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11 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
12 SAN JOSE DIVISION
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FEDERAL TRADE COMMISSION, Case No. 5:17-cv-00220-LHK-NMC
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16 Plaintiff, JOINT PRETRIAL STATEMENT

17 vs.
DATE: December 13, 2018
18 QUALCOMM INCORPORATED, a
Delaware corporation, TIME: 1:30 p.m.
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Defendant. CTRM: Courtroom 8
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JUDGE: Hon. Lucy H. Koh
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JOINT PRETRIAL STATEMENT
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1 Pursuant to the Court’s Guidelines for Final Pretrial Conferences in Bench Trials and the

2 Court’s October 24, 2018 Case Management Order (ECF No. 922), the Parties submit this Joint

3 Pretrial Statement.

4 I. Substance of the Action

5 The Parties to this antitrust action are plaintiff Federal Trade Commission (“FTC”), a
6 United States government agency, and defendant Qualcomm Incorporated, a Delaware
7 corporation with its principal place of business in San Diego, California. The operative pleadings
8 in this case are the FTC’s Complaint (ECF No. 1) and Qualcomm’s Answer (ECF No. 145).
9 FTC’s position. The FTC asserts that Qualcomm has violated Section 5(a) of the FTC
10 Act, 15 U.S.C. § 45(a), which prohibits “[u]nfair methods of competition.” The FTC asserts that
11 Qualcomm has held market and monopoly power in certain markets for modem chips, integrated
12 circuits that enable cellular communications in smartphones and other cellular products.1 The
13 FTC further asserts that Qualcomm has maintained its market and monopoly power and harmed
14 competition through a course of anticompetitive conduct. Qualcomm has (1) conditioned the sale
15 of modem chips on customers’ entry into and maintenance of patent licenses that include terms to
16 which customers would not agree absent Qualcomm’s chip leverage, including unreasonably high
17 royalties that customers must pay on cellular products that include non-Qualcomm modem chips;
18 (2) in some instances, offered customers incentive funds to accept unreasonably high royalties
19 and other unfavorable license terms; (3) refused to make licenses to patents essential to
20 implementing cellular standards (cellular “SEPs”) available to other modem chip suppliers, in
21 breach of commitments to do so; and (4) entered exclusive-dealing arrangements with Apple.
22 Qualcomm’s position. Qualcomm denies the FTC’s assertions. Among other things,
23

24 1
Throughout this statement, the FTC uses the term “modem chips” to be consistent with the
Court’s prior decisions in this case. See, e.g., Order Denying Motion to Dismiss, ECF No. 134, at
25 2 n.1; Order Granting FTC’s Motion for Partial Summary Judgment, ECF No. 931, at 1-2.
26 Qualcomm does not object to the use of the term “modem chips” (for the purposes of this Joint
Pretrial Statement) as long as it is not understood to mean something different from “baseband
27 processors”, which is the term the FTC used to define the alleged antitrust markets in its
Complaint.
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JOINT PRETRIAL STATEMENT
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1 Qualcomm asserts that the FTC’s alleged worldwide markets for CDMA and “premium LTE”

2 baseband processors are not proper antitrust markets;2 that it does not have market power in either

3 of these ill-defined markets; that the terms of Qualcomm’s license agreements reflect the well-

4 established market value of its patent portfolio, comply with Qualcomm’s FRAND commitments,

5 and do not include unreasonably high royalties; that Qualcomm has abided by and continues to

6 abide by its commitments to cellular standard-development organizations; that Qualcomm’s

7 conduct is lawful and supported by legitimate business and economic justifications; that none of

8 the four conducts identified by the FTC has had or currently has any anticompetitive effects; that

9 the FTC cannot prove a violation of the FTC Act that is ongoing or likely to recur; and that the

10 injunctive relief sought by the FTC would be unsupported by the facts or any balancing of the

11 equities, would be contrary to the public interest, and not properly tailored to address the harms

12 alleged by the FTC, even if the FTC could prove any or all of them.

13 ***

14 FTC’s position. On November 6, 2018, the Court granted the FTC’s motion for partial

15 summary judgment. The Court held that the intellectual property rights policies of two U.S.-based

16 standard setting organizations “require Qualcomm to license its SEPs to modem chip suppliers.”

17 (ECF No. 931 at 25.) The issues decided by the Court on partial summary judgment should not

18 be addressed at trial.

19 Qualcomm’s position. In its Motion for Partial Summary Judgment, the FTC represented

20 that it was not seeking summary judgment on “the competitive effects of Qualcomm’s [alleged]

21 refusal to license its competitors” because those “effects must be evaluated at trial”; nor did the

22 FTC seek “to establish that Qualcomm has an antitrust duty to deal with its competitors”. (ECF

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24 2
The FTC states that this action involves allegations of market or monopoly power in “certain
markets for modem chips”. The FTC’s Complaint alleged two antitrust markets in which
25 Qualcomm is alleged to have had market or monopoly power: (1) “baseband processors that
26 comply with CDMA standards”, and (2) “premium baseband processors, which comply with
advanced LTE standards”. (Compl. ¶ 31.) The FTC has refused to confirm in this Joint Pretrial
27 Statement that this action concerns only the two baseband processor markets alleged in the
Complaint. Qualcomm will object to any attempt by the FTC to expand the scope of its claims to
28 allege abuse of market or monopoly power in any market that it has not alleged.

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1 No. 792 at 1.) The FTC conceded that both these subjects would have to be “addressed at trial”.

2 (ECF No. 792 at 1.) Qualcomm would oppose any effort by the FTC to bar Qualcomm from

3 presenting evidence at trial bearing on these or other issues that were not resolved by the Court’s

4 Order on partial summary judgment.

5 II. Relief Sought

6 A. Relief Sought by the FTC
7 The FTC seeks a declaration and adjudication that Qualcomm’s conduct violates
8 Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). In addition, the FTC seeks permanent injunctive
9 and other equitable relief that would redress and prevent recurrence of Qualcomm’s conduct,
10 including an order that would at least:
11  Prohibit Qualcomm from conditioning the supply of modem chips on a customer’s
12 patent-license status;
13  Require Qualcomm to negotiate or renegotiate, as applicable, license terms with
14 customers in good faith under conditions free from the threat of lack of access to or
15 discriminatory provision of modem chip supply or associated technical, software, or
16 other support;
17  Require Qualcomm to submit, as necessary, to arbitral or judicial dispute resolution to
18 determine reasonable royalties and other license terms should a customer choose to
19 pursue such resolution;
20  Require Qualcomm to make exhaustive SEP licenses available to modem-chip
21 suppliers on fair, reasonable, and non-discriminatory terms and to submit, as
22 necessary, to arbitral or judicial dispute resolution to determine such terms;
23  Prohibit Qualcomm from discriminating or retaliating in any way against any modem-
24 chip customer or modem-chip supplier because of a dispute with Qualcomm over
25 license terms or because of a customer’s license status;
26  Prohibit Qualcomm from making payments or providing other value contingent on a
27 customer’s agreement to license terms;
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1  Prohibit Qualcomm from entering express or de facto exclusive-dealing agreements

2 for the supply of modem chips;

3  Prohibit Qualcomm from interfering with the ability of any customer to communicate

4 with a government agency about a potential law enforcement or regulatory matter;

5  Require Qualcomm to adhere to compliance and monitoring procedures and

6 appropriate “fencing in” provisions, including but not limited to a potential firewall

7 between patent licensing and chip personnel; and

8  Impose any other relief that the Court finds necessary and appropriate to redress and

9 prevent recurrence of Qualcomm’s conduct.

10 The FTC believes that that the above list is sufficiently detailed and that the Court is not

11 restrained in its ability to fashion appropriate and effective relief.

12 B. Qualcomm’s Position

13 This Court’s Guidelines for Final Pretrial Conferences in Bench Trials require that the
14 Joint Pretrial Statement contain a “detailed statement of all relief claimed”. (Paragraph B(2).)
15 Qualcomm reserves the right to object to any attempt by the FTC to seek any relief not expressly
16 detailed in this Joint Pretrial Statement.
17 In any event, Qualcomm denies that the FTC is entitled to any relief and seeks judgment
18 in its favor on all of the FTC’s claims and requests for relief. Even if the Court were to find a
19 violation of the FTC Act, the injunctive relief the FTC seeks (to the extent articulated above)
20 would be unsupported by any balancing of the equities, would be contrary to the public interest
21 and would not be properly tailored to address the harms alleged by the FTC.
22 III. Undisputed Facts
23 The Parties have stipulated to the facts appearing in Exhibit A hereto.

24 IV. Disputed Factual Issues

25 The following factual issues (or mixed issues of fact and law) are disputed:

26  Whether the alleged worldwide market for CDMA modem chips and alleged

27 worldwide market for “premium LTE” modem chips constitute properly defined

28 antitrust markets;

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1  Whether Qualcomm had or has monopoly power in the alleged worldwide markets for

2 CDMA modem chips and “premium LTE” modem chips.

3 FTC’s Separate Statement of Disputed Factual Issues

4  Whether Qualcomm has held market power with respect to CDMA and premium LTE

5 modem chips;

6  Whether Qualcomm has maintained a policy of requiring modem-chip customers to

7 enter and maintain a separate patent license agreement with Qualcomm, including a

8 license to Qualcomm’s cellular SEPs (“no license-no chips”);

9  Whether Qualcomm has offered incentive funds tied to customers’ acceptance of

10 patent license terms;

11  Whether Qualcomm has refused to make cellular SEP licenses available to competing

12 modem-chip suppliers;

13  Whether Qualcomm’s “no license-no chips” policy, its use of incentive funds, and its

14 refusal to make licenses available to modem-chip suppliers have contributed to

15 unreasonable royalties and other license terms, including royalties paid on the sale of

16 cellular products that include non-Qualcomm modem chips;

17  Whether agreements that Qualcomm entered with Apple in 2011 and 2013 conditioned

18 payments from Qualcomm to Apple on Apple’s exclusive use of Qualcomm modem

19 chips in new Apple products; and

20  Whether Qualcomm’s licensing policies and practices and its agreements with Apple,

21 taken as a whole, have tended to hamper competition or maintain a monopoly in

22 modem-chip markets.

23 Qualcomm’s Separate Statement of Disputed Factual Issues

24  Whether any monopoly power in the alleged worldwide CDMA or “premium LTE”

25 baseband processor markets resulted from a superior product, business acumen or

26 historic accident rather than from exclusionary conduct;

27  Whether Qualcomm’s license agreements reflect the well-established market value of

28 Qualcomm’s portfolio of cellular SEPs, non-cellular SEPs and non-standard essential

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1 patents relevant to cellular devices;

2  Whether Qualcomm’s challenged licensing practices caused Qualcomm’s licensees to

3 agree to pay royalties to Qualcomm that were supra-FRAND;

4  Whether Qualcomm’s conduct with respect to licensing baseband processor suppliers

5 resulted from a decision to alter a voluntary and profitable course of conduct with

6 anticompetitive malice and the intent to maintain a monopoly;

7  Whether Qualcomm’s practice of licensing its SEPs only for the manufacture and sale

8 of complete devices, and neither licensing nor asserting its SEPs with respect to the

9 manufacture and sale of components, harms competition in any properly defined

10 antitrust market for baseband processors;

11  Whether Qualcomm’s challenged licensing practices caused, are causing, and are

12 likely to continue to cause, a substantial diminution in the demand for the baseband

13 processors of any Qualcomm competitor;

14  Whether Qualcomm’s challenged licensing practices caused any competitor of

15 Qualcomm to exit any well-defined antitrust market for baseband processors, not to

16 enter any well-defined antitrust market for baseband processors or to lose (or fail to

17 gain) substantial market share in any well-defined antitrust market for baseband

18 processors;

19  Whether certain agreements that Qualcomm entered with Apple in 2011 and 2013 (the

20 “Apple Agreements”) have prevented or currently prevent any Qualcomm competitor

21 from supplying baseband processors to Apple;

22  Whether the Apple Agreements could have prevented any as-efficient baseband

23 processor competitor of Qualcomm from supplying Apple;

24  Whether the Apple Agreements have prevented or currently prevent any Qualcomm

25 competitor from supplying baseband processors to any other manufacturer of cellular

26 devices;

27  Whether the Apple Agreements have foreclosed or currently foreclose a substantial

28 share of the alleged CDMA or “premium LTE” markets for baseband processors;

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1  Whether Qualcomm’s conduct has willfully monopolized the alleged worldwide

2 CDMA or “premium LTE” baseband processor markets, to the extent these markets

3 are properly defined;

4  Whether Qualcomm’s conduct, and any alleged effect thereof, is likely to recur;

5  Whether Qualcomm’s conduct is pro-competitive or supported by legitimate business

6 or economic justifications; and

7  Whether the FTC has proven that the injunctive relief it seeks is necessary and

8 properly tailored to address proven harm, is supported by the balancing of the equities

9 and is consistent with the public interest.

10 V. Agreed Statement

11 The Parties concur that no part of the action may be presented upon an agreed statement
12 of facts.
13 VI. Stipulations
14 The Parties have reached agreement, or are discussing proposed agreements, regarding the
15 following issues:
16 A. Objections to Proposed Evidence
17 The Parties have agreed to exchange objections to proposed trial exhibits on December 7,
18 2018, to exchange deposition counter-designations and objections to deposition designations on
19 December 10, 2018 and to exchange objections to deposition counter-designations on
20 December 17, 2018.
21 With respect to objections at trial, the Parties will proceed according to the schedule set
22 forth in the Court’s October 24, 2018 Case Management Order (ECF No. 922 at 2):
23  By 8:00 a.m. two days before any given demonstrative, exhibit, deposition testimony,
24 or live testimony (“HPO evidence”) will be introduced or used at trial, the Parties shall
25 exchange such HPO evidence (which in the case of live testimony means identifying
26 the live witnesses who will testify). As described below in Part B, the Parties have
27 agreed to exchange final designations of deposition testimony earlier than
28 contemplated by the October 24 Case Management Order and otherwise will follow

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1 the HPO evidence procedure with respect to deposition testimony.
2  By 7:00 p.m. that same day, the Parties shall meet and confer in person to discuss
3 objections to the HPO evidence and to try to narrow or eliminate their disputes.
4  By 8:00 a.m. one day before the HPO evidence will be introduced or used at trial, the
5 Parties shall concurrently file high priority objections and responses to the opposing
6 party’s high priority objections.
7 B. Disclosure of Final Deposition Designations

8 The Parties have agreed that the party proposing to play videotaped deposition testimony
9 must disclose its final designations no later than 8:00 a.m. four days before the testimony is
10 scheduled to be presented, and that the opposing party must respond with final counter-
11 designations 8:00 a.m. two days before the testimony is scheduled to be presented.
12 C. Sealing Motions
13 The Parties will follow the procedures for filing administrative motions to file under seal
14 set forth in Court’s September 5, 2018, and October 24, 2018 Orders. (See ECF Nos. 821, 922.)
15 The Parties are discussing procedures to notify third parties regarding the potential use of third-
16 party Protected Material at trial, and to facilitate the receipt of sealing requests from third parties.
17 The Parties have agreed to provide notice to relevant third parties of any currently designated
18 testimony or exhibits containing third-party Protected Material that either Party anticipates using
19 at trial by 8:00 a.m. two days before the third-party Protected Material will be introduced or used
20 at trial, so that they may seek an order protecting the Protected Material from public disclosure at
21 trial if they opt to do so. Giving notice to any affected third parties, the Parties will file a joint
22 motion for an order amending any Supplemental Protective Orders imposing different
23 requirements than provided herein.
24 The Parties request guidance from the Court on its preferred approach for addressing
25 sealing requests at trial.
26 D. Authenticity
27 The Parties have agreed that, absent any specific good-faith written objection to the
28 authenticity of a document, (1) documents produced by non-parties from the non-parties’ files

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1 and (2) documents produced by Qualcomm in this action or in the course of the FTC’s pre-
2 complaint investigation, FTC File No. 141-0199, shall be presumed to be authentic within the
3 meaning of Federal Rule of Evidence 901. (See Stipulated Order re: Discovery of ESI, ECF
4 No. 142 at 10-11.)
5 E. Order of Live Testimony
6 FTC’s Position

7 While the FTC’s preference is that a Party’s cross or redirect examination be limited to

8 matters within the scope of a witness’s direct examination, the FTC is willing to agree—for the

9 convenience of Qualcomm’s live witnesses—that each live fact witness may only be called once,

10 on the condition that the agreement is reciprocal. That is, each Party would agree to waive

11 objections that the opposing Party’s cross or redirect examination of any witness called in its case

12 concerns matters outside the scope of direct examination. While, as Qualcomm notes below, the

13 FTC will call witnesses it intends to elicit direct testimony from as part of its case in chief, it may

14 seek to elicit rebuttal testimony from Qualcomm live witnesses who appear for the first time

15 during Qualcomm’s case, and accordingly seeks a reciprocal agreement on any waiver of

16 objections.

17 Qualcomm’s Position

18 For the convenience of the fact witnesses who will testify live at trial—whether from

19 Qualcomm or a third party—Qualcomm and the FTC discussed agreeing, as is typical, that all

20 fact witnesses may only be called once, except for rebuttal testimony or for good cause shown.

21 To facilitate this agreement, Qualcomm has asked the FTC to agree that Qualcomm’s cross-

22 examination of a witness called in the FTC’s case may concern matters outside the scope of the

23 FTC’s direct examination. The FTC, however, has taken the position that, in exchange,

24 Qualcomm must waive all objections to the scope of any cross-examinations the FTC conducts

25 during Qualcomm’s case (i.e., that during Qualcomm’s case, the FTC be permitted to elicit direct

26 testimony on any topic from witnesses Qualcomm calls, even though the FTC already will have

27 rested its case). Such a waiver is not necessary to implement the Parties’ agreement that each live

28 fact witness be called only once, and the FTC’s proposed course of action would not be

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1 warranted, fair or efficient. If the FTC intends to elicit direct testimony from any live fact

2 witness, then it should call that witness during its case-in-chief, rather than waiting to elicit such

3 direct testimony during Qualcomm’s case. Moreover, to the extent the FTC suggests its position

4 is warranted so as to allow the FTC “to elicit rebuttal testimony from Qualcomm live witnesses

5 who appear for the first time during Qualcomm’s case”, such rebuttal testimony itself should be

6 limited to the scope of Qualcomm’s direct examination of its witnesses. In any event, the FTC’s

7 desire to seek rebuttal testimony during Qualcomm’s case does not warrant requiring Qualcomm

8 to waive all objections that the FTC’s cross-examination has exceeded the scope of direct

9 testimony.

10 F. Foreign Language Deposition Testimony
11 Subject to the Court’s approval, foreign-language videotaped deposition testimony will be
12 played with (1) questions in English; and (2) answers in the witness’s language, along with
13 subtitled English translations, provided that the Parties are capable of timely preparing reasonably
14 comprehensible videotapes with such subtitles.3
15 G. Other
16 The Parties will continue to discuss potential stipulations that may promote efficiency and
17 streamline the trial.
18 VII. Witnesses to be Called
19 The Parties exchanged preliminary witness lists on November 9, 2018, and exchanged
20 lists of additional witnesses on November 21, 2018. The FTC’s witness list is attached as
21 Exhibit B. Qualcomm’s witness list is attached as Exhibit C.4 The Parties hope to reach
22 agreement regarding which current and former Qualcomm employees on the Parties’ witness lists

23 will be available at trial, along with when these witnesses will be available. Should any witness

24 not agree to appear, each party reserves the right to seek to compel the witness’s attendance to the

25 extent permitted by Rule 45.

26
3
27 Some third-party witnesses testified in Korean and Chinese.
4
The FTC objects to Qualcomm’s purported reservation of rights regarding its witness list to the
28 extent those “rights” contravene this Court’s standing order.

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1 FTC Position

2 In September, the FTC requested information regarding the availability at trial of

3 Qualcomm witnesses, including eight former Qualcomm employees represented by Qualcomm’s

4 counsel at deposition (Messrs. Steve Altman, Derek Aberle, Paul Jacobs, Jeff Altman, Eric

5 Reifschneider, Marv Blecker, Irwin Jacobs, and Michael Hartogs). In response to the FTC’s

6 repeated inquiries over the following weeks, Qualcomm’s counsel consistently represented that

7 they were investigating each individual’s availability, and gradually provided information

8 regarding five of the eight witnesses (three of whom Qualcomm has agreed to make

9 available). In response to each of the FTC’s multiple inquiries Qualcomm’s counsel represented

10 that they were investigating the availability of the witnesses whose availability had not yet been

11 confirmed. The FTC’s November 8 initial witness list identified each of the former employees at

12 issue as “Live Witnesses Represented by Qualcomm’s Counsel,” and Qualcomm’s counsel

13 provided no indication that their representation of any of these individuals had ceased. On

14 November 19, the FTC yet again asked Qualcomm’s counsel to “[p]lease confirm that Qualcomm

15 will make available Derek Aberle, Paul Jacobs, Steve Altman, and [other witnesses represented

16 by Qualcomm’s counsel] for trial testimony on [specified dates]…” Nov. 19, 2018 email from D.

17 Matheson.

18 The FTC repeated its request on November 23, and again Qualcomm’s counsel

19 represented that they were investigating the witness’ availability. Finally, on Sunday November

20 25, Qualcomm’s counsel reported for the first time that they were “not authorized to accept trial

21 subpoenas” for Mr. Aberle and Mr. Steve Altman. Nov. 25 email from G. Bornstein (“on the

22 [November 23] call we confirmed that we would be making Eric Reifschneider, Michael Hartogs

23 and Irwin Jacobs available for trial . . . [o]n the call we stated that we were not then authorized to

24 accept trial subpoenas for Derek Aberle, Steve Altman and Paul Jacobs”). In response to the

25 FTC’s further inquiry on November 25, Qualcomm’s counsel announced for the first time on

26 November 26 that it does not represent Mr. Aberle and Mr. Steve Altman. The FTC is now in the

27 process of seeking to serve Messrs. Aberle and Altman, both residing in San Diego, with trial

28 subpoenas and will take the position that they should be commanded to attend trial. See Fed. R.

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1 Civ. P. 45(c).

2 Qualcomm Position5

3 Qualcomm has stated that it will make current employees appearing on the FTC’s witness

4 list available for trial, subject to reasonable arrangements regarding notice and scheduling.

5 Further, Qualcomm has repeatedly informed the FTC that it will seek the cooperation of former

6 employees but does not have the power to compel their attendance. Accordingly, Qualcomm

7 provided definitive responses with respect to former employees once it had them, making clear

8 that it continues to endeavor to obtain the agreement of other former employees.

9 In the FTC’s position above, the FTC incorrectly suggests that Qualcomm somehow has

10 hampered the FTC’s efforts to seek the trial attendance of former Qualcomm employees

11 Derek Aberle and Steve Altman. Between September and November, Qualcomm repeatedly

12 informed the FTC that, despite its ongoing efforts, Qualcomm had not been able to obtain the

13 agreement of Messrs. Aberle and Altman to appear at trial. Nothing prevented the FTC from

14 attempting to subpoena Messrs. Aberle and Altman during that period; Qualcomm merely

15 conveyed that it continued its efforts to obtain their agreement to appear voluntarily. The FTC

16 misleadingly states that “Qualcomm’s counsel announced for the first time on November 26 that

17 it does not represent Mr. Aberle and Mr. Steve Altman”. However, the FTC did not ask

18 Qualcomm’s counsel whether it represented Messrs. Aberle and Altman in connection with any

19 potential trial testimony until the day before, November 25, 2018. (Nov. 25, 2018 email from D.

20 Matheson (“Thanks for the information. Please confirm whether Cravath represents Mr. Aberle

21 and Mr. Steve Altman in connection with this matter.”).)6 Further, whether Qualcomm’s counsel

22 represented those individuals had no bearing on the FTC’s ability to seek their attendance by

23

24 5
The FTC provided a completely re-written version of its position on this issue at 11:46 p.m. on
the due date of this Joint Pretrial Statement, so Qualcomm was unable to fully respond to the
25 FTC’s position in a timely fashion.
6
26 The FTC refers to its own witness list in which the FTC stated that Messrs. Aberle and Altman
were “represented by Qualcomm’s counsel”. But that was not a representation by Qualcomm’s
27 counsel, and before November 25, the FTC never inquired about representation of Messrs. Aberle
or Altman, even though Qualcomm’s counsel informed the FTC that it had not yet been able to
28 secure either former employee’s attendance at trial.

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1 subpoena.

2 VIII. Exhibits, Schedules, Summaries

3 The Parties exchanged preliminary lists of exhibits other than solely for impeachment or

4 rebuttal on November 9, 2018, and exchanged lists of additional exhibits other than solely for

5 impeachment or rebuttal on November 21, 2018. On November 27, 2018, the Parties exchanged

6 lists of 450 trial exhibits other than solely for impeachment or rebuttal pursuant to the Court’s

7 October 24, 2018 Case Management Order. (See ECF No. 922 at 1.) The FTC’s Exhibit List is

8 attached as Exhibit D. Qualcomm’s Exhibit List is attached as Exhibit E. The Parties’ Joint

9 Exhibit List is attached as Exhibit F. Pursuant to Paragraphs D(1)(a) and D(1)(b) of the Court’s

10 Guidelines, which require the exchange and stamping of the Parties’ trial exhibits, the Parties

11 have agreed to deem stamped and exchanged any trial exhibits that were previously produced in

12 this action, and have stamped and exchanged all trial exhibits that were not previously produced

13 in this action. The Parties will deliver pre-marked exhibits listed in this Joint Pretrial Statement

14 to the Court on December 28, 2018, pursuant to Paragraph D(1)(c) of the Court’s Guidelines.

15 IX. Disputed Legal Issues

16 The following legal issues (or mixed issues of fact and law) are disputed:
17  Whether the alleged worldwide market for CDMA modem chips and alleged
18 worldwide market for “premium LTE” modem chips constitute properly defined
19 antitrust markets;
20  Whether Qualcomm had or has monopoly power in the alleged antitrust worldwide
21 markets for CDMA and “premium LTE” modem chips; and
22  Whether the FTC is entitled to injunctive and other equitable relief.
23 FTC’s Separate Statement of Disputed Legal Issues
24  Whether Qualcomm has held market power with respect to CDMA and premium LTE

25 modem chips;

26  Whether Qualcomm’s conduct is anticompetitive;

27  Whether Qualcomm’s conduct constitutes monopolization in violation of Section 5(a)

28 of the FTC Act (corresponding to a violation of Section 2 of the Sherman Act, 15

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1 U.S.C. § 2);

2  Whether through license and other agreements with its customers Qualcomm has

3 entered unreasonable restraints of trade in violation of Section 5(a) of the FTC Act

4 (corresponding to a violation of Section 1 of the Sherman Act, 15 U.S.C. § 1); and

5  Separate and apart from whether Qualcomm’s conduct constitutes unlawful

6 monopolization or unreasonable restraint of trade, whether the conduct violates

7 Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

8 Qualcomm’s Separate Statement of Disputed Legal Issues

9  Whether conduct that does not violate either Sections 1 or 2 of the Sherman Act, 15

10 U.S.C. §§ 1-2, may violate Section 5(a) of the FTC Act, 15 U.S.C § 45(a);

11  Whether Qualcomm had or has any obligation to make available exhaustive cellular

12 SEP licenses to manufacture or sell baseband processors pursuant to its commitments

13 to ETSI or to other cellular standards-development organizations;

14  Whether Qualcomm has any antitrust duty to deal with its baseband processor

15 competitors and, if so, whether Qualcomm has violated such a duty to deal;

16  Whether Qualcomm’s conduct is pro-competitive or supported by legitimate business

17 or economic justifications;

18  Whether the FTC has proven a violation of the FTC Act that is ongoing or likely to

19 recur; and

20  Whether, after balancing the equities and considering the public interest and other

21 equitable principles, the FTC is entitled to the injunctive and other equitable relief it

22 seeks pursuant to Section 13(b) of the FTC Act.

23 X. Further Discovery or Motions

24 The Parties currently do not contemplate further discovery or motions that must be

25 resolved prior to trial apart from motions in limine filed today, November 29, 2018, and potential

26 sealing motions relating to evidence and testimony to be presented at trial.

27 The Parties have completed briefing on the following motions. The Court took the

28 motions under submission on October 12, 2018 (ECF No. 900):

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1  FTC’s Motion To Exclude Expert Testimony of Dr. Edward A. Snyder;7

2  FTC’s Motion To Exclude Expert Testimony of Professor Aviv Nevo;8

3  Qualcomm’s Motion To Strike Portions of Rebuttal Expert Report of Dr. Robert

4 Akl;9 and

5  Qualcomm’s Motion To Exclude Expert Reports of Richard L. Donaldson.10

6 Pursuant to the Court’s October 24, 2018 Case Management Order (ECF No. 922 at 2),

7 the Parties filed simultaneous briefs regarding post-discovery evidence on October 31, 2018, 11

8 and simultaneous responsive briefs regarding post-discovery evidence on November 7, 2018.12

9 XI. Disputed Evidentiary Issues

10 Including but not limited to evidentiary issues raised in the Parties’ respective motions in
11 limine, the Parties identify the following evidentiary disputes:
12 A. FTC’s Statement of Disputed Evidentiary Issues
13 The FTC identifies the following evidentiary issues that it intends to raise at trial:
14  Joint Exhibit List
15 FTC’s Position
16 The Court has limited the parties to a maximum of 550 exhibits at trial: 150 per side, plus
17 250 exhibits to be introduced from an agreed-upon joint exhibit list. The parties have been unable
18 to agree on the purpose of the joint exhibit list and thus have been able to agree on only 126 joint
19 exhibits.
20 The FTC understands that the purpose of the joint exhibit list is to identify documents to
21 which neither party has a substantive objection, so that both parties have available at trial up to
22 250 documents from a joint list that are (i) admissible, and (ii) anticipated to be used with trial
23 witnesses. For example, some of Qualcomm’s contracts with OEMs were the subject of
24

25 7
ECF No. 788 (Motion); ECF No. 874 (Opposition); ECF No. 891 (Reply).
8
26 ECF No. 790 (Motion); ECF No. 873 (Opposition); ECF No. 889 (Reply).
9
ECF No. 797 (Motion); ECF No. 866 (Opposition); ECF No. 894 (Reply).
10
27 ECF No. 799 (Motion); ECF No. 868 (Opposition); ECF No. 896 (Reply).
11
ECF No. 928 (FTC’s Brief); ECF No. 929 (Qualcomm’s Brief).
28 12
ECF No. 932 (FTC’s Response Brief); ECF No. 933 (Qualcomm’s Response Brief).

  JOINT PRETRIAL STATEMENT
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1 deposition testimony during discovery. These documents are indisputably authentic, admissible,

2 and at trial will be the subject of either live testimony or designated video deposition testimony.

3 Qualcomm has refused to include such documents on the joint exhibit list, despite the fact that

4 Qualcomm has no substantive objection. Likewise, certain of Qualcomm’s 10-Ks may be used

5 with live witnesses at trial, yet Qualcomm has refused to include its own 10-Ks on a joint exhibit

6 list. Qualcomm asserts that it can oppose inclusion on a joint exhibit list any document that it

7 deems unfavorable to its positions, even if the document is plainly relevant and it has no

8 cognizable objection to the admission of the document. The FTC disagrees.

9 On November 8, the FTC proposed to Qualcomm candidates for a joint exhibit list

10 comprising a good-faith list of Qualcomm license and supply agreements with third parties that

11 had been identified by the parties in initial disclosures, and other indisputably admissible

12 documents (e.g., Qualcomm’s 10-Ks and commitment letters to SSOs). Qualcomm, on the other

13 hand, made no proposal regarding any joint exhibits, and did not even seek to meet and confer

14 regarding any joint exhibits, contrary to Qualcomm’s October 24 assertion to the Court that the

15 parties were “working on a joint exhibit list.” Tr. 5:17-18. (“we’re working on that, Your Honor

16 . . . we’re working on a joint exhibit list . . .”).

17 Qualcomm made no counter-proposals regarding joint exhibits until November 20, when

18 Qualcomm rejected essentially every document proposed by the FTC that was not a commercial

19 contract, and proposed filling the joint list entirely with (i) SSO-related documents proposed by

20 Qualcomm and (ii) commercial agreements (many of which are of little to no relevance to any

21 issue in the case).13 In a good-faith effort at compromise, the FTC accepted dozens of

22 Qualcomm’s proposed additions, including many of Qualcomm’s proposed documents related to

23 standard-setting. But the FTC refused to accede to all of Qualcomm’s repetitive license

24 agreements, as that would have resulted in a “joint list” consisting of essentially zero documents

25 proposed by the FTC except for commercial contracts acceptable to Qualcomm.

26
13
27 Qualcomm proposed adding dozens of licenses to the joint exhibit list with small companies
that were not identified in its initial disclosures, including companies that either never made
28 royalty payments or made de minimis payments.

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1 The FTC proposed to Qualcomm a number of alternative approaches (including but not

2 limited to offers to stipulate to the content of repetitive documents) that would limit the total

3 number of exhibits introduced at trial to a maximum of 550, while ensuring that both parties are

4 able to introduce unobjectionable evidence through trial witnesses. But Qualcomm has rejected

5 all of the FTC’s proposals, and flatly refused to add to the “joint” list clearly admissible

6 documents proposed by the FTC that are non-prejudicial and helpful to both sides. Thus, the

7 “joint” exhibit list the parties are submitting to the Court contemporaneously with this filing

8 consists of little more than: (i) a subset of the license agreements proposed by the FTC on

9 November 8; (ii) license agreements proposed by Qualcomm on November 21; (iii) other

10 Qualcomm-proposed documents such as standard-setting-related documents; and (iv) documents

11 common to both parties’ individual lists. The “joint” list excludes numerous important

12 commercial contracts, it excludes numerous license agreements the FTC proposed that will be the

13 subject of trial testimony, and it excludes uncontroversial documents such as Qualcomm’s 10-Ks

14 that could assist both parties’ trial presentations.

15 The FTC requests that the Court adopt one of the FTC’s two proposals, both of which

16 Qualcomm has rejected:

17 (1) The FTC’s preferred approach: The current joint exhibit list identifies 126 joint

18 exhibits. The FTC proposes that the parties each propose 62 additional joint exhibits that it

19 believes in good faith are not subject to a serious dispute regarding admissibility (half of the

20 remaining slots for each party). The FTC intends to propose adding to the joint exhibit list

21 admissible documents such as: Qualcomm’s supply agreements; Qualcomm’s 10-K filings;

22 Qualcomm’s license agreements; and final materials submitted to or approved by Qualcomm’s

23 Board of Directors. The FTC is prepared to immediately present a list of such documents to the

24 Court.

25 Qualcomm has suggested that the FTC’s approach would evade the Court’s exhibit limits,

26 but this is untrue: many of the documents the FTC proposes to add to the joint exhibit list

27 currently appear on the FTC’s pretrial list of 450 potential exhibits, and the FTC will not replace

28 documents on its pretrial list of 450. The FTC will simply have less than 450 documents on its

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1 pretrial list (from which it can introduce a maximum of 150).

2 (2) In the alternative: each party identifies 125 proposed joint exhibits that it believes

3 are not subject to a serious dispute regarding admissibility. The parties will eliminate duplicates

4 from the list (without replacing an eliminated duplicate), and the parties promptly provide to the

5 Court the resulting list of 250 or fewer joint exhibits.

6 If the above proposals are not acceptable to the Court, the FTC requests that the Court

7 order an alternative approach to exhibits, in recognition of the fact that the FTC bears the burden

8 of proof and thus may have a greater need than Qualcomm to introduce non-repetitive

9 documentary evidence. For example, the Court could order that each side may introduce no more

10 than 275 exhibits. This would limit the total number of exhibits introduced at trial to 550,

11 without allowing Qualcomm to restrict the FTC to only 150 documents, including documents of

12 undisputed admissibility.14

13 Qualcomm’s Position
14 The FTC has failed to provide good-faith cooperation with Qualcomm in creating a
15 mutually agreeable joint exhibit list, instead treating the joint exhibit list as an extension of its
16 own list. Contrary to the purpose of a joint exhibit list, which should include documents that are
17 both admissible and potentially useful to both parties—in other words, documents that are joint
18 exhibits—the FTC has sought to construct a joint exhibit list that includes only documents that it
19 believes support the FTC’s position while denying Qualcomm the ability to add documents that
20 support its defense. For example, the FTC proposed to include on the joint exhibit list over 100
21 Qualcomm agreements selected by the FTC, but then refused to include on the joint exhibit list
22 the vast majority of a similar number of license agreements that had been proposed by
23 Qualcomm, claiming that they are “repetitive” or unimportant. But the FTC cannot reasonably
24
14
Qualcomm asserts that the FTC included on its November 8 list “Complaints filed against
25 Qualcomm,” which Qualcomm claims are inadmissible. This is misleading. The FTC proposed
26 joint exhibits comprising discovery responses including Qualcomm’s Answers to Complaints,
with Complaints themselves included only to the extent required to understand Qualcomm’s
27 Answers. In any event, Qualcomm rejected the proposal and the FTC has abandoned it, thus it
provides no excuse for Qualcomm’s refusal to agree to exhibits that indisputably are admissible,
28 such as Qualcomm’s component supply agreements with OEMs.

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1 take the position that its preferred agreements are proper joint exhibits, whereas Qualcomm’s

2 preferred agreements are not. The FTC’s assertion that Qualcomm seeks “to restrict the FTC to

3 only 150 documents” is accordingly baseless; Qualcomm agreed to a large number of the joint

4 exhibits proposed by the FTC, on the understanding that the FTC would agree to a similar number

5 of documents proposed by Qualcomm. The FTC refused to reciprocate and insisted that its

6 proposed exhibits should be included on the joint list while most of Qualcomm’s proposed

7 exhibits would be excluded.

8 Contrary to the FTC’s professed understanding that the joint exhibits are meant to include

9 “documents as to which neither party has a substantive objection”, the FTC’s basis for rejecting

10 Qualcomm’s proposed license agreements was not an evidentiary objection—indeed, it could not

11 object consistent with its current assertion (with which Qualcomm agrees) that license agreements

12 “are not subject to a serious dispute about admissibility”. Rather, the FTC stated that it believed

13 that the license agreements proposed by Qualcomm “would be of no benefit to the Court”—in

14 other words, it hoarded spots on the joint exhibit list for documents that it believed supported its

15 theory of the case, rather than Qualcomm’s. (Nov. 24, 2018 email from D. Matheson.) The

16 FTC’s suggestion in this Joint Pretrial Statement that the FTC rejected Qualcomm’s proposal

17 because they were with “small companies” or “repetitive” of other license agreements only

18 confirms the FTC’s goal of excluding from the joint exhibit list documents that would benefit

19 Qualcomm. Qualcomm offered license agreements precisely because they demonstrate that

20 multiple companies have recognized the value of Qualcomm’s portfolio, including at times when

21 they clearly had limited or no demand for Qualcomm’s baseband processors. And, in return for

22 the FTC’s acceptance of those license agreements, Qualcomm proposed agreeing to the vast

23 majority of the agreements that had been proposed by the FTC. The FTC unreasonably refused to

24 compromise in the fashion proposed by Qualcomm.

