Free Proposed Pretrial Order - District Court of Delaware - Delaware


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Case 1 :04-cv-01371-JJF Document 518-11 Filed O9/06/2007 Page 1 of 2
Power Integrations v. Fairchild
Exhibit 10
Power Integrations’ Opinion Testimony
Power Integrations intends to call the following experts to testify in person at trial
to provide opinions on the subjects described:
Robert Bllauschild
‘ I Mr. Blauschild has worked extensively in the field of analog and mixed-signal
circuit design. After obtaining a BSEE degree from Columbia University in 1971 and an
MSEE degree from U.C. Berkeley in 1973, Mr. Blauschild joined the Analog Research
Department of Signetics. He became Manager of Analog Research in 1976, with a `
department charter to investigate the application of new process teclmologies to analog
ftmctions. Mr. Blauschild’s status with Signetics became that of a consultant in 1981, .
which allowed him to work with other companies including Hughes, Micro Linear, Exar,
Stanford Telecom, and many others. He rejoined Signetics as Manager of Advanced
Development in 1990. The charter of Mr. Blauschild’s department at that time was to do
advanced designs with existing IC processes, the first designs with new IC processes, and
consult with other departments on the development of all projects with analog content.
He was also responsible for working with the wafer fabrication groups in developing new
IC processes and devices.
Mr. Blauschild has worked on and consulted on designs of a wide range of analog
and mixed-signal circuits, including data converters, amplifiers, voltage and current
references and regulators, timing circuits, line drivers and receivers, display circuits,
phase—locked loops, and modems. Mr. Blauschild has fourteen US patents and has
designed over two dozen products with cumulative sales above $250 Million.
Mr. Blauschild has also participated as a panelist at various industry conferences,
and taught several short courses and seminars in the U.S., Europe, and Japan. After
presenting two teclmical papers at the 1978 International Solid-State Circuits Conference
(ISSCC), Mr. Blauschild was chosen by the 1979 conference chairman to serve on the
ISSCC Program Committee, and has been similarly chosen 15 times since then. Mr.
Blauschild has twice a member of the European Solid-State Circuits Conference Program
Committee. His work on these committees consisted of evaluating submitted papers for
originality and import, and deciding on rejection or acceptance for presentation at the
conferences. Mr. Blauschild’s designs and lectures have spanned a wide range of
technologies, including NMOS, CMOS, BiCMOS, and Bipolar processing.
Mr. Blauschild will testify that all three of Power Integrations’ circuit patents in
this case, U.S. Patent Nos. 6,249,876 B1 ("the ’876 patent"), and 6,107,851 ("the ’851
patent"), 6,229,366 B1 ("the ’366 patent") are not invalid, including that the circuit
E patents are not obvious or anticipated, and that any allegedly withheld prior art was not
material. Mr. Blauschild’s expected testimony is set forth more fully in his expert reports
and deposition testimony.

Case 1 :04-cv-01371-JJF Document 518-11 Filed O9/06/2007 Page 2 of 2
Michael Shields
Mr. Shields has at least forty years of semiconductor industry experience,
including four years at the Marconi Company in the UK, over thirty years at
Philips/Signetics (Philips acquired Signetics in 1975), and tive years at Implink
Technology. During the course of Mr. Shields’ work in the industry, he has worked on
semiconductor device design, has managed multiple development teams, has overseen the
building of and has run multiple fabrication facilities, and has been responsible for
Philips’ future designs and process roadmaps.
Mr. Shields also holds several patents. He has guest lectured at Stanford
University and at U.C. Berkeley extension. Mr. Shields has been a panel member at
SEMI ISS, SEMI SBC, and has given talks at Wescon and at several IEEE meetings. Mr.
Shields has a Bachelor of Science degree in Physics from Imperial College, London
University, and a Master of Science degree in Electrical Engineering from San Jose State
University.
Mr. Shields will testify that Power Integrations’ ’O75 patent is not invalid,
including that the ’O75 patent is enabled, is not obvious or anticipated, and that any
allegedly withheld prior art was not material. Mr. Shields’s expected testimony is set
forth more fully in his expert reports and deposition testimony.
Dr. Albert H. Lyter III
Dr. Lyter has over 30 years of experience in the area of questioned document
examination, and he specializes in the dating of documents, inks, and papers. Dr. Lyter’s
government service in this area dates back to 1975, when he began working as a Forensic
Chemist for the U.S. Treasury Department, Bureau of Alcohol, Tobacco and Firearms, at
the National Laboratory Center in Rockville, Maryland. He is currently in private
practice, and has been since 1981. Dr. Lyter has Bachelor of Science degrees in
Chemistry and Biology, a Master of Science degree in Forensic Science from George
Washington University, and a Ph.D. in Analytical Chemistry from the University of
North Carolina-Chapel Hill.
Dr. Lyter will testify that the evidence of Klas Eklund’s documents, including Dr.
Lyter’s forensic analyses of the documents, is consistent with Dr. Eklund’s testimony that
the original documents from which copies were made were created on or about the dates
indicated on the d·ocuments. Dr. Lyter’s expected testimony is set forth more fully in his
report and deposition testimony. I
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