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Tech Law Journal |
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UNITED STATES OF AMERICA
COMPLAINT COUNSEL'S FINAL LIST OF TRIAL WITNESSES Pursuant to the Court's Second Revised Scheduling Order in this matter, Complaint Counsel hereby designate those persons whom we now contemplate calling to testify as witnesses at the Hearing in this matter. We reserve the right to present testimony, by deposition or orally by live witness, from any other person who has been or may be identified by Respondent Intel Corporation ("Intel") as a potential trial witness for Intel in this matter. We also reserve the right to supplement this witness list as circumstances may warrant, in accordance with the Court's scheduling orders and other applicable rules. Finally, we reserve the right not to call any of the persons listed herein to testify at the Hearing, as circumstances may warrant. Subject to these reservations of right, our list of trial witnesses is as follows: 1. Richard Hugh Burnes Mr. Barnes retired from Compaq Computer Corporation ("Compaq") in January 1997. At the time of his retirement, he served as Chief Technical Officer for Compaq. [begin page 2] 2. Gary Pat Campbell Mr. Campbell is Vice President and Director of Rep, Inc., a distributor of electronics components with headquarters in Huntsville, Alabama. 3. Gordon A. Campbell Mr. Campbell is a former Intel manager and currently a venture capitalist at Techfarm, Inc., in Sunnyvale, California. 4. G. Gervaise Davis, III (expert witness) Mr. Davis is an attorney in Monterey, California. He has practiced intellectual property and business law in the computer industry for 30 years. 5. Vinod Dham Mr. Dham is a former Intel manager who currently serves as Chairman, President and Chief Executive Officer of Silicon Spice, Inc., in Mountain View, California. 6. Cheryl Dilley (adverse witness; by deposition) Ms. Dilley is Project Manager for Intel Corporation, and has management responsibility for Intel Customer Information Management Services ("CIMS") located in Folsom, California. 7. Howard D. Elias Mr. Elias is Vice President and General Manager of the Storage Products Division of Compaq, and formerly served as Vice President for the NT Business Unit of Digital Equipment Corporation ("Digital") until Digital was acquired by Compaq in 1998. [begin page 3] 8. Robert C. Frame Mr. Frame is Director of Engineering for Compaq's Portable Development Center in Marlborough, Massachusetts, and was formerly Director of Engineering for the Mobile Business Unit of Digital until Digital was acquired by Compaq in 1998. 9. Robert Herb Mr. Herb is Senior Vice President and Co-Chief Marketing Executive for Advanced Micro Devices, Inc., in Sunnyvale, California. 10. David F. Hixson Mr. Hixson serves as inside counsel for Motorola, Inc., in Schaumburg, Illinois. 11. Lee W. Hoevell Dr. Hoevel is an independent consultant based in Austin, Texas. Since February 1997 he has served as President of International Meta Systems, Inc. 12. Dean A. Klein Mr. Klein was recently appointed Vice President for Integrated Products at Micron Technology, Inc., in Boise, Idaho. Prior to that appointment he served as Executive Vice President for Product Development and Chief Technical Officer at Micron Electronics, Inc. in Nampa, Idaho. 13. Donald Lewine Mr. Lewine is Chief Technology Officer for Data General Corporation in Westborough, Massachusetts. 14. James W. Meadlock Mr. Meadlock is the Chairman and Chief Executive Officer of Intergraph Corporation. [begin page 4] 15. Robert B. Palmer Mr. Palmer served as Chairman and Chief Executive Officer of Digital Equipment Corporation until Digital was acquired by Compaq in 1998. 16. James Paschal Mr. Paschal retired from Compaq in February 1998. At the time of his retirement, he served as Vice President of Engineering for Compaq's Desktop Products Group. 17. Prof. Yale N. Patt (expert witness) Prof Patt is Professor of Electrical Engineering and Computer Science at the University of Michigan. He is expected to testify as an expert witness on relevant computer and microprocessor technology. 18. Wade C. Patterson Mr, Patterson is President of Intergraph Computer Systems, Inc., in Huntsville, Alabama. 19. Donald J. Quigg, Esq. (expert witness) Mr, Quigg is a patent attorney with Roper & Quigg in Arlington, Virginia. From 1985 through 1989, Mr. Quigg served as Assistant Secretary of Commerce and the Commissioner of Patents and Trademarks. In the event the Court were to permit Intel to present evidence and expert testimony relating to patent law issues despite the Stipulation Regarding Patent Issues (September 1, 1998), we would expect to call Mr. Quigg, to the extent necessary, to testify as a rebuttal expert on such matters. 20. S. Atiq Raza Mr. Raza currently serves as Executive Vice President and Chief Technical Officer for Advanced Micro Devices, Inc. in Sunnyvale, California. [begin page 5] 21. Thomas S. Respess, III, Ph.D. (expert witness) Dr. Respess currently serves as Assistant Director of the Accounting and Finance Group for the Bureau of Competition of the Federal Trade Commission, in Washington, D.C. 22. Prof. Frederic M. Scherer (expert witness) Prof. Scherer is an economist and the Aetna Professor of Public Policy and Corporate Management at the Kennedy School of Government, Harvard University, Cambridge, Massachusetts. 23. Rodney. W. Schrock Mr. Schrock was recently appointed President and Chief Executive Officer for the Alta Vista Division of Compaq. Prior to that appointment, he was Senior Vice President and General Manager for Compaq's Consumer Product Group. 24. Albert Yu (adverse witness; by deposition) Dr. Yu is an Intel Senior Vice President responsible for Intel's Microprocessor Products Group. Respectfully submitted,
DATE: February 19,1999 [begin page 6] CERTIFICATE OF SERVICE I hereby certify that today I caused a copy of the attached document entitled COMPLAINT COUNSEL'S FINAL LIST OF TRIAL WITNESSES, to be delivered by hand and facsimile to:
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