25 Further illustrating how the FTC has sought to use the joint exhibit as merely an extension

26 of its own exhibit list, the FTC has proposed including as “joint” exhibits documents that would

27 be useless to Qualcomm, such as Complaints and Answers filed in this action, in the MDL action

28 and in the coordinated Southern District of California case between Qualcomm and Apple and its

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1 contract manufacturers. And the FTC now proposes to force the addition of other “joint” exhibits

2 that could solely benefit the FTC. For example, the FTC proposes that the Court allow it to

3 include as “joint” exhibits Qualcomm’s Form 10-Ks. The FTC has said it believes that

4 statements in those documents are admissible against Qualcomm, but has not agreed that their

5 contents would be admissible against the FTC and has not explained why it believes the 10-Ks

6 and other documents like them could be “helpful to both sides”.15

7 As demonstrated by the FTC’s fundamentally unfair (and incorrect) assertion of “greater

8 need than Qualcomm to introduce non-repetitive documentary evidence”, the FTC merely seeks

9 to evade the numerical limits the Court has placed (without objection by the FTC) on the

10 introduction of exhibits from each party’s individual exhibit list. The FTC’s conduct is

11 inconsistent with the purpose of the joint exhibit list; as the Court explained at the October 24,

12 2018 Case Management Conference, the Court allowed the joint exhibit list to “create an

13 incentive that you reach agreement [on exhibits that may be admitted] and not fight”. (Tr. 20:14-

14 17.) Contrary to this goal, both of the FTC’s proposed approaches would result in the joint

15 exhibit list not being jointly agreed at all. Under the FTC’s proposed option (1), the Parties

16 would add up to 134 new exhibits that the Parties have not agreed on, many of which have never

17 appeared on either Party’s individual exhibit lists. Option (2) would apparently undo the Parties’

18 agreement on existing joint exhibits entirely and would simply add 250 exhibits to the Parties’

19 individual exhibit lists. The FTC has provided no good cause for the Court to alter its

20 October 24, 2018 Order or for undoing the Parties’ agreed joint exhibit list incorporated in the

21 Joint Pretrial Statement after many weeks of work, and the FTC should not be rewarded for its

22 lack of cooperation in identifying joint exhibits. The joint exhibits the Parties have agreed on

23
15
The FTC’s description of the Parties’ negotiations regarding a joint exhibit list is incorrect.
24 The FTC does not mention that, prior to November 8, the Parties had discussed principles that
would inform creation of the joint exhibit list, such as agreeing to specific categories of
25 documents such as license agreements. (See Oct. 17 Joint Case Management Statement at 4 (ECF
26 No. 914) (reporting that the Parties “have met and conferred and have also agreed in principle to
identify documents for inclusion on a joint exhibit list”).) The FTC did not pursue further
27 discussions on this topic, but instead unilaterally served a purported “joint” exhibit list that (as
discussed above) contained a very large number of exhibits that Qualcomm is unable to rely upon
28 and that appropriately belonged on the FTC’s individual list.

  JOINT PRETRIAL STATEMENT
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1 should be maintained, and the FTC should not be permitted to identify any new “joint” exhibits to

2 which Qualcomm has not agreed.

3  Evidence of Post-Discovery Facts

4 FTC’s Position

5 For the reasons set forth in briefs the FTC filed on October 31 and November 7, 2018, the

6 FTC intends to object at trial to the use of cherry-picked documents from Qualcomm’s own

7 confidential files that were created after the March 30, 2018 fact discovery deadline, and to the

8 use of any documents not timely produced. (See ECF Nos. 928, 932 (FTC briefing on post-

9 discovery evidence).)

10 Qualcomm’s Position

11 For the reasons set forth in briefs Qualcomm filed on October 31 and November 7, 2018,

12 Qualcomm opposes the FTC’s request that the Court ignore evidence of events that occurred after

13 the close of fact discovery. (ECF Nos. 929, 933.) Such evidence is directly relevant to whether

14 any violation of the FTC Act is “ongoing or likely to recur”, which the FTC must prove to obtain

15 an injunction under Section 13(b) of the FTC Act. The FTC’s accusation that Qualcomm seeks to

16 use “cherry-picked documents” is untrue: Qualcomm made clear to the FTC months ago that it

17 believed evidence of current market conditions, including events occurring after the close of fact

18 discovery, would be necessary in a case seeking prospective injunctive relief, but the FTC

19 repeatedly rebuffed Qualcomm’s efforts to discuss a process for refreshing the discovery record.

20 It would be error for the Court to consider issuing a Section 13(b) injunction while disregarding

21 events that have occurred after the close of fact discovery that establish current market conditions.

22  Certain Witnesses

23 FTC’s Position

24 Qualcomm has identified Mr. Robert Mansfield (of Apple) and Mr. Raj Varadarajan (of

25 Boston Consulting Group) on its witness list. Qualcomm did not identify Mr. Mansfield or Mr.

26 Varadarajan in its initial disclosures or in a January 31, 2018 letter updating these disclosures, and

27 thus Qualcomm is precluded from presenting testimony at trial from these witnesses. The Court

28 has denied requests for their out-of-time depositions. See July 20, 2018 Order, ECF No. 783 at 2.

  JOINT PRETRIAL STATEMENT
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1 The FTC is submitting a motion in limine addressing this issue.16

2 Qualcomm’s Position17

3 Contrary to the FTC’s suggestion, the Court’s July 20, 2018 Order did not address

4 Rule 37(c) or determine whether Messrs. Varadarajan or Mansfield could testify at trial, but

5 merely precluded the possibility of out-of-time depositions. (ECF No. 783.) Qualcomm

6 identified Messrs. Varadarajan and Mansfield as likely trial witnesses on June 18, 2018, to rebut

7 aspects of the FTC’s case that the FTC did not disclose until after the close of fact discovery.

8 Both the FTC and Qualcomm served Rule 26 disclosures identifying witnesses from the Boston

9 Consulting Group (Mr. Varadarajan’s employer) and Apple (Mr. Mansfield’s employer), and both

10 sides’ disclosures identified third-party witnesses by affiliation rather than by name. No

11 applicable deadline required Qualcomm to provide a final list of witnesses it may call at trial prior

12 to the witness lists Qualcomm served on November 9 and November 21, 2018 pursuant to the

13 Court’s Guidelines and the Parties’ agreements, and no rule requires Qualcomm to place rebuttal

14 witnesses on its witness list at all. (See, e.g., Guidelines for Final Pretrial Conferences in Bench

15 Trials, Paragraph B(7) (requiring identification of witnesses to be called at trial “other than solely

16 for impeachment or rebuttal”).) Regardless, Qualcomm’s disclosure of Mr. Varadarajan and Mr.

17 Mansfield on June 18, 2018 should be treated pursuant to Rule 37(c) as substantially justified or

18 harmless—because Qualcomm identified them to respond to and rebut belated disclosures by the

19 FTC. Qualcomm will oppose the FTC’s motion to exclude testimony by Messrs. Varadarajan

20 and Mansfield.

21 Substantial justification. Each witness is being called to address matters that the FTC did

22 not disclose until after fact discovery. In fact, Mr. Varadarajan’s testimony is necessary to

23 address a declaration by Mr. Varadarjan that the FTC produced to Qualcomm after the close of

24

25 16
The FTC objects to Qualcomm’s inclusion in this joint pretrial statement of lengthy arguments
26 about disputes that will be the subject of motions in limine, which are page limited.
17
The FTC states that it objects to the inclusion of argument about matters that are the subject of
27 motions in limine, but the FTC did not identify its motions in limine (or cut back its own
argument) until after 7:00 p.m. on the day this Statement was due and did not make that objection
28 until 11:46 p.m.—literally minutes before this Statement was due.

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1 fact discovery. The FTC seeks to use this belated declaration to permit the admission at trial of

2 documents created by Mr. Varadarajan or others at the Boston Consulting Group (“BCG”). But

3 the FTC improperly seeks to deny Qualcomm the opportunity to introduce testimony by

4 Mr. Varadarajan concerning the very BCG documents the FTC will seek to have admitted.

5 Likewise, Mr. Mansfield’s testimony is necessary to address information in interrogatory

6 responses that the FTC served after the close of fact discovery, and only after an Order by Judge

7 Cousins compelling it to do so. In those post-discovery interrogatory responses, the FTC for the

8 first time identified specific Apple products for which it contended that Apple could have used

9 baseband processors supplied by Qualcomm’s competitors. Mr. Mansfield has unique, important

10 knowledge regarding Apple’s selection of baseband processors for those products, and

11 Qualcomm expects his trial testimony to rebut the FTC’s contentions. The FTC seeks to deny the

12 Court crucial testimony concerning whether Apple actually viewed these products as contestable

13 by Qualcomm competitors, which is directly relevant to whether Qualcomm’s alleged conduct

14 foreclosed competition.

15 Harmlessness. Any omission also is harmless because the FTC received productions of

16 documents from these two individuals’ files during fact discovery, it took testimony from

17 Mr. Varadarajan during its pre-Complaint investigation, and it has access to information about

18 Mr. Mansfield through its common interest agreement with Apple (including access to testimony

19 Mr. Mansfield gave in the coordinated Southern District action). The FTC will not be unfairly

20 prejudiced by the Court’s admission of testimony of which the FTC has had notice and that

21 concerns the FTC’s own contentions.

22  Summary Exhibits

23 FTC’s Position

24 Qualcomm has disclosed several proposed summary exhibits. The FTC intends to object

25 to summary exhibits presented by Qualcomm at trial to the extent they summarize underlying

26 materials that are not admissible (such as late-produced documents) are incomplete or otherwise

27 do not fairly represent underlying materials, or are otherwise inconsistent with Fed. Rule Evid.

28 1006 or applicable case law. See United States v. Rizk, 660 F.3d 1125, 1130 (9th Cir. 2011)

  JOINT PRETRIAL STATEMENT
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1 (citing Amarel v. Connell, 102 F.3d 1494, 1516 (9th Cir. 1996)); Davis & Cox v. Summa Corp.,

2 751 F.2d 1507, 1516 (9th Cir. 1985). Among other things, the “summaries” contain information

3 that does not appear in the source material.

4 The FTC will also object if Qualcomm seeks to introduce any summary exhibit through a

5 witness who cannot be cross-examined about its preparation. See Frank Music Corp. v. Metro–

6 Goldwyn–Mayer, Inc., 772 F.2d 505, 515 n. 9 (9th Cir.1985) (stating that cross-examination gives

7 the opponent an opportunity to reveal any inaccuracies or omissions in the summary).

8 Qualcomm’s Position

9 Qualcomm disclosed summary trial exhibits pursuant to Federal Rule of Evidence 1006,

10 which permits the use of “a summary, chart or calculation to prove the content of voluminous

11 writings . . . that cannot be conveniently examined in court”, and has identified the materials

12 underlying the exhibits. The FTC has not identified any specific objections to Qualcomm’s

13 summary exhibits (such as what information it believes “does not appear in the source material”),

14 and its general objections set forth above are contrary to Rule 1006 and the caselaw it cites. See,

15 e.g., United States v. Rizk, 660 F.3d 1125, 1130 (9th Cir. 2011) (requiring that (1) the materials

16 underlying a Rule 1006 summary be “admissible in evidence”, and (2) the materials be “made

17 available to the opposing party for inspection”); id. at 1131 n.2 (overruling objection based on

18 contention that summaries did not include certain information the objector believed relevant,

19 which “goes to their weight rather than their admissibility”). Contrary to the FTC’s suggestion,

20 Frank Music does not require that a summary exhibit be introduced through a witness who may

21 be cross-examined about its preparation, and even overruled an objection that a summary was

22 created by the party and not independently “verified”, on the ground that Rule 1006 imposes no

23 such requirements. See Frank Music, 772 F.2d at 515 n.9. Qualcomm has produced the

24 underlying materials to the FTC, so the FTC has ample opportunity to challenge the accuracy of

25 the summaries. Id. (“The requirements for Rule 1006 are met when the trial judge ascertains that

26 the underlying documents are made available for inspection.”).

27 The FTC also disclosed summary exhibits pursuant to Rule 1006, and Qualcomm reserves

28 the right to lodge objections to the FTC’s summaries on grounds permitted by Rule 1006 and

  JOINT PRETRIAL STATEMENT
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1 applicable caselaw by the deadline for exchanging objections set forth above.

2  Use of Videotaped Deposition Testimony at Trial

3 FTC’s Position

4 Qualcomm has designated deposition testimony from witnesses that are within 100 miles

5 from the place of trial, or are otherwise not “unavailable” within the meaning of Fed. R. Civ. P.

6 32(4). Based on the information currently available to the FTC, at least two witnesses on

7 Qualcomm’s witness list, Chris Johnson and Taraneh Maghame, are located within 100 miles of

8 the place of trial. To the extent Qualcomm seeks to play such deposition testimony in lieu of live

9 testimony from available witnesses, the FTC will object pursuant to Fed. R. Civ. P. 32.

10 Qualcomm has also designated deposition testimony from witnesses who testified as

11 corporate representatives under Federal Rule of Civil Procedure 30(b)(6), including Chris

12 Johnson, Taraneh Maghame, Ranae McElvaine, Ilkka Rahnasto, Dirk Weiler, and Martin Zander.

13 The FTC intends to object to any Rule 30(b)(6) testimony offered at trial that is not based on

14 personal knowledge. See Fed. Rule Evid. 602. The fact that the FTC took discovery depositions

15 pursuant to Rule 30(b)(6) does not waive Rule 602; nor was the FTC obligated to raise objections

16 about Qualcomm’s improper use of Rule 30(b)(6) testimony at trial during discovery.

17 Qualcomm’s Position

18 The FTC did not identify which depositions it believed were subject to its Rule 32(a)

19 objections until weeks after Qualcomm served designations of those depositions. With respect to

20 Mr. Johnson, the deponent pursuant to Rule 30(b)(6) was his employer, Bain & Company, not

21 Mr. Johnson personally. Bain is headquartered in Boston, which is not within 100 miles of the

22 Court. With respect to Ms. Maghame, Qualcomm understands that the FTC has been in

23 discussions with her counsel regarding waiving any objection to the use of her deposition, to

24 avoid burden to her third-party employer Via Licensing. Qualcomm believes that it would be

25 efficient to the Court and less burdensome to third parties for the FTC to forego any objections

26 based on Rule 32(a) for these witnesses. However, Qualcomm has reserved the right to call

27 Ms. Maghame or Mr. Johnson live at trial if the FTC stands on its objections and they are

28 sustained by the Court, and the witnesses are included on Qualcomm’s live witness list.

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1 The FTC’s objections to testimony provided by witnesses pursuant to Rule 30(b)(6) are

2 misplaced because that Rule allows an organizational entity such as a corporation to testify

3 through a representative concerning “information known or reasonably available to the

4 organization”. The FTC has cited no law excluding such deposition testimony at trial on the

5 ground that it is “not based on personal knowledge” of the corporate representative rather than of

6 the organization being deposed. The FTC belatedly raised its objection based on the corporate

7 representatives’ lack of personal knowledge months after discovery closed, even though the FTC

8 itself took depositions pursuant to Rule 30(b)(6). To the extent that the Court is inclined to

9 entertain the FTC’s objections, the Court should consider such objections in the context of

10 particular testimony that is actually offered by Qualcomm at trial.

11  Testimony of Dr. Bertram Huber

12 FTC’s Position
13 Qualcomm has indicated that it intends to present testimony from Dr. Bertram Huber at
14 trial. At deposition, Dr. Huber testified that his opinions are limited to his critique of the FTC’s
15 experts’ positions “specifically vis-a-vis the ETSI IPR Policy.” Aug. 8, 2018 Deposition of Dr.
16 Bertram Huber at 57:16-58:7. Dr. Huber attended ETSI meetings and should not be able to
17 testify to his recollections of those meetings as a percipient witness. See Fed. R. Civ. P. 26; Fed.
18 R. Evid. 702.
19 Qualcomm’s Position
20 Dr. Huber is an expert on the development of cellular standards, the ETSI IPR Policy and
21 industry practice and understanding relating thereto. The FTC did not move to exclude any
22 portion of Dr. Huber’s expert testimony by August 30, 2018, the deadline for the Parties to file
23 motions to exclude expert testimony. (ECF No. 678.) Further, each party was limited to two
24 motions to exclude expert testimony, and the FTC filed two such motions, neither relating to
25 Dr. Huber. (See ECF Nos. 788, 790.) The FTC should not be permitted to evade the Court’s
26 scheduling order and numerical limit, without leave from the Court, by raising at trial a broad
27 objection to the scope of Dr. Huber’s expert testimony. In any event, the FTC’s objection is not
28 well-taken. Aside from the fact that Dr. Huber’s experience is not the sole basis for his expert

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1 testimony, Federal Rule of Evidence 702 expressly permits an expert to testify on the basis of his

2 “experience” (in addition to the other bases for Dr. Huber’s testimony), and Dr. Huber is qualified

3 to offer expert testimony on the topics addressed by his expert report, as he has done in several

4 other cases. E.g., TCL Commc’n Tech. Holdings, Ltd. v. Telefonaktiebolaget LM Ericsson, No.

5 8:14-CV-00341 JVS-DFMx (C.D. Cal.); Evolved Wireless, LLC v. Apple, Inc., No. 15-CV-542-

6 SLR-SRF (D. Del.); In the Matter of Certain 3G Mobile Handsets & Components Thereof, Inv.

7 No. 337-TA-613 (ITC). Qualcomm reserves the right to oppose any objection to Dr. Huber’s

8 testimony on these or any other grounds.

9  Declaration and Expert Report of Bénédicte Fauvarque-Cosson

10 FTC’s Position
11 Qualcomm’s exhibit list includes the declaration and expert report of Ms. Bénédicte
12 Fauvarque-Cosson.18 The list suggests that Qualcomm will not seek to introduce the declaration
13 and report through a sponsoring witness, but instead will request that these materials be
14 considered under Fed. R. Civ. P. 44.1. Rule 44.1 is not a rule of evidence and cannot be used to
15 establish a basis for admission of an exhibit at trial. To the extent that the Court finds it necessary
16 to consider issues of foreign law, the FTC reserves its rights to present material appropriate for
17 consideration on such issues, including Ms. Fauvarque-Cosson’s deposition testimony, and other
18 evidence of the content of foreign law.
19 Qualcomm’s Position
20 The FTC has known that Qualcomm may seek to submit the expert report of
21 Prof. Fauvarque-Cosson pursuant to Rule 44.1 since May 11, 2018, when Qualcomm filed a
22 Notice of Intent to Raise Issues of Foreign Law that identified her expert report. (ECF No. 737.)
23 Further, in opposing Qualcomm’s Motion to Take a Trial Deposition of Prof. Fauvarque-Cosson
24 before she became a judge of the Conseil d’État of France, the FTC argued that Qualcomm would
25 not suffer significant prejudice without her testimony because “under Rule 44.1, the Court may
26 18
Prof. Fauvarque-Cosson was retained by Qualcomm as an expert witness and was deposed on
27 August 16, 2018. The Court denied Qualcomm’s Motion to take a trial deposition of
Prof. Fauvarque-Cosson. See September 21, 2018 Order Denying Qualcomm’s Motion for Leave
28 to Take the Trial Deposition of an Imminently Unavailable Expert Witness, ECF No. 865.

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1 consider any relevant material or source in determining foreign law, whether or not it is admitted

2 into evidence”. (ECF No. 863-2 at 7.) The FTC purports to reserve the right to submit other

3 materials for consideration under Rule 44.1, but it still has not identified any materials or

4 deposition testimony it would seek to submit. Qualcomm reserves the right to object to any

5 materials that the FTC has not timely disclosed.

6  Documents Subject to a Request for Judicial Notice

7 FTC’s Position

8 Qualcomm’s exhibit list includes documents containing the hearsay statements of third

9 parties, including responses to Korea Fair Trade Commission questionnaires submitted by third

10 parties. On its exhibit list, Qualcomm suggests that it will not seek to introduce these documents

11 through a sponsoring witness, but instead will request pursuant to Fed. R. Evid. 201 that the Court

12 take judicial notice of their contents. Qualcomm has not identified the specific facts that it will

13 ask the Court to judicially notice. The FTC will object to the admission, through judicial notice or

14 otherwise, of any disputed statements made out of court by third parties for the truth of the matter

15 asserted. Such statements are not appropriate for judicial notice under Fed. R. Evid. 201(b), which

16 provides that a “court may judicially notice a fact that is not subject to reasonable dispute because

17 it … is generally known within the trial court’s territorial jurisdiction; or … can be accurately and

18 readily determined from sources whose accuracy cannot reasonably be questioned.” See also

19 Court’s Order Granting in Part and Denying in Part Motion to Dismiss and/or Strike, Case No.

20 17-MD-02773-LHK, ECF No. 175 at 16-17 (denying request to take judicial notice of facts in

21 Apple’s Redacted First Amended Complaint in Apple Inc. v. Qualcomm Inc., S.D. Cal. Case No.

22 17-CV-00108, Dkt. No. 83 where Qualcomm disputed facts contained in the complaint). The

23 Court’s judicial notice of particular undisputed facts in a document does not render other facts in

24 the document appropriate for judicial notice.

25 Qualcomm’s Position

26 The FTC’s objection to the referenced submissions to the Korea Fair Trade Commission is

27 misplaced because the Court already took judicial notice of the submissions in connection with its

28 decision on the FTC’s Motion for Partial Summary Judgment, without objection by the FTC.

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1 (ECF No. 931 at 10.) In those submissions, Qualcomm’s baseband processor competitors

2 reported having no licenses (or, in one instance, a single license) to cellular SEPs. Those

3 statements are not barred by the rule against hearsay at least because they are contrary to the

4 proprietary or pecuniary interests of those companies (Fed. R. Evid. 804(b)(3)(A)), many of

5 which have claimed that licensing baseband processor suppliers is industry practice among

6 holders of cellular SEPs or have claimed that they have been harmed by the lack of a license to

7 Qualcomm’s cellular SEPs. Further, the FTC has not shown that those statements are subject to

8 reasonable dispute after having full discovery of the companies that submitted those statements.

9  Testimony the FTC Asserts Is Improper Lay Opinion

10 FTC’s Position
11 The FTC is submitting a motion in limine seeking an order precluding any fact witness
12 testimony relating to the importance or value of Qualcomm’s patent portfolio, or how
13 Qualcomm’s technical contributions or innovations compare to those of other licensors, on the
14 grounds that such testimony would constitute improper opinion testimony by a lay witness. See
15 Fed. Rule Evid. 701.
16 Qualcomm’s Position
17 The FTC cannot establish that any testimony to be offered by Qualcomm (1) would
18 constitute “opinion testimony” or (2) would be barred by Federal Rule of Evidence 701, which
19 permits opinion testimony by a lay witness. The FTC apparently seeks to prevent Qualcomm
20 from introducing important testimony demonstrating the importance of its patent portfolio and its
21 innovations to cellular and non-cellular technologies. Such testimony does not constitute
22 improper lay testimony, and Qualcomm will oppose the FTC’s attempt to exclude it.
23  Topics the FTC Asserts Are Related to a Claim of Privilege
24 FTC’s Position

25 The FTC is submitting a motion in limine seeking an order excluding evidence concerning

26 Qualcomm’s internal valuation of its patents on the grounds that Qualcomm withheld discovery

27 on this topic on privilege grounds.

28

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1 Qualcomm’s Position

2 As Qualcomm indicated when the FTC previously challenged Qualcomm’s claim of

3 privilege over the patent ratings. (ECF No. 734 at 5.) Qualcomm will offer testimony based on

4 witnesses’ own experience and knowledge, not any evidence related to or informed by the patent

5 ratings. Qualcomm will oppose the FTC’s motion in limine.

6 B. Qualcomm’s Statement of Disputed Evidentiary Issues

7 Qualcomm identifies the following evidentiary issues that it understands to be disputed by

8 the FTC.

9  Exclusion of Evidence Provided by Huawei

10 Qualcomm’s Position
11 Qualcomm will file a motion in limine to exclude testimony and documents provided by
12 Huawei Technologies, Co. and its employees. Huawei, headquartered in China, is a licensee of
13 Qualcomm, a competing baseband processor supplier, and a major competitor of Qualcomm in
14 the development of standardized technology for 5G. In this case, Huawei refused to produce
15 documents in response to a subpoena served by Qualcomm on a U.S. subsidiary or in response to
16 Letters of Request for International Judicial Assistance issued by the Court. It voluntarily
17 produced only a small number of cherry-picked documents and completely excluded any relevant
18 internal documents about its licensing negotiations with Qualcomm.19 At the FTC’s request,
19 however, Huawei voluntarily made witnesses available for deposition testimony, which the FTC
20 has designated for submission at trial. During the discovery period, Qualcomm moved to strike
21 Huawei witnesses from the FTC’s Rule 26 disclosures based on its failure to provide meaningful
22 discovery, and Judge Cousins denied Qualcomm’s request “without prejudice to refiling as a
23 renewed motion to strike or motion in limine after discovery closes”. (ECF No. 537.) It would be
24 fundamentally unfair to permit the FTC to rely on testimony from witnesses that refused to
25 produce anything but cherry-picked documents and that Qualcomm therefore did not have the
26 19
The FTC’s comparison to another third party, Nokia, is inapt, because (to Qualcomm’s
27 knowledge) Nokia did not refuse to produce broad swaths of documents in response to any
requests by the FTC.
28

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1 opportunity to meaningfully cross-examine.20

2 FTC’s Position

3 The FTC will oppose Qualcomm’s motion. Qualcomm has not identified the specific

4 Huawei testimony it seeks to exclude or any specific way in which it has been prejudiced by the

5 discovery voluntarily provided by Huawei in this action. Like other third parties located outside

6 of the United States, Huawei voluntarily produced documents beyond those Qualcomm could

7 have obtained through the Hague Convention process. See Jan. 31, 2018 Joint Discovery

8 Statement, ECF No. 524 at 3.21 The fact that Huawei did not perform a document search to

9 Qualcomm’s liking as a foreign third party is not a valid basis for excluding testimony from

10 Huawei witnesses altogether. Moreover, Qualcomm’s claim that it did not have the “opportunity

11 to meaningfully cross-examine” Huawei witnesses is unfounded. Huawei is a customer and

12 licensee of Qualcomm’s, and Qualcomm is equally knowledgeable regarding its dealings with

13 Huawei.

14  Exclusion of Evidence Provided by LG

15 Qualcomm’s Position
16 Qualcomm will file a motion in limine to exclude a document purporting to reflect the
17 “voluntary” written responses of LG Electronics, Inc. LG is a licensee of Qualcomm that is
18 headquartered in the Republic of Korea. LG’s responses are inadmissible hearsay, and LG, a
19 Qualcomm licensee with a direct financial interest in this case, has unfairly denied Qualcomm
20 any opportunity to cross-examine any LG witness regarding its “voluntary” responses or to
21 defend itself against LG’s self-selected and self-serving written statements. LG’s “voluntary”
22 responses should therefore be excluded pursuant to Federal Rules of Evidence 403 and 802.
23 FTC’s Position
24

25 20
The FTC’s assertion below that Qualcomm had enough basis to examine the witnesses because
26 Huawei is a Qualcomm customer and licensee is frivolous; Qualcomm was deprived of the
internal Huawei communications showing Huawei’s true views and positions.
21
27 For example, Qualcomm has stated it will present witnesses and testimony from Nokia at trial,
which—similar to Huawei—is beyond the subpoena power of the Court and voluntarily produced
28 a limited set of documents in response to the Parties’ requests.

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1 The FTC will oppose Qualcomm’s motion. Qualcomm’s claim that it has been unfairly

2 denied an opportunity to examine LG witnesses is a mischaracterization of the record. Both

3 Qualcomm and the FTC had an equal opportunity to submit questions to, and request documents

4 from LG. LG witnesses responded to questions posed by both Parties, and produced certain

5 documents requested by Qualcomm, to the extent permitted by the Korean Central Authority.

6  Exclusion of Boston Consulting Group Documents

7 Qualcomm’s Position

8 To the extent Qualcomm is not allowed to present testimony from Mr. Varadarajan at trial

9 (an issue covered in further detail above), Qualcomm will file a motion in limine to exclude

10 documents appearing on the FTC’s exhibit list that were generated by Mr. Varadarajan’s

11 employer, Boston Consulting Group, as inadmissible hearsay and based on Federal Rule of Civil

12 Procedure 37(c). The FTC apparently will request admission of the documents on the basis of a

13 conclusory and boilerplate declaration provided by Mr. Varadarajan, who participated in

14 generating some but not all of the documents. The FTC, however, did not obtain nor disclose

15 Mr. Varadarajan’s declaration to Qualcomm until after the close of fact discovery and (as noted

16 above) has opposed Qualcomm’s request for Mr. Varadarajan to testify at trial concerning the

17 documents the FTC will seek to admit. The FTC should not be permitted to sandbag Qualcomm

18 with a late declaration while denying it the opportunity to present testimony concerning the BCG

19 documents.

20 Indeed, the FTC has asserted that it “obtained the declaration from BCG in lieu of seeking

21 the Court’s leave to conduct an out-of-time deposition”, but at no time did the FTC raise the

22 possibility of seeking an out-of-time deposition of BCG with Qualcomm or with the Court. Nor

23 did the FTC advise Qualcomm or the Court that it supposedly faced “significant delay on BCG’s

24 part in obtaining information”, as it had claimed in prior drafts of this Joint Pretrial Statement.

25 The FTC now argues below that Qualcomm “had every opportunity” to seek BCG testimony

26 before the deadline; so too did the FTC have every opportunity to seek such deposition or

27

28

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1 declaration before the deadline. The FTC simply chose to let the discovery cut-off expire.22

2 After it produced the declaration, however, the FTC argued that any further deposition of BCG or

3 Mr. Varadarajan would be prejudicial because the FTC “was bound by the Court’s discovery

4 orders, which did not permit it to continue to take discovery after March 30 in search of

5 incrementally better witnesses than those identified in its Rule 26 disclosures”. (ECF No. 780 at

6 16.) The FTC should not be permitted to evade the Court’s discovery schedule to obtain

7 “incrementally better” evidence, and then seek to deny Qualcomm any opportunity to rebut it.

8 Further, the FTC has not shown that the BCG document are records of a regularly

9 conducted activity pursuant to Federal Rules of Evidence 803(6) and 902(11) or that they are

10 admissible as a statement by a Qualcomm agent within the scope of the agency relationship. To

11 the extent Qualcomm is not allowed to present testimony from Mr. Varadarajan at trial,

12 Qualcomm will object to the admission of the BCG documents.

13 FTC’s Position

14 Qualcomm’s objection to BCG documents created for Qualcomm’s own Board of

15 Directors is not well-founded. Qualcomm itself has claimed privilege over material in certain

16 BCG documents on the grounds that BCG was acting as its agent. The declaration to which

17 Qualcomm objects is limited and straightforward, stating merely that BCG documents are

18 authentic business records containing statements made by the agent of a party opponent. The

19 underlying documents were timely produced, in at least one case from Qualcomm’s own files,

20 and Qualcomm had every opportunity to seek BCG testimony about them before the fact

21 discovery deadline. The fact that Qualcomm did not do so until after the deadline, without this

22 Court’s leave, is not a basis to exclude the documents.

23  Exclusion of Testimony by Ira Blumberg, Vice President of Litigation and

24 Intellectual Property at Lenovo

25 Qualcomm’s Position

26 Qualcomm will object to certain deposition testimony by Ira Blumberg of Lenovo that

27
22
Nor may the FTC fairly blame BCG for any delay. The FTC has been receiving documents and
28 testimony from BCG since 2016, during its pre-Complaint investigation.

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1 was designated by the FTC. In the designated testimony, Mr. Blumberg (who is a fact witness and

2 not an expert witness) offered

3

4

5 . The testimony should be excluded as improper

6 opinion testimony; it is well-established that a fact witness (even one who is a lawyer) may not

7 offer legal opinions, which “invade [] the province of the judge”. Nationwide Transp. Fin. v.

8 Cass Info. Sys., Inc., 523 F.3d 1051, 1059 (9th Cir. 2008). The testimony is independently

9 objectionable because the FTC has not alleged that Qualcomm violated the antitrust laws in

10 Mr.

11 Blumberg’s testimony should be excluded.

12 FTC’s Position

13 Mr. Blumberg testified at length regarding his involvement in Lenovo’s licensing

14 program, and most significantly, as the primary Lenovo executive who participated in licensing

15 negotiations with Qualcomm in 2013. He offers relevant and helpful testimony based on his

16 personal knowledge of the relevant events that transpired in connection with those negotiations.

17 His impressions of those events and views he developed while negotiating with Qualcomm are

18 not transformed into “legal opinions” merely because he is an attorney. To the extent Qualcomm

19 has objections to specific testimony from Mr. Blumberg offered at trial, it should object at that

20 time.

21  FTC’s Improper Designation of Investigation Materials

22 Qualcomm’s Position

23 The FTC has improperly designated “Qualcomm’s responses to the FTC’s Civil

24 Investigative Demands served in In re Qualcomm Incorporated, FTC File No. 141-0199”.

25 Initially, the FTC’s purported designation was made pursuant to Paragraph (D)(3) of the Court’s

26 Guidelines, which permits the designation of “deposition testimony or other discovery to be

27 offered at trial”. Qualcomm’s responses to requests made by the FTC during its investigation,

28 however, do not constitute “discovery” in this action (such as interrogatory responses or

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1 responses to requests for admission served pursuant to the Federal Rules of Civil Procedure) that

2 may be designated in accordance with the Guidelines.

3 After Qualcomm challenged the FTC’s improper designations, the FTC belatedly

4 purported to add to its exhibit list all of Qualcomm’s responses to the FTC’s Civil Investigative

5 Demands (“CID”) as a single trial exhibit. The FTC did so on November 29—the day this Joint

6 Pretrial Statement was due—even though the Court’s October 24 Order required it to disclose all

7 of its trial exhibits no later than November 9 or November 21. The FTC has not specified which

8 materials among the hundreds of pages of responses and large volume of Qualcomm data the FTC

9 intends to offer as evidence, thus circumventing the limitations imposed by the Court on the

10 number of exhibits each side is permitted to present at trial. The FTC states that it “largely did

11 not ask the same questions in interrogatories that it had asked in its pre-Complaint CID”, but that

12 only illustrates the prejudice to Qualcomm because (unlike the FTC) Qualcomm had no

13 opportunity to ask the FTC questions during the investigation (and was limited to serving 15

14 interrogatories in this case). Qualcomm is prejudiced by the FTC’s belated, wholesale and

15 indiscriminate designation of investigation materials, which circumvents both the Court’s

16 schedule and the Court-imposed limitations on the number of allowed trial exhibits, and should

17 thus not be permitted.23

18 FTC’s Position
19 Qualcomm’s responses to the FTC’s pre-complaint Civil Investigative Demand (“CID”)
20 are its own sworn admissions. There is nothing improper about the FTC’s designation of
21 Qualcomm’s CID responses, and it is unclear why Qualcomm is seeking a procedural basis for
22 the exclusion of sworn statements it made to the FTC.24 Moreover, Qualcomm cannot be
23 prejudiced by any alleged belated disclosure where the FTC identified Qualcomm’s CID

24
23
The FTC refers to the fact that both Parties included compilations of materials on their exhibit
25 lists. But, unlike the FTC, Qualcomm has listed compilations of materials that are clearly
26 logically related and meant to be used at trial as a single exhibit (such as collections of patents
Qualcomm’s expert has addressed in his report).
24
27 It is also surprising that Qualcomm objects to the FTC’s creation of a single compilation
exhibit containing all of Qualcomm’s CID responses, where Qualcomm itself has included
28 several expansive compilation exhibits on its own list.

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1 responses on its initial proposed Joint Exhibit List on November 9, 2018. .

2  FTC’s Belated Disclosure of Additional Trial Exhibits

3 Qualcomm’s Position

4 Pursuant to the Court’s October 24, 2018 Order, the Parties were required to disclose all

5 potential trial exhibits (up to 650 exhibits) by November 21, and then reduce their potential trial

6 exhibits to 450 by November 27. On November 27 and 29, however, the FTC purported to add

7 trial exhibits that it had not previously disclosed. When Qualcomm asked the FTC to identify

8 where on its trial exhibit lists the FTC had disclosed these documents, the FTC declined to do so.

9 Qualcomm abided by the Court’s Order and is prejudiced by the FTC’s belated addition of

10 previously undisclosed trial exhibits because (among other things) it did not have any opportunity

11 to identify any witnesses, deposition testimony or other exhibits that may have been prompted by

12 the exhibits. Qualcomm objects to the present disclosure of these proposed trial exhibits and will

13 object to any use by the FTC of these belatedly disclosed trial exhibits.

14 FTC’s Position

15 Qualcomm has not identified any prejudice suffered by the FTC’s addition of three

16 individual trial exhibits. Two of the three additions were inadvertent: one was a duplicate of a

17 previously disclosed exhibit, and the second was added as a result of a typographical error. Both

18 parties—including Qualcomm—have reserved their rights to make additions to the exhibit list

19 where necessary, and particularly where such additions would not prejudice the opposing party.

20 XII. Bifurcation, Separate Trial of Issues

21 The Court’s April 19, 2017 Case Management Order, ECF No. 75 at 2, provided for a

22 single bench trial. The Court stated in November 2017 that the trial will address both liability and

23 remedy issues. (See Nov. 15, 2017 Hr’g Tr. at 4:21-5:1.) At the October 24, 2018 Case

24 Management Conference, the Court raised the possibility of deferring a request by the FTC for a

25 permanent injunction until after trial has concluded and only in the event that the Court finds a

26 violation on the basis of the trial record. This issue is further addressed in briefs submitted by the

27 Parties on October 31 and November 7, 2018.

28

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1 XIII. Estimate of Trial Time

2 Pursuant to the Court’s Case Management Orders, a bench trial will begin on Friday,

3 January 4, 2019, and will continue for 10 trial days. (ECF Nos. 75 at 2; 308 at 2; 922 at 2.) Each

4 side is limited to 25 hours for evidence, and to 30 minutes for opening statements. (See ECF No.

5 922 at 2.)

