DECLARATION OF DAVID L. TAYLOR ISO MSJ RE ESTOPPEL
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CASE NO. CV-00-20905 RMW
semiconductor design methods and technologies which I used in my future design activities.5. I have accumulated significant knowledge and experience in the design andmanufacture of semiconductor devices; this is summarized in my resume, Exhibit A. My work experience has primarily been in the area of semiconductor memory products including DRAM,SRAM, EPROM, EEPROM, and ROM. I have been directly responsible for the design of approximately 75 commercially successful products including, for example, 1M, 4M, and 8Msynchronous DRAMs (at Silicon Access), a 1M synchronous SRAM (at Hyundai ElectronicsAmerica), and a 4M synchronous DRAM-based ATM switch and 4M DRAM-based FIFO, both atIntegrated Device Technologies. I also hold 21 patents in the semiconductor field, most of whichdeal with semiconductor memory circuits and products; a list of these patents is included inExhibit A.6. For convenience and because the exhibits referenced in this declaration are notnumbered sequentially, a list of the exhibits to this declaration is included in Exhibit B.7. Ten claims of the Farmwald/Horowitz patents were tried in the 2006 patent trial.These were:US 5,915,105 – claim 34;US 6,034,918 – claims 24 and 33;US 6,324,120 – claim 33;US 6,378,020 – claims 32 and 36;US 6,426,916 – claims 9, 28, and 40; andUS 6,452,863 – claim 16.For convenience, the patents will be referenced by the last three digits in the patentnumber. A copy of the text of all ten claims is attached in Exhibit 1.8. I understand that, as a result of the trial and other proceedings in the litigation, allten claims were found infringed and none of the claims were found invalid, and that judgment wasentered against Hynix Semiconductor Inc. and the related subsidiaries that are parties to the case(collectively, “Hynix”).
9. These claims recite, using various wording, memory devices and methods of
I understand that, in March 2012, Hynix Semiconductor Inc. was renamed SK hynix Inc., andthat the names of its subsidiaries have also changed accordingly. However, for ease of reference, I will continue to refer to “Hynix”.
Case5:00-cv-20905-RMW Document4169 Filed10/17/12 Page3 of 37