RR neepg ,
ITNTHLE UNITED STATES DISTRICT COURT _
FOR TILE DISTRICT OF DELAWARE
GTECH CORPORATION, ) __
)
Ptaineii > _ A
) Civil Action No. 04-133-ITE *$ 5·
V- ) I 9 Z 7
Z} I
SCIENTIFIC GAMES INTERNATIONAL, INC., ) .
SCIENTIFIC GAMES HOLDMGS )
CORPORATION, SCIEN‘I`R·`lC GAMES ) Q _—__
- FINANCE CORPORATION, and SCIENTIFIC ) `
GAMES CORPORATION, ) I
) '- -2
Defendants. ) ‘€
DECLARATION OF JOSEPH C. PERIN. JR., P.E. _
; I, Joseph C. Perin, declare and state as follows:
‘ l. I am a licensed professional engineer in the state of Ohio since I993, I
currently work as a sohrmre engineer at the Harris Corporation Broadcast
Comomnications Division in the Networking and Government Communications Group.
The details ofmy `baclcgrotmd and experience, which includes Bachelor of Science ,__ I
degrees in Marketing and Electrical Engineering, graduate coursework in engineering,
_ over 20 years of engineering work experience, almost ten years of which involved
engineering work concerning lottery machines including instant ticket vending machines ` l
{‘°I'l"VMsâ€), and experience with the design and operation of various components and Lk
‘ peripherals of vending equipment, including '1'I'VMs, including character and graphic U i
displays, bursting and dispensing equipment, bill acceptors, coin acceptors, motors, and _ ·
Case 1 :04-cv-00138-JJ F Docu ment 161 Filed 12/O9/2005 Page 2 of 4
i sensors, just to name e. few, are pnavided on my curriculum vims which is annexed as
Exhibit A to my opening expert report, Exhibit A hereto. _
· 2. I hevebeeaz engaged as an expert witness by pIeint:iE`G'1`EC}·I Corporation
("GTECH") is this litigation and submit this declaration on behalf ofG’1`ECH in support p'
of its opposition to defenclsnts’, Sclentitic Games et al.’s, motion for summary judgment .
that its accused Pleyfientrei instant ticket vending machine does not inittnge asserted
- claims 18 of U.S. Patent No. 5.222,624 (the "‘624 patent") end claims 20 and 21 of U.S.
Patent No. 4,982,337 (the "’337 petenf) (colieczively "the asserted oleims"). gg.
3. I have previously provided expert reports on tee issue ofthe izzfringsmeut ly
ofthe asserted claims ofthe *624 and *337 patents by det`endams’ PIeyCen¤·elm.ecl1iz1e.
Those expert reports, detect August 12, 2005 and September 16, 2005, respectively, exe ` E
attached hereto as ExIu"¤its A and B. - '
4. I declare under penalty ofpetjury under the laws ofthe United States of il
America that the attached Expert Report 0fJcsqvh CZ Perin. Jr. PE., dated August 12, `
2005, is true and correct D ` _
5. I declare under penalty of perjury under the laws of the United States of I
America that the attached Rebuttal Exper: Report offoszgah CZ Perin, Jr. P.E., dated Q:
September 16, 2005, is one and correct. i
e Executed on Deceuaberé, 2005, atCincinne1i, Ohio. __
Q2 h I erm, Jr. :··
l Case 1 :04-cv-00138-JJF Document 161 Filed 12/O9/2005 Page 3 of 4
CERTIFICATE OF SERVICE
I, Andrew A. Lundgren, Esquire, hereby certify that on December 2, 2005, I caused to be `
5 electronically filed e. true and correct copy ofthe foregoing document with the Clerk of the Court
using CMJECF, which will send notification that such filing is available for viewing and
clowrlloading to the following counsel ofrecord: .
J acl; B. Blumenfeld Esquire
Morris Nichols Arsht &: Tunneii
1201 North Market Street
- Wilmington, DB 19801
I further certify that on December 2, 2005, I caused a copy of the foregoing document to
be served by hand delivery on the ebove-listed counsel of record.
YOUN CONAWEI STARGATT & TAYLOR, LLP _
l { lcd/yu
Josy W. Ingersoll (#i088) l
John W. Shaw (#3362) fl
Karen E. Keller (#4489) f
Andrew A. Lurrdgren (#4429)
YOUNG CONAWAY STARGATT & TAYLOR, LLP
The Brandywine Building
EOOO West Street, 17th Floor
P.O. Box 391
Wiirnirzgton, Delaware l9899—039l
(302) 571-6600 ——
ld
r>su1;1u2ss¤z.1 uesusszoua
Case 1:04-cv-00138-JJF Document 161 Filed 12/O9/2005 Page 4 of 4
CERTIFICATE GF SERVICE
I, Andrew A. Lundgren, Esquire, hereby certify that on December 9, 2005, I caused to be
electronically filed a true and correct copy ofthe foregoing document with the Clerk ofthe Court
using CMJECF, which will send notification that such tiling is available for viewing and
downloading to the following counsel of record:
Jack B. Blumenfeld Esquire
Morris Nichols Arsht & Tunnell
120I North Market Street
Wilmington, DE 19801
I further-certify that on December 9, 2005, I caused a copy ofthe foregoing document to
be served by hand delivery on the above-listed counsel of record.
YOUNG CONAWAY STARGATT & TAYLOR, LLP i
Josy W. Ingersoll (#1088)
John W. Shaw (#3 362)
Karen E. Keller (#4489)
Andrew A. Lundgren (#4429)
The Brandywine Building
1000 West Street, 17th Floor
P.O. Box 39I
Wilmington, Delaware 19899-0391 __
(302) 571-6600
[email protected]
Attorneys for GTECH Corporntion
DB0l:l825692.l 0630511001
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