6 XIV. Other

7 A. High Priority Objections

8 FTC’s Position
9 The Court’s October 24 Order limited each party to 10 high priority objections per day,
10 addressed in no more than 6 pages. Given that the Court’s October 24 Order limits the Parties to
11 250 joint exhibits total plus 150 exhibits per side at trial (or roughly 55 exhibits per day), the FTC
12 has proposed further limits on the number of high priority objections that each Party may file, in
13 order to streamline the trial. Specifically, the FTC has proposed a limit of 5 high priority
14 objections per side per day, amounting to roughly 1 high priority objection for every 10
15 documents introduced at trial.
16 Qualcomm’s Position
17 The Court determined the number of high-priority objections allocated to each party at the
18 October 24, 2018 Case Management Conference and memorialized it in its October 24 Order.
19 The FTC provides no good cause for the Court to deviate from that Order. Further, given the
20 FTC’s ongoing effort to add more documents to its individual exhibit list than contemplated by
21 the Court (as discussed above, in connection with the joint exhibit list) and to “designate”
22 hundreds of pages of investigation responses (subject to Qualcomm’s objection, above), it would
23 be unfair to reduce the number of high-priority objections Qualcomm may use to challenge
24 inadmissible materials among the FTC’s purported designations. As with the numerical limit on
25 exhibits, the FTC is again simply seeking to re-argue the Court’s prior order for no good reason.
26 B. Order of Videotaped Deposition Testimony
27 FTC’s Position
28 The FTC has proposed that, subject to the Court’s approval, videotaped deposition

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1 testimony of a witness be presented during the case of the party proposing the designations.
2 Specifically, the Party that has designated videotaped deposition testimony will play its
3 designations, together with any counter-designations made for the sake of completeness, during
4 its case. If the other Party has designated different videotaped deposition testimony from the same
5 witness other than for the sake of completeness, that party will play such testimony during its own
6 case, together with any counter-designations made for the sake of completeness. In each instance,
7 the designated testimony will be played chronologically. Any testimony designated by a party,
8 whether for completeness or otherwise, will be counted against that party’s time at trial.
9 Qualcomm’s Position
10 Qualcomm believes that it may be more efficient and helpful to the Court if the Court
11 heard both Parties’ designations of a deposition consecutively and on a single day, rather than
12 splitting them so that separate portions of a single deposition are played in each Party’s case, on
13 different days potentially weeks apart. Qualcomm, however, defers to the Court’s preferences
14 with respect to this issue. Qualcomm agrees that any testimony designated by a party, whether
15 for completeness or otherwise, should be counted against that party’s time at trial.
16

17 Dated: November 29, 2018

18
The foregoing admissions having been made
19 by the parties, and the parties having
specified the foregoing issues of fact and
20 law remaining to be litigated, this order
shall supplement the pleadings and govern
21 the course of trial of this action, unless
22 modified to prevent manifest injustice

23

24

25

26

27

28

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1 FEDERAL TRADE COMMISSION
2

3 s/ Jennifer Milici _______
Jennifer Milici
4 Wesley G. Carson
J. Alexander Ansaldo
5 Joseph R. Baker
Elizabeth A. Gillen
6
Daniel Matheson
7 Federal Trade Commission
600 Pennsylvania Avenue, N.W.
8 Washington, D.C. 20580
(202) 326-2912; (202) 326-3496 (fax)
9 jmilici@ftc.gov
10 Attorneys for Federal Trade Commission
11

12

13 CRAVATH, SWAINE & MOORE LLP

14
By: s/ Gary A. Bornstein___
15

16
Gary A. Bornstein
17 Yonatan Even
CRAVATH, SWAINE & MOORE LLP
18 Worldwide Plaza
825 Eighth Avenue
19 New York, NY 10019
Tel: (212) 474-1000
20 Fax: (212) 474-3700
gbornstein@cravath.com
21 yeven@cravath.com

22 Robert A. Van Nest
Eugene M. Paige
23 Justina Sessions
KEKER, VAN NEST & PETERS LLP
24 633 Battery Street
San Francisco, CA 94111-1809
25 Telephone: (415) 391-5400
Facsimile: (415) 397-7188
26 rvannest@keker.com
epaige@keker.com
27 jsessions@keker.com

28

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1
Richard S. Taffet
2 MORGAN, LEWIS & BOCKIUS LLP
101 Park Avenue
3 New York, NY 10178-0060
Tel: (212) 309-6000
4 Fax: (212) 309-6001
richard.taffet@morganlewis.com
5
Willard K. Tom
6 MORGAN, LEWIS & BOCKIUS LLP
1111 Pennsylvania Ave. NW
7 Washington, DC 20004-2541
Tel: (202) 739-3000
8 Fax: (202) 739 3001
willard.tom@morganlewis.com
9
Geoffrey T. Holtz
10 MORGAN, LEWIS & BOCKIUS LLP
One Market, Spear Street Tower
11 San Francisco, CA 94105-1126
Tel: (415) 442-1000
12 Fax: (415) 442-1001
geoffrey.holtz@morganlewis.com
13
Attorneys for Defendant Qualcomm
14 Incorporated
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  JOINT PRETRIAL STATEMENT
40  Case No. 5:17-cv-00220-LHK-NMC
Case 5:17-cv-00220-LHK Document 946 Filed 11/29/18 Page 42 of 42

1 FILER’S ATTESTATION

2
I, Gary A. Bornstein, am the ECF user whose identification and password are being used to file
3 this Joint Status Report. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that the
signatories on this document have concurred in this filing.
4

5 s/ Gary A. Bornstein
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  JOINT PRETRIAL STATEMENT
41  Case No. 5:17-cv-00220-LHK-NMC
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 1 of 20

EXHIBIT A
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 2 of 20

1 FEDERAL TRADE COMMISSION CRAVATH, SWAINE & MOORE LLP
Jennifer Milici Gary A. Bornstein (pro hac vice)
2 J. Alexander Ansaldo gbornstein@cravath.com
Yonatan Even (pro hac vice)
3 Joseph R. Baker yeven@cravath.com
Elizabeth A. Gillen 825 Eighth Avenue
4 Daniel Matheson New York, New York 10019-7475
Mark Woodward Telephone: (212) 474-1000
5 600 Pennsylvania Avenue, N.W. Facsimile: (212) 474-3700
Washington, D.C. 20580
6 Tel.: (202) 326-2912 KEKER, VAN NEST & PETERS LLP
Robert A. Van Nest (SBN 84065)
7 Fax: (202) 326-3496 rvannest@keker.com
jmilici@ftc.gov Eugene M. Paige (SBN 202849)
8 epaige@keker.com
Attorneys for Plaintiff Justina Sessions (SBN 270914)
9 FEDERAL TRADE COMMISSION jsessions@keker.com
633 Battery Street
10 San Francisco, CA 94111-1809
Telephone: (415) 391-5400
11 Facsimile: (415) 397-7188
12 MORGAN, LEWIS & BOCKUS LLP
Richard S. Taffet (pro hac vice)
13 richard.taffet@morganlewis.com
101 Park Avenue
14 New York, New York 10178-0060
Tel: (212) 309-6000
15
Fax: (212) 309-6001
16
Attorneys for Defendant
17 QUALCOMM INCORPORATED

18 Additional Counsel in the Signature Block

19
UNITED STATES DISTRICT COURT
20
NORTHERN DISTRICT OF CALIFORNIA
21
SAN JOSE DIVISION
22

23 FEDERAL TRADE COMMISSION, Case No. 5:17-cv-00220-LHK

24 Plaintiff,
JOINT STIPULATION REGARDING
25 vs. UNDISPUTED FACTS

26 QUALCOMM INCORPORATED, a Delaware
corporation,
27
Defendant.
28

Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 3 of 20

1 Plaintiff the Federal Trade Commission (“FTC”) and Defendant Qualcomm Incorporated
2 (“Qualcomm”) (collectively, the “Parties”) respectfully submit this Joint Stipulation Regarding
3 Undisputed Facts.
4 The following facts are undisputed, and the Parties hereby stipulate to them for
5 incorporation into the trial record without the necessity of supporting testimony or exhibits.
6 However, the Parties agree that neither Party will object to the presentation of evidence in support
7 of these stipulated facts at trial on the ground that such facts were the subject of this stipulation.
8 The Parties agree that the stipulation of facts below is made without prejudice to each Party’s
9 ability to bring any motions in limine.
10 For purposes of the stipulated facts below: “Cellular Handsets” shall refer to complete
11 cellular end-user cellular telephones, including feature phones and smartphones.
12 1. QUALCOMM Incorporated (“Qualcomm”) is headquartered in San Diego,
13 California.
14 2. Since at least 1989, Qualcomm has been, and is now, a corporation.
15 3. Since at least 1989, Qualcomm has been, and is now, engaged in interstate and
16 international commerce.
17 4. Qualcomm’s operating segment relating to its chip and software business is called
18 Qualcomm CDMA Technologies (“QCT”). Qualcomm’s operating segment relating to the
19 licensing of its patents is called Qualcomm Technology Licensing (“QTL”).
20 5. In 2012, Qualcomm created Qualcomm Technologies, Inc. (“QTI”), a wholly
21 owned subsidiary of Qualcomm. QTI operates substantially all of Qualcomm’s products and
22 services businesses, including QCT, as well as substantially all of Qualcomm’s engineering,
23 research and development functions. Qualcomm continues to operate QTL.
24 6. Qualcomm CDMA Technologies Asia -Pacific Pte. Ltd. (“QCTAP”), a Singapore
25 company, is a wholly owned indirect subsidiary of Qualcomm.
26 7. Cellular communications depend on widely distributed networks that implement
27 cellular communications standards.
28
1 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 4 of 20

1 8. Some OEMs have purchased multimode modem chips for use in Cellular Handsets
2 intended for operation on the major U.S. wireless networks.
3 9. Cellular Handsets are designed, marketed, and sold by original equipment
4 manufacturers (“OEMs”) such as Samsung, Huawei, Apple, Xiaomi, Oppo, Vivo, Google,
5 Lenovo/Motorola Mobility, and LG.
6 10. Consumers purchase Cellular Handsets for a variety of reasons, including for
7 (a) their ability to transmit and receive data at high-speeds over cellular networks, such as those
8 implementing LTE, the highest-speed cellular standard which has been widely commercialized to
9 date, and (b) their ability to perform voice calls.
10 11. The Third Generation Partnership Project (“3GPP”) and the Third Generation
11 Partnership Project 2 (“3GPP2”) are global collaborative partnerships of standards
12 development/standards-setting organizations (“SDOs” or “SSOs”) and other industry participants
13 that develop technical specifications for cellular standards.
14 12. The current “organizational partners” of 3GPP are seven regional SDOs,
15 specifically: the European Telecommunications Standards Institute (“ETSI”), the Alliance for
16 Telecommunications Industry Solutions (“ATIS”), the Association of Radio Industries and
17 Businesses, Japan (“ARIB”), the Telecommunication Technology Committee, Japan (“TTC”), the
18 China Communications Standards Association (“CCSA”), the Telecommunications Standards
19 Development Society, India (“TSDSI”), and the Telecommunications Technology Association,
20 Korea (“TTA”).
21 13. The current organizational partners of 3GPP2 are five regional SDOs, specifically:
22 the Telecommunications Industry Association (“TIA”), ARIB, TTC, CCSA, and TTA.
23 14. Cellular communications standards have evolved over “generations,” including
24 second-generation (“2G”), third-generation (“3G”), and fourth-generation (“4G”) standards.
25 15. 2G cellular standards include the Global System for Mobile (“GSM”) and
26 cdmaOne (also sometimes called “TIA/EIA/IS-95” or “IS-95”).
27 16. ETSI adopted GSM as a cellular standard. ETSI also adopted General Packet
28
2 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 5 of 20

1 Radio Service (“GPRS”) and Enhanced Data Global Evolution (“EDGE”) as improvements to
2 GSM. These are considered 2G standards.
3 17. GSM uses time division multiple access (“TDMA”) technology.
4 18. TIA adopted cdmaOne as a cellular standard. TIA also adopted IS-95A and
5 IS-95B as improvements to cdmaOne. These are considered 2G standards.
6 19. cdmaOne uses code division multiple access (“CDMA”) technology.
7 20. 3G cellular standards include the Universal Mobile Telecommunications System
8 (“UMTS”) and CDMA2000.
9 21. UMTS is an umbrella term for three 3G cellular air interfaces standardized within
10 3GPP: UTRA-FDD, commonly called Wideband CDMA (“WCDMA”), used worldwide; UTRA-
11 TDD High Chip Rate, having little deployment; and UTRA-TDD Low Chip Rate, commonly
12 called Time Division-Synchronous CDMA (“TD-SCDMA”), used primarily in China. The term
13 HSDPA refers to certain additional UMTS features included in Release 5. HSUPA refers to
14 certain additional UMTS features included in Release 6. The combination of HSDPA and
15 HSUPA is commonly called HSPA, and HSPA/HSPA+ refers to certain additional UMTS
16 features included in Release 7 and beyond.
17 22. Included within the CDMA2000 family of standards are CDMA2000 1x, often
18 called 1xRTT, and High Rate Packet Data, often called 1xEV-DO or EV-DO.
19 23. CDMA2000 was standardized by 3GPP2.
20 24. In the United States, AT&T and T-Mobile have operated WCDMA networks.
21 Verizon and Sprint have operated CDMA2000 networks.
22 25. All four major U.S. carriers (Verizon, AT&T, T-Mobile and Sprint) have deployed
23 Long Term Evolution (“LTE”), which also encompasses the LTE Advanced, or “LTE-A,”
24 standard), as their 4G standard.
25 26. LTE uses orthogonal frequency division multiple access (“OFDMA”) technology
26 for downlink transmissions and single-carrier frequency division multiple access (“SC-FDMA”)
27 technology for uplink transmissions.
28
3 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 6 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 7 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 8 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 9 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 10 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 11 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 12 of 20
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 13 of 20

1 this role for approximately ten years, and has worked at Qualcomm since 1993.
2 113. Jeffrey (Jeff) Altman worked in Business Development within QTL from 1998
3 until his retirement on January 3, 2018. He joined Qualcomm in 1992.
4 114. Steven (Steve) Altman was President of Qualcomm from 2005 to 2011, and Vice
5 Chairman from November 2011 until his retirement in January 2014. Prior to those roles, he had
6 worked at Qualcomm since 1989, in various roles including General Counsel, Senior Vice
7 President and Vice President.
8 115. Cristiano Amon is President of Qualcomm, a position he has held since January
9 2018, and oversees Qualcomm’s semiconductor business. He was previously Executive Vice
10 President and President of QCT from 2015 to December 2018, and was Executive Vice President
11 and Co-President of QCT from 2012 to 2015. He started at Qualcomm in 1995 and since then,
12 excluding a period from June 1999 to November 2001 during which he was not employed by
13 Qualcomm, has held various other roles relating to Qualcomm’s semiconductor business.
14 116. Robert (Xiaopeng) An was Senior Director of Business Development at QTL,
15 located in Beijing, until August 2018. He began working at Qualcomm in approximately 2010.
16 117. Marvin (Marv) Blecker was Senior Vice President of QTL from April 1995 to
17 April 2005 and General Manager of QTL from November 2001 to April 2005, and then President
18 of QTL from April 2005 through October 2008, also serving as Executive Vice President of
19 Qualcomm from 2006 through October 2008. He also served as Senior Vice President of QTL
20 from October 2008 until his retirement in February 2014. He joined Qualcomm in 1992.
21 118. Lorenzo Casaccia is Vice President of Technical Standards at Qualcomm Europe
22 Inc. He has been the lead for Qualcomm’s 3GPP technical standards efforts since 2008. He
23 joined Qualcomm in 2001.
24 119. Yunhui Chae-Banks is Vice President of Business Development at QTL a position
25 she has held since 2016. Prior to her current role, she was an attorney for QTL and other
26 Qualcomm business units since she started at Qualcomm in 2003.
27 120. Anand Chandrasekher was Senior Vice President and General Manager for
28
11 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 14 of 20

1 Qualcomm’s Datacenter Technologies Inc. from December 2015 until departing Qualcomm in
2 July 2018. He previously was Senior Vice President for Business Development of the Data
3 Center Group from October 2013 to December 2015, and was Senior Vice President and Chief
4 Marketing Officer from August 2012, when he joined Qualcomm, until October 2013.
5 121. Liren Chen is Senior Vice President of Engineering and Legal Counsel in QTL,
6 where he leads QTL’s technology and product management team. He has been a Senior Vice
7 President of Engineering and Legal Counsel since October 2015; prior to that, from February
8 2009, he was Vice President of Engineering and Legal Counsel in the Intellectual Property and
9 Strategic IP departments. He joined Qualcomm in 1996.
10 122. Victoria (Vicky) Chen is Senior Vice President, Legal Counsel at QTI. She started
11 at Qualcomm in 1998 as Attorney in the subscriber unit group. That group was sold to Kyocera
12 Wireless in 2000, and she re-joined Qualcomm in 2004.
13 123. David Cianflone is Senior Vice President, Finance at QTL. Prior to his current
14 position, he has held various finance roles for different Qualcomm business units since he started
15 in 1998.
16 124. George Davis is Executive Vice President and Chief Financial Officer for
17 Qualcomm, and has been since he joined Qualcomm in March 2013.
18 125. Jim Doh was Vice Chairman, Qualcomm Asia, from approximately 2014 until his
19 retirement in January 2017. He previously held various other roles, including Senior Vice
20 President of Worldwide Sales, President of QCT Asia, and Senior Vice President and President of
21 QCT, since he started at Qualcomm in 1997.
22 126. Deborah Dwight is Vice President, Division Counsel at QTL, a position she has
23 held since May 2017. She previously held various other roles as an attorney in QTL and in
24 Qualcomm’s Corporate Legal department since starting at the company in 2001.
25 127. Fabian Gonell is Senior Vice President, Licensing Strategy, and Legal Counsel at
26 QTL and has been in this role since 2017. Prior to his current role, he has held roles as Division
27 Counsel and as an attorney in QTL since 2009, and as an attorney in Qualcomm’s Corporate
28
12 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 15 of 20

1 Legal department from 2007 to 2009.
2 128. Matthew Grob was Executive Vice President of Technology from April 2017 until
3 May 2018. He previously was Qualcomm’s Chief Technology Officer from 2011 to March 2017,
4 Senior Vice President of Engineering in Qualcomm’s Corporate R&D unit from 2006 to 2010,
5 and held other engineering roles at Qualcomm since starting at the company in 1991.
6 129. Kirti Gupta was Director of Economic Strategy within Qualcomm’s Strategic
7 Intellectual Property group from approximately 2012 through 2016, when she assumed her
8 current role as Senior Director of Economic Strategy within Qualcomm’s legal department. She
9 previously held various other roles since starting in Qualcomm, with the exception of a brief
10 period from late 2008 through early 2009, when she was not a Qualcomm employee.
11 130. Michael Hartogs was Senior Vice President and Division Counsel of QTL from
12 October 2006 until 2012, and was Vice President and Division Counsel of QTL from June 2005
13 until February 2012. He held roles in Qualcomm’s Corporate Legal department when since he
14 joined the company in 1999.
15 131. Irwin Jacobs was a co-founder of Qualcomm in 1985. He has served as President,
16 Chief Executive Officer and Chairman of the company. He left his role as Chief Executive
17 Officer in 2005 and retired from Qualcomm in 2009.
18 132. Paul Jacobs served as Chairman of the Qualcomm Board of Directors from March
19 2009 to March 2014, as Executive Chairman of the Board of Directors from March 2014 to
20 March 2018. Mr. Jacobs also served as a Director from June 2005 to March 2018. He served as
21 Chief Executive Officer from June 2005 to March 2014. He began working at Qualcomm full-
22 time in 1990.
23 133. Sanjay Jha was President of QCT from 2003 to 2008, as well as Chief Operating
24 Officer of Qualcomm from 2006 to 2008. He also served as Executive Vice President of QCT
25 from 2003 to 2006. He joined Qualcomm in 1994.
26 134. Aliyar (Alex) Katouzian is Senior Vice President and General Manager of the
27 Mobile Business Operations Unit at QTI. He joined Qualcomm in October 2002.
28
13 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 16 of 20

1 135. Eric Koliander is Vice President, Sales, in QCT. He joined Qualcomm in 2006.
2 136. Keith Kressin is Senior Vice President of Product Management at QTI, a position
3 he has held since 2015. He has held various other roles in QTI and QCT since he joined
4 Qualcomm in 2008.
5 137. James (Jim) Lederer was Executive Vice President and General Manager of QCT
6 from May 2009 until his retirement in January 2014. He previously held other roles at
7 Qualcomm since he joined the company in 1997.
8 138. Louis (Lou) Lupin was Senior Vice President, General Counsel, from 2000 to
9 2006, and Executive Vice President and General Counsel of Qualcomm from 2006 to August
10 2007. He served as Legal Consultant from August 2007 until his retirement in August 2014. He
11 previously held other roles at Qualcomm. He joined Qualcomm in 1995.
12 139. Durga Malladi is Senior Vice President of Engineering and General Manager of
13 4G/5G at QTI. He has held this role since June 2018. He held various other roles, including
14 Senior Vice President, Vice President of Engineering, Senior Director of Engineering, and Senior
15 Engineer, since he started at Qualcomm in 1998.
16 140. Roger Martin was Senior Vice President, Chief IP Strategist at Qualcomm, from
17 October 2008 until his retirement in March 2018. From April 2003 to October 2008 he served as
18 Vice President, Patent Counsel, and has held various other roles since he joined Qualcomm in
19 1993.
20 141. Sanjay Mehta is Senior Vice President for Compute Products, a role has held since
21 July 2018. He previously was Senior Vice President of QCT China from 2016 to July 2018, and
22 held various other roles in QCT since he started at Qualcomm in 2004.
23 142. Steven (Steve) Mollenkopf is Chief Executive Officer of Qualcomm, a position he
24 has held since March 2014. Prior to being Chief Executive Officer, he was President from
25 November 2011 to March 2014, Chief Operating Officer from approximately November 2011 to
26 December 2013, and prior to that he was Executive Vice President and President of QCT. He
27 previously held various other roles at Qualcomm since he started with the company in 1994.
28
14 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 17 of 20

1 143. Kun Qian is Vice President of Business Development at QTL. He has been in this
2 role since April 2017. Prior to that role, he was Vice President, Account Management, from
3 November 2016 to April 2017. Before 2016 he was responsible for QCT’s China sales, and he
4 held various other sales roles since he started at Qualcomm in 2004.
5 144. Eric Reifschneider was Senior Vice President at QTL from March 2016 until his
6 departure from the company in July 2016. He previously served as Senior Vice President and
7 General Manager of QTL from April 2012, when he started at Qualcomm, to March 2016.
8 145. Hank Robinson worked at QCT in various sales positions from approximately
9 2000 through 2015. His last position was Vice President of Sales in QCT.
10 146. Alexander (Alex) Rogers is Executive Vice President of Qualcomm and President
11 of QTL, positions he has held since 2016. He previously held other roles in QTL and
12 Qualcomm’s Corporate Legal department since joining the company in 2001.
13 147. Abbaseh Samimi is Vice President of Strategic Market Analysis and Contracts at
14 QTL, a position she has held since October 2008. She has held other roles at Qualcomm since
15 joining the company in 1996.
16 148. James (Jim) Thompson is Executive Vice President of Engineering and Chief
17 Technology Officer of QTI. Previously, he was Senior Vice President of Engineering within
18 QCT’s Engineering Management unit, and Mr. Thompson has overseen all of QCT engineering
19 since 2004. He joined Qualcomm in 1992.
20 149. Edward (Ed) Tiedemann, Jr., is Senior Vice President, Engineering within the
21 Qualcomm Standards and Industry Organization unit at QTI.
22 150. Jonathan Weiser is Senior Vice President and Division Counsel at QTI, positions
23 he has held since June 2011. He joined Qualcomm in 1994.
24 151. Serge Willenegger is Senior Vice President and General Manager of Industrial
25 IOT in QTI’s Swiss Department business unit. He joined Qualcomm in 1995.
26 152. David (Dave) Wise is Senior Vice President and Treasurer at Qualcomm, positions
27 he has held since December 2015. He held various other roles since he joined Qualcomm in
28
15 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 18 of 20

1 1997.
2 153. William (Will) Wyatt is Vice President, Finance at QTI, a position he began in
3 October 2012. He joined Qualcomm in 2005.
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16 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 19 of 20

1 Dated: November 29, 2018
Respectfully submitted,
2

3
FEDERAL TRADE COMMISSION,
4
/s/ Jennifer Milici
5 Jennifer Milici
6 J. Alexander Ansaldo
Joseph R. Baker
7 Elizabeth A. Gillen
Daniel Matheson
8
Mark Woodward
9 Federal Trade Commission
600 Pennsylvania Avenue, N.W.
10 Washington, D.C. 20580
Tel.: (202) 326-2912
11 Fax: (202) 326-3496
12 jmilici@ftc.gov

13 Attorneys for Plaintiff Federal Trade Commission

14 CRAVATH, SWAINE & MOORE LLP,
15 /s/ Gary A. Bornstein
16 Gary A. Bornstein
Yonatan Even
17
Worldwide Plaza
18 825 Eighth Avenue
New York, NY 10019
19 Tel: (212) 474-1000
Fax: (212) 474-3700
20 gbornstein@cravath.com
21 yeven@cravath.com

22

23

24

25

26

27

28
17 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-1 Filed 11/29/18 Page 20 of 20

Robert A. Van Nest
1
Eugene M. Paige
2 Justina Sessions
KEKER, VAN NEST & PETERS LLP
3 633 Battery Street
San Francisco, CA 94111-1809
4 Tel: (415) 391-5400
Fax: (415) 397-7188
5
rvannest@keker.com
6 epaige@keker.com
jsessions@keker.com
7
Richard S. Taffet
8 MORGAN, LEWIS & BOCKIUS LLP
9 101 Park Avenue
New York, NY 10178-0060
10 Tel: (212) 309-6000
Fax: (212) 309-6001
11 richard.taffet@morganlewis.com
12 Willard K. Tom
13 MORGAN, LEWIS & BOCKIUS LLP
1111 Pennsylvania Ave. NW
14 Washington, DC 20004-2541
Tel: (202) 739-3000
15 Fax: (202) 739 3001
willard.tom@morganlewis.com
16

17
Geoffrey T. Holtz
18 MORGAN, LEWIS & BOCKIUS LLP
One Market, Spear Street Tower
19 San Francisco, CA 94105-1126
Tel: (415) 442-1000
20
Fax: (415) 442-1001
21 geoffrey.holtz@morganlewis.com

22 Attorneys for Defendant Qualcomm Incorporated

23

24

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27

28
18 Joint Stipulation Regarding Undisputed Facts
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-2 Filed 11/29/18 Page 1 of 18

EXHIBIT B
Case 5:17-cv-00220-LHK Document 946-2 Filed 11/29/18 Page 2 of 18

1 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
2 SAN JOSE DIVISION
3

4

5 FEDERAL TRADE COMMISSION, Case No. 5:17-cv-00220-LHK

6 Plaintiff,
PLAINTIFF FEDERAL TRADE
v. COMMISSION’S WITNESS LIST
7
QUALCOMM INCORPORATED, a
8 Delaware corporation,
9 Defendant.

10

11

12
Northern District of California
United States District Court

13

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CASE NO. 5:17-CV-00220-LHK
Case 5:17-cv-00220-LHK Document 946-2 Filed 11/29/18 Page 3 of 18

1 PLAINTIFF FEDERAL TRADE COMMISSION’S WITNESS LIST

2

3 Pursuant to the Court’s Standing Order, the Federal Trade Commission respectfully submits the

4 following list of witnesses that it may call to testify at trial other than solely for impeachment or

5 rebuttal with a brief statement describing the general subject matter of the testimony to be given.

6 The FTC has also indicated whether it intends to call each witness live or by deposition

7 designation, based on the information currently known to it about each witness and whether the

8 attendance of the witness may be compelled by the Court.

9 FACT WITNESSES BY LIVE TESTIMONY

10 Live Witnesses Represented by Qualcomm’s Counsel at deposition, each of whom may testify

11 about: Qualcomm’s supply and licensing agreements; negotiations with actual and prospective

12 customers and licensees; Qualcomm’s policies and practices related to product sales and licensing;

13 the development and adoption of cellular standards; Qualcomm’s commitments to license standard

14 essential patents (“SEPs”) on fair, reasonable, and non-discriminatory (“FRAND”) terms; modem

15 chip markets; Qualcomm’s market power; barriers to entry and expansion in modem chip markets;

16 the effects of Qualcomm’s policies and practices on competition, innovation, and consumers; any

17 other issues addressed in his deposition or his investigational hearing; or any documents or data

18 introduced into evidence by Qualcomm or the FTC as to which the witness has knowledge:

19 1. Derek Aberle was President of Qualcomm from 2014 until December 31, 2017, when

20 he left the company, and was a paid consultant for Qualcomm after his departure from

21 the company. His prior roles at Qualcomm included Legal Counsel (2000-2005),

22 General Manager of Licensing (2005-2011), and Group President of Qualcomm

23 Technology Licensing (“QTL”) (2011-2014).

24 2. Steve Altman was President of Qualcomm from approximately 2004-2011, and Vice

25 Chairman from approximately 2011 until his retirement in January 2014.

26 3. Cristiano Amon is President of Qualcomm, responsible for oversight of Qualcomm’s

27 semiconductor business, and previously held various other roles relating to

28 Qualcomm’s semiconductor business since he started at Qualcomm in 1995.
2
FTC’S PRELIMINARY WITNESS LIST
CASE NO. 5:17-CV-00220-LHK
Case 5:17-cv-00220-LHK Document 946-2 Filed 11/29/18 Page 4 of 18

1 4. Fabian Gonell is Senior Vice President, Licensing Strategy, and Legal Counsel at

2 Qualcomm, and has been in this role since approximately 2017. Prior to 2017, he was

3 Senior Vice President and Division Counsel, QTL. Prior to his position as SVP and

4 Division Counsel, QTL, he was in the legal department at QTL, where he worked since

5 2007.

6 5. Irwin Jacobs was co-founder, Chief Executive Officer, and Chairman of Qualcomm

7 beginning with its founding in 1985. He left his role as Chief Executive Officer in

8 2005.

9 6. Paul Jacobs served as Chairman of the Qualcomm Board of Directors from March

10 2009 to March 2018, as Executive Chairman from March 2014 to March 2018, and as a

11 director from June 2005 to March 2018. He served as Chief Executive Officer from

12 July 2005 to March 2014. He previously held various other roles since he joined

13 Qualcomm in 1990. He is the son of Irwin Jacobs.

14 7. Steven (Steve) Mollenkopf is Chief Executive Officer of Qualcomm, a position he has

15 held since March 2014, and has worked at Qualcomm CDMA Technologies (“QCT”)

16 since 2008.

17 8. Eric Reifschneider was Vice President and General Manager of QTL from 2012

18 through approximately March 2016. He left Qualcomm in July 2016.

19 9. Alex Rogers has been Executive Vice President of Qualcomm and President of QTL

20 since October 2016 and has worked at Qualcomm since 2001.

21 10. David Wise is Senior Vice President of Finance and Treasurer at Qualcomm.

22 11. William Wyatt is Vice President of Finance at Qualcomm. He is currently the finance

23 lead for QCT.

24

25 Live Witnesses Not Represented by Qualcomm:

26 12. Tony Blevins is Vice President of Procurement at Apple. Mr. Blevins may testify

27 about: the design, engineering, assembly, procurement, and sale of Apple’s cellular

28 products; Apple’s procurement of modem chips and other components from
3
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1 Qualcomm and other suppliers; Apple’s licensing of cellular patents from Qualcomm

2 and other patent owners; Apple’s negotiations and agreements with Qualcomm relating

3 to the supply of modem chips and/or patent licensing or royalties; the impact of

4 Qualcomm’s agreements with Apple on Apple’s procurement decisions; Apple’s

5 concerns regarding chip supply as a result of Qualcomm’s policies; the meaning and

6 importance of FRAND commitments for SEPs; whether the effective royalties

7 historically paid by Apple through its contract manufacturers for rights to Qualcomm’s

8 SEPs are FRAND compliant; royalties paid by Apple to cellular SEP owners other than

9 Qualcomm; conditions extracted by Qualcomm in exchange for royalty relief;

10 competitive conditions in markets for modem chips; Qualcomm’s market power; the

11 effects of Qualcomm’s policies and practices on competition, innovation, and

12 consumers; any other issues addressed in his deposition or his investigational hearing;

13 or any documents or data introduced into evidence by Qualcomm or the FTC as to

14 which he has knowledge.

15 13. Aichatou (Aicha) Evans is Chief Strategy Officer at Intel and previously was in

16 charge of Intel’s chipset division until 2016. Ms. Evans may testify about: modem

17 chip markets; Qualcomm’s market power; attempts to obtain patent licenses from

18 Qualcomm; competition in modem chip markets; barriers to entry and expansion in

19 modem chip markets; the effects of Qualcomm’s policies and practices on competition,

20 innovation, and consumers; the development and adoption of cellular standards; the

21 meaning and importance of FRAND commitments for SEPs; patent agreements and

22 negotiations with licensees; any other issues addressed in her deposition or

23 investigational hearing; or any documents or data introduced into evidence by

24 Qualcomm or the FTC as to which she has knowledge.

25 14. Dana Hayter was in-house counsel for Intel responsible for negotiating a patent cross

26 license with Qualcomm. Mr. Hayter may testify about: modem chip markets;

27 Qualcomm’s market power; attempts to obtain patent licenses from Qualcomm;

28 competition in modem chip markets; barriers to entry and expansion in modem chip
4
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1 markets; the effects of Qualcomm’s policies and practices on competition, innovation,

2 and consumers; the development and adoption of cellular standards; the meaning and

3 importance of FRAND commitments for SEPs; patent agreements and negotiations

4 with actual and prospective agreement counterparties; any other issues addressed in his

5 deposition or his investigational hearing; or any documents or data introduced into

6 evidence by Qualcomm or the FTC as to which he has knowledge.

7 15. John Kalkman was Vice President of Marketing at Samsung System LSI from 2011 to

8 2015 and is currently Vice President of IoT Business at Samsung Electronics. Mr.

9 Kalkman may testify about: industry supply and licensing agreements; modem chip

10 markets and competition in these markets; Qualcomm’s market power; barriers to entry

11 and expansion in modem chip markets; the effects of Qualcomm’s policies and

12 practices on competition, innovation, and consumers; attempts to obtain patent licenses

13 from Qualcomm; the development and adoption of cellular standards; any other issues

14 addressed in his deposition; or any documents or data introduced into evidence by

15 Qualcomm or the FTC as to which he has knowledge.

16 16. Finbarr Moynihan is the General Manager, Corporate Sales (International) for

17 MediaTek and has worked at MediaTek since 2008. Mr. Moynihan may testify about:

18 modem chip markets and competition in these markets; Qualcomm’s market power;

19 attempts to obtain patent licenses from Qualcomm; barriers to entry and expansion in

20 modem chip markets; the effects of Qualcomm’s policies and practices on competition,

21 innovation, and consumers; the development and adoption of cellular standards; the

22 meaning and importance of FRAND commitments for SEPs; patent agreements and

23 negotiations with actual and prospective licensees; any other issues addressed in his

24 deposition or his investigational hearing; or any documents or data introduced into

25 evidence by Qualcomm or the FTC as to which he has knowledge.

26 17. Aaron Schafer is a Senior Director for Procurement at Apple. Mr. Schafer may testify

27 about: the design, engineering, assembly, procurement, and sale of Apple’s cellular

28 products; Apple’s procurement of modem chips and other components from
5
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1 Qualcomm and other suppliers; Apple’s licensing of cellular patents from Qualcomm

2 and other patent owners; Apple’s negotiations and agreements with Qualcomm relating

3 to the supply of modem chips and/or patent licensing or royalties; the impact of

4 Qualcomm’s agreements with Apple on Apple’s procurement decisions; Apple’s

5 concerns regarding chip supply as a result of Qualcomm’s policies; the meaning and

6 importance of FRAND commitments for SEPs; whether the effective royalties

7 historically paid by Apple through its contract manufacturers for rights to Qualcomm’s

8 SEPs are FRAND compliant; royalties paid by Apple to cellular SEP owners other than

9 Qualcomm; conditions extracted by Qualcomm in exchange for royalty relief;

10 competitive conditions in markets for modem chips; Qualcomm’s market power; the

11 effects of Qualcomm’s policies and practices on competition, innovation, and

12 consumers; any other issues addressed in his deposition; or any documents or data

13 introduced into evidence by Qualcomm or the FTC as to which he has knowledge.

14 18. Bruce (BJ) Watrous is Vice President and Chief Intellectual Property Counsel at

15 Apple. Mr. Watrous may testify about: the design, engineering, assembly,

16 procurement, and sale of Apple’s cellular products; Apple’s procurement of modem

17 chips and other components from Qualcomm and other suppliers; Apple’s licensing of

18 cellular patents from Qualcomm and other patent owners; Apple’s negotiations and

19 agreements with Qualcomm relating to the supply of modem chips and/or patent

20 licensing or royalties; the impact of Qualcomm’s agreements with Apple on Apple’s

21 procurement decisions; Apple’s concerns regarding chip supply as a result of

22 Qualcomm’s policies; the meaning and importance of FRAND commitments for SEPs;

23 whether the effective royalties historically paid by Apple through its contract

24 manufacturers for rights to Qualcomm’s SEPs are FRAND compliant; negotiations

25 with and royalties paid by Apple to cellular SEP owners other than Qualcomm;

26 conditions extracted by Qualcomm in exchange for royalty relief; competitive

27 conditions in markets for modem chips; Qualcomm’s market power; the effects of

28 Qualcomm’s policies and practices on competition, innovation, and consumers; any
6
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1 other issues addressed in his deposition; or any documents or data introduced into

2 evidence by Qualcomm or the FTC as to which he has knowledge.

3 19. Jeff Williams is the Chief Operating Officer of Apple. Mr. Williams may testify

4 about: the design, engineering, assembly, procurement, and sale of Apple’s cellular

5 products; Apple’s procurement of modem chips and other components from

6 Qualcomm and other suppliers; Apple’s licensing of cellular patents from Qualcomm

7 and other patent owners; Apple’s negotiations and agreements with Qualcomm relating

8 to the supply of modem chips and/or patent licensing or royalties; the impact of

9 Qualcomm’s agreements with Apple on Apple’s procurement decisions; Apple’s

10 concerns regarding chip supply as a result of Qualcomm’s policies; the meaning and

11 importance of FRAND commitments for SEPs; whether the effective royalties

12 historically paid by Apple through its contract manufacturers for rights to Qualcomm’s

13 SEPs are FRAND compliant; royalties paid by Apple to cellular SEP owners other than

14 Qualcomm; conditions extracted by Qualcomm in exchange for royalty relief;

15 competitive conditions in markets for modem chips; Qualcomm’s market power; the

16 effects of Qualcomm’s policies and practices on competition, innovation, and

17 consumers; any other issues addressed in his deposition or his investigational hearing;

18 or any documents or data introduced into evidence by Qualcomm or the FTC as to

19 which he has knowledge.

20

21 FACT WITNESSES BY DEPOSITION

22 Each of the below-listed witnesses may testify about any issue addressed in the portions of his or

23 her deposition designated pursuant to the FTC’s initial designations, supplemental designations,

24 and subject to the cross-designation and counter-designation process as instructed by the Court

25 or/and agreed to by the parties.

26 20. Seungho Ahn is Head of Samsung’s IP Center and is responsible for all matters

27 relating to intellectual property at Samsung. The FTC may present testimony from Mr.

28 Ahn regarding the subjects of his deposition, including without limitation Samsung’s
7
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1 agreements, communications, and negotiations with Qualcomm and with other

2 intellectual property licensors and licensees; Qualcomm’s commitments to license

3 standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory

4 (“FRAND”) terms; and the effects of Qualcomm’s policies and practices on

5 competition, innovation, and consumers.

