Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1067

Administrative Motion to File Under Seal filed by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company). (Attachments: #1 Proposed Order Granting Motion to Seal, #2 Declaration of Brian von Herzen in Support of Samsung's Reply in Support of Motion to Strike Expert Testimony Based on Undisclosed Facts and Theories, #3 Exhibit 1 to von Herzen Declaration, #4 Exhibit 2 to von Herzen Declaration, #5 Exhibit 3 to von Herzen Declaration, #6 Exhibit 4 to von Herzen Declaration, #7 Exhibit 5 to von Herzen Declaration, #8 Exhibit 6 to von Herzen Declaration)(Maroulis, Victoria) (Filed on 6/8/2012)

EXHIBIT 1

Brian Von Herzen, Ph.D.
Expertise
FPGA Architecture and Applications
Network Hardware Architecture
Video & Audio Compression
ASIC Design
Software Engineering
Signal Processing
D/A & A/D Converters

Image Processing/Computer
Graphics
PCI Express Architecture
PLD Technology
Video Codec Design
Hardware Engineering
6G and 10G networking

Professional Summary
From:
To:

1993
Rapid Prototypes, Inc.
Present
Carson City, NV
Position: CEO
Rapid Prototypes provides turnkey electronic product design
services, including commercial product specifications and fully
functional engineering product prototypes frequently using
programmable logic devices. Rapid Prototypes are experts in the
electronic engineering technologies to minimize time to market for
new electronic products in networking, consumer electronics and
other commercial products. They also develop the world's fastest
commercial FPGA applications. Clients have included:
Xilinx, Inc.—Representation at OIF, NPF, IEEE and
RapidIO—Chairman of the Interoperability Working Group
of the Optical Internetworking Forum, 2003-2007
responsible for industry demonstration of 10Gb networking
interfaces
Woods Hole Oceanographic Institution
The Climate Foundation
Bright Energy Storage Technologies, LLP
Guzik Technical Enterprises
Alpha Touch, Inc.
DRC Computers
Walt Disney Feature Animation
Syntax Brillian
Proview
Amtran

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Vizio
Taiwan Kolin Co. Ltd.
Polaroid
TPV Technology Ltd.
Top Victory Electronics
Envision Peripherals
International Reliance Corp
Sakura Networks, Inc.
Silicon Informatics, Inc.
Silicon Valley Expert Witness Group
Andes Networks
Data Transit
Core Capital
Gerson Lehrman Group
Impossible Pictures, Ltd.
Hoffman and Zur
Keyeye
Magnalynx
Mercury Computer
Nvidia
Specific Magic
Hi/fn
ViaSat
Quicksilver
Zebra Imaging
Rockwell International Corporation
California Institute of Technology
Microsoft Corporation
Intel
Synaptics, Inc.
General Dynamics Corporation
AMCC/3Ware
Interval Research Corporation
Enact Products, Inc.
MediaLink Technologies
Design achievements include:
Sparse Chevron™ patent pending pin configuration for
Xilinx Virtex-4.
Demonstration of 10Gb/s optical and copper serial links
between Xilinx and Altera FPGA’s and ASSP/ASIC devices
including AMCC, Vitesse, NEC, Intel, Broadcom, PMC etc.
SDRAM IP Cores for Xilinx FPGA's, a high performance
SDRAM controller for the Xilinx Virtex family of FPGA's.
A FastRAM development board designed for high memory
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bandwidth
Developed a high-speed FPGA application, a fully parallel
cross-correlator. (http://www.fpga.com/papers/corr256.pdf)
Architected, designed, developed, tested and demonstrated a
2K x 2K, 144 Hz real-time composition graphics engine.
Created a 1-GHz analog video output daughter card.
Designed and developed a 60-Hz vector quantization video
codec ASIC using FPGA rapid product prototyping
techniques.
Architected and built a reconfigurable computing machine
using a two-dimensional toroidal array of 32 FPGA and
static memory devices for Interval Research Corporation.
(http://www.fpga.com/papers/stereovis.pdf)
Built a 10-GIPS depth-from-stereo video processor using the
reconfigurable computing machine.
From:
To:

1992
Synaptics, Inc.
1993
San Jose, CA
Position: Applications Research Manager
Research in video compression. Achievements include:
Developed digital neural networks using FPGA’s.
Commercial applications of image processing.
Analyzed VLSI CCD devices for MPEG motion
compensation.

