthfully to them if called upon to do so. 2. Attached hereto as Exhibit 1 is a true and correct copy of the Expert Report of

Erich J. Speckin, marked Highly Confidential ­ Outside Counsel Only, and dated August 1, 2007. 3. Attached hereto as Exhibit 2 is a true and correct copy of the Rebuttal Expert

Report of Erich J. Speckin, marked Highly Confidential ­ Outside Counsel Only, and dated August 20, 1007. 4. Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the August

27, 2007 deposition of Erich J. Speckin, marked Highly Confidential ­ Attorneys' Eyes Only. 5. Attached hereto as Exhibit 4 is a true and correct copy of excerpts of the March

29, 2007 deposition of Erich Speckin submitted in connection with a motion to exclude Mr. Speckin's testimony (D.I. 340) in the case of Armament Systems & Procedures, Inc. v. IQ Hong Kong Limited, et al., USDC-E.D. Wis. C.A. No. 00cv1257, obtained from the Public Access to Court Electronic Records ("PACER") online service. 6. Attached hereto as Exhibit 5 is a true and correct copy of excerpts of the August

28, 2007 deposition of Albert H. Lyter, III, Ph.D., marked Confidential ­ Attorneys' Eyes Only. 7. Attached hereto as Exhibit 6 is a true and correct copy of the Expert Report of

Albert H. Lyter, III, dated August 9, 2007. 8. Attached hereto as Exhibit 7 is a true and correct copy of excerpts from the

opinion in the matter Re Estate of Wang Teh Huei, 2002 WL 1341762 (CFI HCAP 8/1999) (Nov. 21, 2002).

Case 1:04-cv-01371-JJF

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I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 31st day of August, 2007, at Wilmington, Delaware. /s/ Kyle Wagner Compton Kyle Wagner Compton

Case 1:04-cv-01371-JJF

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CERTIFICATE OF SERVICE I hereby certify that on August 31, 2007, I served the DECLARATION OF KYLE WAGNER COMPTON IN SUPPORT OF POWER INTEGRATIONS INC.'S APPLICATION TO EXCLUDE CERTAIN EVIDENCE FROM FAIRCHILD REGARDING FORENSIC TESTING on the following as indicated: BY HAND DELIVERY Steven J. Balick John G. Day Ashby & Geddes 500 Delaware Avenue, 8th Floor P. O. Box 1150 Wilmington, DE 19899 Attorneys for Defendants FAIRCHILD SEMICONDUCTOR INTERNATIONAL, INC. and FAIRCHILD SEMICONDUCTOR CORPORATION, and third party INTERSIL CORPORATION

BY E-MAIL AND FIRST CLASS MAIL G. Hopkins Guy, III Bas de Blank Orrick, Herrington & Sutcliffe, LLP 1000 Marsh Road Menlo Park, CA 94025

Attorneys for Defendants FAIRCHILD SEMICONDUCTOR INTERNATIONAL, INC. and FAIRCHILD SEMICONDUCTOR CORPORATION

/s/ Kyle Wagner Compton Kyle Wagner Compton
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