6 21. Jeffrey (Jeff) Altman worked in Business Development within the QTL division from

7 1998 until his retirement on January 3, 2018. He had previously been in various other

8 roles since he started at Qualcomm in 1992. The FTC may present testimony from Mr.

9 Altman regarding the subjects of his deposition, including without limitation

10 Qualcomm’s supply and licensing agreements; negotiations with actual and prospective

11 customers and licensees; Qualcomm’s policies and practices related to product sales

12 and licensing; Qualcomm’s commitments to license standard essential patents (“SEPs”)

13 on fair, reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets;

14 Qualcomm’s market power; and the effects of Qualcomm’s policies and practices on

15 competition, innovation, and consumers.

16 22. Richard Blaylock is a partner at Pillsbury Winthrop Shaw Pittman LLP and has

17 represented ZTE in several negotiations with Qualcomm, including 2015 license

18 negotiations. The FTC may present testimony from Mr. Blaylock regarding the

19 subjects of his deposition, including without limitation ZTE’s negotiations regarding

20 intellectual property license agreements with Qualcomm and others; ZTE’s agreements

21 with Qualcomm, Qualcomm’s policies and practices related to product sales and

22 licensing; Qualcomm’s commitments to license standard essential patents (“SEPs”) on

23 fair, reasonable, and non-discriminatory (“FRAND”) terms; Qualcomm’s market

24 power; and the effects of Qualcomm’s policies and practices on competition,

25 innovation, and consumers.

26 23. Marvin Blecker joined Qualcomm in 1992 and was President of QTL from the early

27 2000s through 2008, and Senior Vice President in Qualcomm’s licensing business from

28 1996 through his promotion to President, and again from 2008 until his retirement in
8
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1 March 2014. Mr. Blecker served as a consultant to Qualcomm after his retirement.

2 The FTC may present testimony from Mr. Blecker regarding the subjects of his

3 deposition, including without limitation Qualcomm’s supply and licensing agreements;

4 negotiations with actual and prospective customers and licensees; Qualcomm’s policies

5 and practices related to product sales and licensing; Qualcomm’s commitments to

6 license standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory

7 (“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry

8 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

9 practices on competition, innovation, and consumers.

10 24. Ira Blumberg has been Vice President of Intellectual Property at Lenovo since 2012.

11 The FTC may present testimony from Mr. Blumberg regarding the subjects of his

12 deposition, including without limitation Lenovo’s agreements with Qualcomm; the

13 negotiation of patent licenses and supply agreements with Qualcomm and others;

14 Qualcomm’s policies and practices related to product sales and licensing; Qualcomm’s

15 commitments to license standard essential patents (“SEPs”) on fair, reasonable, and

16 non-discriminatory (“FRAND”) terms; modem chip markets; Qualcomm’s market

17 power; barriers to entry and expansion in modem chip markets; and the effects of

18 Qualcomm’s policies and practices on competition, innovation, and consumers.

19 25. Hwi-Jae Cho is Director of the Intellectual Property Center at LGE in charge of all

20 patent licensing matters at LGE, and has worked at LGE since 2000. Mr. Cho may

21 testify about any issue addressed in the designated portions of his sworn testimony

22 provided in response to written questions propounded by the FTC and Qualcomm

23 pursuant to the Hague Convention on Evidence. The FTC may present testimony from

24 Mr. Cho regarding the subjects of his sworn testimony, including without limitation

25 LGE’s agreements with Qualcomm; the negotiation of patent licenses and supply

26 agreements with Qualcomm and others; Qualcomm’s policies and practices related to

27 product sales and licensing; Qualcomm’s commitments to license standard essential

28 patents (“SEPs”) on fair, reasonable, and non-discriminatory (“FRAND”) terms;
9
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1 modem chip markets; Qualcomm’s market power; barriers to entry and expansion in

2 modem chip markets; and the effects of Qualcomm’s policies and practices on

3 competition, innovation, and consumers.

4 26. Brian Chong is chief of the medical business development center and chief of new

5 technology development and product planning at Wistron. The FTC may present

6 testimony from Mr. Chong regarding the subjects of his deposition, including without

7 limitation Wistron’s agreements with Qualcomm; the negotiation of patent licenses and

8 supply agreements with Qualcomm and others; Qualcomm’s policies and practices

9 related to product sales and licensing; Qualcomm’s commitments to license standard

10 essential patents (“SEPs”) on fair, reasonable, and non-discriminatory (“FRAND”)

11 terms; modem chip markets; the effects of Qualcomm’s licensing practices on

12 Qualcomm’s licensees and chip competitors; Qualcomm’s market power; barriers to

13 entry and expansion in modem chip markets; and the effects of Qualcomm’s policies

14 and practices on competition, innovation, and consumers.

15 27. Mark Davis was the director of the wireless design center of LSI Logic and later

16 served as the chief technology officer of VIA Telecom until 2015. The FTC may

17 present testimony from Mr. Davis regarding the subjects of his deposition, including

18 without limitation, Via’s agreements with Qualcomm; Qualcomm’s policies and

19 practices related to product sales and licensing; Qualcomm’s commitments to license

20 standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory

21 (“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry

22 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

23 practices on competition, innovation, and consumers.

24 28. Jianxin (Jason) Ding is Vice President and Head of Intellectual Property Rights for

25 Huawei Technology. The FTC may present testimony from Mr. Ding regarding the

26 subjects of his deposition, including without limitation the volume of Huawei’s handset

27 sales; Huawei’s agreements with Qualcomm; the negotiation of patent licenses and

28 supply agreements with Qualcomm and others; Qualcomm’s policies and practices
10
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1 related to product sales and licensing; Qualcomm’s commitments to license standard

2 essential patents (“SEPs”) on fair, reasonable, and non-discriminatory (“FRAND”)

3 terms; modem chip markets; Qualcomm’s market power; barriers to entry and

4 expansion in modem chip markets; and the effects of Qualcomm’s policies and

5 practices on competition, innovation, and consumers.

6 29. John Grubbs is Senior Director of IP Transactions at BlackBerry. The FTC may

7 present testimony from Mr. Grubbs regarding the subjects of his deposition, including

8 without limitation Blackberry’s agreements with Qualcomm; the negotiation of patent

9 licenses and supply agreements with Qualcomm and others; Qualcomm’s policies and

10 practices related to product sales and licensing; Qualcomm’s commitments to license

11 standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory

12 (“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry

13 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

14 practices on competition, innovation, and consumers.

15 30. Andrew Hong has worked at Samsung since 2003. He is an attorney in the Global

16 Legal Affairs group at Samsung, and previously was an attorney within Samsung’s IP

17 Center, and before that within Samsung’s Semiconductor IP team. The FTC may

18 present testimony from Mr. Hong regarding the subjects of his deposition, including

19 without limitation Samsung’s agreements with Qualcomm; the negotiation of patent

20 licenses and supply agreements with Qualcomm and others; Qualcomm’s policies and

21 practices related to product sales and licensing; Qualcomm’s commitments to license

22 standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory

23 (“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry

24 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

25 practices on actual and potential modem chip rivals, competition, innovation, and

26 consumers.

27 31. Hojin Kang is the former Director of Purchasing at Samsung Mobile, and was

28 employed by Samsung from 1987 to 2016. The FTC may present testimony from Mr.
11
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1 Kang regarding the subjects of his deposition, including without limitation Samsung’s

2 agreements with Qualcomm; Qualcomm’s policies and practices related to product

3 sales and licensing; modem chip markets; Qualcomm’s market power; barriers to entry

4 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

5 practices on competition, innovation, and consumers.

6 32. Asha Keddy is the manager of Intel’s Next Generation and Standards team and has

7 worked at Intel since 1999. The FTC may present testimony from Ms. Keddy

8 regarding the subjects of her deposition, including without limitation Intel’s

9 agreements with Qualcomm; Qualcomm’s policies and practices related to product

10 sales and licensing; modem chip markets; Qualcomm’s market power; barriers to entry

11 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

12 practices on competition, innovation, and consumers.

13 33. Yooseok Kim is Vice President of the IP Center at Samsung and has worked at

14 Samsung since 1995. The FTC may present testimony from Mr. Kim regarding the

15 subjects of his deposition, including without limitation Samsung’s agreements with

16 Qualcomm; the negotiation of patent licenses and supply agreements with Qualcomm

17 and others; Qualcomm’s policies and practices related to product sales and licensing;

18 Qualcomm’s commitments to license standard essential patents (“SEPs”) on fair,

19 reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets;

20 Qualcomm’s market power; barriers to entry and expansion in modem chip markets;

21 and the effects of Qualcomm’s policies and practices on competition, innovation, and

22 consumers.

23 34. Injung Lee is the Head of the License Team at the IP Center at Samsung. The FTC

24 may present testimony from Mr. Lee regarding the subjects of his deposition, including

25 without limitation Samsung’s agreements with Qualcomm; the negotiation of patent

26 licenses and supply agreements with Qualcomm and others; Qualcomm’s policies and

27 practices related to product sales and licensing; Qualcomm’s commitments to license

28 standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory
12
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1 (“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry

2 and expansion in modem chip markets; and the effects of Qualcomm’s policies and

3 practices on competition, innovation, and consumers.

4 35. Thomas Lindner is Head of the Cellular Modem & Mobile Connectivity business line

5 at Intel and has worked at Intel since 2011, after Intel acquired his former employer,

6 Infineon. The FTC may present testimony from Mr. Lindner regarding the subjects of

7 his deposition, including without limitation modem chip markets; Intel’s relationship

8 with Apple; Qualcomm’s market power; barriers to entry and expansion in modem

9 chip markets; and the effects of Qualcomm’s policies and practices on competition,

10 innovation, and consumers.

11 36. Todd Madderom has been Director of Procurement at Motorola since 2012. The FTC

12 may present testimony from Mr. Madderom regarding the subjects of his deposition,

13 including without limitation Motorola’s agreements with Qualcomm; Qualcomm’s

14 policies and practices related to product sales and licensing; modem chip markets;

15 Qualcomm’s market power; barriers to entry and expansion in modem chip markets;

16 and the effects of Qualcomm’s policies and practices on competition, innovation, and

17 consumers.

18 37. Isabel Mahe is Managing Director for Greater China at Apple, and was Vice President

19 of Wireless Technology at Apple from 2008 to 2017. The FTC may present testimony

20 from Ms. Mahe regarding the subjects of her deposition, including without limitation

21 Apple’s purchasing processes and decisions; Apple’s design processes; modem chip

22 markets; Apple’s products and product requirements; handset competition and market

23 conditions; Apple’s negotiations and relationship with Intel, Qualcomm, and other

24 suppliers; Apple’s agreements with Qualcomm; Qualcomm’s policies and practices

25 related to product sales and licensing; Qualcomm’s market power; barriers to entry and

26 expansion in modem chip markets; and the effects of Qualcomm’s policies and

27 practices on competition, innovation, and consumers.

28
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1 38. Scott McGregor was President and CEO of Broadcom until January 2016. The FTC

2 may present testimony from Mr. McGregor regarding the subjects of his deposition,

3 including without limitation competitive conditions and barriers to entry and expansion

4 in modem chip markets; Broadcom’s efforts to compete with Qualcomm and

5 relationship with Apple; modem chip and handset characteristics and markets;

6 Broadcom’s agreements with Qualcomm; Qualcomm’s market power; and the effects

7 of Qualcomm’s policies and practices on its rivals and potential rivals, competition,

8 innovation, and consumers.

9 39. Shen Nan has been the Chief Intellectual Property Officer for ZTE since 2016 and

10 previously served as ZTE’s Chief Licensing Officer. The FTC may present testimony

11 from Mr. Nan regarding the subjects of his deposition, including without limitation

12 ZTE’s agreements with Qualcomm; Qualcomm’s policies and practices related to

13 product sales and licensing; modem chip markets; Qualcomm’s market power; barriers

14 to entry and expansion in modem chip markets; and the effects of Qualcomm’s policies

15 and practices on competition, innovation, and consumers.

16 40. Christina Petersson is a senior licensing attorney at Ericsson. The FTC may present

17 testimony from Ms. Petersson regarding the subjects of her deposition, including

18 without limitation Ericsson’s patent license negotiations and agreements with

19 Qualcomm and others; Qualcomm’s policies and practices related to product sales and

20 licensing; Qualcomm’s commitments to license standard essential patents (“SEPs”) on

21 fair, reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets;

22 Qualcomm’s market power; barriers to entry and expansion in modem chip markets;

23 and the effects of Qualcomm’s policies and practices on competition, innovation, and

24 consumers.

25 41. Robert Rango was Executive Vice President of Broadcom’s Wireless Connectivity

26 Group until he retired in 2014. The FTC may present testimony from Mr. Rango

27 regarding the subjects of his deposition, including without limitation competitive

28 conditions and barriers to entry and expansion in modem chip markets; Broadcom’s
14
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1 efforts to compete with Qualcomm and relationship with Apple; modem chip and

2 handset characteristics and markets; Broadcom’s agreements with Qualcomm;

3 Qualcomm’s market power; and the effects of Qualcomm’s policies and practices on its

4 rivals and potential rivals, competition, innovation, and consumers.

5 42. Tony (Taekwon) Son is Deputy Senior Manager at LG Electronics, Inc. (“LGE”) in

6 charge of mobile chipsets in the Mobile Communications semiconductor procurement

7 team, and has worked at LGE since July 2004. Mr. Son may testify about any issue

8 addressed in the designated portions of his sworn testimony provided in response to

9 written questions propounded by the FTC and Qualcomm pursuant to the Hague

10 Convention on Evidence, including without limitation LGE’s agreements with

11 Qualcomm; the negotiation of patent licenses and supply agreements with Qualcomm

12 and others; Qualcomm’s policies and practices related to product sales and licensing;

13 Qualcomm’s commitments to license standard essential patents (“SEPs”) on fair,

14 reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets;

15 Qualcomm’s market power; barriers to entry and expansion in modem chip markets;

16 and the effects of Qualcomm’s policies and practices on competition, innovation, and

17 consumers.

18 43. Richard Wang has been Huawei’s Director of Terminal Chipset Platform Planning

19 since 2011. From 2004 through 2007, he was responsible for marketing wireless

20 terminal products for HiSilicon. The FTC may present testimony from Mr. Wang

21 regarding the subjects of his deposition, including without limitation HiSilicon’s

22 negotiations and agreements with Qualcomm; Qualcomm’s policies and practices

23 related to product sales and licensing; Qualcomm’s commitments to license standard

24 essential patents (“SEPs”) on fair, reasonable, and non-discriminatory (“FRAND”)

25 terms; modem chip markets; Qualcomm’s market power; barriers to entry and

26 expansion in modem chip markets; and the effects of Qualcomm’s policies and

27 practices on competition, innovation, and consumers.

28
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1 44. Stefan Wolff held several marketing and managerial positions at Infineon from 1996

2 to 2011, including Vice President and General Manager for RF and Modem, and held

3 similar roles at Intel from 2011 to approximately 2017. The FTC may present

4 testimony from Mr. Wolff regarding the subjects of his deposition, including without

5 limitation, Infineon’s agreements with Qualcomm; limitation modem chip markets;

6 Infineon’s efforts to compete with Qualcomm; Qualcomm’s market power; barriers to

7 entry and expansion in modem chip markets; and the effects of Qualcomm’s policies

8 and practices on competition, innovation, and consumers.

9 45. Monica Yang is a manager in Pegatron’s legal department. The FTC may present

10 testimony from Ms. Yang regarding the subjects of her deposition, including without

11 limitation Pegatron’s agreements with Qualcomm; the negotiation of patent licenses

12 and supply agreements with Qualcomm and others; Qualcomm’s policies and practices

13 related to product sales and licensing; Qualcomm’s commitments to license standard

14 essential patents (“SEPs”) on fair, reasonable, and non-discriminatory (“FRAND”)

15 terms; modem chip markets; Qualcomm’s market power; barriers to entry and

16 expansion in modem chip markets; and the effects of Qualcomm’s policies and

17 practices on competition, innovation, and consumers.

18 46. Nanfen (Nancy) Yu is Senior Legal Counsel at Huawei. The FTC may present

19 testimony from Ms. Yu regarding the subjects of her deposition, including without

20 limitation Huawei’s negotiations with and agreements with Qualcomm; Qualcomm’s

21 policies and practices related to product sales and licensing; Qualcomm’s market

22 power; and Qualcomm’s commitments to license standard essential patents (“SEPs”)

23 on fair, reasonable, and non-discriminatory (“FRAND”) terms.

24

25 EXPERT WITNESSES BY LIVE TESTIMONY

26 47. Dr. Robert Akl is an Associate Professor at the University of North Texas and a

27 Senior Member of IEEE, with over 20 years of experience with patents and technology

28
16
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1 in the wireless and networking industry. Dr. Akl may testify about the opinions

2 disclosed in his expert reports and deposition, including cellular patent portfolios.

3 48. Richard Donaldson is a patent and licensing consultant and testifying expert. Mr.

4 Donaldson spent 31 years as a licensing executive and patent attorney at Texas

5 Instruments, Inc., where he developed global patent licensing strategies and negotiated

6 patent licenses, including licenses to SEPs. Mr. Donaldson may testify about the

7 opinions disclosed in his expert reports and deposition, including patent licensing.

8 49. Michael J. Lasinski is a Managing Director and the Chief Executive Officer of 284

9 Partners, LLC, a firm focused on intellectual property valuation, litigation consulting,

10 IP strategy, and IP transactional services. Mr. Lasinski may testify about the opinions

11 disclosed in his expert reports and deposition, including reasonable royalty rates.

12 50. Carl Shapiro is a Professor of the Graduate School at the University of California at

13 Berkeley and is an economist who has studied antitrust, innovation, and competitive

14 strategy for over thirty years. Prof. Shapiro may testify about the opinions disclosed in

15 his expert reports and deposition, including market definition, market power, and harm

16 to competition.

17

18

19

20

21

22

23

24

25

26

27

28
17
FTC’S PRELIMINARY WITNESS LIST
CASE NO. 5:17-CV-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 1 of 13

EXHIBIT C
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 2 of 13

1 DEFENDANT QUALCOMM INCORPORATED’S WITNESS LIST

2 Defendant Qualcomm Incorporated (“Qualcomm”) discloses its list of witnesses,
3 including a summary of each witness, that it may call at trial, other than for impeachment or
4 rebuttal, identifying which witnesses it expects to call live and which it expects to call by
5 deposition. Qualcomm reserves the right to: (1) add or remove witnesses or deposition testimony
6 as necessary, including, but not limited to, in response to witness testimony, exhibits or other
7 evidence that the Federal Trade Commission (“FTC”) may proffer; (2) call witnesses or use
8 deposition testimony that may be necessary to lay the foundation for the admissibility of evidence
9 if the Parties are unable to agree to the admissibility of such evidence; (3) call additional
10 witnesses or use deposition testimony not on this list for the purposes of rebuttal or impeachment;
11 and (4) call any witness identified by the FTC on its live or by-designation witness lists or use
12 any deposition testimony designated by the FTC. By including witnesses on its lists, Qualcomm
13 assumes no obligation to call or make available any witness at trial.
14 In the event that a witness from whom Qualcomm anticipates offering live testimony is
15 unavailable to testify at trial, Qualcomm reserves the right to use deposition testimony given by
16 such witness. For witnesses as to which Qualcomm currently believes it to be reasonably possible
17 that the witness will not be available for trial and not within 100 miles of the courthouse,
18 Qualcomm has listed the witness both as a live witness and as a witness by deposition. In the
19 event that the FTC objects to the use of Qualcomm’s deposition designations at trial, Qualcomm
20 reserves the right to call the deponent to provide live testimony.
21 Qualcomm further reserves the right to update the subjects on which the persons identified
22 as witnesses may testify based on new information (including any newly produced documents);
23 and to question the persons identified herein on any topics on which that person testified in a
24 deposition or investigational hearing, or regarding any matter that is discussed in any document to
25 which that person had access and that is designated as an exhibit by either party.
26

27

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1 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 3 of 13

1 Live Witnesses
2 Derek Aberle was President of Qualcomm Incorporated until January 2018.
3 Mr. Aberle may testify about Qualcomm’s licensing program, practices and negotiations,
4 Qualcomm’s business relationships with cellular device makers, Qualcomm’s corporate strategy,
5 and any other issues addressed in Mr. Aberle’s deposition or investigational hearing or any
6 documents or data introduced into evidence by Qualcomm or the FTC as to which he has
7 knowledge.
8 Baaziz Achour is Senior Vice President of Engineering at Qualcomm
9 Technologies, Inc. (“QTI”). He has been in this role for approximately ten years, and has worked
10 at Qualcomm since 1993. Mr. Achour may testify regarding modem chip engineering,
11 Qualcomm’s contributions to and innovations relating to cellular and non-cellular technologies,
12 Qualcomm’s research and development efforts, Qualcomm’s investments with respect to
13 particular technologies, projects, and/or customers, and any other issues addressed in
14 Mr. Achour’s deposition or documents or data introduced into evidence by Qualcomm or the FTC
15 as to which he has knowledge.
16 Jeffrey Andrews is the Cullen Trust for Higher Education Endowed Professor in
17 the Electrical and Computer Engineering Department of the University of Texas at Austin.
18 Dr. Andrews may testify about the opinions disclosed in his expert reports and deposition.
19 Steven Altman was Vice Chairman of Qualcomm Incorporated until January
20 2014. Mr. Altman may testify about Qualcomm’s licensing program, practices and negotiations,
21 Qualcomm’s business relationships with cellular device makers, Qualcomm’s corporate strategy,
22 and any other issues addressed in Mr. Altman’s deposition or documents or data introduced into
23 evidence by Qualcomm or the FTC as to which he has knowledge.
24 Cristiano Amon is President of Qualcomm, and responsible for oversight of
25 Qualcomm’s semiconductor business. He was previously Executive Vice President and President
26 of Qualcomm CDMA Technologies (“QCT”). He started at Qualcomm in 1995 and since then,
27 excluding a period from June 1999 to November 2001 during which he was not employed by
28
2 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 4 of 13

1 Qualcomm, has held various other roles relating to Qualcomm’s semiconductor business.
2 Mr. Amon may testify regarding Qualcomm’s research and development efforts, Qualcomm’s
3 contributions to and innovations relating to cellular and non-cellular technologies, Qualcomm’s
4 modem chip sales, competition for sales of modem chips, Qualcomm’s business relationships
5 with OEMs, specific negotiations relating to the sale of chips, Qualcomm’s investments with
6 respect to particular technologies, projects, and/or customers, and any other issues addressed in
7 Mr. Amon’s deposition or investigational hearing or documents or data introduced into evidence
8 by Qualcomm or the FTC as to which he has knowledge.
9 Lorenzo Casaccia is Vice President of Technical Standards of Qualcomm Europe
10 Inc. Mr. Casaccia may testify about Qualcomm’s role and history in the development of cellular
11 standards and the cellular standardization process, and any other issues addressed in
12 Mr. Casaccia’s depositions or documents or data introduced into evidence by Qualcomm or the
13 FTC as to which he has knowledge. Mr. Casaccia has been designated as a fact witness who may
14 give expert opinions in this case and may testify about the opinions and topics disclosed in his
15 expert disclosure, served pursuant to Fed R. Civ. P. 26(a)(2)(C), and depositions.
16 Liren Chen is Senior Vice President of Engineering and Legal Counsel at QTL.
17 Mr. Chen may testify about Qualcomm’s contributions to and innovations relating to cellular and
18 non-cellular technologies, Qualcomm’s practices regarding patent prosecution and licensing, the
19 scope and history of Qualcomm’s patent portfolio, including its patented cellular technologies and
20 patented non-cellular technologies, and any other issues addressed in Mr. Chen’s deposition or
21 documents or data introduced into evidence by Qualcomm or the FTC as to which he has
22 knowledge.
23 Tasneem Chipty is the Founder and Managing Principal at Matrix Economics.
24 Dr. Chipty is an economist who has studied antitrust and competition economics, econometrics,
25 and industrial organization for over twenty years. Dr. Chipty may testify about the opinions
26 disclosed in her expert report and deposition.
27

28
3 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 5 of 13

1 Fabian Gonell is Senior Vice President, Licensing Strategy and Legal Counsel at
2 QTL. Mr. Gonell may testify about Qualcomm’s licensing program, practices and negotiations,
3 Qualcomm’s business relationships with cellular device makers and patent licensing pools and
4 platforms, and any other issues addressed in Mr. Gonell’s depositions or investigational hearing,
5 and any other documents or data introduced into evidence by Qualcomm or the FTC as to which
6 he has knowledge.
7 Michael Hartogs was Senior Vice President and Division Counsel at QTL until
8 January 2012. Mr. Hartogs may testify about Qualcomm’s licensing program, practices and
9 negotiations, Qualcomm’s business relationships with cellular device makers, and any other
10 issues addressed in Mr. Hartogs’s deposition or documents or data introduced into evidence by
11 Qualcomm or the FTC as to which he has knowledge.
12 Bertram Huber is a Principal of IP*SEVA and is a Lecturer at the University of
13 Tübingen/Germany on Laws of IPRs, International IP Strategy and Management and License
14 Agreements/Licensing Law. He has extensive negotiation and technology licensing experience,
15 and has participated in the elaboration of IPR/patent policies at ETSI. Dr. Huber may testify
16 regarding the subject matter of his expert report.
17 Irwin Jacobs is the co-founder and former CEO, Chairman and Director of
18 Qualcomm. Mr. Jacobs may testify about the founding of Qualcomm, the development and roll-
19 out of CDMA technology, Qualcomm’s fundamental contributions to cellular and non-cellular
20 technologies, Qualcomm’s post-CDMA innovations, Qualcomm’s licensing program, practices
21 and negotiations, any other issues addressed in his deposition, and any documents or data
22 introduced into evidence by Qualcomm or the FTC as to which he has knowledge.
23 Chris Johnson is a partner at Bain & Company, where he has worked since 2010.
24 Mr. Johnson may testify about work that Bain performed for Intel Corporation, and any issues
25 addressed in his deposition or documents or data introduced into evidence by Qualcomm or the
26 FTC as to which he has knowledge.
27

28
4 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 6 of 13

1 Keith Kressin is Senior Vice President, Product Management at QTI. Mr. Kressin
2 may testify about Qualcomm’s contributions to and innovations relating to cellular and non-
3 cellular technologies, Qualcomm’s product roadmap, competition for sales of modem chips,
4 Qualcomm’s relationship with OEMs, and any other issues addressed in Mr. Kressin’s deposition
5 or documents or data introduced into evidence by Qualcomm or the FTC as to which he has
6 knowledge.
7 Louis Lupin was Legal Consultant for QTL until August 2014. Prior to that,
8 Mr. Lupin was Executive Vice President and General Counsel of Qualcomm Incorporated until
9 August 2007. Mr. Lupin may testify about Qualcomm’s licensing program, practices and
10 negotiations, Qualcomm’s business relationships with cellular device makers, and any other
11 issues addressed in Mr. Lupin’s deposition or documents or data introduced into evidence by
12 Qualcomm or the FTC as to which he has knowledge.
13 Taraneh Maghame is Senior Director of Wireless Programs and Corporate
14 Development at Via Licensing Corporation, and was a member of Apple’s patent licensing and
15 strategy group from 2010 to 2016. Ms. Maghame may testify about Via Licensing’s licensing
16 and business practices and any issues addressed in her deposition or documents or data introduced
17 into evidence by Qualcomm or the FTC as to which she has knowledge.
18 Durga Malladi is Senior Vice President Engineering and General Manager of
19 4G/5G at QTI. Dr. Malladi may testify about Qualcomm’s research and development efforts and
20 innovations, Qualcomm’s role in the development of cellular technologies and cellular standards,
21 his patented inventions, and any other issues addressed in Dr. Malladi’s deposition or documents
22 or data introduced into evidence by Qualcomm or the FTC as to which he has knowledge.
23 Robert Mansfield was the Senior Vice President of Hardware Engineering from
24 fall 2005 to early 2012, and then was Senior Vice President of Technologies at Apple from 2012
25 to 13. Mr. Mansfield may testify about the design, engineering, assembly, procurement, and sale
26 of Apple’s cellular products, Apple’s procurement of modem chips and other components from
27 Qualcomm and other suppliers, whether modem chip suppliers other than Qualcomm met Apple’s
28
5 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 7 of 13

1 technical and scheduling requirements for Apple cellular products from 2011 to 2014, and any
2 other issues addressed in documents or data introduced into evidence by Qualcomm or the FTC as
3 to which he has knowledge.
4 Steve Mollenkopf is Chief Executive Officer of Qualcomm, a position he has held
5 since March 2014. Prior to being Chief Executive Officer, he was President from November
6 2011 to March 2014, Chief Operating Officer from approximately November 2011 to December
7 2013, and prior to that he was Executive Vice President and President of QCT. He joined
8 Qualcomm in 1994. Mr. Mollenkopf may testify about Qualcomm’s contributions to and
9 innovations relating to cellular and non-cellular technologies, the development and
10 commercialization of cellular technologies, competition for sales of modem chips, the rationale
11 for and negotiation of various agreements with Apple, the superiority and differentiation of
12 Qualcomm’s modem chip products, any other issues addressed in his deposition or investigational
13 hearing, and any documents or data introduced into evidence by Qualcomm or the FTC as to
14 which he has knowledge.
15 Aviv Nevo is the George A. Weiss and Lydia Bravo Weiss University Professor at
16 the Wharton School of Business and Department of Economics at the University of Pennsylvania.
17 Professor Nevo is an economist who has studied antitrust and competition economics,
18 econometrics, and industrial organization for over twenty years. Professor Nevo may testify
19 about the opinions disclosed in his expert report and deposition.
20 Eric Reifschneider was Senior Vice President of QTL until July 2016.
21 Mr. Reifschneider may testify about Qualcomm’s licensing program, practices and negotiations,
22 Qualcomm’s business relationships with cellular device makers and any other issues addressed in
23 Mr. Reifschneider’s deposition or investigational hearing or documents or data introduced into
24 evidence by Qualcomm or the FTC as to which he has knowledge.
25 Alex Rogers is Executive Vice President of Qualcomm and President of QTL,
26 positions he began in 2016. Mr. Rogers may testify about Qualcomm’s licensing program,
27 practices and negotiations, Qualcomm’s recent licensing negotiations and programs, Qualcomm’s
28
6 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 8 of 13

1 relationships with OEMs, any other issues addressed in his deposition, and any documents or data
2 introduced into evidence by Qualcomm or the FTC as to which he has knowledge.
3 Matthias Sauer held various positions at Infineon, including Director of Baseband
4 Architecture, Head of Worldwide for Business Unit Feature Phone, and Senior Director for
5 System Engineering for Business Line Smartphone and RF Engine, from 1998 to 2011.
6 Mr. Sauer is now the Director of Cellular Systems at Apple. Mr. Sauer may testify about the
7 design, engineering, assembly, procurement, and sale of Apple’s cellular products, Apple’s
8 procurement of modem chips and other components from Qualcomm and other suppliers, whether
9 modem chip suppliers other than Qualcomm met Apple’s technical and scheduling requirements
10 for Apple cellular products from 2011 to 2016, and any other issues addressed in Mr. Sauer’s
11 deposition or documents or data introduced into evidence by Qualcomm or the FTC as to which
12 he has knowledge. Mr. Sauer may also testify about Infineon’s design, engineering, manufacture
13 and sale of Infineon chipsets.
14 Mark Schankerman is Professor of Economics at the London School of
15 Economics. Professor Schankerman is an economist who has specialized in intellectual property
16 rights, innovation, university-technology transfer, industrial organization and emerging
17 economics. Professor Schankerman may testify regarding the subject matter of his expert report.
18 Steve Schell was the Senior Director of Wireless Systems Architecture from June
19 2005 to February 2015 at Apple. Mr. Schell may testify about the design, engineering, assembly,
20 procurement, and sale of Apple’s cellular products, Apple’s procurement of modem chips and
21 other components from Qualcomm and other suppliers, whether modem chip suppliers other than
22 Qualcomm met Apple’s technical and scheduling requirements for Apple cellular products from
23 2011 to 2016, and any other issues addressed in Mr. Schell’s deposition or documents or data
24 introduced into evidence by Qualcomm or the FTC as to which he has knowledge.
25 Edward Snyder is the Indra K. Nooyi Dean and William S. Beinecke Professor of
26 Economics and Management at the Yale School of Management. Dr. Snyder began his
27 professional career as an economist with the U.S. Department of Justice’s Antitrust Division. He
28
7 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 9 of 13

1 earned a Ph.D. in Economics and an M.A. in Public Policy from the University of Chicago.
2 Qualcomm expects Dr. Snyder will testify regarding the subject matter of his expert reports,
3 including the modem chip industry and Apple’s and the CMs’ theories of antitrust harm.
4 James Thompson is Executive Vice President of Engineering and Chief
5 Technology Officer of QTI. Previously, he was Senior Vice President of QCT, and
6 Mr. Thompson has overseen all of QCT engineering since 2004. Mr. Thompson may testify
7 about Qualcomm’s contributions to and innovations relating to cellular and non-cellular
8 technologies, modem chip engineering, Qualcomm’s research and development efforts,
9 Qualcomm’s investments with respect to particular technologies, projects, and/or customers,
10 competition for sales of modem chips, and any other issues addressed in Mr. Thompson’s
11 deposition or documents or data introduced into evidence by Qualcomm or the FTC as to which
12 he has knowledge.
13 Godavarthi Varadarajan is the Senior Partner and Managing Director of Boston
14 Consulting Group (“BCG”). Mr. Varadarajan may testify about BCG’s work relating to strategic
15 alternatives under consideration by a special committee of Qualcomm’s Board of Directors in and
16 around 2015 and any other issues addressed in Mr. Varadarajan’s deposition or investigational
17 hearing or any subject raised by Qualcomm or the FTC at trial as to which Mr. Varadarajan has
18 knowledge.
19 B.J. Watrous has been Chief IP Counsel at Apple since he began at the company
20 in June 2011. Mr. Watrous may testify about Apple’s business relationship with Qualcomm, the
21 practice within the cellular industry of licensing cellular SEPs and/or other patents, Apple’s
22 licensing practices, and any other issues addressed in Mr. Watrous’s deposition or documents or
23 data introduced into evidence by Qualcomm or the FTC as to which he has knowledge.
24 Dirk Weiler has been Nokia’s Head of Standards Policy since 2017. He was
25 previously a Vice President and Manager at Siemens AG, which Nokia acquired in 2006. From
26 that point onwards, he became Head of Standards Management at Nokia. Mr. Weiler was Chair
27 of ETSI’s IPR Special Committee from 2008 through November 2018; was a member of the
28
8 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 10 of 13

1 ETSI Board from 2008 to the present, serving ex officio from 2010 to 2014, and as chairman
2 from 2014 to the present. He was chair of ETSI’s General Assembly, ETSI’s highest ranking
3 governance body, from 2010 to 2014. Mr. Weiler may testify about cellular industry licensing
4 practices, including Nokia’s licensing practices, the ETSI Intellectual Property Rights Policy, and
5 any other issues addressed in Mr. Weiler’s deposition or documents or data introduced into
6 evidence by Qualcomm or the FTC as to which he has knowledge.
7 Tim Williams is the Chief Executive Officer of Beach Technologies, LLC, a
8 consulting firm focused on technology, intellectual property, and business consulting.
9 Dr. Williams may testify about the opinions disclosed in his expert reports and deposition.
10 David Wise is Senior Vice President and Treasurer at Qualcomm, positions he has
11 held since December 2015. Mr. Wise may testify about strategic alternatives under consideration
12 by a special committee of Qualcomm’s Board of Directors in and around 2015, documents on the
13 FTC’s exhibit list that he drafted, revised, or received, and any other issues addressed in Mr.
14 Wise’s deposition or documents or data introduced into evidence by Qualcomm or the FTC as to
15 which he has knowledge.
16 Testimony by Deposition
17 Each of the below-listed witnesses may testify about any issue addressed in the
18 designated portions of his or her deposition testimony:
19 Derek Aberle was President of Qualcomm from 2014 until January 3, 2018, when
20 he left the company, and was a paid consultant for Qualcomm after his departure from the
21 company until April 2018. His prior roles at Qualcomm included Legal Counsel (2000-2005),
22 General Manager of Licensing (2005-2011), and Group President of QTL (2011-2014).
23 Seungho Ahn is Head of Samsung’s IP Center and is responsible for all matters
24 relating to intellectual property at Samsung.
25 Steven Altman was President of Qualcomm from approximately 2005 to 2011,
26 and Vice Chairman from approximately 2011 until his retirement in January 2014.
27

28
9 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 11 of 13

1 Hermann Eul was corporate vice president and general manager of the Mobile
2 and Communications Group at Intel Corporation until 2016, and had worked at Intel since 2011,
3 after Intel acquired his former employer, Infineon.
4 John Grubbs is Senior Director of IP Transactions at BlackBerry.
5 Alex Hojin Kang is the former Director of Purchasing at Samsung Mobile, and
6 was employed by Samsung from 1987 to 2016.
7 Sanjay Jha is the former CEO of GlobalFoundries and former chairman and CEO
8 of Motorola Mobility. Mr. Jha was President of QCT from 2003 to 2008 and COO of Qualcomm
9 from 2006 to 2008.
10 Chris Johnson is a partner at Bain & Company, where he has worked since 2010.
11 Asha Keddy is the manager of Intel’s Next Generation and Standards team and
12 has worked at Intel since 1999.
13 Injung Lee is the Head of the License Team at the IP Center at Samsung.
14 Thomas Lindner is Head of the Cellular Modem & Mobile Connectivity business
15 line at Intel and has worked at Intel since 2011, after Intel acquired his former employer,
16 Infineon.
17 Taraneh Maghame is Senior Director of Wireless Programs and Corporate
18 Development at Via Licensing Corporation, and was a member of Apple’s patent licensing and
19 strategy group from 2010 to 2016.
20 Isabel Mahe is Managing Director for Greater China at Apple, and was Vice
21 President of Wireless Technology at Apple from 2008 to 2017.
22 Ranae McElvaine is Vice President and Deputy General Counsel of Intellectual
23 Property at InterDigital, where she has worked as an in-house lawyer since 2008.
24 Christina Petersson has been Vice President of Intellectual Property Rights in
25 Ericsson’s legal department since 2011. She was previously Senior Legal Counsel in the
26 Intellectual Property Rights Legal Services group from 2003 to 2011.
27

