Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF

Document 519

Filed 09/07/2007

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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. C.A. No . 04-1371 JJF

POWER INTEGRATIONS' [PROPOSED] VOIR DIRE It is the parties' understanding that the Court will conduct standard voir dire in the form appended to this document, entitled "Standard Voir Dire." In addition, Power Integrations requests that the jury pool be asked the following specific voir dire questions: 1. Do you have education, vocational training, or work experience in patents, electronics, engineering, the design of integrated circuits, or forensics? 2. Does anyone in your immediate family, such as a spouse or child who lives with you or a close relative, have education, vocational training, or work experience in patents, electronics, engineering, the design of integrated circuits, or forensics? 3. Are you, or is anyone in your immediate family, an inventor or coinventor on a U.S . patent or an application for a U. S. patent? 4. Have you, or has anyone in your immediate family, ever been involved in applying for or obtaining a U.S. patent? 5. Does your employer own any U.S. patents, or have a license to use patents owned by someone else?

Case 1:04-cv-01371-JJF

Document 519

Filed 09/07/2007

Page 2 of 4

6. Do you have strong feelings, either positive or negative, about patents, the rights of patent holders, or the process by which patents are obtained? 7. Have you ever heard of Power Integrations or Fairchild or any of their products? 8. Have you ever used a Power Integrations or Fairchild product, or a product that contains a Power Integrations or Fairchild product? 9. Do you or any member of your household own stocks or bonds or have any other financial interest in Power Integrations, Fairchild, or any company involved in the production or sale of power supplies or power supply components? 10. Have you ever been sued or been a party to a lawsuit, testified at a deposition or in court, or served as a juror in a civil lawsuit?

Case 1:04-cv-01371-JJF

Document 519

Filed 09/07/2007

Page 3 of 4

STANDARD VOIR DIRE 1 Judge will read brief description of the case. Is any member of the panel familiar with the case, or has any member of the panel heard or read anything about it? 2. Judge will ask counsel to introduce himself or herself. Do you know or have you or has any member of your family had any business dealings with any of the attorneys in their law firms. Judge will ask counsel to introduce the parties and name any witnesses they expect to call. Do any members of the panel know the parties or any of the witnesses? If you are selected to sit on this case, will you be able to render a verdict solely on the evidence presented at the trial and in the context of the law as I will give it to you in my instructions, disregarding any other ideas, notions , or beliefs about the law that you may have encountered in reaching your verdict? Is there any member of the panel who has any special disability or problem that would make it difficult or impossible for you to serve as a member of the jury?
days to try, so that we expect the testimony This case is expected to take . Is there any member in the trial will be completed by of the panel who would be unable to sit as a juror in the case for that period of time?

3.

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Voir dire as submitted by the parties A. Up to ten questions from plaintiff. The questions should be designed to elicit a yes or no answer. Up to ten questions from defendants . The questions should be designed to elicit a yes or no answer.

B.

FINAL QUESTION: Having heard the questions put to you by the court, does any other reason suggest itself to you as to why you could not sit on this jury and render a fair verdict based on the evidence presented to you and in the context of the court's instructions to you on the law?

Case 1:04-cv-01371-JJF

Document 519

Filed 09/07/2007

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that on September 7, 2007, I electronically filed with the Clerk of Court POWER INTEGRATIONS' [ PROPOSED ] VOIR DIRE using CM/ECF which will send electronic notification of such filing(s) to the following Delaware counsel. In addition, the filing will also be sent 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 FEDERAL EXPRESS 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/ William I Marsden, Jr. William J. Marsden, Jr.
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