Free Redacted Document - District Court of Delaware - Delaware

Case 1 :04-cv-01371-JJF Document 442 Filed 1 1/28/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
POWER INTEGRATIONS, INC., a Delaware i
corporation, · ’
Plaintiff] I
v.
C.A. No. 04-1371 (JJF) ·
FAIRCHILD SEMICONDUCTOR
INTERNATIONAL, INC., a Delaware ‘
corporation, and FAlRCHH.D .
SEMICONDUCTOR CORPORATION,
a Delaware corporation, REDACTED - .
. Defendants.
A DECLARATION OF GABRIEL M. RAMSEY PIN SUPPORT OF
FAIRCHILD’S OPPOSITION TO PLAINTIFF’S CROSS-MOTION RE F AIRCHILD’S ‘
PRIOR ART DOCUMENTS AND CONTENTIONS AT TRIAL
I, Gabriel M. Ramsey, the undersigned, declare as follows:
1. I am an attomey with the firm of Orrick, Herrington & Sutcliffe LLP, counsel of
r p record for Defendants Fairchild Semiconductor Intemational, Inc. and Fairchild Semiconductor
‘ Corp. (collectively, "Fairchild"). I am admitted to the Bar ofthe State of California. Imake this
declaration in support of Fairchild’s Opposition To Plaintiffs Cross-Motion Re: Fairchi1d’s Prior
Art Documents And Contentions At Trial. I make this declaration of my own personal
knowledge and, if called as a witness, I could and would testify competently to the truth ofthe V
matters set forth herein. ' I
2. _ Attached hereto as Exhibit 1 is a tme and correct copy of Defendants’ Trial
Exhibit DX035.
3. Attached hereto as Exhibit 2 is a true and correct copy of excerpts of the Court’s
October 2, 2006 Trial Transcript.
4. Attached hereto as Exhibit 3 is a true and correct copy of Dr. Paul I-lorowitz’s
November 30, 2005 Invalidity Report.

Case 1 :04-cv-01371-JJF Document 442 Filed 1 1/28/2006 Page 2 of 4
5. Attached hereto as Exhibit 4 is a true and correct copy of F airchild’s June 30,
2005 Supplemental Responses to Power Integrations’ First Set of Interrogatories.
6. Attached hereto as Exhibit 5 is a true and correct copy of excerpts of Dr. Paul
Horowitz’s deposition testimony. I
7. Attached hereto as Exhibit 6 is a true and correct copy of Dr. Paul Horowitz’s ‘
January 10, 2006 Rebuttal Expert Report on Norrlntiingement.
8. Attached heretoas Exhibit 7 is a true and correct copy of Dr. Peter Gwozdz’s P
December 1, 2005 Expert Report.
9. Attached hereto as Exhibit 8 is a true and correct copy of Dr. Peter Gwozdz’s -
February 23, 2006 Supplemental Expert Report. » -
10. Attached hereto as Exhibit 9 is a true and correct copy of U.S. Pat. No. 4,823,173.
11. Attached hereto as Exhibit 10 is a true and correct copy of Defer1dants’ Trial V
Exhibit DX66.
12. Attached hereto as Exhibit ll is a true and correct copy of Defendants’ Trial
Exhibit DXl28. . .
13. Attached hereto as Exhibit 12 is a true and correct copy of Defendarits’ Trial A
Exhibit DX129. `
14. Attached hereto as Exhibit 13 is a true and correct copy of Defenda.nts’ Trial
Exhibit DXl30. U .
15. Attached hereto as Exhibit 14 is a true and correct copy of Defendants’ Trial
Exhibit DX13 1 . _ - I
p 16. Attached hereto as Exhibit 15 is a true and correct copy of Defendants’ Trial
Exhibit DX132.
17. Attached hereto as Exhibit 16 is a tme and correct copy of Defendants’ Trial
Exhibit DX542.
· 18. Attached hereto as Exhibit 17 is a true and correct copy of Defendauts’ Trial
Exhibit DX543.
- 2 -

Case 1 :04-cv-01371-JJF Document 442 Filed 1 1/28/2006 Page 3 of 4
19. Attached hereto as Exhibit 18 is a true and correct copy of James Beasom’s
deposition testimony.
i ‘ 20. Attached hereto as Exhibit 19 is a true and correct copy of Fairchi1d’s September
13, 2005 Subpoena to James Beasom. ·
21. Attached hereto as Exhibit 20 is a true and correct copy of Det°endants’ Trial
Exhibit DX548.
22. Attached hereto as Exhibit 21 is a true and correct copy of excerpts of Dr. Peter
Gwozdz’s deposition testimony. l -
23. Attached hereto as Exhibit 22 is a picture of Defendants’ Trial Exhibit DX544. .
24. Attached hereto as Exhibit 23 is a true and conect copy of Defendants’ Trial
Exhibit DX545.
25. Attached hereto as Exhibit 24 is a picture of Defendants’ Trial Exhibit DX546.
26. Attached hereto as Exhibit 25 is a true and correct copy of Det`endants’ Trial
Exhibit DX547.
_27. Attached hereto as Exhibit 26 is a time and correct copy of Fairchi1d’s First
. Amended Answer and Counterclaims. I
A . I declare the foregoing is true and correct under penalty of perjury under the laws ofthe
United States of America. A
- Executed on November 17, 2006 in Menlo Park, Califorrr
ORRICK, ERRINGTON TCLIFFE LLP
OHS Wcst:260l2725l.2
. - 3 -

Case 1 :04-cv-01371-JJF Document 442 Filed 1 1/28/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on the 28th day of November, 2006, the attached REDACTED
PUBLIC VERSION OF DECLARATION OF GABRIEL M. RAMSEY IN SUPPORT OF
FAIRCHILD’S OPPOSITION TO PLAINTIFF’S CROSS—MOTION RE FAIRCHILD’S
PRIOR ART DOCUMENTS AND CONTENTIONS AT TRIAL was served upon the below-
named counsel of record at the address and in the manner indicated:
William J. Marsden, Jr., Esquire HAND DELIVERY
Fish & Richardson, P.C.
919 N. Market Street, Suite 1100
Wilmington, DE 19801
Frank E. Scherkenbach, Esquire VIA FEDERAL EXPRESS
Fish & Richardson P.C.
225 Franklin Street
Boston, MA 02110-2804
Howard G. Pollack, Esquire VIA FEDERAL EXPRESS
Fish & Richardson P.C.
500 Arguello Street, Suite 500
Redwood City, CA 94063
/s/Lauren. E. Maguire
Lauren E. Maguire