28
10 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 12 of 13

1 Ilkka Rahnasto is Vice President of Patent Licensing at Nokia. He previously
2 served as an intellectual property lawyer at Nokia from 1997 to 2003, as Head of Intellectual
3 Property from 2003 to 2010 and as Head of Legal for Nokia’s Smartphone Business from 2010 to
4 2014.
5 Robert Rango is the former Executive Vice President and General Manager of
6 Broadcom’s Mobile and Wireless Group. He held that position from 2011 to 2014. He also
7 previously served as Vice President and General Manager of Broadcom’s Networking
8 Infrastructure Group from 2002 to 2004, and as Executive Vice President and General Manager
9 of the Wireless Connectivity Group from 2004 to 2011 (and Senior Vice President therein from
10 2004 to 2005).
11 Spencer Shen has been the Chief Intellectual Property Officer for ZTE since 2016
12 and previously served as ZTE’s Chief Licensing Officer.
13 Dirk Weiler has been Nokia’s Head of Standards Policy since 2017. He was
14 previously a Vice President and Manager at Siemens AG, which Nokia acquired in 2006. From
15 that point onwards, he became Head of Standards Management at Nokia. Mr. Weiler was Chair
16 of ETSI’s IPR Special Committee from 2008 through November 2018; was a member of the
17 ETSI Board from 2008 to the present, serving ex officio from 2010 to 2014, and as chairman
18 from 2014 to the present. He was chair of ETSI’s General Assembly, ETSI’s highest ranking
19 governance body, from 2010 to 2014.
20 Stefan Wolff held several marketing and managerial positions at Infineon from
21 1996 to 2011, including Vice President and General Manager for RF and Modem, and held
22 similar roles at Intel from 2011 to approximately 2017.
23 Martin Zander is Ericsson’s Vice President and Head of Strategic Initiatives and
24 Eco-Systems. He assumed this role in 2017. He previously joined Ericsson in 2000 as Strategic
25 Product Manager. In 2003, he became Product Marketing Manager, and in 2005, he became
26 General Manager of Product Marketing. From 2006 to 2008, he served as Director of Product
27 Management for Mobile Platforms, and from 2008 to 2009 as Director of Portfolio Management
28
11 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-3 Filed 11/29/18 Page 13 of 13

1 and Technology. Between 2009 and 2011, he was ST-Ericsson’s Head of Portfolio Management.
2 After ST-Ericsson dissolved, he rejoined Ericsson in 2015 as Vice President and Head of the
3 Partnering & Strategy Program Office.
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12 Exhibit C
Case No. 5:17-cv-00220-LHK
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 1 of 23

EXHIBIT D
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 2 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
CX0101 CX0101 7/26/2018 Figure 2 of Donaldson Rebuttal Report CX0101-001 CX0101-001 FTC Richard Donaldson
Summary Exhibit: Summary of Contract and
CX0102 CX0102 NA CX0102-001 CX0102-035 FTC Carl Shapiro
Contract Licensing Agreements
Summary Exhibit: Revenues and WCDMA units
CX0103 CX0103 NA sold under WCDMA and CDMA license CX0103-001 CX0103-009 FTC Carl Shapiro
agreements signed between OEMs and Qualcomm
Summary Exhibit: Component Supply Agreements Carl Shapiro, Richard
CX0104 CX0104 NA CX0104-001 CX0104-002 FTC
between Qualcomm and Select OEMs/ODMs Donaldson
Summary Exhibit: Qualcomm and VIA CDMA units
CX0105 CX0105 NA sold under CDMA license agreements between CX0105-001 CX0105-002 FTC Carl Shapiro
OEMs and Qualcomm
Email from Mark Savoy to Tony Blevins, Mei Zhu,
Hank Robinson, et al. re: Apple RFQ response
Tony Blevins; Qualcomm
CX0507 CX0507 9/11/2006 w/Attach: FORM-StdSubscrLicAgmt-WCDMA(8-08- AAPL-FTC-00011519 AAPL-FTC-00011575 Mark Savoy Apple
Executives
06)1.pdf, Apple - Third Party Paper and
Letter1 pdf Apple Final.doc1.doc
Email from Bruce Sewell to Steve Altman re:
CX0516 CX0516 2/9/2010 AAPL-FTC-00053777 AAPL-FTC-00053777 Bruce Sewell Apple Steve Altman
checking in
Email from Saku Hieta to Jeffrey Williams and
Tony Blevins re: new proposal w/Attach: Tony Blevins, Jeffrey
CX0522 CX0522 10/31/2010 AAPL-FTC-00077229 AAPL-FTC-00077262 Saku Hieta Apple
Commercial Update 10-31 pdf, Commercial Williams; Steven Mollenkopf
Update 10.31.key
Email from Michael Miramontes to David Tom re:
checking in w/Attach: -Apple TA 2011-1-19 Michael Jeffrey Williams, Steven
CX0526 CX0526 1/25/2011 AAPL-FTC-00107137 AAPL-FTC-00107151 Apple
v2 DBT.docx, Deal elements Miramontes Mollenkopf
External(012111)vc.pdf
Email from Tony Blevins to Jeffrey Williams and Jeffrey Williams; Tony
CX0531 CX0531 1/29/2013 AAPL-FTC-00081011 AAPL-FTC-00081011 Tony Blevins Apple
Aaron Schafer re: communication to Hermann Blevins Aaron Schafer
Jeffrey Williams; Tony
CX0534 CX0534 4/24/2014 Apple Presentation: AAPL-FTC-00128661 AAPL-FTC-00128665 Apple
Blevins Aaron Schafer
Email from Aaron Schafer to Robinder Virk re:
CX0557 CX0557 8/3/2012 AAPL-FTC-00035230 AAPL-FTC-00035231 Aaron Schafer Apple Aaron Schafer
summary - keynote
Email from Tony Blevins to Jeffrey Williams and
Jeffrey Williams; Tony
CX0560 CX0560 9/11/2012 Aaron Schafer re: fwd: IMC - summary w/Attach: AAPL-FTC-00010253 AAPL-FTC-00010256 Tony Blevins Apple
Blevins, Aaron Schafer
IMC Exec Brief 9.11.12
Email from Tony Blevins to Isabel Mahe, Stephan
CX0578 CX0578 2/24/2014 Schell, Jeffrey Williams, et al. re: 2nd cellular AAPL-FTC-00128420 AAPL-FTC-00128422 Tony Blevins Apple Tony Blevins, Jeffrey Williams
supplier in 2015?
Email from Jeffrey Williams to Tony Blevins re:
CX0582 CX0582 5/31/2014 AAPL-FTC-00005038 AAPL-FTC-00005039 Jeffrey Williams Apple Tony Blevins, Jeffrey Williams
Qualcomm/update (05/31)
Email from Tony Blevins to Jeffrey Williams re:
fwd: QCOM pricing targets w/Attach
CX0597 CX0597 12/2/2013 AAPL-FTC-00077423 AAPL-FTC-00077440 Tony Blevins Apple Tony Blevins; Jeffrey Williams
2016 RFP LTE modem points to consider.pdf,
QMtg Summary 2013-10-30 rl key
Email from Jeffrey Williams to David Tom, Kim
CX0599 CX0599 8/5/2010 Cooper, and Tony Blevins re: fwd: 3G royalty for AAPL-FTC-00061199 AAPL-FTC-00061200 Jeffrey Williams Apple Tony Blevins; Jeffrey Williams
iPad
Email from Robinder Virk to Achim Pantfoerder,
Aaron Schafer, Aon Mujtaba, et al. re: cellular Tony Blevins, Aaron Schafer;
CX0601 CX0601 8/15/2012 chipset options for 2014 - notes w/Attach: Cellular AAPL-FTC-00080046 AAPL-FTC-00080066 Robinder Virk Apple Stephan Schell; Matthias
Chipset Vendor and Program Alignment 080712 Sauer; Isabel Mahe
v3.pdf
Email from Jeffrey Williams to Marvin Blecker re:
CX0617 CX0617 1/4/2007 AAPL-FTC-00126863 AAPL-FTC-00126864 Jeffrey Williams Apple Jeffrey Williams
our discussion
CX0621 CX0621 9/27/2010 Email from Jeffrey Williams re: Qualcomm AAPL-FTC-00075750 AAPL-FTC-00075750 Jeffrey Williams Apple Jeffrey Williams
Email from Jeffrey Williams re: division meeting,
CX0632 CX0632 8/25/2010 AAPL-FTC-00075738 AAPL-FTC-00075749 Jeffrey Williams Apple Jeffrey Williams
stuff - 4/21
Email from Jeffrey Williams to Steven Mollenkopf Jeffrey Williams, Steven
CX0638 CX0638 5/9/2012 AAPL-FTC-00078886 AAPL-FTC-00078886 Jeffrey Williams Apple
re: San Diego Mollenkopf Tony Blevins
Email from Isabel Mahe to Aon Mujtaba, Jason Shi,
Tony Blevins, Jeffrey
CX0652 CX0652 2/24/2014 and Arun Mathias re: 2nd cellular supplier in APL-QC-FTC_01562169 APL-QC-FTC_01562172 Isabel Mahe Apple
Williams; Stephan Schell;
2015?
Email from Christopher Renner to BJ Watrous,
Steven Holtzman, Sarita Venkat, et al. re: fwd: FTC
Christopher
CX0678 CX0678 12/13/2016 file no. 141-0199 w/Attach: Apple QC Submission APL-QC-FTC_34550449 APL-QC-FTC_34550462 Apple BJ Watrous; Jeffrey Williams
Renner
FRAND 12.12.16.pdf, Specification5 (as
modified).xlsx

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 3 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Dan Lenoski to Isabel Mahe re:
CX0696 CX0696 9/17/2013 APL-QC-FTC_07877224 APL-QC-FTC_07877226 Dan Lenoski Apple Isabel Mahe
alternative BB's
Email from Tony Blevins to Isabel Mahe re: SW
CX0724 CX0724 2/20/2014 APL-QC-FTC_17910720 APL-QC-FTC_17910722 Tony Blevins Apple Tony Blevins; Aaron Schafer;
readiness
Email from Stephan Schell to Robert Mansfield,
BJ Watrous, Jeffrey Williams;
Culbert Michael, John Srouji, et al. re: long-term
CX0754 CX0754 12/14/2012 APL-QC-FTC_23942855 APL-QC-FTC_23942870 Stephan Schell Apple Stephan Schell; Robert
wireless kick-off: slides and notes w/Attach:
Mansfield;
LongTerm kickoff 20121212.key.pdf
Email from Matthias Sauer to Gerhard Martin re: Matthias Sauer; Aaron
CX0850 QX1539 2/13/2013 APL-QC-FTC_11695385 APL-QC-FTC_11695386 Matthias Sauer Apple
data only investigation/6255 status Schafer Stephan Schell
Framework Agreement between Nokia and Apple
CX0851 PX180 5/23/2017 APL-QC-FTC_22481550 APL-QC-FTC_22481706 Apple BJ Watrous; WiliamsJ
(Effective May 23 2017)
Email from Isabel Mahe to Stephan Schell re: Isabel Mahe; Jeffrey Williams;
CX0852 PX350_Mahe 1/25/2013 APL-QC-FTC_12122764 APL-QC-FTC_12122765 Isabel Mahe Apple
MC? Stephan Schell
Email from Tony Blevins to Isabel Mahe re: SW Isabel Mahe; Aaron Schafer;
CX0853 PX357_Mahe 2/20/2014 APL-QC-FTC_07878280 APL-QC-FTC_07878281 Tony Blevins Apple
readiness Tony Blevins
Email from Isabel Mahe to Tony Blevins, Stephan Isabel Mahe; Jeffrey Williams;
CX0854 PX358_Mahe 2/22/2014 Schell and Jeffrey Williams re: 2nd cellular AAPL-FTC-00075234 AAPL-FTC-00075236 Isabel Mahe Apple Stephan Schell; Tony Blevins;
supplier in 2015? Aaron Schafer

CX0855 PX540 2/24/2014 Apple Presentation: AAPL-FTC-00108170 AAPL-FTC-00108211 Apple Aaron Schafer; Tony Blevins
Email from Tony Blevins to Jeffrey Williams re:
CX0856 PX689 9/10/2014 AAPL-FTC-00073946 AAPL-FTC-00073947 Tony Blevins Apple Tony Blevins; Jeffrey Williams
QCOM/Mollenkopf
Cristiano Amon; Aaron
Email from Tony Blevins to Jeff Risher, BJ
CX0857 PX691 4/10/2014 AAPL-FTC-00066122 AAPL-FTC-00066124 Tony Blevins Apple Schafer; Tony Blevins; BJ
Watrous, David Tom, et al. re: fwd:
Watrous
Email from Tony Blevins to KhanS re: fwd: /
CX0858 PX693 12/11/2015 AAPL-FTC-00153047 AAPL-FTC-00153049 Tony Blevins Apple Tony Blevins; Aaron Schafer
QC chipset cost savings
Global Patent License Agreement between
CX0859 QX1377 12/19/2015 APL-QC_00451103 APL-QC_00451155 Apple BJ Watrous; WiliamsJ
Ericsson and Apple (Effective Dec. 19, 2015)
Apple Presentation:
CX0860 QX1384 10/16/2012 AAPL-FTC-00131936 AAPL-FTC-00131944 Boris Teksler Apple Jeffrey Williams; BJ Watrous
Williams
Email from Jeffrey Williams re: Call with Paul
CX0861 Qualcomm 1/11/2011 APL-QC-FTC_08272303 APL-QC-FTC_08272304 Jeffrey Williams Apple Jeffrey Williams
Jacobs
Exhibit 42
Email from Eric Reifschneider to Xuxin Cheng,
Eric Eric Reifschneider, Jason
CX1000 CX1000 5/8/2013 Jeffrey Altman, Robert (Xiaopeng) An, et al. re: FTC-HUAWEI-0001208 FTC-HUAWEI-0001211 Huawei
Reifschneider Ding, Nancy (Nanfun) Yu
Email from Xuxin Cheng to Eric Reifschneider,
Eric Reifschneider, Jason
CX1004 CX1004 3/5/2014 Jason Ding, Nancy (Nanfun) Yu, et al. re: new FTC-HUAWEI-0001259 FTC-HUAWEI-0001269 Xuxin Cheng Huawei
Ding, Nancy (Nanfun) Yu
confidential Qualcomm proposal
CX1009 CX1009 1/20/2009 FTC-HUAWEI-0002096 FTC-HUAWEI-0002121 Huawei Nancy (Nanfun) Yu
Email from Xuxin Cheng to Fabian Gonell, Liren
Chen, Robert (Xiaopeng) An, et al. re: QC-HW Fabian Gonell, Liren Chen,
CX1061 CX1061 2/17/2017 HUAWEI-QUALCOMM-00021780 HUAWEI-QUALCOMM-00021788 Xuxin Cheng Huawei
discussions w/Attach: mime htm, 2017-02-17 Nancy (Nanfun) Yu
Request for renegotiation pdf
Email from Fabian Gonell to Michael Jian, Kun
Qian, Gaoerwei, et al. re: letter from Fabian Gonell
w/Attach: 2017-10-23 QC Letter to HiSilicon
CX1075 CX1075 10/23/2017 HUAWEI-QUALCOMM-00003831 HUAWEI-QUALCOMM-00005207 Fabian Gonell Huawei Fabian Gonell, Alex Rogers
enclosing patent list draft agreement and
framework-final.pdf,

Email from Jonathan Weiser to Nancy (Nanfun) Jonathan Nancy (Nanfun) Yu, Liren
CX1079 CX1079 7/14/2016 HUAWEI-QUALCOMM-00007584 HUAWEI-QUALCOMM-00007586 Huawei
Yu Michael Chen Luochenli, et al. re: Weiser Chen Fabian Gonell
Ding Apple Huawei Presentation: Fabian Gonell; Alex Rogers;
CX1099 3/29/2017 HUAWEI-QUALCOMM-00193824 HUAWEI-QUALCOMM-00193827 Huawei
Exhibit 8 Jason Ding
Email from Eric Reifschneider to Xuxin Cheng,
Eric Nancy (Nanfun) Yu; Eric
CX1100 QX2303 5/8/2013 Jeffrey Altman, Robert (Xiaopeng) An, et al. re: FTC-HUAWEI-0001208 FTC-HUAWEI-0001211 Huawei
Reifschneider Reifschneider
Email from Xuxin Cheng to Fabian Gonell, Jeffrey
Nancy (Nanfun) Yu; Fabian
Yu Apple Exhibit Altman, Liren Chen, et al. re:
CX1101 6/24/2016 HUAWEI-QUALCOMM-00012571 HUAWEI-QUALCOMM-00012573 Xuxin Cheng Huawei Gonell; Alex Rogers; Liren
2
Chen
Email from Hang Tan to Asha Keddy, David
Ginsberg, June Thanasophon, et al. re: 5GxG
CX1529 CX1529 5/18/2015 86600DOC097253 86600DOC097268 Hang Tan Intel Asha Keddy
small team mtg: rvw core part mock up of MCM
presentation

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 4 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Anthony Lin to Brian Krzanich, Stacy
Smith, Wendell Brooks, et al. re: Vine pre-sign -
CX1598 CX1598 7/28/2015 executive office approval requested by 7/29 please INTEL-QCOM000420594 INTEL-QCOM000420607 Anthony Lin Intel Aicha Evans
w/Attach: Vine Executive Office Approval Materials
72815 vFinal pptx
Email from Stefan Wolff to Hermann Eul, Kevin
CX1599 CX1599 10/31/2014 Constantine, Allon Stabinsky, et al. re: Apple INTEL-QCOM000573550 INTEL-QCOM000573553 Stefan Wolff Intel Aicha Evans
Modem Win Design

Email from Chris Siems to Aicha Evans, Jaklin
Jones, and Chris Siems re: MWC briefing
documents w/Attach:
ATT_Briefing_MWC2013_Tue_Feb_26_12pm pdf;
CX1601 CX1601 2/22/2013 Verizon_Briefing_MWC2013 INTEL-QCOM000118289 INTEL-QCOM000118307 Chris Siems Intel Aicha Evans
_Mon_Feb_25_4pm pdf;
KT_Briefing_MWC2013_Wed_Feb_27_11am pdf;
Inside_Secure_Briefing_Tue_Feb_26_12pm.pdf;
Apple_Briefing_MWC2013_Tue_Feb_26_4pm pdf

Email from Stefan Wolff to Hermann Eul and Aicha
CX1602 CX1602 3/23/2012 INTEL-QCOM001003290 INTEL-QCOM001003290 Stefan Wolff Intel Aicha Evans
Evans re: Apple feedback
Email from Kevin Constantine to Gerhard Schmidt,
Kevin
CX1603 CX1603 10/3/2012 Tomasz Wener, Thomas Lueftner, et al. re: ICE INTEL-QCOM001733382 INTEL-QCOM001733383 Intel Aicha Evans
Constantine
update and next steps
Email from Thomas Lueftner to Hermann Eul,
Stefan Wolff, Aicha Evans, et al. re:
XMM6360/7160 OPR report - WW1249 w/Attach: Thomas
CX1604 CX1604 12/12/2012 INTEL-QCOM002375141 INTEL-QCOM002375216 Intel Aicha Evans
Multi- Lueftner
Comm_OPR_Report_XMM6360_7160_ww1249.pp
tx
Email from Shelagh Glaser to Aicha Evans,
Samuel Spangler, David Weigand, et al. re:
CX1606 CX1606 3/17/2015 wireless BOD whitepaper+ financial one-pager as INTEL-QCOM007900028 INTEL-QCOM007900057 Shelagh Glaser Intel Aicha Evans
of May 7th w/Attach: M 05-18-10 BOD Ex I
Wireless.ppt; M 05-18-10 BOD Ex J Feldberg.pptx
Email from Kevin Constantine to Thomas Lueftner,
Constantine Kevin
CX1607 10/9/2012 Stefan Wolff, Aicha Evans, et al. re: [ICE] LTE INTEL-QCOM005462792 INTEL-QCOM005462796 Intel Aicha Evans
Apple Exhibit 1 Constantine
weekly report - WW39
Email from Kevin Constantine to Aicha Evans,
Constantine Kevin
CX1608 2/2/2013 'WPRD-Staff,' Stefan Wolff, et al. re: Karoo - INTEL-QCOM001660866 INTEL-QCOM001660867 Intel Aicha Evans
Apple Exhibit 2 Constantine
heads up
Wolff Apple Email from Stefan Wolff to Kevin Constantine re:
CX1609 11/1/2014 INTEL-QCOM000573628 INTEL-QCOM000573632 Stefan Wolff Intel Stefan Wolff Aicha Evans
Exhibit 1 Apple Modem Design Win
MCG Market
Wolff Apple Intel Presentation: Gamma Force - "Future of Slim
CX1610 8/12/2014 INTEL-QCOM000588723 INTEL-QCOM000588745 Model Forecast Intel Stefan Wolff
Exhibit 3 Modem- Integrated or Discrete?"
Team
Wolff Apple
CX1611 4/20/2010 Infineon Presentation: Project Mountain INTEL-QCOM005179948 INTEL-QCOM005180050 Stefan Wolff Intel Stefan Wolff
Exhibit 5
VIA Presentation: VIA Telecom LTE/DO support
CX1770 CX1770 04/??/09 VIA-QCOM000617467 VIA-QCOM000617492 VIA Mark Davis
issue Executive Summary
CX1771 CX1771 11/??/08 VIA Presentation: VIA Telecom Presentation VIA-QCOM000638768 VIA-QCOM000638855 VIA Mark Davis
Email from Ker Zhang to Annie Leong re: w/Attach:
CX1774 CX1774 8/27/2014 1B_CarrierReqts9.ppt, 1C_legalenvironment.pptx, VIA-QCOM000704080 VIA-QCOM000704126 Zhang Ker VIA Mark Davis
1A_Workshop for Annie v2.pptx
Email from John Sun to Mark Davis, Ker Zhang,
CX1775 CX1775 12/11/2012 VIA-QCOM000705806 VIA-QCOM000705807 John Sun VIA Mark Davis
Stanley Wei et al. re: follow-up
Email from Mark Davis to Ker Zhang re: patents/
CX1785 CX1785 8/11/2014 VIA-QCOM000564628 VIA-QCOM000564628 Mark Davis VIA Mark Davis
Intel
Amendment to ASIC Patent License Agreement Derek Aberle; Eric
CX1800 CX1800 3/31/2015 between Qualcomm and LSI Logic (Effective Mar. VIA-QCOM000537755 VIA-QCOM000537756 VIA Reifschneider; Qualcomm
31 2015) Executives
Email from Mark Davis to Ewa Gawora, Douglas
Martel, Brahm Parasher, et al. re: MDG - list of
Mark Davis; Marvin Blecker;
CX1801 QX67 9/8/2014 questions and updated ppt w/Attach: VIA-QCOM000115035 VIA-QCOM000115043 Mark Davis VIA
Derek Aberle
20140910_MDG_ VIATelecom_v4.pptx;
VIATelecom unused slides pptx
CX2005 CX2005 6/26/2015 Motorola Presentation: Chipsets MOTO-QUAL-01601575 MOTO-QUAL-01601575 Motorola Todd Madderom

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REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Darrell Zunigha to Todd Madderom,
Matt Brown, Kristen Yang, et al. re:
CX2017 CX2017 5/29/2015 MOTO-QUAL-01197192 MOTO-QUAL-01197200 Darrell Zuniga Motorola Todd Madderom

CX2018 CX2018 6/5/2015 MBG Procurement Weekly Summary MOTO-QUAL-01933599 MOTO-QUAL-01933608 Motorola Todd Madderom
Email from Todd Madderom to Christian Eigen, Ira
Blumberg, Paul Pitarra, et al. re: potential slides
CX2060 CX2060 10/21/2016 MOTO-QUALSUB-00149570 MOTO-QUALSUB-00149571 Todd Madderom Motorola Ira Blumberg, Todd Madderom
for Qualcomm discussion w/Attach: QTL Briefing --
Rev 1.pptx
Email from Rich Lockwood to LV Hui, Sara Shi,
CX2065 CX2065 11/11/2016 and Todd Madderom re: MBG 2017 price MOTO-QUALSUB-00181526 MOTO-QUALSUB-00181526 Rich Lockwood Motorola Todd Madderom
configuration summary Nov 9 2016.pdf
Email from Yang Chu to Wenhui Chen, Ira
CX2079 CX2079 12/20/2013 LENOVO-QUALSUB-00013373 LENOVO-QUALSUB-00013380 Yang Chu Motorola Ira Blumberg
Blumberg, Kathryn Tsirigotis, et al. re: alternative
Email from Louise Roberts to Christian Eigen,
Ira Blumberg Eric
CX2093 CX2093 12/17/2015 Sanjay Vanjani, David Kenzer, et al. re: MOTO-QUALSUB-01102003 MOTO-QUALSUB-01102005 Louise Roberts Motorola
Reifschneider Cristiano Amon

Email from Liu Jun to Jay Clemens, Wenhui Chen,
Blumberg Apple
CX2120 11/16/2013 Kathryn Tsirigotis, et al. re: Qualcomm matter LENOVO-QUALSUB-00013080 LENOVO-QUALSUB-00013082 Liu Jun Motorola Ira Blumberg
Exhibit 1
ATTORNEY CLIENT PRIVILEGED
Blumberg Apple
CX2121 4/25/2015 Lenovo Presentation: Qualcomm Update MOTO-QUAL-01830543 MOTO-QUAL-01830543 Motorola Ira Blumberg
Exhibit 4
Blumberg Apple Meeting Notes from Qualcomm/Lenovo meeting on
CX2122 8/20/2015 MOTO-QUAL-01935722 MOTO-QUAL-01935723 Motorola Ira Blumberg
Exhibit 5 June 23 2015
Madderom Apple Motorola Presentation:
CX2123 ??/??/15 MOTO-QUALSUB-00179713 MOTO-QUALSUB-00179713 Motorola Todd Madderom
Exhibit 1
Madderom Apple Motorola Presentation: Qualcomm Strategy
CX2124 8/15/2017 MOTO-QUALSUB-01191737 MOTO-QUALSUB-01191737 Motorola Todd Madderom
Exhibit 2 'Moonshot' Model
Madderom Apple Email from Todd Madderom to Hui Lv re: Chipset
CX2125 5/18/2016 MOTO-QUALSUB-01147200 MOTO-QUALSUB-01147200 Todd Madderom Motorola Todd Madderom
Exhibit 3 Weekly
Email from Todd Madderom to LV Hui re: QCOM
Madderom Apple
CX2126 4/25/2016 strategic proposal executive summary w/Attach: MOTO-QUALSUB-00176855 MOTO-QUALSUB-00176857 Todd Madderom Motorola Todd Madderom
Exhibit 5
Strategic Funds.pptx
CX2167 QX2460 12/9/2014 Motorola Presentation: Qualcomm Strategy MOTO-QUAL-01322848 MOTO-QUAL-01322863 Motorola Todd Madderom
Email from Todd Madderom to Hui Lv, Janet
CX2168 QX2465 5/8/2015 Robinson, and Yang Chu re: some slides w/Attach: MOTO-QUAL-01320237 MOTO-QUAL-01320238 Todd Madderom Motorola Todd Madderom
Chipset Strategy - May 2015 pptx
Report on Results of Third Negotiation
CX2564A CX2564A 4/30/2008 SFT-0036165_Official Translation SFT-0036167_Official Translation Samsung Injung Lee
(Official Translation)
PARK, Seung-
Report on Results of Seventh Negotiation Geon; Injung
CX2568A CX2568A 8/29/2008 SFT-0036177_Official Translation SFT-0036179_Official Translation Samsung Injung Lee
Lee; LEE Jae-
Chang
Email from Cheolwoo Ahn to K.H. Lee re: fwd:
CX2587 CX2587 3/19/2008 SFT-0036383 SFT-0036385 Cheolwoo Ahn Samsung Derek Aberle; Injung Lee
March 4th meeting
Email from John Kalkman to Richard Yeh, Seth
CX2608 CX2608 3/27/2012 Bernsen, and Akshay Agrawl re: DragonFly project SFT-0908806 SFT-0908808 John Kalkman Samsung John Kalkman
(modem) update fyi.
CX2609 CX2609 1/9/2013 Rio - CES Executive Meeting Minutes SFT-17832129 SFT-17832130 Samsung John Kalkman
Email from Sehwoong Jeong to Yiwan Wong,
Richard Yeh, John Kalkman, et al. re: Dell meeting Sehwoong
CX2611 CX2611 12/11/2011 SFT-17847579 SFT-17847583 Samsung John Kalkman
executive summary - w/ Steve Lalla VP/GM mobile Jeong
products
Efforts toward supplier diversification for high-
CX2619A CX2619A 8/20/2010 SFT-0014204 _Official Translation SFT-0014230 _Official Translatipn Samsung Alex Hojin Kang
reliance materials
Current Status of Efforts Toward
CX2621A CX2621A 10/14/2011 SFT-0007335_Official Translation SFT-0007347_Official Translation Samsung Andrew Hong, Yooseok Kim
Email from Andrew Hong to Yooseok Kim, You
Ree Kim, and Andrew Hong re:
CX2624 CX2624 12/13/2013 SFT-0013063 SFT-0013106 Andrew Hong Samsung Yooseok Kim

Joint Venture Agreement Draft between NTT
Docomo, Fujitsu Limited, Samsung, NEC
CX2628 CX2628 12/??/11 SFT-0036341 SFT-0036382 Samsung Andrew Hong;
Corporation, Panasonic, and Fujitsu
Semiconductor
CX2639A CX2639A 6/11/2015 Affidavit of Injung Lee SFT-0003734_Official Translation SFT-0003737_Official Translation Injung Lee Samsung Injung Lee

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REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses

Email from Gaby Boy to Eric Reifschneider re:
powerpoint w/Attach: QTL_ P Effect Conf_032615
(no links, no notes).pptx, PLI IP Monetization
Conference Slides - final pptx, ER Presentation -
Derek Aberle, Fabian Gonell,
CX5173 CX5173 2/19/2016 Bay Area Inventor Conference 12-4-13.pptx, Q2017MDL1_02802612 Q2017MDL1_02802617 Gaby Boy Qualcomm
Eric Reifschneider
ER Presentation - QTL Licensing_FINAL 2-19-
2013.pptx,
3. Qualcomm's Licensing Business (06 21.2015
Draft) pptx
Email from Yunhui Chae-Banks to Eric
Yunhui Chae- Derek Aberle, Fabian Gonell,
CX5179 CX5179 10/15/2015 Reifschneider, Derek Aberle, Fabian Gonell, et al. Q2017MDL1_02867962 Q2017MDL1_02867963 Qualcomm
Banks Eric Reifschneider
re: LGE update
Email from Eric Reifschneider to Marvin Blecker, Derek Aberle, Fabian Gonell,
Eric
CX5185 CX5185 10/31/2012 Fabian Gonell, Don Rosenberg, et al. re: legal Q2017MDL1_01199710 Q2017MDL1_01199715 Qualcomm Eric Reifschneider, Alex
Reifschneider
privilege Rogers
Email from Eric Reifschneider to Marvin Blecker,
Eric Derek Aberle, Fabian Gonell,
CX5186 CX5186 10/20/2012 Fabian Gonell, Derek Aberle, et al. re: final draft of Q2017MDL1_01199818 Q2017MDL1_01199822 Qualcomm
Reifschneider Eric Reifschneider
license agreement and royalty credit letter
Email from Eric Reifschneider to Derek Aberle,
Eric Derek Aberle, Fabian Gonell,
CX5191 CX5191 10/16/2012 Marvin Blecker, Thomas Rouse, et al. re: Sony Q2017MDL1_01517525 Q2017MDL1_01517525 Qualcomm
Reifschneider Eric Reifschneider
Mobile update - for now - privileged
Email from Cristiano Amon to Derek Aberle, Derek Aberle, Cristiano Amon,
CX5198 CX5198 6/9/2015 Murthy Renduchintala, Eric Reifschneider, et al. re: Q2017MDL1_01860471 Q2017MDL1_01860473 Cristiano Amon Qualcomm Steven Mollenkopf, Eric
discussion in Bordeaux Reifschneider
Email from Eric Reifschneider to Derek Aberle,
Eric Derek Aberle, Fabian Gonell,
CX5208 CX5208 10/4/2013 Marvin Blecker, Jeffrey Altman, et al. re: Huawei Q2017MDL1_02408023 Q2017MDL1_02408023 Qualcomm
Reifschneider Eric Reifschneider
update
Derek Aberle, Jeffrey Altman
CX5210 CX5210 3/14/2013 QTL Presentation: Lenovo 4G Strategy Q2017MDL1_02658173 Q2017MDL1_02658199 Qualcomm Fabian Gonell, Eric
Reifschneider
Email from Eric Reifschneider to Fabian Gonell,
Eric Derek Aberle, Fabian Gonell,
CX5211 CX5211 7/11/2013 Derek Aberle, Marvin Blecker, et al. re: recap of Q2017MDL1_02739242 Q2017MDL1_02739245 Qualcomm
Reifschneider Eric Reifschneider
Huawei meeting - privileged
Derek Aberle, Steve Altman,
Email from Steven Mollenkopf to Derek Aberle re: Steven
CX5231 CX5231 5/20/2013 Q2017MDL1_02774602 Q2017MDL1_02774605 Qualcomm Fabian Gonell, Steven
update on Huawei - privileged Mollenkopf
Mollenkopf, Eric Reifschneider
Email from Matt Gettinger to Fabian Gonell and
Fabian Gonell, Eric
CX5242 CX5242 11/4/2013 Deborah Dwight re: fwd: Lenovo w/Attach Q2017MDL1_01344367 Q2017MDL1_01344370 Matt Gettinger Qualcomm
Reifschneider

Email from Erik Terjesen to Thomas Rouse, David
Wise, Fabian Gonell, et al. re: attorney client Fabian Gonell, David Wise;
CX5248 CX5248 6/8/2015 Q2017MDL1_01599812 Q2017MDL1_01599866 Erik Terjesen Qualcomm
privileged:// 5G consortium draft for Derek meeting Lorenzo Casaccia
w/Attach: 5G-Consortium Strawman 6_8.pptx
Email from Yunhui Chae-Banks to Derek Aberle,
Alex Rogers, and Fabian Gonell re: LGE w/Attach:
Yunhui Chae- Derek Aberle, Fabian Gonell,
CX5260 CX5260 3/7/2016 LGE-Qualcomm Arbitration Request, Qualcomm Q2017MDL1_02017941 Q2017MDL1_02018040 Qualcomm
Banks Alex Rogers
Response to LG Request for Arbitration_02 18
2016 pdf
Email from Cristiano Amon to James Lederer,
Cristiano Amon, Steven
CX5279 CX5279 11/20/2008 Steven Mollenkopf, Jonathan Weiser, et al. re: Q2017MDL1_00240570 Q2017MDL1_00240574 Cristiano Amon Qualcomm
Mollenkopf
CDMA pricing - what's our position?
Email from Cristiano Amon to Murthy
CX5282 CX5282 1/19/2010 Renduchintala and Alex Katouzian re: strategy Q2017MDL1_01957373 Q2017MDL1_01957374 Cristiano Amon Qualcomm Cristiano Amon
agreement
Email from Cristiano Amon to Jim Doh re: fwd:
CX5287 CX5287 10/15/2012 Q2017MDL1_01998220 Q2017MDL1_01998220 Cristiano Amon Qualcomm Cristiano Amon, Paul Jacobs
GSM chipsets
Email from Cristiano Amon to Derek Aberle, Jeff Derek Aberle, Cristiano Amon,
CX5294 CX5294 6/18/2013 Lorbeck, Murthy Renduchintala, et al. re: attorney- Q2017MDL1_02364232 Q2017MDL1_02364233 Cristiano Amon Qualcomm Paul Jacobs, Steven
client privileged communications - CT proposal Mollenkopf
Email from Fabian Gonell to Eric Reifschneider,
Derek Aberle, Cristiano Amon,
Derek Aberle, Cristiano Amon, et al. re: aw:
CX5301 CX5301 3/25/2014 Q2017MDL1_01194712 Q2017MDL1_01194718 Fabian Gonell Qualcomm Fabian Gonell, Eric
feedback for the offer and follow up meeting -
Reifschneider
privileged
Derek Aberle, Cristiano Amon,
Email from Cristiano Amon to Steven Mollenkopf
CX5308 CX5308 9/6/2015 Q2017MDL1_02013489 Q2017MDL1_02013492 Cristiano Amon Qualcomm Paul Jacobs, Steven
re: confidential
Mollenkopf

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REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from David Wise to Steven Mollenkopf, Paul
Jacobs, Derek Aberle, et al. re: draft
board committee slides for 11/9 meeting w/Attach: Derek Aberle, Cristiano Amon,
CX5419 CX5419 11/5/2015 Boston Consulting Group Pre- Q2017MDL1_02694510 Q2017MDL1_02694577 David Wise Qualcomm Paul Jacobs, Steven
Read 03Nov15.pdf, Nov 5 Committee Mollenkopf, David Wise
Meeting Prep pptx, Board Committee
v56 pdf
Email from Roel Dill to Kevin Frizzell, James
Derek Aberle, Cristiano Amon,
Lederer, Sanjay Mehta, et al. re: final accounting
CX5425 CX5425 4/19/2011 Q2017MDL1_02550896 Q2017MDL1_02550905 Roel Dill Qualcomm Steven Mollenkopf, William
memo: Q2FY11 Transition Agreement
Wyatt; Qualcomm Executives
w/Attach: Incentive offers - FINAL doc
Email from Kathleen Young to Steven Mollenkopf
Derek Aberle, Irwin Jacobs,
and Connie Ybarrondo re: May 2015 board
Paul Jacobs, Steven
CX5428 CX5428 4/30/2015 package w/Attach: Draft Minutes for approval.pdf, Q2017MDL1_02684802 Q2017MDL1_02685098 Kathleen Young Qualcomm
Mollenkopf; Qualcomm
May 5. 2015 Guest Presenters.pdf, May 2015 BoD
Executives
Pkg .. pdf
Email from Kathleen Young to Loretta Gross,
Derek Aberle, David Wise, et al. re: Nov. 9, 2015
special committee on structure w/Attach: 11 09.15
Special Committee Pkg. pdf; 1_Special Committee
on Structure Invitees November 9 2015.pdf;
Derek Aberle, David Wise;
CX5429 CX5429 11/8/2015 2_Draft Minutes of Special Committee Meeting - 10 Q2017MDL1_02634510 Q2017MDL1_02634702 Kathleen Young Qualcomm
Qualcomm Executives
20 15 pdf; 3_Jones Day Report.pdf; 4_
Boston Consulting Group
Presentation.pdf; 5_ Update
November 9, 2015.pdf; 6_Goldman Sachs and
Evercore Presentation pdf
Email from Dere e to Angela Williamson,
Marvin Blecker, and Abbaseh Samimi re:
CX5438 CX5438 7/3/2007 Q2017MDL1_02401282 Q2017MDL1_02401287 Derek Aberle Qualcomm Derek Aberle

Email from Michael Hartogs to Derek Aberle,
Marvin Blecker, Fabian Gonell, et al. re: fwd: Derek Aberle, Fabian Gonell,
CX5451 CX5451 6/24/2009 Q2017MDL1_00457105 Q2017MDL1_00457119 Michael Hartogs Qualcomm
Michael Hartogs, Louis Lupin

