Case 1 :04-cv-01371-JJF Document 160 Filed 01/11/2006 Page 1 of 2
1N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
POWER INTEGRATIONS, INC., a Delaware
corporation,
Plaintiff,
v.
C.A. No. 04-1371
FAIRCHILD SEMICONDUCTOR
INTERNATIONAL, INC., a Delaware
corporation, and FAIRCHILD
SEMICONDUCTOR CORPORATION,
a Delaware corporation,
Defendants.
DECLARATION OF BAS DE BLANK IN SUPPORT OF DEFENDANTS’
MOTION FOR PROTECTIVE ORDER RE DEPOSITION OF DELL, INC.
I, Bas de Blank, the undersigned, declare as follows:
1. I am an attorney with the firm of Orrick, Herrington & Sutcliffe LLP, counsel of
record for Defendants Fairchild Semiconductor International, Inc. and Fairchild Semiconductor
Corp. (collectively, "Fairchild"). I am admitted to the Bar of the State of California. I make this
declaration in support of Defendants’ Motion for Protective Order re Deposition of Dell, Inc. I
make this declaration of my own personal knowledge and, if called as a witness, I could and
would testify competently to the truth of the matters set forth herein.
2. Attached hereto as Exhibit A is a true and correct copy of a Notice of Deposition
& Service of Subpoena to Dell, Inc. dated August l0, 2005.
3. Attached hereto as Exhibit B is a true and correct copy of an electronic message
from Michael Headley to Bas de Blank dated January 9, 2006.
4. Attached hereto as Exhibit C is a true and correct copy of a letter from Bas de
Blank to Michael Headley dated January 9, 2006.
Docssvi :439728.1
10414-25 Mzn/Mzra
Case 1:04—cv—01371-JJF Document 160 Filed 01/11/2006 Page 2 of 2
5. Attached hereto as Exhibit D is a true and correct copy of an electronic message
from Michael Headley to Bas de Blank dated January 10, 2006 enclosing an Amended Notice of
Deposition to Dell, Inc.
6. Attached hereto as Exhibit E is a true and correct copy of a letter from Bas de
Blank to Michael Headley dated January 10, 2006.
I declare the foregoing is true and correct under penalty of perjury under the laws of the
United States of America.
Executed on January l0, 2006 in Menlo Park, California.
/ Q era Q
Bas de ank
ORRICK, HERRINGTON & SUTCLIFFE LLP
- 2 -
1>ocssvr;4397zs;.1
10414.25 Mza/Mze