Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF

Document 501

Filed 06/29/2007

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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 WILLIAM J. MARSDEN, JR. IN SUPPORT OF POWER INTEGRATIONS INC.'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS OF DR. KLAS EKLUND FOR FORENSIC TESTING I, William J. Marsden, Jr., declare as follows: 1. I am an attorney at Fish & Richardson P.C., counsel of record in this C.A. No. 04-1371-JJF

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 A is a true and correct copy of the September

29, 2006 letter from Gabriel Ramsey to from Michael Headley re the last two pages of Exhibit 37, bates numbered KE00005-6. 3. Attached hereto as Exhibit B is a true and correct copy of the November

29, 2006 letter to Gabriel Ramsey from Michael Headley re documents for use at trial and trial exhibits. 4. Attached hereto as Exhibit C is a true and correct copy of the December 1,

2006 letter to Howard Pollack from Gabriel Ramsey re Eklund trial exhibits.

Case 1:04-cv-01371-JJF

Document 501

Filed 06/29/2007

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5.

Attached hereto as Exhibit D is a true and correct copy of the January 5,

2007 letter to Gabriel Ramsey from Michael Headley re testing of Eklund documents. 6. Attached hereto as Exhibit E is a true and correct copy of the January 26,

2007 letter to Gabriel Ramsey from Michael Headley re Mr. Speckin's review of Eklund documents. 7. Attached hereto as Exhibit F is a true and correct copy of the June 12,

2007 letter to Michael Headley from Gabriel Ramsey re authenticity and reliability of Eklund's notes and testimony. 8. Attached hereto as Exhibit G is a true and correct copy of the June 19,

2007 letter to Gabriel Ramsey from Michael Headley consenting to testing of produced Eklund materials. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 29th day of June, 2007, at Wilmington, Delaware.

/s/ William J. Marsden, Jr. William J. Marsden, Jr.
80046283.doc

Case 1:04-cv-01371-JJF

Document 501

Filed 06/29/2007

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CERTIFICATE OF SERVICE I hereby certify that on June 29, 2007, I electronically filed with the Clerk of Court DECLARATION OF WILLIAM J. MARSDEN, JR. IN SUPPORT OF POWER INTEGRATIONS INC.' S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS OF DR. KLAS EKLUND FOR FORENSIC TESTING using CM/ECF which will send electronic notification of such filing(s) to the following counsel. In addition, the filing will also be sent in the manner 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

William J. Marsden, Jr. (#2247)
80046283.doc