Email from Steven Mollenkopf to Eric Derek Aberle, Paul Jacobs,
Steven
CX5481 CX5481 12/15/2014 Reifschneider, Paul Jacobs, Don Rosenberg, et al. Q2017MDL1_00512034 Q2017MDL1_00512035 Qualcomm Steven Mollenkopf, Eric
Mollenkopf
re: Reifschneider
Steve Altman, Irwin Jacobs,
Email from Kathleen Young to Paul Jacobs,
Paul Jacobs, Steven
Barbara Alexander, Don Cruickshank, et al. re:
CX5527 CX5527 5/1/2013 Q2017MDL1_01943487 Q2017MDL1_01943592 Kathleen Young Qualcomm Mollenkopf; Derek Aberle;
May 2013 board briefing material w/Attach: May 6,
Cristiano Amon; Qualcomm
2013 Board Pkg..pdf
Executives
Email from Taylor Cabaniss to William Wyatt re: Derek Aberle; Cristiano Amon;
CX5551 CX5551 4/17/2015 QCT deck for tomorrow's discussion w/Attach: Q2017MDL1_02548395 Q2017MDL1_02548396 Taylor Cabaniss Qualcomm Steven Mollenkopf; William
QCT Target Business Model FY16-17.pptx Wyatt
Email from Kun Qian to Cristiano Amon, Sanjay Cristiano Amon; Eric
CX5592 CX5592 1/24/2013 Mehta, Murthy Renduchintala, et al. re: attorney Q2017MDL1_02923801 Q2017MDL1_02923802 Kun Qian Qualcomm Reifschneider; Steven
client privileged information - Lenovo Mollenkopf
Derek Aberle; Steve Altman;
Fabian Gonell; Eric
CX5612 CX5612 5/27/2013 Q2017MDL1_02927374 Q2017MDL1_02927378 Qualcomm
Reifschneider; Qualcomm
Executives
Email from Fabian Gonell to Amy Olsen re: fwd:
Derek Aberle; Fabian Gonell;
Sony Mobile w/Attach:
CX5620 CX5620 5/30/2013 Q2017MDL1_02322233 Q2017MDL1_02322338 Fabian Gonell Qualcomm Eric Reifschneider; Qualcomm
Executives

Email from Derek Aberle to Abbaseh Samimi re: Derek Aberle; Steve Altman;
CX5703 CX5703 6/18/2004 Q2014FTC04152699 Q2014FTC04152702 Derek Aberle Qualcomm
fwd: Louis Lupin; Michael Hartogs
Email from James Lederer to Steven Mollenkopf Steven Mollenkopf; Derek
CX5705 CX5705 5/20/2010 Q2017MDL1_02910685 Q2017MDL1_02910686 James Lederer Qualcomm
re: R M slides for Mike L meeting Aberle
Email from Sanjay Mehta to James Lederer re: Derek Aberle, Steve Altman,
CX5708 CX5708 11/1/2006 Q2014FTC03840036 Q2014FTC03840037 Sanjay Mehta Qualcomm
Michael Hartogs, Louis Lupin

5:17-cv-0220-LHK-NMC "Qualcomm Executives" includes officers, directors, and other employees with knowledge of the document Page 9 of 22
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 11 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from William Wyatt to Sanjay Mehta, Akash
Palkhiwala, and Marc McCloskey re: QCT strategic Cristiano Amon, Steven
CX5731 CX5731 6/16/2013 Q2014FTC04696814 Q2014FTC04696820 William Wyatt Qualcomm
plans financials w/Attach: Response to Steve's Mollenkopf, William Wyatt
points.pptx
Email from William Wyatt to Marc McCloskey re:
fwd: last round - impact to fy13 budget Cristiano Amon, Steven
CX5739 CX5739 1/9/2013 Q2017MDL1_00382998 Q2017MDL1_00383002 William Wyatt Qualcomm
(prelim) + vs strat plan for 14 and 15 w/Attach: Mollenkopf, William Wyatt
Update v6 0 (3) pptx
Email from William Wyatt to Chenwei Yan re: MTK
CX5753 CX5753 6/22/2012 Q2017MDL1_01625873 Q2017MDL1_01625876 William Wyatt Qualcomm Cristiano Amon, William Wyatt
competition threat at ZTE
Email from William Wyatt to Kevin Frizzell, Alex
CX5760 CX5760 2/29/2012 Tobi, and Edward Burke re: MTK pricing deck Q2017MDL1_02552403 Q2017MDL1_02552404 William Wyatt Qualcomm William Wyatt
w/Attach: MTK March 2012 Pricing Discussion.pptx
Email from William Wyatt to Sanjay Mehta, Taylor
CX5767 CX5767 6/19/2015 Cabaniss, Jiten Bhatt, et al. re: read this - Q2014FTC04721804 Q2014FTC04721807 William Wyatt Qualcomm William Wyatt
what if
Email from Shahin Farahani to Shahin Farahani,
Kedar Kondap, Katie Arner, et al. re: potential new Steven Mollenkopf, William
CX5785 CX5785 2/23/2016 Q2014FTC03955007 Q2014FTC03955009 Shahin Farahani Qualcomm
strategy for MSM8909 w/Attach: 8909 Wyatt
Scenario.xlsx
Email from William Wyatt to
Mauricio Lopez-Hodoyan, Cristiano Amon, Murthy
CX5793 CX5793 10/3/2015 Q2014FTC03959858 Q2014FTC03959860 William Wyatt Qualcomm Cristiano Amon, William Wyatt
Renduchintala, et al. re: action item: QCT
share analysis w/Attach: QCT ASP Impact pptx
Email from William Wyatt to Cristiano Amon,
Akash Palkhiwala, Alex Katouzian, et al. re: fwd:
CX5798 CX5798 5/16/2016 Q2017MDL1_03349609 Q2017MDL1_03349611 William Wyatt Qualcomm Cristiano Amon, William Wyatt
8909 deal w/Attach: 5_13_16 Low end program
review with George.pptx
Derek Aberle, Cristiano Amon,
Email from William Wyatt to Sanjay Mehta re: LTE-
CX5800 CX5800 8/31/2015 Q2017MDL1_03362131 Q2017MDL1_03362133 William Wyatt Qualcomm Paul Jacobs, Steven
U -> risks
Mollenkopf, William Wyatt
Email from Hank Robinson to Hank Robinson,
Derek Aberle, Steven
CX5802 CX5802 7/19/2010 Derek Aberle, Steven Mollenkopf, et al. re: new Q2014FTC03849552 Q2014FTC03849555 Hank Robinson Qualcomm
Mollenkopf, William Wyatt
proposal
Email from Jeremy Blair to Sanjay Mehta, William
Wyatt, Sean Zanderson, et al. re: 11/23/09 draft
CX5809 CX5809 11/24/2009 Q2017MDL1_01132946 Q2017MDL1_01132947 Jeremy Blair Qualcomm William Wyatt
PRC minutes w/Attach: PRC MM
112309 DRAFT.pptx
Email from Matthew Grob to David Wise, Steven Derek Aberle, Cristiano Amon,
CX5913 CX5913 4/20/2015 Mollenkopf, and exc re: exc mtg today w/Attach: QNDCAL00812571 QNDCAL00812573 Matthew Grob Qualcomm Steven Mollenkopf, David
Pentad FY15 Strat Plan (post review update).pptx Wise
Email from Kathleen Young to Derek Aberle re: Derek Aberle, Paul Jacobs,
CX5952 CX5952 8/13/2015 mtg. materials attached. w/Attach: 08.13.15 Q2017MDL1_02688355 Q2017MDL1_02688794 Kathleen Young Qualcomm Steven Mollenkopf; Qualcomm
Special Committee Mtg_Final, complete.pdf Executives
Email from David Wise to Alex Rogers, Roger
Martin, David Cianflone, et al. re: Modem
CX5953 CX5953 12/15/2015 Licensing Perspective - Draft v11 15 pptx w/Attach: Q2014FTC03584363 Q2014FTC03584364 David Wise Qualcomm Alex Rogers, David Wise
Modem Licensing Perspective - Draft v11
15 pptx
Email from Keith Kressin to James Thompson re: Cristiano Amon, Keith Kressin,
CX6001 CX6001 11/1/2015 company all hands help w/Attach: QCT Design Q2014FTC04802352 Q2014FTC04802354 Keith Kressin Qualcomm Steven Mollenkopf, James
Momentum All Hands - Oct 2015 rev 2.pptx Thompson
Email from Keith Kressin to Alex Katouzian re: fwd:
Cristiano Amon, Keith Kressin,
CX6008 CX6008 5/8/2017 strat plan -- slides to complete w/Attach: Roadmap Q2014FTC04873449 Q2014FTC04873450 Keith Kressin Qualcomm
Steven Mollenkopf,
Cadence and Costs rev 01 - 2017.pptx
Email from Keith Kressin to Sanjay Mehta, William
Cristiano Amon, Keith Kressin,
Wyatt, and Ziad Asghar re: fwd: auc comparisons
CX6036 CX6036 9/17/2013 QNDCAL01004583 QNDCAL01004586 Keith Kressin Qualcomm Steven Mollenkopf, James
w/Attach: AUC & perf Comparison across tiers
Thompson, William Wyatt
Final.pptx
Cristiano Amon, Keith Kressin,
Qualcomm Presentation: QCT Chipset Product
CX6055 CX6055 3/2/2015 Q2017MDL1_00000212 Q2017MDL1_00000212 Qualcomm Steven Mollenkopf, James
Roadmaps
Thompson, William Wyatt

5:17-cv-0220-LHK-NMC "Qualcomm Executives" includes officers, directors, and other employees with knowledge of the document Page 10 of 22
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 12 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Roger Martin to Ken Kaskoun and
Jason Kenagy re: fwd: 5G consortium working Derek Aberle, Lorenzo
CX6138 CX6138 4/18/2015 group: review of workstreams - attorney client Q2017MDL1_00950903 Q2017MDL1_00950906 Roger Martin Qualcomm Casaccia, Fabian Gonell, Eric
privileged w/Attach: Reifschneider, David Wise
Tech Input 5G Consortium v1.pptx
Derek Aberle, Cristiano Amon,
Email from James Thompson to Cristiano Amon re: James Fabian Gonell, Steven
CX6250 CX6250 8/6/2016 QNDCAL03133752 QNDCAL03133757 Qualcomm
RFFE MDSA and W FI MDSA Thompson Mollenkopf, Alex Rogers,
James Thompson
Email from James Thompson to George Davis and
James Cristiano Amon, Steven
CX6311 CX6311 10/2/2013 Murthy Renduchintala re: slides from today on Q2014FTC04815247 Q2014FTC04815248 Qualcomm
Thompson Mollenkopf, James Thompson
QCT opex w/Attach: OpEx control 10_1_13 r1.pptx
Baaziz Achour, Cristiano
Email from James Thompson to Sandeep Pandya,
James Amon, Steven Mollenkopf,
CX6312 CX6312 10/3/2013 Cristiano Amon, Baaziz Achour, et al. re: 9x22 or QNDCAL04455114 QNDCAL04455120 Qualcomm
Thompson James Thompson, William
9x25? - ***please read*** Apple meeting today
Wyatt
Email from James Thompson to Steven Mollenkopf James Cristiano Amon, Steven
CX6333 CX6333 8/4/2017 QNDCAL03926397 QNDCAL03926398 Qualcomm
and Cristiano Amon Re: Samsung thoughts Thompson Mollenkopf, James Thompson

Baaziz Achour, Cristiano
Email from Natalie Young to Steven Mollenkopf,
Amon, Keith Kressin, Steven
CX6334 CX6334 11/11/2011 QCT pc exec, Mark Barnett, et al. re: product QNDCAL02589409 QNDCAL02589699 Natalie Young Qualcomm
Mollenkopf, James Thompson;
council: Elan MDM9x25 PC2
Qualcomm Executives
Email from Lorenzo Casaccia to Edward
Tiedemann, Jr., Stein Lundby,
Ananthapadmanabhan Kandhadai, et al. re: Lorenzo Baaziz Achour, Lorenzo
CX6336 CX6336 6/8/2009 QNDCAL00244983 QNDCAL00245010 Qualcomm
standards review task force - update w/Attach: Casaccia Casaccia, Fabian Gonell
ATT00001.htm; Standards_Task_Force - 3GPP
input.pdf
Email from Lorenzo Casaccia to Peter Gaal, Dino
Lorenzo Lorenzo Casaccia, Fabian
CX6373 CX6373 3/22/2017 Flore, Etienne Chaponniere, et al. re: Ericsson QNDCAL00286684 QNDCAL00286687 Qualcomm
Casaccia Gonell, Alex Rogers
tries to avoid patent war by publishing rates for 5G
Email from Peter Carson to Peter Carson, Andy
Baaziz Achour, Cristiano
Oberst, Cristiano Amon, et al. re: review final draft
CX6381 CX6381 6/5/2010 Q2014FTC03672180 Q2014FTC03672181 Peter Carson Qualcomm Amon, Keith Kressin, Steven
modem strat plan [latest draft attached] w/Attach:
Mollenkopf
ModemStratPlan 7-June10 v5.pptx
Email from Serge Willenegger to Keith Kressin,
Baaziz Achour, Cristiano
Pranesh Sinha, Andy Oberst, et al. re: core strat Serge
CX6393 CX6393 5/28/2015 Q2014FTC04332009 Q2014FTC04332011 Qualcomm Amon, Keith Kressin, Steven
plan review < MDM/modem w/Attach: Strat Plan Willenegger
Mollenkopf
MDM.pptx
Email from Baaziz Achour to Pillappakkam Srinivar
CX6407 CX6407 8/19/2015 re: how can we be sure Samsung will not sell their Q2014FTC03666092 Q2014FTC03666092 Baaziz Achour Qualcomm Baaziz Achour
solution to external customer <eom>
Email from JungSheek Juhn to Marvin Blecker,
JungSheek Derek Aberle, Marvin Blecker,
CX6418 CX6418 9/15/2003 oaktree@lge.com, Greg Cobb, et al. re Q2014FTC03375550 Q2014FTC03375555 Qualcomm
Juhn Michael Hartogs, Louis Lupin
Email from Marvin Blecker to Derek Aberle,
Derek Aberle, Marvin Blecker,
CX6430 CX6430 6/30/2011 Michael Hartogs, Roy Hoffinger, et al. re: Via Q2017MDL1_00414492 Q2017MDL1_00414495 Marvin Blecker Qualcomm
Michael Hartogs, Alex Rogers
meeting summary
Email from Marvin Blecker to Roy Hoffinger, Derek Derek Aberle, Marvin Blecker,
CX6436 CX6436 1/13/2009 Q2017MDL1_00680740 Q2017MDL1_00680747 Marvin Blecker Qualcomm
Aberle, and Michael Hartogs re: Via #51 Michael Hartogs, Paul Jacobs
Transcript: Qcom - Qualcomm Inc. New York Derek Aberle, Paul Jacobs,
CX6439 CX6439 11/17/2010 QNDCAL03941575 QNDCAL03941630 Qualcomm
Analyst Meeting Steven Mollenkopf
Email from Derek Aberle to Marvin Blecker, Paul
Derek Aberle, Steve Altman,
Jacobs, Michael Hartogs, et al. re: assurances --
CX6449 CX6449 9/6/2006 Q2017MDL1_01457177 Q2017MDL1_01457184 Derek Aberle Qualcomm Michael Hartogs, Paul Jacobs,
confidential w/Attach:
Louis Lupin,
Email from Marvin Blecker to Genehyuk Choi, YS
Cho, Haso Choi, et al. re:
CX6469 CX6469 1/7/2002 QNDCAL00668926 QNDCAL00668997 Marvin Blecker Qualcomm Derek Aberle

Email from Marvin Blecker to Steve Altman, Sanjay
Derek Aberle, Steve Altman,
Jha, Don Rosenberg, et al. re: Huawei signed a
CX6477 CX6477 7/20/2008 Q2017MDL1_01436915 Q2017MDL1_01436919 Marvin Blecker Qualcomm Marvin Blecker Michael
5year strategic partnership agreement with QC
Hartogs, Paul Jacobs
legal issues

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 13 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Eric Reifschneider to Derek Aberle,
Fabian Gonell, and Marvin Blecker re: QGT royalty Eric Derek Aberle, Fabian Gonell,
CX6488 CX6488 5/18/2012 Q2017MDL1_00761422 Q2017MDL1_00761439 Qualcomm
memo legal privilege w/Attach: QGT - FYE11 Reifschneider Eric Reifschneider
Transfer Pricing -.doc
Email from Eric Reifschneider to Derek Aberle,
Eric Derek Aberle, Fabian Gonell,
CX6491 CX6491 11/20/2013 Marvin Blecker, Jeffrey Altman, et al. re: revised Q2017MDL1_01195524 Q2017MDL1_01195526 Qualcomm
Reifschneider Eric Reifschneider
Qualcomm strat fund proposal - confidential
Derek Aberle, Fabian Gonell,
Email from Eric Reifschneider to Derek Aberle, Eric
CX6495 CX6495 10/28/2012 Q2017MDL1_01517506 Q2017MDL1_01517507 Qualcomm Steven Mollenkopf, Eric
Marvin Blecker, Fabian Gonell, et al. Reifschneider
Reifschneider
Email to Derek Aberle re: fwd: preliminary meeting Eric Derek Aberle, Fabian Gonell,
CX6498 CX6498 4/9/2013 Q2017MDL1_01736777 Q2017MDL1_01736777 Qualcomm
with Huawei Reifschneider Eric Reifschneider
Email from Eric Reifschneider to Thomas Rouse,
Jeffrey Altman, and Deborah Dwight re: Huawei Eric Eric Reifschneider, Jeffrey
CX6508 CX6508 7/26/2013 Q2017MDL1_02728478 Q2017MDL1_02728483 Qualcomm
call notes 7-25-13 w/Attach: Huawei Call Notes 7- Reifschneider Altman
25-13 + ER.docx
Email from Eric Reifschneider to Mark Snyder,
Eric Eric Reifschneider, Derek
CX6513 CX6513 12/11/2013 Chris Longman, and Victoria Chen re: fwd: report Q2017MDL1_02822764 Q2017MDL1_02822765 Qualcomm
Reifschneider Aberle, Fabian Gonell
on call with Huawei -- privileged
Email from Eric Reifschneider to Derek Aberle and Eric Eric Reifschneider; Derek
CX6516 CX6516 5/2/2013 Q2017MDL1_02882885 Q2017MDL1_02882885 Qualcomm
Marvin Blecker re: Oppo - privileged Reifschneider Aberle
Eric Reifschneider, Derek
Email from Eric Reifschneider to Fabian Gonell,
Eric Aberle, Fabian Gonell,
CX6522 CX6522 2/23/2012 Derek Aberle, Don Rosenberg, et al. re: E Q2017MDL1_02910181 Q2017MDL1_02910186 Qualcomm
Reifschneider Michael Hartogs, Louis Lupin,
divestiture of SEMC
Steven Mollenkopf
Email from Eric Reifschneider to Thomas Rouse
Eric
CX6528 CX6528 5/11/2013 and Deborah Dwight re: Huawei meeting notes QNDCAL03524857 QNDCAL03524868 Qualcomm Eric Reifschneider;
Reifschneider
w/Attach: Huawei meeting 5-10-13 + ER.docx
Email from Eric Reifschneider to Thomas Rouse,
Eric Eric Reifschneider, Fabian
CX6534 CX6534 10/20/2012 Marvin Blecker, Fabian Gonell, et al. re: final draft QNDCAL03527861 QNDCAL03527865 Qualcomm
Reifschneider Gonell; Derek Aberle
of license agreement and royalty credit letter
Email from Eric Reifschneider to Jeffrey Altman,
Eric Eric Reifschneider, Fabian
CX6544 CX6544 8/13/2014 Fabian Gonell, and Deborah Dwight re: Huawei - QNDCAL04021744 QNDCAL04021744 Qualcomm
Reifschneider Gonell;
confidential & privileged
Email from Eric Reifschneider to Fabian Gonell, Eric Reifschneider; Derek
Eric
CX6545 CX6545 7/12/2013 Deborah Dwight, Derek Aberle, et al. re: Huawei QNDCAL04021775 QNDCAL04021775 Qualcomm Aberle; Steve Altman; Fabian
Reifschneider
and FRAND - privileged Gonell
Email from Eric Reifschneider to Derek Aberle,
David Cianflone, Marvin Blecker, et al. re: draft Eric Reifschneider; Fabian
Eric
CX6548 CX6548 5/4/2012 strat plane slide - privileged w/Attach: Slide for QNDCAL04152600 QNDCAL04152601 Qualcomm Gonell; Derek Aberle, Louis
Reifschneider
QTL FY13 Strat Plan - PRIVILEGED AND Lupin;
CONFIDENTIAL DRAFT.PPTX
Email from Luis Guerra to John Sun, Max
Spurlock, Derek Aberle, et al. re: Via AP &
sublicensee list September 2012 w/Attach: Jeffrey Altman; Mark Davis;
CX6552 CX6552 11/13/2012 Q2017MDL1_01757748 Q2017MDL1_01757757 Luis Guerra Qualcomm
Derek Aberle;

CX6579 CX6579 9/5/2017 Email draft re: QNDCAL04202953 QNDCAL04202954 Qualcomm Alex Rogers
Email from Xuxin Cheng to Fabian Gonell, Liren
Chen, Robert (Xiaopeng) An, et al. re: QC-HW
CX6587 CX6587 1/6/2017 Q2014FTC03968020 Q2014FTC03968035 Xuxin Cheng Qualcomm Fabian Gonell, Liren Chen
discussions w/Attach: Response to Qualcomm
feedback-20170106.pdf
Email from Alex Rogers to Gaby Boy re: fwd: some
materials for our Wednesday dinner discussion
w/Attach: 150729 QC LT China Strategy - Selected
CX6594 CX6594 3/23/2016 QNDCAL00711879 QNDCAL00711882 Alex Rogers Qualcomm Derek Aberle; Alex Rogers
slides for QTL (vSent).pptx; 160322 QTL -
collection of relevant materials (vSent).pptx;
160322 QTL - one pager (vSent).pptx
Paul Jacobs; Louis Lupin,
Email from Marvin Blecker to Paul Jacobs, Louis
Fabian Gonell; Eric
CX6605 CX6605 5/6/2007 Lupin, and 'exc' re: scenarios for off site w/Attach: QNDCAL04808594 QNDCAL04808597 Marvin Blecker Qualcomm
Reifschneider; Derek Aberle;
Scenarios MBl.doc
Marvin Blecker
Alex Rogers; Derek Aberle,
Qualcomm Presentation: QTL Strat Plan FY17-
CX6607 CX6607 6/15/2016 Q2017MDL1_03165154 Q2017MDL1_03165297 Qualcomm Steven Mollenkopf, Qualcomm
FY21
Executives

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 14 of 23
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 15 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from David Zuckerman to Steven
Mollenkopf, Paul Jacobs, Akash Palkhiwala, et al.
re: Qualcomm Technologies, Inc. | board meeting
David Cristiano Amon; Steven
CX6846 CX6846 5/17/2017 materials (May 23, 2017) -- privileged and QNDCAL04840556 QNDCAL04840580 Qualcomm
Zuckerman Mollenkopf, Paul Jacobs
confidential w/Attach: QTI Board
Meeting_052317_Final pdf; QTI Notice of BOD
Meeting 5.23.17 dated 5.17.17 pdf
Email from Eric Reifschneider to David Cianflone,
Eric Reifschneider; Derek
Jeffrey Altman, Matt Gettinger, et al. re: fwd: new Eric
CX6850_Mehta CX6850_Mehta 1/21/2014 Q2014FTC04185853 Q2014FTC04185863 Qualcomm Aberle, Cristiano Amon,
Qualcomm proposal - confidential w/Attach: 3RD Reifschneider
Fabian Gonell; William Wyatt
PARTY 3G WHITE PAPER(FINAL)(04-12-13).pdf
Email from Kathleen Young to Loretta Gross,
Derek Aberle, David Wise, et al. re: 12.03.15
Special Committee Meeting w/Attach: 1_Special
Committee on Structure Invitees December 3
Derek Aberle, Paul Jacobs,
2015.pdf; 2_Meeting Agenda_ December 3,
CX6894 CX6894 12/3/2015 QNDCAL00140520 QNDCAL00140632 Kathleen Young Qualcomm Steven Mollenkopf, David
2015.pdf; 3_Goldman Sachs, Evercore
Wise; Qualcomm Executives
Presentation pdf;
.pdf; 5_Draft Investor Script docx pdf;
6_Draft Press Release.docx. pdf; 12.03.15 Special
Committee Mtg Pkg pdf
Email from Sanjay Jha to Steve Altman and Paul Steve Altman; Derek Aberle,
CX6923 CX6923 1/5/2007 Q2017MDL1_01475139 Q2017MDL1_01475142 Sanjay Jha Qualcomm
Jacobs re: LGE Paul Jacobs
Email from Sanjay Jha to James Lederer re:
CX6946 CX6946 2/20/2005 Q2017MDL6_00605267 Q2017MDL6_00605268 Sanjay Jha Qualcomm Steve Altman
Huawei requested datapoints
Email from Sanjay Jha to Don Schrock, David
CX6962 CX6962 3/13/2003 QNDCAL02804710 QNDCAL02804711 Sanjay Jha Qualcomm Steve Altman, Irwin Jacobs
Bush Johan Lodenius et al. re: ASIC licenses
Email from Kathleen Young to Paul Jacobs, Irwin Derek Aberle; Paul Jacobs;
Jacobs, Barbara Alexander, et al. re: July 9, 2012 Steven Mollenkopf; Steve
CX6974 CX6974 7/4/2012 QNDCAL01051173 QNDCAL01051353 Kathleen Young Qualcomm
board briefing materials w/Attach: July 9, 2012 Altman; Irwin Jacobs;
Board Pkg.pdf Qualcomm Executives
Email from Steve Altman to Marvin Blecker, Louis Steve Altman, Louis Lupin;
CX6979 CX6979 3/8/2005 Lupin, Michael Hartogs, et al. re: fwd: Q2017MDL5_04134260 Q2017MDL5_04134267 Steve Altman Qualcomm Michael Hartogs; Derek
Aberle
Email from Steve Altman to Don Schrock, Irwin
CX6981 CX6981 8/24/2001 Q2017MDL5_12370432 Q2017MDL5_12370437 Steve Altman Qualcomm Steve Altman; Irwin Jacobs
Jacobs and David Bush re: K.T. Lee's Letter
CX6983 CX6983 4/22/2004 Email from Steve Altman to Derek Aberle Q2017MDL5_12372255 Q2017MDL5_12372258 Steve Altman Qualcomm Steve Altman; Derek Aberle
Email from Steve Altman to Marvin Blecker re: fwd:
CX6987 CX6987 5/11/2005 QNDCAL04808593 QNDCAL04808593 Steve Altman Qualcomm Steve Altman
certain large company-more
Email from Sanjay Jha to Jonathan Weiser, James
Lederer, Andy Oberst, et al. re: fwd: attorney client Steve Altman Paul Jacobs;
CX6992 CX6992 12/13/2007 Q2017MDL1_03368697 Q2017MDL1_03368689 Sanjay Jha Qualcomm
privileged w/Attach: Discussion Steven Mollenkopf
DRAFT 1 11 08v8 ppt
CX6996 CX6996 8/31/2000 Email from Steve Altman to 'senglish' re: fwd: NEC Q2014FTC03435735 Q2014FTC03435737 Steve Altman Qualcomm Steve Altman
Email from Derek Aberle to Paul Jacobs, Steven Derek Aberle, Paul Jacobs;
CX6998 CX6998 7/2/2012 Mollenkopf, Steve Altman, et al. re: QTL strat plan QNDCAL01051354 QNDCAL01051355 Derek Aberle Qualcomm Steven Mollenkopf; Steve
slides w/Attach: QTL FY13 Strat Plan BOD v2.pptx Altman;
Email from Paul Syrowik to Paul Jacobs, Steve
Altman, Sanjay Jha, et al. re: Attorney Client Steve Altman; Paul Jacobs;
CX7015 CX7015 9/7/2007 Privileged/Project w/Attach: Overview Q2017MDL1_02697837 Q2017MDL1_02697874 Paul Syrowik Qualcomm Michael Hartogs; Derek
Sept 75 PM draft.doc; - BOD DRAFT_9.7.07 Aberle
5pm ppt
Email from Irwin Jacobs to Rich Sulpizio and Steve
CX7022 CX7022 1/13/1999 QNDCAL04864688 QNDCAL04864689 Irwin Jacobs Qualcomm Steve Altman; Irwin Jacobs
Altman re:
CX7024 Amon CX7024 Amon 12/7/2015 Handwritten notes: Cristiano Amon Q2017MDL1 02704177 Q2017MDL1 02704182 Cristiano Amon Qualcomm Cristiano Amon
Email from Steve Altman to Don Rosenberg and
CX7035 CX7035 2/27/2008 Q2017MDL1_02697467 Q2017MDL1_02697467 Steve Altman Qualcomm Steve Altman; Paul Jacobs
Paul Jacobs re: discussion
Email from Kathleen Young to 'qcbod' and Doug Paul Jacobs; Derek Aberle;
Rein re: meeting materials (10/06/06 special QC Michael Hartogs; David Wise;
CX7042 CX7042 10/6/2006 Q2014FTC03592698 Q2014FTC03592699 Kathleen Young Qualcomm
board meeting) w/Attach: Irwin Jacobs; Qualcomm
Executives
Email from Steve Altman to Paul Jacobs re: fwd: Steve Altman; Derek Aberle;
CX7054 CX7054 10/28/2009 Q2017MDL1_01442546 Q2017MDL1_01442549 Steve Altman Qualcomm
proposal Paul Jacobs

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 16 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from David Wise to Steven Mollenkopf, Derek Aberle; Cristiano Amon;
CX7067 CX7067 10/18/2015 Cristiano Amon, and Derek Aberle re Q2017MDL1_02695888 Q2017MDL1_02695893 David Wise Qualcomm Steven Mollenkopf; David
Board Materials - Draft Wise
Email from Derek Aberle to Marvin Blecker, Steve Derek Aberle; Steve Altman;
CX7104 CX7104 1/6/2007 Altman, Paul Jacobs, et al. re: review of the Q2017MDL1_02716706 Q2017MDL1_02716708 Derek Aberle Qualcomm Paul Jacobs; Louis Lupin;
Michael Hartogs
Email from Marvin Blecker to Steve Altman and
CX7105 CX7105 1/30/2007 Q2017MDL1_01469241 Q2017MDL1_01469245 Marvin Blecker Qualcomm Derek Aberle; Steve Altman;
Derek Aberle re: new obstacles
Email from Priscilla Srbu to Derek Aberle, Alex
Derek Aberle; Fabian Gonell;
Rogers, David Cianflone, et al. re: draft strat plan
CX7122 CX7122 6/22/2017 QNDCAL04194194 QNDCAL04194364 Priscilla Srbu Qualcomm Alex Rogers; Qualcomm
& board decks w/Attach: Board Deck_062117
Executives
Draft pptx; QTL Strat Plan 2018-2022_062117.pptx
Email from John Sinnott to Alex Rogers re: QTL Derek Aberle, Steve Altman;
CX7125 CX7125 9/29/2017 comments to investors w/Attach: Analyst Day QNDCAL04198891 QNDCAL04198991 John Sinnott Qualcomm Alex Rogers; Qualcomm
Licensing Biz Presentations 2005-2016.docx Executives
Presentation:
CX7128 CX7128 7/22/2015 Q2017MDL1_00030823 Q2017MDL1_00030920 Qualcomm Fabian Gonell

CX7141 CX7141 12/16/2004 Email from Derek Aberle to Steve Altman re: Nokia QNDCAL04935111 QNDCAL04935111 Derek Aberle Qualcomm Derek Aberle; Steve Altman
Email from Derek Aberle to Paul Jacobs re: fwd:
Word doc w/Attach: 5 Year Key Deal Update_3 31
CX7142 CX7142 5/10/2016 QAPPCMSD02953730 QAPPCMSD02953736 Derek Aberle Qualcomm Derek Aberle; Paul Jacobs
16 (No Links) .pptx; DA Deal - without exhibits
5&6.docx
Email from Liren Chen to Derek Aberle and Alex
Derek Aberle; Alex Rogers;
CX7143 CX7143 8/12/2016 Rogers re: QTL 5G work streams w/Attach: 5G QNDCAL04937515 QNDCAL04937547 Liren Chen Qualcomm
Liren Chen
QTL Work Streams Proposal-v9.pptx
Letter from Seungho Ahn to Derek Aberle re: Derek Aberle; Seungho Ahn;
CX7170 CX7170 1/26/2017 Q2014FTC04139525 Q2014FTC04139525 Seungho Ahn Qualcomm
Alex Rogers
Paul Jacobs, Steven
Email from Paul Jacobs to "exc," David Wise, and Mollenkopf; Derek Aberle;
CX7198 CX7198 5/27/2005 Q2017MDL6_01380502 Q2017MDL6_01380505 Paul Jacobs Qualcomm
Louis Lupin re: Flarion proposal Louis Lupin, David Wise;
Qualcomm Executives
Email from Steve Altman to Don Rosenberg re:
Steve Altman; Paul Jacobs;
fwd: attorney client privileged
CX7200 CX7200 10/15/2007 Q2017MDL1_02696440 Q2017MDL1_02696502 Steve Altman Qualcomm David Wise; Qualcomm
w/Attach Discussion_10.17.07_FNL.ppt;
Executives
-Competitive Response 10.17 07 FNL.doc
CX7220 CX7220 12/11/2003 Email from Steve Altman to Greg Cobb QNDCAL02176585 QNDCAL02176589 Steve Altman Qualcomm Steve Altman; Paul Jacobs
Email from Paul Jacobs to Steve Altman re: TMO
CX7224 CX7224 7/16/2006 Q2017MDL1_01125900 Q2017MDL1_01125905 Paul Jacobs Qualcomm Paul Jacobs; Steve Altman
IPR meet - 11th July 2006
Paul Jacobs; Steve Altman;
Email from Marvin Blecker to Jing Wang, Len
CX7229 CX7229 10/10/2007 QNDCAL04965783 QNDCAL04965783 Marvin Blecker Qualcomm Irwin Jacobs; Derek Aberle;
Lauer, and Paul Syrowik re : China Factor
Michael Hartogs
Paul Jacobs; Steve Altman;
Email from Bill Keitel to Sanjay Jha re: Jan 11 David Wise; James
board meeting w/Attach: Analysis & Prelim Thompson; Michael Hartogs;
CX7234 CX7234 1/11/2008 QNDCAL02797418 QNDCAL02797573 Bill Keitel Qualcomm
Recommendation.pdf; Appendices.pdf; Derek Aberle; Steven
Lehman.pdf; Morgan Stanley. pdf Mollenkopf; Qualcomm
Executives
Email from Warren Kneeshaw to George Davis re:
Warren Paul Jacobs; Steven
CX7251 CX7251 12/15/2015 faq w/Attach: Project FAQ Final - 12 14 QAPPCMSD01246292 QAPPCMSD01246308 Qualcomm
Kneeshaw Mollenkopf; David Wise
2015.docx
Steven Mollenkopf; Paul
CX7257 CX7257 11/1/2017 Qualcomm 2017 Annual Report Form 10-K CX7257-001 CX7257-148 Public Jacobs; Liren Chen;
Qualcomm Executives
Email from Paul Jacobs to Sanjay Jha w/Attach: Paul Jacobs; Qualcomm
CX7279 CX7279 7/28/2007 QNDCAL04966103 QNDCAL04966118 Paul Jacobs Qualcomm
Strat Comm Discussion 7.26 06pj ppt Executives
Email from Louis Lupin to Marvin Blecker, Luke Louis Lupin; Steve Altman;
CX7303 CX7303 10/4/2002 Bonacci, Greg Cobb, et al. re: hop-on wireless test Q2014FTC03370383 Q2014FTC03370384 Louis Lupin Qualcomm Derek Aberle; Michael
market Hartogs
Email from Jeffrey Altman to Derek Aberle re: fwd:
CX7304 CX7304 7/9/2001 license agreement w/Attach: StdSubscrLicAgmt 2G- Q2014FTC03374277 Q2014FTC03374278 Jeffrey Altman Qualcomm Derek Aberle; Jeffrey Altman
only 4-6-0111 doc
Email from Jeffrey Altman to Shou Wei Lam and
CX7308 CX7308 12/14/2012 Q2014FTC03475059 Q2014FTC03475061 Jeffrey Altman Qualcomm Derek Aberle; Jeffrey Altman
Abbaseh Samimi re: fwd: follow-up
Email from Jeffrey Altman to Xuyuan re:
CX7351 CX7351 4/1/2010 Q2017MDL1_01759049 Q2017MDL1_01759052 Jeffrey Altman Qualcomm Jeffrey Altman;
CDMA2000 licence

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 17 of 23
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 18 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses

Presentation: Technology Licensing: Market Derek Aberle; Steve Altman;
CX7602 CX7602 4/18/2007 Q2017MDL1_02942431 Q2017MDL1_02942431 Qualcomm
Trends Michael Hartogs; Louis Lupin
Presentation: Technology Licensing: Market Derek Aberle; Steve Altman;
CX7603 CX7603 4/29/2011 Q2017MDL1_02944115 Q2017MDL1_02944115 Qualcomm
Trends Paul Jacobs
Presentation: Technology Licensing: Market Derek Aberle; Steve Altman;
CX7604 CX7604 4/17/2013 Q2017MDL1_02944264 Q2017MDL1_02944264 Qualcomm
Trends Paul Jacobs
Steven Mollenkopf; Cristiano
CX7606 CX7606 5/24/2011 Qualcomm Presentation: QCT Strategic Plan Q2017MDL1_03031492 Q2017MDL1_03031492 Qualcomm
Amon
Steven Mollenkopf; Cristiano
CX7607 CX7607 6/11/2012 Qualcomm Presentation: FY12 Strat Plan Q2017MDL1_03031496 Q2017MDL1_03031496 Qualcomm
Amon
Steven Mollenkopf; Derek
Qualcomm Presentation: Technology Licensing: Aberle; Eric Reifschneider;
CX7617 CX7617 4/9/2015 Q2017MDL1_03127051 Q2017MDL1_03127222 Qualcomm
Market Trends Fabian Gonell; Qualcomm
Executives
Derek Aberle; Steven
Qualcomm Presentation: Technology Licensing: Mollenkopf; Alex Rogers;
CX7618 CX7618 7/15/2016 Q2017MDL1_03127921 Q2017MDL1_03128095 Qualcomm
Market Trends Fabian Gonell; Qualcomm
Executives
Email from Sanjay Jha to Cristiano Amon, sj.staff,
Cristiano Amon; Steven
CX7624 CX7624 2/19/2008 cdma pm, et al. re: China Telecom CDMA plans Q2017MDL5_07802830 Q2017MDL5_07802831 Sanjay Jha Qualcomm
Mollenkopf;
approved!
Email from Zena Blecker to Abbaseh Samimi and Derek Aberle; Steven
CX7629 CX7629 7/21/2017 Yunyun Guo re: tech book through CY17Q1 QAPPCMSD02139297 QAPPCMSD02139470 Zena Blecker Qualcomm Mollenkopf; Alex Rogers;
w/Attach: 2017Q1 Tech book Final.zip Qualcomm Executives
Email from Jacob Magdaleno to 'ww.staff' re: Cristiano Amon; Steven
Jacob
CX7637 CX7637 8/18/2015 CQ3'15 competitive pricing deck w/Attach: Q2014FTC04601517 Q2014FTC04601607 Qualcomm Mollenkopf; Qualcomm
Magdaleno
Competitive Pricing Deck - Q3 CY15 pdf Executives
Qualcomm Presentation: Strategy Pricing Review - Cristiano Amon; Steven
CX7639 CX7639 6/1/2016 QNDCAL01104282 QNDCAL01104282 Qualcomm
Low/Mid Focus Mollenkopf
Strategy Analytics Spreadsheet: Baseband Market
Cristiano Amon, Steven
CX7640 CX7640 09/??/17 Share Tacker Q2 2017: Intel, HiSilicon Register QNDCAL01104489 QNDCAL01104489 Qualcomm
Mollenkopf, William Wyatt
Triple-digit LTE Shipment Growth
Steven Mollenkopf; Cristiano
CX7644 CX7644 6/10/2013 Presentation: QCT FY14 Strat Q2017MDL1_03031501 Q2017MDL1_03031501 Qualcomm
Amon; Qualcomm Executives
Letter from Louis Lupin to Susan Miller re:
Louis Lupin; Qualcomm
CX7648 CX7648 6/25/1999 intellectual property rights on IMT-2000 radio Q2017MDL1_00009588 Q2017MDL1_00009588 Louis Lupin Qualcomm
Executives
transmission technologies
Email from Eric Reifschneider to Derek Aberle re: Eric Eric Reifschneider; Derek
CX7650 CX7650 2/22/2012 Q2017MDL1_01206699 Q2017MDL1_01206705 Qualcomm
draft license agreement Reifschneider Aberle
Eric Reifschneider; Derek
CX7669 CX7669 3/10/2008 Q2017MDL1_03048829 Q2017MDL1_03048845 Qualcomm
Aberle; Qualcomm Executives
Email from Derek Aberle to Scottie Yoo and
William Kim re:
Derek Aberle; Qualcomm
CX7692 CX7692 5/9/2007 Q2014FTC03937507 Q2014FTC03937570 Derek Aberle Qualcomm
Executives