From:
To:

1988
Caltech Submillimeter Observatory
1992
Hilo, HI
Position: Design Project Manager
Obtained NSF grant for VLSI correlator development.
Produced a 250 MHz micropipelined cross-correlator in 1.2
µm CMOS.
Designed and developed a 2 GHz digital spectrometer using
correlators.
Created a 2 GHz GaAs A/D converter.

From:
To:

1986
Pixar, Inc.
1988
San Rafael, CA
Position: Systems Analyst
Developed an image processing architecture for the Pixar Image
Computer

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From:
To:

1982
Dolby Laboratories
1986
San Francisco, CA
Position: Research and Development Engineer
Developed a digital audio compression and decompression system.

From:
To:

1980
Hewlett-Packard Laboratories
1981
Palo Alto, CA
Position: Research & Development Engineer
Developed an electron-beam annealing process for MOSFET
devices.

Litigation Support
Date:

2011
Case
Project:

Status:
Date:

2010
Case
Project:

Status:
Date:

2009
Case
Project:

Status:
Date:

2009
Case

DLA Piper
Freescale v. Zoran
Dr. Von Herzen was retained as an expert witness in this case, plans
to provide written expert reports, depositions and testimony in this
ITC case.
Open
Weil, Gotchal, Manges
Elan vs. Apple
Dr. Von Herzen was retained as an expert witness in this case,
provided written expert reports, was deposed, and prepared to
testify in this Federal case in San Francisco.
Closed
Winston and Straun
Opti vs. AMD et al.
Dr. Von Herzen was retained as an expert witness in this case,
provided written expert reports, depositions, and prepared to testify
before the case settled.
Closed

Ropes and Gray.
Realtime Data vs. PACKETEER, INC.,
BLUE COAT SYSTEMS, INC., CITRIX SYSTEMS, INC.,
EXPAND NETWORKS, INC., F5 NETWORKS, INC., 7ELEVEN, INC., ABM INDUSTRIES, INC., ABM JANITORIAL
SERVICES –
SOUTH CENTRAL, INC., AVERITT
EXPRESS, INC., BUILD-A-BEAR WORKSHOP, INC., DHL
EXPRESS (USA), INC., INTERSTATE BATTERY SYSTEM OF
AMERICA, INC., AND O’REILLY AUTOMOTIVE, INC.
Project:
Dr. Von Herzen was retained as an expert witness in this case,
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Status:
Date:

2008
Case
Project:

provided written expert reports, was deposed, plans to testify and be
cross examined in this Federal case in the East District of Texas.
Open

Status:

O’Melveny and Myers, Ropes and Gray, Sidley Austin, etc.
Funai vs. TPV, Polaroid, Proview, Amtran, Syntax Brillian
Dr. Von Herzen was retained as an expert witness in this case,
provided written expert reports, was deposed, testified and was
cross examined in this ITC case before Judge Carl C. Charneski.
Closed

Date:

2006
Case
Project:
Status:

Weil, Gotshal & Manges LLP
Apple Computer v. Burst
Dr. Von Herzen has been retained as an expert witness in this case.
Closed

Date:

2004
Case
Project:

Sidley Austin
Burst v. Microsoft
Dr. Von Herzen testified and was deposed with regard to streaming
video technology.
Closed

Status:
Date:

2002
Case
Project:

Status:
Date:

2002
Project:

Date:

Status:
2001
Case
Project:

Status:

United States District Court, Fresno, CA
LectroLarm v. Pelco
Court appointed Master. Provided written expert report and
technical advice to the court on a video technology patent. Testified
and was cross-examined on expert report and related topics.
Closed
Alschuler, Crossman, Stein & Kahan, Arbitration, New York, NY
nVidia v. Microsoft
Dr. Von Herzen developed several expert reports and was deposed
with regard to ASIC technology and graphics processors.
Closed
Fish and Richardson
Intel v. Broadcom
Dr. Von Herzen was retained as the primary expert witness, was
deposed, testified and cross-examined at both Markman hearings
and at jury trial in Federal District Court in Wilmington, DE. The
case involved MPEG2 technology, video compression and
encoders, integrated circuit design, computer graphics and video.
Closed

