Free Declaration - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF

Document 794

Filed 09/25/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

LG.PHILIPS LCD CO., LTD., Plaintiff, v. TATUNG CO.; TATUNG COMPANY OF AMERICA, INC.; AND VIEWSONIC CORPORATION Defendants. Civil Action No. 04-343 (JJF)

DECLARATION OF ARIS SILZARS IN SUPPORT OF OPENING BRIEF OF DEFENDANT VIEWSONIC CORPORATION IN SUPPORT OF ITS MOTION FOR LEAVE TO FILE AMENDED ANSWER I, Aris Silzars, declare as follows: 1. I am an independent consultant and have been retained jointly by Connolly Bove

Lodge & Hutz, LLP and Raskin Peter Rubin & Simon LLP on behalf of defendant ViewSonic Corporation and by Greenberg Traurig LLC on behalf of defendants Tatung Company and Tatung Co. of America. For the work presented here, my research, meetings and testimony, I have been or will be paid at the rate of $200.00 per hour, not to exceed $1,600 per day, plus reasonable expenses. I will receive no other compensation for my work on this case. My compensation is not dependent on or related in any way to the outcome of this case. 2. I hold a B.A. degree and Masters degree in Physics and a Ph.D. degree in

Electrical Engineering. I have over 30 years of experience in display design and manufacturing. I have participated in and/or managed the design and fabrication of plasma display panels ("PDPs"), liquid crystal displays ("LCDs"), electroluminescent ("EL") display panels and field emission displays ("FEDs"). For the past 12 years, I have served as a consultant to numerous

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client companies ranging from major corporations to start-ups on searching out and developing new display technologies into viable commercial products. I am currently on the technical advisory boards of Nanolumens Inc. and Microvision Corp. and have also recently consulted (or am currently consulting) with Moscow State University, Corning Glass Corporation, Sony Corporation, Thomson Multimedia, and Dow Chemical on various projects relating to flat panel display development and applications. Over the years, I have been responsible for the development and integration of numerous display designs, including the mechanical design and integration of displays into end products. I currently maintain a laboratory with capabilities for testing all aspects of display performance, for disassembly and analysis of display products, and for research into new display technologies and related mechanical structures. 3. In addition to hands-on experience in the design and manufacture of display

panels, I have followed carefully the technical developments relating to displays for over 25 years. My familiarity with display technology comes not only from my professional involvement as a consultant to the industry, but also from my active involvement with the Society for Information Display ("SID"), the largest and most prestigious technical society dedicated to advances in display technology. From 1992 to 2000, I was Chair of the SID Publications Committee, with oversight responsibility for all SID publications including the SID/Wiley book series, the refereed SID scientific journal ("The Journal of the SID"), and the SID industry trade publication ("Information Display Magazine"). As chair of the SID Publications Committee, I helped direct the content of the Journal and Information Display Magazine to the most important technological advancements. For the ten-year period from 1993 to 2003, I wrote a monthly column entitled "The Display Continuum" covering a wide range of display industry topics, including technology, management, and product related issues.

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4.

In addition to my role as Chair of the SID Publications Committee, from 1994 to

2002 I was elected to the Executive Committee of the SID and served two-year terms as Secretary, Treasurer, President Elect, and President. I continue to participate on the SID Executive Committee and the Board of Directors as Past President and Chair of the Publications Committee. 5. To stay current in my technical field, I have, over the past 10 years, also offered a

general two-day intensive course on display technology. I have taught this course for SEMI (Semiconductor Equipment and Materials International), SPIE (International Society for Optical Engineering), and in-house for several major corporations including Sony and Dell. I have also made numerous conference presentations and keynote speeches regarding the future of display technologies at events such as the International Display Workshop and other international display conferences. 6. I have been asked to evaluate and provide an opinion as to the validity of Claims

35, 36, 38, 39, 44, 45, 55, and 56 of US Patent No. 6,501,641 (the "`641 Patent") and Claims 33, 34, 35, and 40 of US Patent No. 6,498,718 (the "`718 Patent", collectively the "patents in suit"). I understand that this declaration is for use in connection with the above encaptioned legal action. 7. As part of my analysis of the validity of the patents in suit, I have been asked to

examine a physical specimen of the LC056N1 product (the "GoldStar Product") as well as drawings related to that product produced by LPL (LPL22139). It is my opinion that the above identified claims are invalid based on the structure of the GoldStar Product. The specifics of my opinion are set forth more fully in my opening expert report which was served in this case on August 31, 2007.

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