Email from Marvin Blecker to HT Cho, Peter Chou, Paul Jacobs; Steve Altman;
CX7786 CX7786 12/15/2000 Q2014FTC03367248 Q2014FTC03367249 Marvin Blecker Qualcomm
M Liang, et al. re: CDMA license agreement review Michael Hartogs
Email from Steve Altman to Jon Meyer, Steve
Steve Altman; Paul Jacobs;
CX7799 CX7799 2/23/2000 Altman, Rich Sulpizio, Paul Jacobs,et al. re: Q2014FTC03438266 Q2014FTC03438267 Steve Altman Qualcomm
Irwin Jacobs
discussions
Email from Enrico Salvatori to Jonathan Weiser Derek Aberle; Steven
CX7824 CX7824 2/23/2012 Q2014FTC04497009 Q2014FTC04497010 Enrico Salvatori Qualcomm
and James Lederer re: urgent Mollenkopf
Email from Steve Altman to Jeff Jacobs re: update
CX7886 CX7886 10/1/2004 Q2017MDL5_10141828 Q2017MDL5_10141831 Steve Altman Qualcomm Steve Altman
on 6250 IOT with CMCC
Email from Steven Mollenkopf to James Lederer,
Steven Steven Mollenkopf; Cristiano
CX7910 CX7910 3/2/2013 Cristiano Amon, Murthy Renduchintala, et al. re: QNDCAL00413487 QNDCAL00413488 Qualcomm
Mollenkopf Amon
deals are done
Email from Eric Reifschneider to Jonathan Weiser,
Fabian Gonell, Amy Olsen, et al. re: fwd: Sony
Eric Eric Reifschneider; Derek
CX7961 CX7961 10/25/2012 Mobile - privileged w/Attach: Sony Mobile Backlog QNDCAL05028762 QNDCAL05028768 Qualcomm
Reifschneider Aberle; Fabian Gonell
77714 10.13.12.xls; Sony Mobile Backlog 80715
10.13.12.xls

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 19 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Steven Mollenkopf to Cristiano Amon,
James Lederer, Jonathan Weiser, et al. re: Steven Cristiano Amon; Steven
CX7968 CX7968 12/13/2012 QAPPCMSD02659282 QAPPCMSD02659283 Qualcomm
**privileged and confidential attorney client Mollenkopf Mollenkopf
communication**
Accounting Memo from Larry Griffith and Erin
Polek to Corporate Accounting File re: Larry Griffith; Derek Aberle; Qualcomm
CX7988 CX7988 8/10/2011 Q2017MDL1_03100642 Q2017MDL1_03100644 Qualcomm
Erin Polek Executives

Accounting Memo from Joyce Ford to Corporate
Derek Aberle; Marvin Blecker;
CX7991 CX7991 8/12/2005 Accounting File re: Flarion acquisition - use of QNDCAL03960159 QNDCAL03960161 Joyce Ford Qualcomm
Michael Hartogs
assumptions and probabilities in valuation
Tax Department Memo from Lee Gilbert to
Derek Aberle; Qualcomm
CX8000 CX8000 3/18/2005 Corporate Tax Files re: Qualcomm Global Trading, QNDCAL04808503 QNDCAL04808512 Lee Gilbert Qualcomm
Executives
Inc - (DRAFT)
Qualcomm Presentation: China Long Term
CX8008 CX8008 4/17/2015 Q2017MDL1_02652787 Q2017MDL1_02652802 Qualcomm Derek Aberle
Strategy: 'Big Moves' work stream
Email from Sanjay Mehta to Jonathan Weiser,
Steven Mollenkopf, James Lederer, et al. re:
Steven Mollenkopf; Cristiano
CX8071 CX8071 4/24/2013 slides for upcoming board meeting - privileged and Q2017MDL1_01067576 Q2017MDL1_01067577 Sanjay Mehta Qualcomm
Amon;
confidential w/Attach Deal Summary
Framework v1 ppt
Email from William Wyatt to Jacob Magdaleno re: Cristiano Amon; Steven
CX8082 CX8082 3/13/2015 Q2017MDL1_01993021 Q2017MDL1_01993027 William Wyatt Qualcomm
fwd: continuity of supply and SOW Mollenkopf
Email from Thomas Rouse to Eric Reifschneider,
Joseph Lee, Matt Gettinger, et al. re: Sony meeting
CX8090 CX8090 12/10/2014 Q2017MDL1_02738814 Q2017MDL1_02738819 Thomas Rouse Qualcomm Eric Reifschneider
notes -- attorney-client privileged w/Attach: Sony
Meeting 12-10-14.docx
Email from Derek Aberle to Jim Cathey, Cristiano Derek Aberle; Cristiano Amon;
CX8116 CX8116 3/15/2016 QAPPCMSD00949883 QAPPCMSD00949883 Derek Aberle Qualcomm
Amon Fabian Gonell et al. re: HTC Fabian Gonell
Email from Steve Altman to Woo Paik re: fwd: final Steve Altman; Paul Jacobs;
CX8117 CX8117 12/16/2003 QNDCAL02123631 QNDCAL02123641 Steve Altman Qualcomm
LG arb. request w/Attach: SFX3C5.pdf Qualcomm Executives
Email from Irwin Jacobs to Tony Thornley, Steve
Paul Jacobs; Steve Altman;
CX8118 CX8118 2/23/2004 Altman, Louis Lupin, et al. re: our license Q2014FTC04156839 Q2014FTC04156849 Irwin Jacobs Qualcomm
Irwin Jacobs
agreement from web courtesy of NeoPoint
Email from Derek Aberle to Larry Griffith and David
Cianflone re: accounting memos w/Attach: CM
2011 2G to 3G Market Growth Memo -
DRAFT2/3+dka.docx; Q4 2011 Embedded
CX8121 CX8121 10/10/2011 Q2017MDL1_00477921 Q2017MDL1_00477931 Derek Aberle Qualcomm Derek Aberle
Modules - DRAFT- 10-9-11+dka.docK QTL Annual
License Amortization Review FY11 Draft 10-9-
11+dka docx;
(Q4FY11) - Draft 10-9-11+dka docx
Derek Aberle, Alex Rogers;
CX8126 CX8126 10/21/2016 2016 TIA Intellectual Property Rights Policy CX8126-001 CX8126-024 Public
Fabian Gonell
2015 Operating Procedures for ATIS Forums and
CX8127 CX8127 3/1/2015 Q2017MDL1_00024028 Q2017MDL1_00024053 Qualcomm Derek Aberle, Alex Rogers
Committees
CX8128 CX8128 5/1/2014 2014 TIA Intellectual Property Rights Policy Q2017MDL1_00025790 Q2017MDL1_00025797 Qualcomm Derek Aberle Alex Rogers
Letter from Thomas Rouse to Thomas Goode re:
patent holder statement on behalf of Qualcomm Derek Aberle, Alex Rogers;
CX8144 CX8144 7/23/2012 Q2017MDL2_00006366 Q2017MDL2_00006658 Thomas Rouse Qualcomm
Incorporated for ATIS input to Rec. 1.1741.8 Qualcomm Executives
(3GPP Release 10 specifications)
Letter from Louis Lupin to Billie Zidek-Conner re:
standard IS-9B, "mobile station-base station
CX8152 CX8152 7/10/1998 Q2017MDL1_00013626 Q2017MDL1_00013626 Louis Lupin Qualcomm Louis Lupin
compatibility standard for dual-mode spread
spectrum systems"
Email from Steve Altman to Louis Lupin and
CX8177 CX8177 10/21/1999 QNDCAL01422595 QNDCAL01422597 Steve Altman Qualcomm Steve Altman; Louis Lupin
Marvin Blecker re: Intel/DSPC
Email from Marvin Blecker to Derek Aberle,
Steve Altman; Louis Lupin;
CX8178 CX8178 6/9/2005 Michael Hartogs, Greg Cobb, et al. w/Attach: db Q2014FTC04057446 Q2014FTC04057461 Marvin Blecker Qualcomm
Derek Aberle
QTL report.pdf
Email from Gaby Boy to Shawn Ambwani and Eric
Reifschneider re: presentation w/Attach: ER
CX8181 CX8181 2/16/2013 QAPPCMSD02321080 QAPPCMSD02321122 Gaby Boy Qualcomm Eric Reifschneider
Presentation - QTL Licensing and SEPs (Final -
Feb 15).pdf
Email from Amy Berguson to Steve Altman, Derek
Aberle, Aisha Williams, et al. re: final version of
CX8183 CX8183 11/14/2007 QNDCAL05003905 QNDCAL05003908 Amy Berguson Qualcomm Derek Aberle; Steve Altman
New York Slides w/Attach: NY Analyst Day_SA_11-
14-07 vF NAL.ppt

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REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Michael Hartogs to Jennifer Vasta re:
fwd: Ericsson argument w/Attach: Ericsson's
Opposition to QC's Motion for Partial SJ.pdf:
Ericsson's Response to QC's Reply in
CX8185 CX8185 4/10/2009 Q2017MDL1_01430889 Q2017MDL1_01431213 Michael Hartogs Qualcomm Fabian Gonell Steve Altman
Support of its Motion for Partial SJ.pdf: QC's
Answer to Ericsson's 3rd Amended Complaint.pdf:
QC's Motion for Partial SJ.pdf; QC's Reply in
Support of its Motion for Partial SJ pdf
Email from Gunnar Thoreson to William Wyatt,
Mauricio Lopez-Hodoyan, Larry Gianulis, et al. re: Gunnar
CX8189 CX8189 5/17/2017 Q2014FTC03873785 Q2014FTC03873788 Qualcomm William Wyatt
5G units w/Attach: 2017-05 5G Market Share Thoreson
Walk.pptx
Email from Taylor Cabaniss to Steven Mollenkopf,
Akash Palkhiwala, and Cristiano Amon re: QCT
earning call and budget financial & units decks Steven Mollenkopf; Cristiano
CX8190 CX8190 10/26/2017 QAPPCMSD03730556 QAPPCMSD03730559 Taylor Cabaniss Qualcomm
w/Attach: FY18 Budget F NAL UNITS - QCT Amon
v6 0 pptx; QCT Earnings Call Q4 FY17.pptx; QCT
FY18 Budget Deck pptx
Steven Mollenkopf; Cristiano
CX8191 CX8191 7/10/2017 Board of Directors Meeting July 27, 2017 QNDCAL04505886 QNDCAL04506087 Qualcomm Amon; James Thompson;
Qualcomm Executives
Email from Jenny Gore to Steven Mollenkopf, Paul
Jacobs, George Davis, et al. re: communications
materials for review w/Attach: 2018.01.10 Failed
MA_v4.pdf; 2018 01.13 QCOM Sell-Side Analysts
Recap ver11.pdf; Dispelling Myths v01.13.18 -
Updated.pdf; Employee Emails for Investor
Deck_1.13.18 docx; Investor meeting prep - Key Steven Mollenkopf; Cristiano
CX8193 CX8193 1/14/2018 QNDCAL04949521 QNDCAL04949634 Jenny Gore Qualcomm
Themes and QA_v16 CLEAN.DOCX; Investor Amon; Qualcomm Executives
meeting prep - Key Themes and
QA_v16_CLEAN1.DOCX; Project - Fight
Letter #1 DRAFT 1-13-18 (4 30PM).docx; Project
Investor Presentation v155 (Jan_13)
IR_1PM pdf; - Prep Materials for
Investor Meetings (Week of 1-15-18).pdf
Email from Cindy Ping to Steven Mollenkopf, John
Sinnot, George Davis, et al. re: SS- draft release /
Steven Mollenkopf; Fabian
CX8194 CX8194 1/13/2018 privileged and confidential w/Attach: QNDCAL04949635 QNDCAL04949654 Cindy Ping Qualcomm
Gonell; Alex Rogers
QTL_SSmessagingreactiveQA_v5 docx;
Qualcomm Samsung Draft6.docx
Email from Patty Schaeffer to Steven Mollenkopf,
Don Rosenberg, George Davis, et al. re: Q1 FY18
earnings / q&a prep w/Attach: FY18 Q1 IR
Earnings FAQ (v6 CLEAN) docx; FY18 Q2 FAQ Steven Mollenkopf; Paul
CX8195 CX8195 1/30/2018 QNDCAL04950697 QNDCAL04950782 Patty Schaeffer Qualcomm
QCT_1.29.18.docx; FY18 Q2 FAQ Jacobs
QCT_1.29.181.docx; Hot Topics FY18Q1 - Draft
V2.docx Q1 FY18 George Script v11 GSD Final
edits Clean docx Q1FY18 SM script v9 docx
Steven Mollenkopf; Cristiano
CX8196 CX8196 12/4/2017 Board of Directors Meeting Dec. 4, 2017 QNDCAL04971227 QNDCAL04971548 Qualcomm Amon; James Thompson;
Qualcomm Executives
Qualcomm Presentation: A Clear Roadmap for Steven Mollenkopf; Cristiano
CX8197 CX8197 1/16/2018 CX8197-001 CX8197-044 Public
Value Creation Amon
Qualcomm Press Release: Qualcomm Sends
CX8198 CX8198 1/16/2018 Letter to Stockholders and Files Investor CX8198-001 CX8198-013 Public Steven Mollenkopf;
Presentation
Qualcomm Press Release: Global OEMs Select
Steven Mollenkopf; Cristiano
CX8199 CX8199 2/8/2018 Qualcomm Snapdragon X50 5G NR Modem Family CX8199-001 CX8199-009 Public
Amon; Qualcomm Executives
for Mobile Device Launches in 2019
Email from Amy Olsen to Alex Rogers, Don
Rosenberg, John Han, et al. re: Alex Rogers; Qualcomm
CX8200 CX8200 11/17/2017 QNDCAL04878208 QNDCAL04878232 Amy Olsen Qualcomm
: FW: Executives
Letter from Qualcomm
Email from Steve Altman to Irwin Jacobs and Rich
CX8206 CX8206 12/1/1998 Q2014FTC03372707 Q2014FTC03372707 Steve Altman Qualcomm Steve Altman; Irwin Jacobs
Sulpizio re: fwd: royalties vs. ASICs sales

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Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 21 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Paul Jacobs to Derek Aberle, Don
Derek Aberle; Steve Altman;
CX8208 CX8208 8/9/2008 Rosenberg, Steve Altman, et al. re: Samsung Q2017MDL1_03368176 Q2017MDL1_03368180 Paul Jacobs Qualcomm
Paul Jacobs
meeting--legal privileged communication
Email from Steve Altman to Sanjay Mehta, Derek
CX8209 CX8209 8/25/2006 Aberle, David Bush, et al. re: QNDCAL00407244 QNDCAL00407244 Steve Altman Qualcomm Steve Altman; Derek Aberle

Email from Eric Reifschneider to Fabian Gonell,
Thomas Rouse, Deborah Dwight, et al. re: Eric Eric Reifschneider; Derek
CX8211 CX8211 11/15/2013 QNDCAL04849610 QNDCAL04849617 Qualcomm
comments on - privileged Reifschneider Aberle; Fabian Gonell
w/Attach:
Email from Steven Mollenkopf to Michelle Sterling Steven Derek Aberle; Steven
CX8213 CX8213 3/7/2016 QAPPCMSD06819284 QAPPCMSD06819288 Qualcomm
re: tonight's discussion Mollenkopf Mollenkopf
Email from Marvin Blecker to Steve Altman re:
CX8214 CX8214 6/10/2002 letter sent to LGE in May, attached w/Attach: Sung- Q2014FTC03369840 Q2014FTC03369843 Marvin Blecker Qualcomm Steve Altman
Yong Kang 5-16-02.doc
Cristiano Amon, Derek Aberle,
Qualcomm Response to Specifications 1 and 2 of Irwin Jacobs, Paul Jacobs,
CX8215 CX8215 6/15/2016 CX8215-001 CX8215-512 Qualcomm
the CID Dated Apr. 28, 2016 Steven Mollenkopf, David
Wise; Qualcomm Executives
Email from James Thompson to Steven
Mollenkopf, Murthy Renduchintala, and Cristiano James Cristiano Amon; Steven
CX8233 CX8233 4/7/2015 Q2014FTC04801440 Q2014FTC04801441 Qualcomm
Amon re: opex analysis 4_6_15 r1.pptx w/Attach: Thompson Mollenkopf; James Thompson
Opex analysis 4 6 15 r1 pptx
Derek Aberle, Cristiano Amon,
Qualcomm Presentation: QMC Chipset Product Keith Kressin, Steven
CX8234 CX8234 1/3/2013 Q2017MDL1_00000099 Q2017MDL1_00000099 Qualcomm
Roadmaps Mollenkopf, Eric
Reifschneider, William Wyatt
Email from Andy Oberst to 'exc,' Steven Steven Mollenkopf; Keith
Mollenkopf, James Lederer, et al. re: QCT Kressin; Cristiano Amon;
CX8236 CX8236 6/9/2012 QAPPCMSD00510555 QAPPCMSD00510556 Andy Oberst Qualcomm
strategic plan w/Attach: QCT strategy 2012 Final Derek Aberle; James
EXC.potx Thompson
Email from John Choi to Don Rosenberg, Mark Derek Aberle, Cristiano Amon,
Snyder, Chris Longman, et al. re: fwd: : Paul Jacobs, Steven
CX8239 CX8239 12/27/2016 QAPPCMSD09925309 QAPPCMSD09925338 John Choi Qualcomm
follow up items -- privileged w/Attach: Press- Mollenkopf; Qualcomm
release-161228-t02-all.docx Executives
Japan Fair Derek Aberle, Cristiano Amon,
Japan Fair Trade Commission Press Release:
CX8243 CX8243 9/30/2009 CX8243-001 CX8243-004 Trade Public Paul Jacobs, Steven
Cease and Desist Order against Qualcomm Inc.
Commission Mollenkopf
Email from Greg Cobb to Derek Aberle, Jeffrey
CX8251 CX8251 10/20/2006 QNDCAL03321989 QNDCAL03321990 Greg Cobb Qualcomm Derek Aberle
Altman Louis Lupin et al. re: Sagem
Email from Derek Aberle to Francisco Ros, Paul
Jacobs, and Steven Mollenkopf re: Qualcomm and Paul Jacobs; Steven
CX8252 CX8252 2/9/2015 Q2017MDL1_00158900 Q2017MDL1_00158905 Derek Aberle Qualcomm
China's National Development and Reform Mollenkopf; Derek Aberle;
Commission reach resolution
Email from Aisha Williams to Stein Lundby, Roger
Derek Aberle; Michael
CX8253 CX8253 8/25/2011 Martin, Alex Rogers, et al. re: Master List Updat QAPPCMSD02256945 QAPPCMSD02256946 Aisha Williams Qualcomm
Hartogs
w/Attach: Master Lic List 2011-08-24 xlsx
Email from Katie Arner to William Wyatt re:
CX8254 CX8254 6/2/2016 8917_8940 Pricing Strategy (003).pptx w/Attach: Q2014FTC04599055 Q2014FTC04599056 Katie Arner Qualcomm Cristiano Amon, William Wyatt
8917 8940 Pricing Strategy (003) pptx
AltmanJ Apple Email from Jeffrey Altman to Barry Corlett re:
CX8255 4/27/2005 Q2017MDL5_04482120 Q2017MDL5_04482120 Jeffrey Altman Qualcomm Jeffrey Altman
Exhibit 3 Qualcomm licensing program
Email from Savi Soin to Cristiano Amon re: QCT
Amon Apple strat plan decks w/Attach: Cristiano Amon; Qualcomm
CX8256 7/3/2016 Q2014FTC04073554 Q2014FTC04073555 Savi Soin Qualcomm
Exhibit 3 QCT_Stratplan_June2016_Final Presented wo Executives
backup.pptx
Amon Apple Email from Sanjay Mehta to Cristiano Amon and
CX8257 10/24/2008 Q2014FTC03869031 Q2014FTC03869032 Sanjay Mehta Qualcomm Cristiano Amon
Exhibit 7 James Lederer re: CDMA vs UMTS pricing
Email from Marvin Blecker to Abbaseh Samimi,
Blecker Apple
CX8258 9/12/2007 Derek Aberle, Sanjay Jha, et al. re: cap for Q2017MDL1_01598957 Q2017MDL1_01598961 Marvin Blecker Qualcomm Derek Aberle; Marvin Blecker
Exhibit 1
smartphone devices
Blecker Apple Email from Marvin Blecker to Steve Altman re: Marvin Blecker, Steve Altman,
CX8259 12/7/2006 Q2017MDL1_01173718 Q2017MDL1_01173719 Steve Altman Qualcomm
Exhibit 5 Apple ipod-phone deal Derek Aberle, Paul Jacobs
Email from Paul Jacobs to Steve Altman, Marvin
Blecker Apple Steve Altman, Marvin Blecker,
CX8260 12/8/2006 Blecker, Sanjay Jha, et al. re: Apple ipod-phone Q2014FTC03520714 Q2014FTC03520715 Marvin Blecker Qualcomm
Exhibit 6 Paul Jacobs
deal

5:17-cv-0220-LHK-NMC "Qualcomm Executives" includes officers, directors, and other employees with knowledge of the document Page 20 of 22
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 22 of 23
REDACTED VERSION OF DOCUMENTS SOUGHT TO BE SEALED FTC Exhibit List

Trial Exhibit No. Exhibit No. Date Description Bates - Begin Bates - End Author(s) Producing Party + Sponsoring Witnesses
Email from Victoria Chen to Phil Fries re: Following
Chen Apple up....today's presentation, follow up call to be
CX8261 2/28/2008 QNDCAL03583789 QNDCAL03583790 Victoria Chen Qualcomm Tony Blevins
Exhibit 2 scheduled w/Attach: MDSA issues
(022108vc)v21 ppt
Liren Chen, Alex Rogers,
ChenL Apple Qualcomm Presentation: Standards, SEPs,
CX8262 9/6/2016 QAPPCMSD07412973 QAPPCMSD07413052 Qualcomm Fabian Gonell; Qualcomm
Exhibit 12 Licensing, and Litigation in the ICT Industry
Executives
Email from David Wise to Steven Mollenkopf,
Derek Aberle, Paul Jacobs, et al. re: Ed
Derek Aberle; Cristiano Amon;
DavisG Apple Tiedemann's Revisions to Bullets - privileged and
CX8263 9/8/2015 Q2017MDL1_02688236 Q2017MDL1_02688248 David Wise Qualcomm Paul Jacobs; Steven
Exhibit 6 confidential w/Attach: Board Committee
Mollenkopf
Regulatory Discussion FINAL docx; Board
Committee Standards Discussion.docx
Hartogs Apple Email from Steve Altman to Marvin Blecker, Louis Steve Altman; Michael
CX8264 8/2/2004 Q2017MDL5_04133887 Q2017MDL5_04133887 Steve Altman Qualcomm
Exhibit 17 Lupin Derek Aberle et al. re: Intel update Hartogs Derek Aberle
Hartogs Apple Email from Marvin Blecker to Paul Jacobs, Michael Michael Hartogs; Paul Jacobs;
CX8265 12/30/2006 Q2017MDL1_02924841 Q2017MDL1_02924845 Marvin Blecker Qualcomm
Exhibit 4 Hartogs, and Steve Altman re: Apple Derek Aberle; Steve Altman;
JacobsP Apple Conference Call Transcript: Q4 2005 Qualcomm Steve Altman; AberlD; Paul
CX8266 11/3/2005 Q2017MDL5_05759950 Q2017MDL5_05759965 Qualcomm
Exhibit 1 Earnings Call Jacobs
Paul Jacobs; Derek Aberle;
Email from Marvin Blecker to Paul Jacobs, Sanjay Steve Altman; Michael
JacobsP Apple
CX8267 2/22/2008 Jha, Steven Mollenkopf, et. al. re: QAPPCMSD00432506 QAPPCMSD00432506 Marvin Blecker Qualcomm Hartogs; Irwin Jacobs; Paul
Exhibit 25
Jacobs; Sanjay Jha; Steven
Mollenkopf

Kressin Apple Email from Keith Kressin to Ron Tessitore re: it's
CX8268 8/31/2010 Q2014FTC04860918 Q2014FTC04860921 Keith Kressin Qualcomm Keith Kressin
Exhibit 10 official: Intel to acquire Infineon Wireless Solutions
Lederer Apple Email from James Lederer to Steven Mollenkopf Steven Mollenkopf; Steve
CX8269 11/30/2010 Q2017MDL1_02924861 Q2017MDL1_02924862 James Lederer Qualcomm
Exhibit 17 re: fwd - legal privilege Altman
Email from Steven Mollenkopf to Paul Jacobs re:
Mollenkopf Apple Steven Steven Mollenkopf; Paul
CX8270 12/27/2012 - latest product outlook (tablet/phone) - QAPPCMSD00697077 QAPPCMSD00697082 Qualcomm
Exhibit 15 Mollenkopf Jacobs
competitive updates
Mollenkopf Apple Email from Derek Aberle to Steven Mollenkopf re: Steven Mollenkopf; Derek
CX8271 1/9/2013 QAPPCMSD02616059 QAPPCMSD02616060 Derek Aberle Qualcomm
Exhibit 18 new offer Aberle Jeffrey Williams
Fabian Gonell; Eric
Letter from Jeffrey Ju to Fabian Gonell re: FRAND
CX8272 PX100 3/4/2013 Q2017MDL1_01205317 Q2017MDL1_01205318 Jeffrey Ju Qualcomm Reifschneider; Derek Aberle;
license
Marvin Blecker
Letter from Jeffrey Ju to Fabian Gonell re: FRAND
CX8273 PX102 3/19/2013 Q2017MDL1_01602693 Q2017MDL1_01602693 Jeffrey Ju Qualcomm Fabian Gonell
license
Email from Don Rosenberg to Eric Reifschneider, Eric Reifschneider; Fabian
CX8274 PX104 5/10/2013 Alex Rogers, Roy Hoffinger, et al. re: Mediatek - QNDCAL03535778 QNDCAL03535780 Don Rosenberg Qualcomm Gonell; Steve Altman; Alex
privileged Rogers Derek Aberle
Email from Cristiano Amon to James Lederer,
Sandeep Pandya, Steven Mollenkopf, et al. re: Cristiano Amon; Steven
CX8275 PX111 2/11/2010 Q2014FTC04474119 Q2014FTC04474120 Cristiano Amon Qualcomm
additional arguments to help address CDMA to Mollenkopf
UMTS price delta at
Email from Cristiano Amon to Steven Mollenkopf,
Murthy Renduchintala, Sanjay Mehta, et al. re: Steven Mollenkopf; Cristiano
CX8276 PX115 12/19/2012 Q2014FTC03858461 Q2014FTC03858466 Cristiano Amon Qualcomm
- latest product outlook (tablet/phone) - Amon
competitive updates
Email from Kun Qian to Reiner Klement, William
CX8277 PX206 8/19/2015 Q2014FTC03963115 Q2014FTC03963119 Kun Qian Qualcomm William Wyatt
Wyatt Gang Sun et al. re: China 8909 discussion
Email from Baaziz Achour to Sudarashan
Keshava, Jon Detra, and Baaziz Achour re:
CX8278 PX214 8/24/2015 PX214-001 PX214-029 Baaziz Achour Qualcomm Baaziz Achour
Baaziz's modem all-hands ppt w/Attach: Modem All-
Hands August2015-v1.pptx
Email from David Wise to Liz Gasser re: fwd: QCT
CX8279 PX243 2/3/2016 vs. QTL breakeven w/Attach: QTL Breakeven Q2014FTC03600815 Q2014FTC03600816 David Wise Qualcomm David Wise
v2.2.16 4pm pptx
Email from Louis Lupin to Derek Aberle and Derek Aberle; Louis Lupin;
CX8280 PX264 6/13/2011 QNDCAL04495575 QNDCAL04495576 Louis Lupin Qualcomm
Fabian Gonell re: E-legal privilege Fabian Gonell
Email from Peggy Johnson to Steve Altman, Tony
CX8281 PX300 10/7/2004 QNDCAL04961414 QNDCAL04961421 Peggy Johnson Qualcomm Steve Altman; Paul Jacobs
Thornley Jeff Jacobs et al. re: Qualcomm Claims
Email from Lorenzo Casaccia to Peter Gaal and Lorenzo Lorenzo Casaccia; Fabian
CX8282 PX355_Casaccia 5/18/2016 Q2014FTC03734769 Q2014FTC03734772 Qualcomm
Dino Flore re: fwd: 3GPP contributions Casaccia Gonell

5:17-cv-0220-LHK-NMC "Qualcomm Executives" includes officers, directors, and other employees with knowledge of the document Page 21 of 22
Case 5:17-cv-00220-LHK Document 946-4 Filed 11/29/18 Page 23 of 23
Case 5:17-cv-00220-LHK Document 946-5 Filed 11/29/18 Page 1 of 20

EXHIBIT E
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 2 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Email regarding FW: Intel - Qualcomm Meeting 5/12 - Attorney
QX0002 QX0002 5/24/2005 Adams, Joe 86600DOC106552 86600DOC106554 Hayter, Dana anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
Client Privileged & Confidential
commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX0015 QX0015 9/30/2009 Revised Patent Agreement Proposal 9-30-09 - Confidential doc Intel 86600DOC002305 86600DOC002307 Hayter, Dana; Hartogs, Michael; Aberle, Derek; Gonell, Fabian anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0020 QX0020 2/1/2010 Infineon WLS RS Platform Roadmap with attachment(s) Intel 86600DOC074395 86600DOC074401 Expert: Snyder, Edward; Expert: Williams, Tim; Wolff, Stefan do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
QX0021 QX0021 11/25/2010 Email regarding ICE Modem Options ppt with attachment(s) Straub, Alexander 86600DOC065271 86600DOC065273 Expert: Williams, Tim; Wolff, Stefan (Intel) Reasons for Qualcomm’s success in the modem chip business
Email regarding FW: RS roadmap workshop, update into RS M Winkelmeyr,
QX0022 QX0022 5/4/2011 INTEL-QCOM003401033 INTEL-QCOM003401036 Evans, Aicha (Intel); Wolff, Stefan (Intel) Reasons for Qualcomm’s success in the modem chip business
with attachment(s) Christian
Constantine, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0023 QX0023 9/29/2011 Email regarding ICE RFP Feedback INTEL-QCOM000216400 INTEL-QCOM000216402 Wolff, Stefan (Intel); Expert: Edward, Snyder; Expert: Williams, Tim
Kevin G do not cause anticompetitive harm
Email regarding Apple RF Feedback Oct 2011 pptx with Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX0024 QX0024 10/17/2011 Wolff, Stefan INTEL-QCOM000718638 INTEL-QCOM000718649 Expert: Snyder, Edward; Expert: Williams, Tim; Wolff, Stefan (Intel)
attachment(s) Apple were not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0025 QX0025 3/21/2012 Email regarding ICE presentation 21-Mar-2012 with attachment(s) Lueftner, Thomas 86601DOC022146 86601DOC022150 Evans, Aicha (Intel); Expert: Williams, Tim; Wolff, Stefan (Intel)
do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Constantine, Expert: Snyder, Edward; Expert: Williams, Tim; Evans, Aicha (Intel);
QX0026 QX0026 3/30/2014 Email regarding Re: TDD TD-SCDMA URGENT INTEL-QCOM000162907 INTEL-QCOM000162909 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Kevin G Wolff, Stefan (Intel)
anticompetitive
Evans, Aicha (Intel); Expert: Snyder, Edward; Expert: Williams, Tim; Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0028 QX0028 3/21/2013 Email regarding RE: Ask for help on 7360 Wolff, Stefan INTEL-QCOM000134237 INTEL-QCOM000134241
Wolff, Stefan (Intel) do not cause anticompetitive harm
Email regarding
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0029 QX0029 3/27/2014 Wolff, Stefan 86600DOC014153 86600DOC014161 Eul, Hermann (Intel); Evans, Aicha (Intel); Wolff, Stefan (Intel)
do not cause anticompetitive harm
Constantine, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0031 QX0031 6/10/2011 Email regarding RE: ICE roadmap workshop for 2014 INTEL-QCOM000214743 INTEL-QCOM000214748 Sauer, Matthias (Intel); Wolff, Stefan (Intel)
Kevin G do not cause anticompetitive harm
QX0032 QX0032 6/24/2011 Email regarding New RFP with attachment(s) Umerani, Wahid INTEL-QCOM006166247 INTEL-QCOM006166259 Evans, Aicha (Intel); Expert: Williams, Tim Reasons for Qualcomm’s success in the modem chip business
Constantine, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0033 QX0033 7/21/2011 Email regarding New RFP with attachment(s) INTEL-QCOM000215595 INTEL-QCOM000215620 Evans, Aicha (Intel); Expert: Williams, Tim
Kevin G do not cause anticompetitive harm
Email regarding FW: Hermann Eul Executive Briefing ICE LTE Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0037 QX0037 10/5/2011 Straub, Alexander INTEL-QCOM000749294 INTEL-QCOM000749299 Evans, Aicha (Intel); Expert: Snyder, Edward; Expert: Williams, Tim
9_29_11 pptx with attachment(s) do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0039 QX0039 10/5/2011 Email regarding FW: LTE comparison chart with attachment(s) Straub, Alexander INTEL-QCOM000749196 INTEL-QCOM000749199 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0043 QX0043 8/28/2012 Email regarding FW: Private chat with Matthias Wolff, Stefan INTEL-QCOM001729923 INTEL-QCOM001729923 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Email regarding FW: IMC roadmap (was Re: IMC key milestone Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0045 QX0045 11/1/2012 Lindner, Thomas INTEL-QCOM001432423 INTEL-QCOM001432428 Evans, Aicha (Intel); Expert: Williams, Tim; Sauer, Matthias (Apple)
update) do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding RE: ICE 2015 requirements; MoM of May 17th
QX0048 QX0048 5/23/2013 Martin, Gerhard INTEL-QCOM001673398 INTEL-QCOM001673408 Evans, Aicha (Intel); Expert: Williams, Tim do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
call with attachment(s)
anticompetitive
Email regarding XMM7460 final ICE RFI materials with CDMA and premium LTE are not appropriate antitrust markets; Qualcomm’s business practices
QX0050 QX0050 9/9/2013 Zhang, Zhiwei 86601DOC034407 86601DOC034409 Evans, Aicha (Intel); Expert: Williams, Tim
attachment(s) do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0075 QX0075 11/7/2012 Email regarding Re: Quick question on LTE product Evans, Aicha INTEL-QCOM001145202 INTEL-QCOM001145203 Evans, Aicha (Intel); Expert: Snyder, Edward; Keddy, Asha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0076 QX0076 11/7/2012 Email regarding RE: Quick question on LTE product Keddy, Asha INTEL-QCOM001145240 INTEL-QCOM001145242 Evans, Aicha (Intel); Keddy, Asha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0077 QX0077 1/20/2011 Email regarding Re: InterDigital - San Diego Presentation 101215 Keddy, Asha R INTEL-QCOM007033037 INTEL-QCOM007033043 Expert: Snyder, Edward; Keddy, Asha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive

