Free Redacted Document - District Court of Delaware - Delaware

Case 1:04—cv—01371-JJF Document 433 Filed 11/21/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
POWER INTEGRATIONS, INC., a
Delaware corporation,
Plaintiff,
V C.A. N0. 04-1371 JJF
FAIRCHH.D SEMICONDUCTOR _ ' i
INTERNATIONAL, INC., a Delaware
corporation, and FAIRCHILD .
SEMICONDUCTOR CORPORATION, a 1,V__, _
Delaware corporation, . I ,
Defendants.
DECLARATION OF WILLIAM J. MARSDEN, JR. IN SUPPORT OF POWER
INTEGRATIONS, INC.’S COMBINED OPPOSITION TO DEFENDANTS’
MOTION TO ADD PRIOR ART REFERENCES TO THE INVALIDITY TRIAL
AND CROSS-MOTION TO PRECLUDE FAIRCHILD’S UNTIMELY
CONTENTIONS AND DOCUMENTS AT TRIAL
FISH & RICHARDSON P.C.
William J. Marsden, Jr. (#2247) ([email protected])
919 N. Market Street, Suite 1100
P.O. Box 1 114
Wilmington, DE 19899-1114
Telephone: (302) 652-5070
Facsimile: (302) 652-0607
Frank E. Scherkenbach
225 Franklin Street
Boston, MA 02110-2804
Telephone: (617) 542-5070
Facsimile: (617) 542-8906
Michael R. Headley
Howard G. Pollack
500 Arguello Street, Suite 500
Redwood City, CA 94063
Telephone: (650) 839-5070
Facsimile: (650) 839-5071
Attorneys for Plaintiff
POWER INTEGRATIONS, INC.
Dated: November 13, 2006

Case 1:04—cv—01371-JJF Document 433 Filed 11/21/2006 Page 2 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
POWER INTEGRATIONS, INC., a
Delaware corporation,
Plaintiff,
V C.A. No. 04-1371-JJF
FAIRCHHDD SEMICONDUCTOR I
INTERNATIONAL, INC., a Delaware
corporation, and FAIRCHH.D
SEMICONDUCTOR CORPORATION, a
Delaware corporation, I ` ‘ ’ “ · ··`’`
Defendants.
DECLARATION OF WILLIAM J. MARSDEN, JR. IN SUPPORT OF POWER
INTEGRATIONS, INC.’S COMBINED OPPOSITION TO DEFENDANTS’
MOTION TO ADD PRIOR ART REFERENCES TO THE INVALIDITY TRIAL
AND CROSS—MOTION TO PRECLUDE FAIRCHILD’S UNTIMELY
CONTENTIONS AND DOCUMENTS AT TRIAL
I, William J. Marsden, J r., declare as follows:
l. I am an attorney at Fish & Richardson P.C., counsel of record in this
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 Fairchild’s list
of seven prior art references, provided to Power Integrations on October 2, 2006.
3. Attached hereto as Exhibit B is a true and correct copy of an excerpt from
the transcript of the first day of trial in this case, October 2, 2006. (D.I. 416)
4. Attached hereto as Exhibit C is a true and correct copy of a November 2,
2006 e—mail from Fairchild counsel, Brian VanderZanden, to Power Integrations’
counsel, Howard Pollack, regarding Fairchild’s new list of prior art references for trial.

Case 1 :04-cv-01371-JJF Document 433 Filed 11/21 /2006 Page 3 of 4
5. Attached hereto as Exhibit D is a true and correct copy of an October 20,
2006 letter from Fairchild counsel, Brian VanderZanden, to Power Integrations’ counsel,
Howard Pollack, enclosing new production documents.
6. Attached hereto as Exhibit E is a true and correct copy of an October 24,
2006 letter from Fairchild counsel, Brian VanderZanden, to Power Integrations’ counsel,
Howard Pollack, enclosing additional new production documents.
7. Attached hereto as Exhibit F is a true and correct copy of an October 30,
2006 letter from Fairchild counsel, Brian VanderZanden, to Power Integrations’ counsel,
Howard Pollack, regarding additional new production documents.
8. Attached hereto as Exhibit G is a true and correct copy of an October 26,
2006 letter from Power Integrations’ counsel, Howard Pollack, to Fairchild counsel,
Brian VanderZanden, regarding Fairchild’s untimely production of new documents.
9. Attached hereto as Exhibit H is a true and correct copy of a November 9,
2006 letter from Fairchild counsel, Brian VanderZanden, to Power Integrations’ counsel,
Howard Pollack, regarding Fairchild’s new production documents.
l0. Attached hereto as Exhibit I is a true and correct copy of the opening
expert report of Fairchild technical expert Dr. Peter Gwozdz, served December 1, 2005.
ll. Attached hereto as Exhibit J is a true and correct copy of the
"Supplementary" expert report of Fairchild technical expert Dr. Peter Gwozdz, served
February 23, 2006.
12. Attached hereto as Exhibit K is a true and correct copy of the opening
expert report of Fairchild technical expert Dr. Paul Horowitz, served December l, 2005.
13. Attached hereto as Exhibit L is a true and correct copy of an excerpt from
Fairchild’s March 7, 2005 Response to Power Integrations’ First Set of Interrogatories
containing Fairchild’s invalidity contention regarding the SGS—Thompson TEA2262.
14. Attached hereto as Exhibit M is a true and correct copy of an excerpt from
Fairchild’s June 30, 2005 Supplemental Response to Power Integrations’ First Set of

Case 1 :04-cv-01371-JJF Document 433 Filed 11/21 /2006 Page 4 of 4
Interrogatories containing Fairchild’s invalidity contention regarding the SGS-Thompson
TEA2262.
15. Attached hereto as Exhibit N is a true and correct copy of an excerpt from
Exhibit 6 to the deposition of Paul Horowitz containing a claim chart regarding Dr.
Horowitz’s revised invalidity contention regarding the SMP240/260.
16. Attached hereto as Exhibit O is a true and correct copy of an excerpt from
the minuscript of the Videotaped Deposition Transcript of Paul Horowitz, taken on
February 4, 2006.
17. Attached hereto as Exhibit P is a true and correct copy of an e-mail from
Power Integrations’ Vice President of Worldwide Sales, Bruce Renouard, dated October
18, 2006.
18. Attached hereto as Exhibit Q is a true and correct copy of a Fairchild press
release dated October 10, 2006.
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
Executed this 13th day of November, 2006, at Wilmington, Delaware.
/s/ William J. Marsden, Jr.
William J. Marsden, Jr.