Free Affidavit - District Court of Delaware - Delaware

Case 1 :04-cv-01231-SLR Document 127 Filed 12/30/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
VERSUS TECHNOLOGY, INC., )
Plaintiff, g
v. l Civil Action N0. G4-1231-—SLR
RADIANSE, INC. g
. Defendant. i
AFFIDAVIT OF NATHANIEL M. SIMS
I, Nathaniel M. Sims, being duly sworn, hereby depose and say as follows:
1. I have been retained as an expert witness by Radjanse, Inc. in this action,
2. I previously submitted two reports, entitled "Expe1‘t Report of Nathaniel
M. Sims" and "Expert Report of Nathaniel M. Sims Regarding Non—Infringement" in this
action (collectively, the "Sims Reports”).
3. I incorporate the Sims Reports herein by reference, including any and all
attachments thereto, and repeat each statement made by me in the Sims Reports as if they
were stated her in full. Exhibit A documents evidencing my statement in Paragaph l9
ofthe Expert Report of Nathaniel M. Sims that the technology ofthe Welch ‘363 patent
was developed atleast as early as November 10, 1989.

I Case 1:04-cv—01231-SLR Document 127 Filed 12/30/2005 Page 2 of 2
Signed under the pains and penalties ofpeijury this @cIay of December, 2005.
AQ./yall; Miéxw
Nathaniel M. Sims, MJD.
COMMONWAFEALTH OF MASSACHUSETTS
SUFFOLIC., SS:
Then appeared before me the abovemamed Nathaniel M. Sims and gav oath that
the foregoing statements, and those in the above-referenced Report of Nathaniel M. Sims
and Report of Nathaniel M. Sims Regarding Non··1r1frin_ge1nent ax true on the basis of his
personal imowledge. 5}
Notary Pub
. My commission expires: C2 gg -{ E
Dated: Decembenyg, 2005