Date:
1997-98
Gray Cary Ware & Freidenrich LLP
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Case
Project:

Status:

Mentor Graphics vs. Quickturn– ITC Case, Washington, DC
This case was an ITC patent case regarding electronic device
emulators. Dr. Von Herzen provided written direct testimony, was
deposed as an expert and testified before the ITC judge Paul
Luckern in this case.
Closed

Patents
Patent Number

7,608,931

Date Issued Title
2009
Interconnect array formed at least in part with repeated

7,567,702
7,501,341

2009
2009

7,312,773
7,066,023
6,456,737
6,353,334

2007
2006
2002
2002

6,348,775
6,222,885
6,215,898
5,924,115

2002
2001
2001
1999

5,451,890

1995

application of an interconnect pattern
Data processing system and method
Interconnect array formed at least in part with repeated
application of an interconnect pattern
Illuminated Wearable Ornament
Distributed sensor array for fluid contaminant monitoring
Data processing system and method
Circuit for converting a logic signal on an output node to a pair
of low-voltage differential signals
Drive wave form synchronization for induction motors
Video codec semiconductor chip
Data processing system and method
Hierarchical memory architecture for a programmable integrated
circuit having an interconnect structure connected in a tree
configuration
Gallium arsenide source follower FET logic family with diodes
for preventing leakage currents

Eight additional patents pending.

Publications
Von Herzen, Brian, "Signal Processing at 250 MHz using High-Performance FPGA’s"
IEEE Transactions on VLSI, Volume: 6 Issue 2, June 1998, Page(s): 238-246
Woodfill, John and Brian Von Herzen, "Real-Time Stereo Vision on the PARTS
Reconfigurable Computer," IEEE FPGA’s for Custom Computing Machines, April 1997,
Napa, CA (FCCM97).
Von Herzen, Brian, "VLSI Partitioning of a 2 GHz Digital Spectrometer," IEEE Journal
of Solid-State Circuits, Volume 25, Number 5, May 1991.
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Von Herzen, Brian, Alan Barr and Harold Zatz, "Geometric Collisions for TimeDependent Parametric Surfaces," Computer Graphics, Vol. 21, No. 3 August, 1990.
Von Herzen, Brian and Alan Barr, "Accurate Triangulations of Deformed, Intersecting
Parametric Surfaces," Computer Graphics, Vol. 21, No. 3, 1987.
Barr, Alan, Brian Von Herzen and Ronen Barzel, "Computational Techniques for the
Self-Assembly of Large Space Structures," Eighth Princeton Conference on Space
Manufacturing, Princeton, NJ, May 1987.
Kajiya, Jim and Brian Von Herzen, "Ray Tracing Volume Densities," Computer
Graphics, Vol. 18, No. 3, July 1984.
Von Herzen, Brian, Ted Kamins and Cliff Drowley, "A Technique for Profiling a Laser
Beam and its Application to the Recrystallization of Polysilicon Films," Journal of the
Electrochemical Society, Vol. 128, No. 12, December 1981.
Kamins, Ted and Brian Von Herzen, "MOSFET’s in Electron-Beam Recrystallized
Polysilicon," IEEE Electron Device Letters, Vol. EDL-2, No. 12, December 1981.

Education
Year
1988

College/University
Caltech, Pasadena, CA

1984

Caltech, Pasadena, CA

1980

Princeton University

Degree
Ph.D., Computer Graphics & VLSI
Hertz Foundation Fellowship
M.S.., Computer Graphics & VLSI
Hertz Foundation Fellowship
AB, Physics, Magna Cum Laude

Professional Associations and Achievements
Member, IEEE
Member, Optical Internetworking Forum (OIF, Chair, Interoperability Working Grp.)
Member, Professional And Technical Consultants Association (PATCA)
Member, AOPA Pilots Association, PPMEL, SES, IFR
Languages: Russian & French
Ross Freeman Nomination for outstanding technical achievement, Xilinx, 2000
Ross Freeman Award for outstanding technical achievement, Xilinx 2006

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