Nokia Corporation v. Apple Inc.

Filing 63

Declaration of William C. Simpson filed by Plaintiff Nokia Corporation, Counter Defendant Nokia Inc. re: 58 Motion Requesting Claims Construction by Plaintiff Nokia Corporation, Counter Defendant Nokia Inc. (Attachments: # 1 Exhibit Ex. A - CV) (Newton, Michael) Modified docket text on 12/22/2010 (jas/p).

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Nokia Corporation v. Apple Inc. Doc. 63 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN NOKIA CORPORATION, Plaintiff, v. APPLE INC., Defendant. Civil Action No. 10-CV-249 JURY TRIAL DEMANDED APPLE INC., Counterclaim-Plaintiff, v. NOKIA CORPORATION and NOKIA INC., Counterclaim-Defendants. DECLARATION OF WILLIAM C. SIMPSON I, William C. Simpson, declare and state as follows: 1. I am an expert in the field of design and development of computer display systems. I hold a B.S. degree in Electrical Engineering from Lehigh University, in Bethlehem, Pennsylvania and an M.S. degree in Electrical Engineering from Rensselaer Polytechnic Institute, in Troy, New York. Additionally, I have 21 post-masters credits in Electrical Engineering from Lehigh University, where, from 1975 to 1977, I taught Electrical Engineering courses as an Instructor. I have developed and taught computer architecture courses at Intel, Unisys, and Texas Instruments. I have 38 years of experience in the design and development of computer systems, including computer display systems. I have been designing computer graphic display hardware and software LEGAL02/32319708v1 Dockets.Justia.com since 1984. I have extensive experience with computer graphic software standards including Graphical Kernel System (GKS), PHIGS (Programmer's Hierarchical Interactive Graphics System), the X Window system, OpenGL (Open Graphics Library), Computer Graphics Metafile (CGM), and raster graphics. I have designed PC hardware, including PC video computer display systems, since 1988. I designed computer graphic display hardware and software for Omnicomp Graphics Corp in 1984 and for Ferranti International Controls in 1985 through 1989. I designed computer graphic software for Magnavox in 1987 using the GKS computer graphic software standard. I designed computer graphic display hardware and software for Dupont Graphics Division in 1988. I designed PC computer graphic display hardware and software for Intel in 1987 through 1993. I designed PC hardware and software, including PC video display, Plug-and-Play for PCMCIA, PCI, and ISA, docking stations, and VESA DDC for Compaq (now HP) in 1995 through 1997. 2. I have been retained by Alston & Bird LLP, attorneys for Nokia Corporation and Nokia, Inc. ("Nokia"), to offer my opinions regarding Apple Inc.'s ("Apple") Patent No. 7,380,116 (the "`116 patent"). The matters set forth herein are of my own personal knowledge and if called as a witness I could competently testify thereto. 3. Exhibit A. 4. In connection with my preparation of this declaration, I reviewed the `116 My experience and education are detailed in my resume, attached as patent in its entirety and portions of its file history, and the patents and applications cited therein. I believe that I am an expert regarding the subject matter disclosed therein. 5. In my opinion, a person of ordinary skill in the art at the time would have had a B.S. degree in electrical engineering or computer systems engineering, and five years experience in the field of computer systems engineering, including computer display systems, or equivalent practical experience. 6. The `116 patent is directed to computer display systems, and specifically, changes in the configuration of the display environment. The term "modifying" is a general term and has no specialized meaning in the industry. The term "allocation" is a general term and has no specialized meaning in the industry. The phrase "modifying the allocation of display space," as used in Claim 1 of the `116 patent, was not a term of the art that was used by persons having ordinary skill in the art at the time the patent was filed, and does not have a specialized meaning in the industry. I declare under penalty of perjury that the foregoing is true and correct. Dated: December 16, 2010 William C. Simpson

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