Free Proposed Pretrial Order - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF

Document 518-10

Filed 09/06/2007

Page 1 of 4

EXHIBIT 9 Defendants' Witness List Defendants Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corp. (collectively, "Fairchild") may call one or more of the following witnesses in its case in chief as a live witness during the invalidity trial. Fairchild reserve the right to have the witness testify through deposition: Name James D. Beasom Address
James D. Beasom 506 South Wildwood Ln Melbourne FL 32904-2562

Robert Conrad

Fairchild Semiconductor Corporation 82 Running Hill Road South Portland, ME 04106

Peter Gwozdz Fairchild's Expert Witness Specialty ­ Semiconductor processes and structures. Paul Horowitz Fairchild's Expert Witness Specialty ­ Electronic circuit design, including PWM devices. Bob Moore

21865 Regnant Road Cupertino, CA 95014

Harvard, FAS Department of Physics Lyman Lab 225 19 Oxford St Cambridge, MA 02138 Bob Moore 143 Dickinson St. NE Palm Bay, FL 32907 Conexant 2401 Palm Bay Rd., NE Bldg. 62, Mail Stop B017 Room B294 Palm Bay, FL 32905 Speckin Forensic Laboratories 2105 University Park Drive Suite A Okemos, MI 48864 Harvard, FAS Department of Physics Lyman Lab 225 19 Oxford St Cambridge MA 02138

John Prentice

Erich Speckin Fairchild's Expert Witness Specialty ­ Forensic document analysis. Gu-Yeon Wei Fairchild's Expert Witness Specialty ­ Electronic circuit design, including PWM devices.

Fairchild may call any of the following rebuttal witnesses, depending on the evidence presented by Power Integrations:

OHS West:260116144.5

1

Case 1:04-cv-01371-JJF

Document 518-10

Filed 09/06/2007

Page 2 of 4

Name Robert Conrad

Address Fairchild Semiconductor Corporation 82 Running Hill Road South Portland, ME 04106

Peter Gwozdz Fairchild's Expert Witness Specialty ­ Semiconductor processes and structures. Paul Horowitz Fairchild's Expert Witness Specialty ­ Electronic circuit design, including PWM devices. Erich Speckin Fairchild's Expert Witness Specialty ­ Forensic document analysis. Gu-Yeon Wei Fairchild's Expert Witness Specialty ­ Electronic circuit design, including PWM devices.

21865 Regnant Road Cupertino, CA 95014

Harvard, FAS Department of Physics Lyman Lab 225 19 Oxford St Cambridge, MA 02138 Speckin Forensic Laboratories 2105 University Park Drive Suite A Okemos, MI 48864 Harvard, FAS Department of Physics Lyman Lab 225 19 Oxford St Cambridge MA 02138

Fairchild reserves its right to call additional witnesses on the issue of inequitable conduct once the Court schedules the hearing on this issue. Fairchild expects these witness to testify on a least the following topics: James Beasom Dr. Beasom will testify about his conception and reduction to practice of his invention claimed in U.S. Patent No. 4,823,173 (the "`173 Patent"). Dr. Beasom will also testify that the `173 Patent anticipates the `075 Patent. Robert Conrad Mr. Conrad is the Senior Vice President and General Manager, Analog Products Group of Fairchild. He will introduce Fairchild and provide background information about the corporation. He will testify that since joining Fairchild in 2003 he has been, either alone or jointly, the head of the business unit that produces the accused Fairchild Power Switch ("FPS") products. If necessary, he will rebut testimony and evidence presented by Power Integrations concerning secondary indicia of non-obviousness. Peter Gwozdz: Dr. Gwozdz is Fairchild's designated expert on the invalidity issues raised by the asserted claim (claims 1 and 5) of the Eklund `075 patent. The `075 patent relates to the structure

OHS West:260116144.5

2

Case 1:04-cv-01371-JJF

Document 518-10

Filed 09/06/2007

Page 3 of 4

of a high voltage MOS transistor. The details of Dr. Gwozdz's testimony are provided in his December 1, 2005, January 10, 2006 Rebuttal, and February 23, 2006 Supplemental expert reports and in his deposition of March 14, 2006, and Dr. Gwozdz may testify about any of the opinions and background provided in those reports or testimony. Generally, Dr. Gwozdz will testify that claims 1 and 5 of the `075 Patent are invalid in light of the prior art. Dr. Gwozdz may also respond to any topics raised in Power Integrations' case. Paul Horowitz: Dr. Horowitz is Fairchild's designated expert on the invalidity issues raised by the asserted claims of the `366, `876 and `851 patents. Those patents relate to circuits for performing softstart and frequency variation functionality in a power switch. The details of Dr. Horowitz's testimony are provided in his November 30, 2005, January 10, 2006, and December 29, 2006 expert reports and in his depositions of February 4, 2006, January 30, 2007, and January 31, 2007 and Dr. Horowitz may testify about any of the opinions and background provided in those reports or testimony. Generally, Dr. Horowitz will testify that claims 9 and 14 of the `366 patent, claim 1 of the `876 patent, and claims 1 and 4 of the `851 patent are invalid in light of the prior art. Dr. Horowitz may also respond to any topics raised in Power Integrations case. Bob Moore: Mr. Moore will testify about Dr. Beasom's conception and reduction to practice of Dr. Beasom's invention claimed in the `173 patent. John Prentice: Mr. Prentice will testify about Dr. Beasom's conception and reduction to practice of Dr. Beasom's invention claimed in the `173 Patent. Erich Speckin: Mr. Speckin is Fairchild's designated expert on forensic issues raised by certain notes of Dr. Klas Eklund, including issues concerning the dating and substance of those documents. The details of Mr. Speckin's testimony are provided in his August 1, 2007 expert report and in his deposition of August 27, 2007 and Mr. Speckin may testify about any of the opinions and background provided in those reports or testimony. Mr. Speckin may also respond to any topics raised in Power Integrations case. Gu-Yeon Wei: The details of Dr. Wei's testimony are provided in his January 5, 2006 expert report and in his deposition of February 17, 2006 and Dr. Wei may testify about any of the opinions and background provided therein. Generally, Dr. Wei will testify that the accused Fairchild devices were not copied from Power Integrations' patents or devices. Dr. Wei may also respond to any topics raised in Power Integrations' case. In addition, Defendants Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corp. may call one or more of the following witnesses to testify via deposition. Fairchild reserves the right to have them testify as a live witness: Derek Bell Leif Lund
OHS West:260116144.5

3

Case 1:04-cv-01371-JJF

Document 518-10

Filed 09/06/2007

Page 4 of 4

Fairchild will call additional witnesses during any hearing before the Court on equitable issues such as Power Integrations' inequitable conduct, whether an injunction is appropriate, whether any damages should be increased, and whether this case is exceptional. Fairchild will supplement this identification when that hearing is scheduled.

OHS West:260116144.5

4