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Case1:O4—cv-01371-JJF D0cument433—4 Fi|ec|11/21/2006 Page10f3
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Case 1:04-cv-01371-JJF Document 433-4 Filed 11/21/2006 Page 2 of 3
Howard Pollack
From: VanderZanden, Brian [[email protected]]
Sent: Thursday, November 02, 2006 2:05 PM ‘
To: Howard Pollack
Cc: Frank Scherkenbach; Vlhlliam Marsden
Subject: prior art references
Dear Howard,
Fairchild intends to rely upon 11 prior art references at the invalidity phase of the trial. These references are as follows:
1. U.S. Pat. No. 4,638,417 ("Martin"). I
2. Wang and Sanders, "Programmed Pulsewidth Modulated Waveforms For Electromagnetic Interference Mitigation In DC-DC
Converters", IEEE Transactions on Power Electronics, Vol. 8, No. 4 (October 1993).
3. Habetler and Divan, "Acoustic Noise Reduction In Sinusoidal PWM Drives Using A Randomly Modulated Carrier", IEEE
Transactions on Power Electronics, Vol. 6, No. 3, July 1991, p. 356.
4. Power Integrations' SMP211 device.
5. Power Integrations' SMP240/60 series device.
6. SGS-Thompson TEA2262 device.
7. Power Integrations' SMP3 device.
8. U.S. Pat. No. 4,823,173 ("Beasom").
9. Wakaumi, "A Highly Reliable 16 Output High Voltage NMOS/CMOS Logic IC Vlhth Shielded Source Structure," IEMD 83, pp.
416-19 (1983).
10. Ludikhuize, "High-Voltage DMOS and PMOS in Analog IC's, IEMD 82, pp. 81-84 (1982).
11. Wacyk, "A Power IC with CMOS Analog Control," (1986).
These references (along with the supporting articles, datasheets, schematics, etc.) have all been previously disclosed to Power
lntegrations. ·
As the Court requested, Fairchild will file a motion tomorrow explaining the relevance of and need for these 11 references. Please
let me know by noon tomorrow whether Power Integrations intends to oppose this motion.
Sincerely,
Brian VanderZanden
anmu vANoERzANoEN
associate
omzicx, Hemzimcron st surcum; rrp
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email .b.va.n.;[email protected]<;.ls.€.;Qm
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