This case involves an intellectual property (IP) claim involving two non-volatile memory providers. The plaintiff designs, develops, and manufactures a non-volatile memory technology, including a type of electrically erasable programmable read-only memory commonly known as “flash memory.” The plaintiff alleges that the flash memory/data storage products that the defendant manufactures and sells for importation to the U.S is protected under patent. The right expert for this case will have in depth knowledge relevant to the specific patents listed in the case, rather than an expert with a general knowledge of flash memory.
Question(s) For Expert Witness
- 1. Please explain your knowledge / experience pertaining to flash memory.
- 2. Have you ever testified as an expert witness on an IP claim involving flash memory?
- 3. Are you familiar with the products developed by these companies?
- 4. Do you have proficiency with circuit design?
- 5. Can you read hardware design / programming language code?
- 6. Are you familiar with GDS?
Expert Witness Response E-009178
I am happy to review this case on behalf of the plaintiff. I have been doing research on semiconductor electronic devices for over 25 years. During the period, 1990-1993, I was a manager of a group at AT&T Bell Labs that included research on flash memory. Over the years since then, on the faculty of UC Berkeley, I have followed the field of flash closely. I have worked as an expert witness in two cases related to flash memory and testified at deposition in one. I am not specifically familiar with the products involved in this claim, however, I believe I could serve as an expert on this topic given my expertise in the field and prior experience on two other IP cases regarding flash memory.
Expert Witness Response E-009270
I have written 3 books pertaining to flash memory and have done research in the area. I am familiar with the products involved in this case. I have proficiency with circuit design. I am familiar with GDS, and I can read hardware design / programming source code having taught in this area.