1 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 3 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Intel's Response to FTC's Request for Comments in Connection
QX0079 QX0079 8/5/2011 Nied, Earl N/A N/A Keddy, Asha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
with its Patent Standards Workshop, Project No P11-1204
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0082 QX0082 8/19/2013 Email regarding Re: Lost of Galaxy S4 Zoom (Camera) Evans, Aicha INTEL-QCOM000965099 INTEL-QCOM000965100 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Modem chip business is highly competitive; Qualcomm's business practices do not cause
QX0084 QX0084 1/30/2015 Email regarding modem business with attachment(s) Kim, Sam 86601DOC015482 86601DOC015483 Evans, Aichatou
anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding today was not a good day to be from Intel DO
QX0085 QX0085 9/16/2013 Krzanich, Brian INTEL-QCOM000113034 INTEL-QCOM000113036 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
NOT FORWARD!!!! AT ALL
anticompetitive
Constantine, Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX0087 QX0087 3/21/2013 Email regarding Re: Meeting with Apple(Wireless) Bob Mansfield INTEL-QCOM000027415 INTEL-QCOM000027419 Evans, Aicha (Intel)
Kevin competitive; Qualcomm’s business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding FW: SoC Learnings Whitepaper with
QX0089 QX0089 5/10/2017 Wyatt, Carly INTEL-QCOM000354039 INTEL-QCOM000354044 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
attachment(s)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding RE: Project Execution Leadership Virtual Teams
QX0090 QX0090 4/6/2016 Wolff, Stefan INTEL-QCOM000350032 INTEL-QCOM000350038 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
for Critical Programs
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0091 QX0091 12/20/2012 Email regarding QCom Benchmark Discussion with attachment(s) Glaser, Shelagh INTEL-QCOM008048153 INTEL-QCOM008048187 Evans, Aicha (Intel); Expert: Snyder, Edward do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Cellular Industry is thriving; Reasons for Qualcomm’s success in the modem chip business;
Evans, Aicha (Intel); Expert: Chipty, Tasneem; Expert: Snyder, Edward;
QX0092 QX0092 7/6/2015 Email regarding PEG Benchmarking with attachment(s) Ardalan, Kayvan INTEL-QCOM007957504 INTEL-QCOM007957535 Modem chip business is highly competitive; Qualcomm’s business practices do not cause
Expert: Williams, Tim
anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding 7360 1$ Cost Challenge ---> Response with
QX0094 QX0094 9/12/2016 Jungman, Frank INTEL-QCOM000487295 INTEL-QCOM000487302 Evans, Aicha (Intel) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
attachment(s)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding Multi-Generational LTE Pricing Proposal - Final Spangler, Samuel
QX0095 QX0095 5/30/2017 INTEL-QCOM002236311 INTEL-QCOM002236327 Evans, Aicha (Intel); Expert: Chipty, Tasneem; Expert: Snyder, Edward do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Slides with attachment(s) G
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0096 QX0096 7/20/2015 Email regarding RE: Call with Ruben ICE Evans, Aicha INTEL-QCOM000372826 INTEL-QCOM000372826 Evans, Aicha (Intel); Expert: Snyder, Edward do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; CDMA and premium LTE are not
Islam, Abdullah Evans, Aicha (Intel); Expert: Snyder, Edward; Eul, Hermann (Intel);
QX0097 QX0097 9/13/2010 2010_04_22_100421-Project Mountain Presentation_Final_a ppt INTEL-QCOM005246984 INTEL-QCOM005247039 appropriate antitrust markets; Qualcomm’s business practices do not cause anticompetitive
Tasfiqul Sauer, Matthias (Apple); Expert: Chipty, Tasneem
harm; Qualcomm’s agreements with Apple were not anticompetitive
Evans, Aicha (Intel); Expert: Snyder, Edward; Eul, Hermann (Intel); Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0098 QX0098 10/1/2010 From fast follower to leader v4 ppt Straub, Alexander INTEL-QCOM005246267 INTEL-QCOM005246308
Sauer, Matthias (Apple) do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX0100 QX0100 2/25/2011 Email regarding AW: RE: FW: TD-SCDMA Straub, Alexander 86600DOC064365 86600DOC064369 Expert: Williams, Tim; Eul, Hermann (Intel)
Apple were not anticompetitive
Email regarding Draft for LTE Deep Dive for Dadi - Monday April Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0102 QX0102 4/2/2012 Moeller, Bernd INTEL-QCOM006910893 INTEL-QCOM006910959 Eul, Hermann (Intel); Evans, Aicha (Intel)
2 6 to 8 pm in OR with attachment(s) do not cause anticompetitive harm
Email regarding Apple Executive Briefing for Hermann Eul with Constantine, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX0103 QX0103 4/18/2012 INTEL-QCOM001003784 INTEL-QCOM001003800 Eul, Hermann (Intel); Evans, Aicha (Intel)
attachment(s) Kevin Apple were not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX0104 QX0104 10/15/2014 Email regarding Intel Wireless Clausen, Greg INTEL-QCOM003979076 INTEL-QCOM003979077 Eul, Hermann (Intel); Mansfield, Robert (Apple)
Apple were not anticompetitive
Email regarding 20110531 6th steering committee v5 2 pptx with Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0105 QX0105 8/12/2011 Straub, Alexander INTEL-QCOM002912976 INTEL-QCOM002913014 Expert: Snyder, Edward; Lindner, Thomas (Intel)
attachment(s) do not cause anticompetitive harm
Email regarding Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0109 QX0109 10/11/2013 Mohebbi, Babak INTEL-QCOM004330074 INTEL-QCOM004330124 Evans, Aicha (Intel); Lindner, Thomas (Intel)
do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0110 QX0110 11/6/2012 Email regarding RE: 7260 V2 meeting with attachment(s) Lindner, Thomas INTEL-QCOM002974583 INTEL-QCOM002974627 Expert: Williams, Tim; Lindner, Thomas (Intel) do not cause anticompetitive harm
Email regarding RE: [ICE] Technology Review meeting series
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0111 QX0111 11/6/2012 Kick-off : 1st session this Friday: Operator activities NEED Lindner, Thomas INTEL-QCOM002974578 INTEL-QCOM002974582 Expert: Williams, Tim; Lindner, Thomas (Intel)
do not cause anticompetitive harm
SUPPORT !!
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0112 QX0112 12/12/2012 Email regarding FW: Question on 7262-TDD Zhang, Zhiwei INTEL-QCOM002994017 INTEL-QCOM002994017 Expert: Williams, Tim; Lindner, Thomas (Intel)
do not cause anticompetitive harm

2 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 4 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Email regarding RE: INTERNAL mail chain for ICE CA question; Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0113 QX0113 1/9/2013 Martin, Gerhard INTEL-QCOM001360855 INTEL-QCOM001360859 Lindner, Thomas (Intel); Expert: Williams, Tim
RE: 7262/92 CA questions do not cause anticompetitive harm
Email regarding FW: MM7260 SE Architecture Workshop 12/13 Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0114 QX0114 4/10/2013 Zhang, Zhiwei INTEL-QCOM001448899 INTEL-QCOM001448908 Expert: Williams, Tim; Lindner, Thomas (Intel)
March 2013 ~~~ Action Items *** REMINDER *** do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0115 QX0115 1/15/2014 Email regarding RE: Lenovo update to MCG MPP China Lindner, Thomas INTEL-QCOM001406283 INTEL-QCOM001406284 Expert: Williams, Tim; Lindner, Thomas (Intel)
do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX0117 QX0117 1/26/2018 Subpoena to Testify at Deposition in a Civil Action for Bain Qualcomm N/A N/A Johnson, Chris (Bain)
competitive; Qualcomm’s business practices do not cause anticompetitive harm
QX0120 QX0120 3/14/2011 Bain BAIN00002230 BAIN00002230 Expert: Snyder, Edward; Johnson, Chris (Bain) Reasons for Qualcomm’s success in the modem chip business
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0121 QX0121 8/30/2012 Bain BAIN00000393 BAIN00000393 Expert: Snyder, Edward; Johnson, Chris (Bain) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0122 QX0122 1/7/2014 Bain BAIN00051010 BAIN00051010 Expert: Snyder, Edward; Johnson, Chris (Bain) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Xanthakis,
QX0123 QX0123 7/10/2015 BAIN00070742 BAIN00070754 Expert: Snyder, Edward; Johnson, Chris (Bain) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Christopher
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0124 QX0124 4/8/2011 Bain BAIN00001665 BAIN00001665 Johnson, Chris (Bain) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0126 QX0126 9/7/2012 Bain BAIN00000058 BAIN00000325 Expert: Snyder, Edward; Johnson, Chris (Bain) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
QX0202 QX0202 1/15/2010 MediaTek MTK_00601420 MTK_00601420 Moynihan, Finbarr Modem chip business is highly competitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Expert: Chipty, Tasneem; Expert: Williams, Tim; Moynihan, Finbarr
QX0204 QX0204 8/1/2010 Hsu, HY MTK_00652246 MTK_00652250 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
(MediaTek)
anticompetitive
QX0208 QX0208 6/27/2017 Chien, George MTK_00533745 MTK_00533746 Moynihan, Finbarr Modem chip business is highly competitive
QX0212 QX0212 3/11/2016 Lin, Ray MTK_00296018 MTK_00296021 Moynihan, Finbarr Modem chip business is highly competitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX0213 QX0213 3/27/2017 Moffat, Robert MTK_00797311 MTK_00797366 Expert: Chipty, Tasneem; Moynihan, Finbarr (MediaTek) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Moynihan, Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX0214 QX0214 10/12/2017 MTK_00454783 MTK_00454786 Moynihan, Finbarr
Finbarr competitive; Qualcomm’s business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX0216 QX0216 3/16/2015 Odani, Mark MTK_00245034 MTK_00245036 Moynihan, Finbarr
competitive; Qualcomm’s business practices do not cause anticompetitive harm
Qualcomm's business practices are justified; Qualcomm's business practices do not cause
QX0218 QX0218 10/21/2009 Email regarding Many thanks and look forward for happy ending Chang, David Q2017MDL4_00010241 Q2017MDL4_00010241 Hartogs, Michael; Aberle, Derek
anticompetitive harm
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Moynihan,
QX0219 QX0219 5/8/2014 MTK_00816667 MTK_00816672 Moynihan, Finbarr (MediaTek) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
Finbarr
commitments and not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Sauer, Matthias (Apple); Schafer, Aaron (Apple); Moynihan, Finbarr
QX0221 5/18/2017 Email regarding Cellular RFP with attachment(s) Chhugani, Sunil APL-QC-FTC_11310603 APL-QC-FTC_11310606 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
(MediaTek)
QX0221 anticompetitive
QX0222 QX0222 11/9/2017 Keating, Kevin MTK_00450489 MTK_00450491 Moynihan, Finbarr Modem chip business is highly competitive
Ahn, Seungho (Samsung); Hojin Kang, Alex (Samsung); Kalkman, John
QX0519 QX0519 12/14/2013 Business Report of Procurement Group 1 Samsung SFT-0030196 SFT-0030235 Modem chip business is highly competitive
(Samsung); Lee, Injung (Samsung)
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0520 QX0520 1/6/2010 First Chipset Committee Meeting Minutes with translation(s) Samsung SFT-0030001 SFT-0030004 Kang, Hojin (Samsung); Lee, Injung (Samsung)
are justified
Expert: Chipty, Tasneem; Hojin Kang, Alex (Samsung); Kalkman, John
QX0521 QX0521 1/26/2012 Modem Management Plan with translation(s) Samsung SFT-0030124 SFT-0030140 Modem chip business is highly competitive
(Samsung)
Expert: Chipty, Tasneem; Hojin Kang, Alex (Samsung); Kalkman, John
QX0522 QX0522 4/14/2013 Second Chipset Committee with translation(s) Samsung SFT-0030560 SFT-0030582 Modem chip business is highly competitive
(Samsung)
QX0524 QX0524 1/5/2015 Email regarding RE: RE: MDM9x35 Price Issue Kwon, O H Q2014FTC02161769 Q2014FTC02161775 Amon, Cristiano; Hojin Kang, Alex (Samsung); Expert: Chipty, Tasneem Cellular Industry is thriving; Modem chip business is highly competitive

3 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 5 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0530 QX0530 10/26/2011 Review of Modem Chip Agreement with translation(s) Samsung SFT-0007264 SFT-0007266 Kim, Yooseok; Hong, Andrew
are justified; Qualcomm's business practices do not cause anticompetitive harm
Qualcomm's business practices are justified; Qualcomm's business practices do not cause
QX0534 QX0534 7/29/2013 7 (eng) Nokia-HTC Standstill docx Samsung SFT-0000803 SFT-0000804 Kim, Yooseok; Hong, Andrew; Aberle, Derek; Gonell, Fabian
anticompetitive harm
QX0536;
CX2629; Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
6f108d81-7748-4ed2-83f8-61ce9a75667b_ 2018-01-30
CX6624; Ahn, Seungho (Samsung); Chen, Liren; Gonell, Fabian; Hong, Andrew not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX0536 1/29/2018 Purchases of QCOM Components for use in Lic Products Qualcomm QAPPCMSD02163035 QAPPCMSD02163036
PX0282; (Samsung); Rogers, Alex practices do not cause anticompetitive harm; Device-level licensing is consistent with
pdf
PX0309; Qualcomm’s FRAND commitments and not anticompetitive
PX0928
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
QX0537;
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX0537 QX0544; 1/1/2018 Qualcomm QAPPCMSD02163098 QAPPCMSD02163113 Chen, Liren; Gonell, Fabian; Rogers, Alex; Expert: Nevo, Aviv
practices do not cause anticompetitive harm; Device-level licensing is consistent with
CX6630
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX0539; Approval Request for the Conclusion of Amendment to Patent Hong, Andrew (Samsung); Kalkman, John (Samsung); Lee, Injung
QX0539 10/15/2009 Samsung SFT-0006775 SFT-0006782 anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
QX0554 Agreement with translation(s) (Samsung)
commitments and not anticompetitive
QX0546 QX0546 2/4/2008 Email regarding Re: Renewal Notice Aberle, Derek Q2017MDL3_00039813 Q2017MDL3_00039814 Aberle, Derek; Lee, Injung (Samsung) Qualcomm's license agreements are not the result of coercion
QX0548; Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0548 2/16/2016 Results Report on the 6th Negotiation with translation(s) Samsung SFT-0036174 SFT-0036176 Lee, Injung (Samsung)
CX2567 are justified
QX0549;
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0549 CX2568; 2/12/2016 Results report on the 7th round of negotiations with translation(s) Samsung SFT-0036177 SFT-0036179 Lee, Injung (Samsung)
Qualcomm’s FRAND commitments and not anticompetitive
CX2568A
QX0550; Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0550 9/18/2008 Results report on the 8th round of negotiations with translation(s) Samsung SFT-0036180 SFT-0036182 Lee, Injung (Samsung)
CX2569 are justified
QX0551; Hojin Kang, Alex (Samsung); Lee, Injung (Samsung); Expert: Chipty,
QX0551 2/12/2016 Report on the 1st Negotiation with translation(s) Samsung SFT-0036160 SFT-0036161 Modem chip business is highly competitive
CX2562 Tasneem
Email regarding Undeliverable: Re: March 4th meeting with Qualcomm’s license agreements are not the result of coercion; G Qualcomm’s business
QX0552 QX0552 3/18/2008 Aberle, Derek Q2014FTC00794671 Q2014FTC00794673 Aberle, Derek; Gonell, Fabian
attachment(s) practices are justified
Email regarding March 27th meeting(claim charts) with Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0553 QX0553 3/24/2008 Lee, Heungmo Q2017MDL3_00039830 Q2017MDL3_00039836 Aberle, Derek; Lee, Injung; Altman, Steven; Hartogs, Michael
attachment(s) are justified
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0556 QX0556 12/12/2012 Samsung submission to ITC Samsung N/A N/A Ahn, Seungho (Samsung); Lee, Injung (Samsung)
Qualcomm’s FRAND commitments and not anticompetitive
Email regarding Re: Re: Re: Report on Summary of Nokia's Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0557 QX0557 4/13/2015 Lee, Injung SFT-2657060 SFT-2657061 Ahn, Seungho (Samsung); Lee, Injung (Samsung)
Rebuttal Brief with translation(s) Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0558 QX0558 11/21/2009 Modem chip acquisition status with translation(s) Samsung SFT-0014133 SFT-0014134 Lee, Injung; Aberle, Derek
are justified; Qualcomm's business practices do not cause anticompetitive harm
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0560 QX0560 4/6/2013 RMC IPR strategy and operations pptx with attachment(s) Samsung SFT-3145866 SFT-3145893 Kalkman, John (Samsung) are justified; Qualcomm’s business practices do not cause anticompetitive harm; Device-level
licensing is consistent with Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0561 QX0561 4/29/2012 IP Issues Under Management of DS with translation(s) Samsung SFT-2284599 SFT-2284601 Kim, Yooseok; Gonell, Fabian
are justified
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0562 QX0562 10/20/2011 Email regarding sale of modem chips with translation(s) Samsung SFT-2925191 SFT-2925192 Ahn, Seungho (Samsung); Kim, Yooseok (Samsung) are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
not anticompetitive
QX0564; Negotiation Results Report regarding modem chips with Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0564 2/16/2012 Samsung SFT-0008700 SFT-0008702 Kim, Yooseok; Gonell, Fabian
CX2507 translation(s) are justified; Qualcomm's business practices do not cause anticompetitive harm
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0565 QX0565 3/21/2013 Report on Meeting Results with translation(s) Samsung SFT-0007261 SFT-0007263 Kim, Yooseok; Reifschneider, Eric; Gonell, Fabian
are justified
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX0566 QX0566 5/20/2013 Meeting Result Report with translation(s) Samsung SFT-0013319 SFT-0013323 Kim, Yooseok; Reifschneider, Eric; Gonell, Fabian
are justified
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Samsung memo regarding meeting with Qualcomm with Aberle, Derek; Gonell, Fabian; Kalkman, John (Samsung); Kim, Yooseok
QX0567 QX0567 7/29/2013 Samsung SFT-0000805 SFT-0000806 anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
translation(s) (Samsung); Reifschneider, Eric
commitments and not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0572 QX0572 6/27/2010 Re: Re: Meeting Samsung APL-QC-FTC_36935452 APL-QC-FTC_36935456 Ahn, Seungho (Samsung); Watrous, BJ (Apple); Williams, Jeff (Apple) are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
not anticompetitive

4 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 6 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Ahn, Seungho (Samsung); Kalkman, John (Samsung); Watrous, BJ Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0573 QX0573 6/20/2013 Letter to Watrous from Samsung Chi, Jae Wan SFT-2640002 SFT-2640003
(Apple) Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0574 QX0574 7/25/2011 Email regarding Fwd: Apple : FRAND with attachment(s) Teksler, Boris APL-QC-FTC_34726648 APL-QC-FTC_34726653 Ahn, Seungho (Samsung); Blevins, Tony (Apple); Watrous, BJ (Apple) are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
Ahn, Seungho (Samsung); Kalkman, John (Samsung); Watrous, BJ
QX0575 QX0575 3/22/2013 March 22,2013 Samsung letter to Apple pdf Samsung SFT-2639967 SFT-2639968 are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
(Apple)
not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0577 QX0577 1/31/2012 Letter from Samsung to Apple Samsung SFT-2639976 SFT-2639977 Ahn, Seungho (Samsung); Kalkman, John (Samsung)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0578 QX0578 5/11/2012 Letter from Kim to Teksler Kim, Seongwoo APL-QC-FTC_34544648 APL-QC-FTC_34544651 Ahn, Seungho (Samsung); Blevins, Tony (Apple); Watrous, BJ (Apple)
Qualcomm’s FRAND commitments and not anticompetitive
Email regarding Fwd: Re: (Question) Re: Please call with
QX0579 QX0579 1/13/2016 Choi, SB SFT-2230828 SFT-2230834 Ahn, Seungho (Samsung); Lee, Injung (Samsung) Qualcomm’s license agreements are not the result of coercion
attachment(s) and translation(s)
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
Email regarding Qualcomm- Terms with
QX0580 QX0580 9/5/2013 Lee, Dongwoo SFT-2757075 SFT-2757079 Anh, Seungho (Samsung); Lee, Injung (Samsung) are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
attachment(s) and translation(s)
not anticompetitive
Email regarding CEO Note Update Request with attachment(s) Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0582 QX0582 4/10/2014 Lee, Dongg SFT-2764114 SFT-2764122 Ahn, Seungho (Samsung)
and translation(s) Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX0583 QX0583 2/17/2016 Company Q Response with translation(s) Samsung SFT-2969937 SFT-2969941 Ahn, Seungho (Samsung); Kalkman, John (Samsung) are justified; Qualcomm’s business practices do not cause anticompetitive harm; Device-level
licensing is consistent with Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0879 QX0879 8/28/2017 Blackberry BB-Q-ATR-01009815 BB-Q-ATR-01009833 Grubbs, John (Blackberry)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX0881 QX0881 11/10/2017 Blackberry BB-Q-ATR-01011257 BB-Q-ATR-01011364 Grubbs, John (Blackberry)
Qualcomm’s FRAND commitments and not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1017; Expert: Williams, Tim; Rango, Robert (Broadcom); McGregor, Scott
QX1003 5/13/2014 Cellular Scenarios Broadcom BCRM000238 BCRM000250 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
QX1003 (Broadcom)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1004 QX1004 4/17/2014 Email regarding RE: Apple - Aaron LTE notes McGregor, Scott BRCM173176 BRCM173177 Rango, Robert (Broadcom) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Expert: Snyder, Edward; Rango, Robert (Broadcom); Expert: Williams,
QX1005 QX1005 5/8/2014 Email regarding Fwd: Apple LTE - bad news McGregor, Scott BRCM173161 BRCM173162 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Tim
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1006 QX1006 5/14/2014 Email regarding RE: Blevins conversation McGregor, Scott BRCM173157 BRCM173158 Expert: Snyder, Edward; Rango, Robert (Broadcom) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1007 QX1007 5/10/2010 Mobile and Wireless Group Presentation Broadcom BCRM000002 BCRM000025 Rango, Robert (Broadcom) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Device-level licensing is
Email regarding RE: Tech Trading Thoughts: BRCM Print Expert: Chipty, Tasneem; Expert: Snyder, Edward; Expert: Williams,
QX1009 QX1009 7/25/2011 Rango, Robert BRCM174660 BRCM174661 consistent with Qualcomm’s FRAND commitments and not anticompetitive; Qualcomm’s
Tonight Tim; Rango, Robert (Broadcom)
agreements with Apple were not anticompetitive
Modem chip business is highly competitive; Qualcomm’s business practices do not cause
QX1010 QX1010 2012 2012 3YP BOD PRESENTATION Broadcom BCRM000131 BCRM000172 Expert: Williams, Tim; Rango, Robert (Broadcom)
anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1013 QX1013 6/21/2013 Email regarding Fwd: JK McGregor, Scott BRCM176297 BRCM176298 Expert: Williams, Tim; Rango, Robert (Broadcom) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1014 QX1014 8/23/2013 Email regarding FW: Scenarios McGregor, Scott BRCM174110 BRCM174110 Rango, Robert (Broadcom) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1019 QX1019 2/13/2014 Minutes of a Meeting of the Board of Directors Broadcom BCRM000397 BCRM000428 Rango, Robert (Broadcom); McGregor, Scott (Broadcom) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX1170 QX1170 09/30/2015 Shu, David ZTE105686 ZTE105687 Aberle, Derek; Shen, Spencer
are justified; Qualcomm's business practices do not cause anticompetitive harm

5 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 7 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Email regarding Re: URGENT Re: LTE RFP Review Presentation Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX1351 8/7/2011 Umerani, Wahid APL-QC-FTC_07827378 APL-QC-FTC_07827400 Expert: Williams, Tim
QX1351 with attachment(s) competitive; Qualcomm’s business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Expert: Snyder, Edward; Expert: Williams, Tim; Sauer, Matthias
QX1353 3/8/2012 Email regarding Re: schedule/project options Sauer, Matthias APL-QC-FTC_11041222 APL-QC-FTC_11041227 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
(Apple); Schell, Steve (Apple)
QX1353 anticompetitive
Expert: Chipty, Tasneem; Expert: Snyder, Edward; Expert: Williams, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX1357 1/31/2013 Email regarding Re: iPad roadmap planning - actions Schell, Steve APL-QC-FTC_01197513 APL-QC-FTC_01197514
QX1357 Tim; Schell, Steve (Apple) Apple were not anticompetitive
QX1387 QX1387 02/22/2012 Apple letter to ETSI re FRAND PDF Apple APL-QC-FTC_37126006 APL-QC-FTC_37126007 Watrous, BJ Qualcomm's license agreements are not the result of coercion
Qualcomm
QX1388 Williams 0010; 02/03/2012 M6381-Google-MMI-Apple -Remedies pdf Apple APL-QC-FTC_22482300 APL-QC-FTC_22482306 Watrous, BJ Qualcomm's license agreements are not the result of coercion
QX1388
QX1389 QX1389 02/12/2012 Asia FRAND ppt Apple APL-QC-FTC_22482703 APL-QC-FTC_22482703 Watrous, BJ Qualcomm's license agreements are not the result of coercion
QX1391 QX1391 3/20/2015 Ericsson ERIC-QCOM-00021154 ERIC-QCOM-00021155 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX1392 QX1392 3/30/2015 March 30 2014 Alfalahi letter pdf Alfalahi, Kasim APL-QC-FTC_36701850 APL-QC-FTC_36701852 Petersson, Christina; Watrous, BJ
are justified; Qualcomm's business practices do not cause anticompetitive harm
Email regarding Re: Nokia - Draft Letters - Privileged &
QX1394 QX1394 2/16/2017 Whitt, Jayna APL-QC-FTC_35089935 APL-QC-FTC_35089948 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
Confidential with attachment(s)
QX1396 QX1396 2/5/2016 Email regarding Fwd: Letter from BJ Watrous with attachment(s) Gonell, Fabian Q2017MDL1_02001041 Q2017MDL1_02001044 Gonell, Fabian; Watrous, BJ; Aberle, Derek; Rogers, Alex Qualcomm's license agreements are not the result of coercion
QX1397 QX1397 2/17/2016 2016-02-17 Letter to BJ Watrous responding to 05Feb Letter pdf Gonell, Fabian APL-QC-FTC_32292649 APL-QC-FTC_32292651 Gonell, Fabian; Watrous, BJ; Aberle, Derek; Rogers, Alex Qualcomm's license agreements are not the result of coercion
Blevins, Tony (Apple); Expert: Snyder, Edward; Mahe, Isabel (Apple); Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1452 QX1452 3/26/2009 Email regarding Isabel 1X1 Topic for Thursday Blevins, Tony APL-QC-FTC_18781956 APL-QC-FTC_18781957 Williams, Jeff (Apple) do not cause anticompetitive harm
Email regarding Re: IFX missed NS Complete Milestone yet Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1453 10/17/2009 Mecklai, Hussein APL-QC-FTC_08783619 APL-QC-FTC_08783621 Expert: Snyder, Edward; Mahe, Isabel (Apple)
QX1453 again do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding Supplemental Wireless Roadmap Status (February
QX1454 2/4/2010 Murelaga, Debra APL-QC-FTC_20522022 APL-QC-FTC_20522027 Mahe, Isabel (Apple) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
4, 2010) with attachment(s)
QX1454 anticompetitive
Email regarding Roll up for Scott (Re: Response Needed: Status
QX1456 9/16/2010 Mujtaba, S Aon APL-QC-FTC_07441472 APL-QC-FTC_07441479 Expert: Chipty, Tasneem; Mahe, Isabel (Apple) Reasons for Qualcomm’s success in the modem chip business
QX1456 Update 9/15 -- Systems Engineering) with attachment(s)
Expert: Williams, Tim; Mahe, Isabel (Apple); Mansfield, Robert (Apple);
QX1459 11/15/2011 Email regarding Planning Status Virk, Rob APL-QC-FTC_15103202 APL-QC-FTC_15103215 Modem chip business is highly competitive
QX1459 Sauer, Matthias (Apple); Schell, Steve (Apple); Williams, Jeff (Apple)
Qualcomm
Blevins, Tony (Apple); Expert: Chipty, Tasneem; Expert: Snyder, Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
Williams 0019; Email regarding LTE modem chipset RFP - 8/9 review notes with
QX1460 8/9/2011 Hieta, Saku AAPL-FTC-00123661 AAPL-FTC-00123672 Edward; Expert: Williams, Tim; Mahe, Iasabel (Apple); Schell, Steve competitive; Qualcomm’s business practices do not cause anticompetitive harm; Qualcomm’s
QX1460; attachment(s)
(Apple); Williams, Jeff (Apple) agreements with Apple were not anticompetitive
CX0552
QX1461 QX1461 2/23/2011 Email regarding Re: happy new year, and a favor Mahe, Isabel APL-QC-FTC_22582536 APL-QC-FTC_22582537 Mahe, Isabel (Apple); Mansfield, Robert (Apple) Reasons for Qualcomm’s success in the modem chip business
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX1464 11/7/2012 Email regarding Re: Intel CEO meeting Mucke, Christian APL-QC-FTC_00389944 APL-QC-FTC_00389947 Expert: Williams, Tim; Mahe, Isabel (Apple); Expert: Chipty, Tasneem
QX1464 competitive; Qualcomm’s agreements with Apple were not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX1465 2/1/2013 Email regarding Re: Intel Mujtaba, S Aon APL-QC-FTC_05296065 APL-QC-FTC_05296065 Mahe, Isabel (Apple); Mansfield, Robert (Apple)
QX1465 Apple were not anticompetitive
Blevins, Tony (Apple); Expert: Williams, Tim; Mahe, Isabel (Apple); Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX1466 2/1/2013 Email regarding Fwd: Intel Wireless Mansfield, Robert APL-QC-FTC_22169280 APL-QC-FTC_22169281
QX1466 Mansfield, Robert (Apple); Schell, Steve (Apple); Williams, Jeff (Apple) Apple were not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1467 3/20/2013 Email regarding IMC 7292 Schell, Steve APL-QC-FTC_07998887 APL-QC-FTC_07998887 Mahe, Isabel (Apple); Sauer, Matthias (Apple); Schell, Steve (Apple)
QX1467 do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Constantine, do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
QX1524 QX1524 5/26/2011 Email regarding ICE roadmap meeting notes with Steve Schell Kevin G INTEL-QCOM000214345 INTEL-QCOM000214349 Sauer, Matthias (Apple) anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX1636 QX1636 10/18/2013 Email regarding Re: BRCM Wireless with attachment(s) Schell, Steve APL-QC-FTC_29838053 APL-QC-FTC_29838216 Expert: Williams, Tim; Schell, Steve (Apple)
do not cause anticompetitive harm
Qualcomm's business practices are justified; Qualcomm's business practices do not cause
QX1715 1/9/2013 Email regarding Redlined Agreements with attachment(s) Sewell, Bruce APL-QC-FTC_14513289 APL-QC-FTC_14513331 Aberle, Derek; Williams, Jeff
QX1715 anticompetitive harm; Qualcomm's agreements with Apple were not anticompetitive
Email regarding Letter enclosing draft agreements with Qualcomm’s license agreements are not the result of coercion; Qualcomm’s agreements with
QX1725 7/16/2016 Gonell, Fabian AAPL-FTC-00131613 AAPL-FTC-00131679 Blevins, Tony (Apple); Gonell, Fabian; Watrous, BJ (Apple)
QX1725 attachment(s) Apple were not anticompetitive
QX2259; Email regarding FW: Follow up on Hong Kong meeting with
QX2259 5/20/2014 Rouse, Tom Q2017MDL1_00775609 Q2017MDL1_00775612 Ding, Jason; Gonell, Fabian; Reifschenider, Eric Qualcomm’s license agreements are not the result of coercion
QX2305 attachment(s)
QX2260 QX2260 12/28/2013 Huawei FTC-Huawei-0001237 FTC-Huawei-0001242 Ding, Jason Qualcomm’s license agreements are not the result of coercion

6 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 8 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
QX2310;
QX2418; Apple HUAWEI-QUALCOMM- HUAWEI-QUALCOMM- Ding, Jianxin (Jason) (Huawei); Petersson, Christina (Ericsson); Yu, Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2310 1/13/2016 Ericsson Huawei GPLA-executed (2016) pdf Huawei
Ding 0011; 00001660 00001689 Nanfen (Nancy) (Huawei) Qualcomm’s FRAND commitments and not anticompetitive
PX0625
QX2353; TRANS-FTC-HUAWEI- TRANS-FTC-HUAWEI-
QX2353 CX1041 11/26/2013 Email regarding RE: Important: cdma chip related matters Wang, Richard 0003774 0003775 Wang, Richard Modem chip business is highly competitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX2452 QX2452 8/6/2012 Meyer, George MOTO-QUAL-01481119 MOTO-QUAL-01481120 Expert: Nevo, Aviv; Madderom, Todd (Lenovo/Motorola)
are justified
CDMA and premium LTE are not appropriate antitrust markets; E Modem chip business is
QX2454 QX2454 12/3/2013 Madderom, Todd MOTO-QUAL-00722107 MOTO-QUAL-00722107 Madderom, Todd (Lenovo/Motorola)
highly competitive
QX2456 QX2456 1/31/2014 Touvannas, John MOTO-QUAL-01130751 MOTO-QUAL-01130754 Madderom, Todd (Lenovo/Motorola) Cellular Industry is thriving; Modem chip business is highly competitive
Qualcomm’s business practices are justified; Qualcomm’s agreements with Apple were not
QX2458 QX2458 6/3/2014 Robinson, Janet MOTO-QUAL-01138141 MOTO-QUAL-01138142 Madderom, Todd (Lenovo/Motorola)
anticompetitive
QX2459 QX2459 11/4/2014 Lv, Hui MOTO-QUAL-00694812 MOTO-QUAL-00694818 Expert: Chipty, Tasneem Cellular Industry is thriving; Modem chip business is highly competitive
Cellular Industry is thriving; Modem chip business is highly competitive; Qualcomm’s business
QX2462 QX2462 2/10/2015 Lv, Hui MOTO-QUAL-01048253 MOTO-QUAL-01048257 Madderom, Todd (Lenovo/Motorola)
practices do not cause anticompetitive harm
CDMA and premium LTE are not appropriate antitrust markets; Modem chip business is highly
QX2464 QX2464 03/09/2015 Motorola N/A N/A Madderom, Todd
competitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Subpoena to Testify at Deposition in a Civil Action for Via
QX2501 QX2501 12/6/2017 Qualcomm N/A N/A Maghame, Taraneh (Via) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
Licensing Corp
commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2503 QX2503 11/4/2010 Via Licensing Via-FTCQ-00000007 Via-FTCQ-00000044 Maghame, Taraneh (Via)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX2504 QX2504 11/3/2010 Via Licensing Via-FTCQ-00000001 Via-FTCQ-00000006 Maghame, Taraneh (Via) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2516 QX2516 11/25/2011 Via Licensing Via-FTCQ-00000125 Via-FTCQ-00000128 Maghame, Taraneh (Via)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2519 QX2519 4/9/2012 Via Licensing Via-FTCQ-00000283 Via-FTCQ-00000344 Maghame, Taraneh (Via)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2520 QX2520 3/28/2012 Via Licensing Via-FTCQ-00000280 Via-FTCQ-00000282 Maghame, Taraneh (Via)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2524 QX2524 3/11/2015 Via Licensing Via-FTCQ-00001291 Via-FTCQ-00001435 Maghame, Taraneh (Via)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2528 QX2528 5/19/2017 Via Licensing Via-FTCQ-00002705 Via-FTCQ-00002707 Maghame, Taraneh (Via)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2776 QX2776 11/29/2017 ETSI Rules of Procedure, 29 November 2017 N/A N/A Weiler, Dirk (Nokia); Expert: Huber, Bertram
Qualcomm’s FRAND commitments and not anticompetitive
QX2779; FTC-PROD-0028895 Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX2778 QX2778; 1/16/2017 Hoffman, Alan (containing FTC-NOKIA- FTC-PROD-0028921 Weiler, Dirk (Nokia) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
CX4321 0000001-19) commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2783 QX2783 10/3/2012 ETSI IPR submission Bahsoun, Maissa Q2017MDL1_02702458 Q2017MDL1_02702475 Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Email regarding ETSI/IPR(13)14_018 - Meeting Report with ETSI IPR Special Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2785 QX2785 6/4/2013 Q2017MDL1_01344702 Q2017MDL1_01344709 Expert: Huber, Bertram; Gonell, Fabian; Weiler, Dirk (Nokia)
attachment(s) Committee Qualcomm’s FRAND commitments and not anticompetitive
Email regarding SSO Policy meeting agenda 11/23/15 with Casaccia, Lorenzo; Expert: Huber, Bertram; Gonell, Fabian; Weiler, Dirk Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX2786 QX2786 11/23/2015 Boyne, Kalli Q2017MDL1_02018965 Q2017MDL1_02019177
attachment(s) (Nokia) Qualcomm’s FRAND commitments and not anticompetitive
Email regarding FW: Background Materials for January 11 Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX2879 QX2879 1/7/2017 Meeting with Ericsson - FTC FILE NO 141-0199, QUALCOMM Woodward, Mark FTC-PROD-0010830 FTC-PROD-0010897 Petersson, Christina (Ericsson) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
INC (privileged and confidential) with attachment(s) commitments and not anticompetitive

QX2884 QX2884 10/31/2012 Ericsson ERIC-QCOM-00003742 ERIC-QCOM-00003746 Petersson, Christina (Ericsson) Qualcomm’s business practices are justified
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Expert: Snyder, Edward; Expert: Williams, Tim; Zander, Martin
QX2928 QX2928 Ericsson ERIC-QCOM-00040883 ERIC-QCOM-00040883 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
(Ericsson)
anticompetitive

7 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No. Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 9 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Expert: Chipty, Tasneem; Expert: Williams, Tim; Zander, Martin
QX2929 QX2929 Ericsson ERIC-QCOM-00041055 ERIC-QCOM-00041157 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
(Ericsson)
anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Interdigital Inc's Response to Specification 2 of the Civil IDCC-FTCQCOM-
QX3502 QX3502 InterDigital IDCC-FTCQCOM-0000139 McElvaine, Ranae (InterDigital) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
Investigative Demand Re: Qualcomm Inc 0000144
commitments and not anticompetitive
Email regarding Licensing Discussions - Apple and InterDigital Blevins, Tony (Apple); McElvaine, Ranae (InterDigital); Watrous, BJ Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX3506 9/3/2014 Grewe, Anthony J APL-QC-FTC_20494645 APL-QC-FTC_20494649
QX3506 Group with attachment(s) (Apple) Qualcomm’s FRAND commitments and not anticompetitive
Email regarding Patent License Discussions Between Apple and Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX3507 QX3507 10/23/2015 Mewes, Heather APL-QC-FTC_37045646 APL-QC-FTC_37045655 McElvaine, Ranae (InterDigital); Watrous, BJ (Apple)
InterDigital Group with attachment(s) Qualcomm’s FRAND commitments and not anticompetitive
QX6456 QX6456 1/1/2016 3GPP change request N/A N/A Cassacia, Lorenzo Qualcomm is a leading contributor of cellular technologies
QX6457 QX6457 5/1/2000 3GPP change request N/A N/A Cassacia, Lorenzo Qualcomm is a leading contributor of cellular technologies
QX6458 QX6458 2006 3GPP TSG-RAN WG1 contribution N/A N/A Cassacia, Lorenzo Qualcomm is a leading contributor of cellular technologies
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9066 Intel 86600DOC000931 86600DOC000958 Judicial Notice
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX9067 8/9/2013 Email regarding FW: DPP presentations with attachment(s) Straub, Alexander 86600DOC064753 86600DOC064755 Evans, Aicha (Intel); Expert: Williams, Tim anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
Email regarding Re: Update - WIP information for MDM9615M -
QX9068 5/29/2012 Badal, Michelle AAPL-FTC-00023858 AAPL-FTC-00023859 Mollenkopf, Steven; Williams, Jeff; Amon, Cristiano Qualcomm’s license agreements are not the result of coercion
non-TSMC fab sources
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX9069 10/21/2010 Email regarding Pricing with attachment(s) Hieta, Saku AAPL-FTC-00060129 AAPL-FTC-00060148 Blevins, Tony (Apple); Expert: Chipty, Tasneem; Williams, Jeff (Apple)
Apple were not anticompetitive
Mollenkopf,
QX9070 1/7/2013 Email regarding Partnership AAPL-FTC-00074736 AAPL-FTC-00074740 Mollenkopf, Steven; Expert: Chipty, Tasneem; Williams, Jeff (Apple) Qualcomm’s agreements with Apple were not anticompetitive
Steven
Blevins, Tony (Apple); Mansfield, Robert (Apple); Sauer, Matthias
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9071 8/15/2012 Email regarding IMC with attachment(s) Blevins, Tony AAPL-FTC-00125120 AAPL-FTC-00125135 (Apple); Expert: Chipty, Tasneem; Expert: Snyder, Edward; Williams,
do not cause anticompetitive harm
Jeff (Apple)
CY13-CY17 Apple Cellular Device Product Spend and Royalty, Qualcomm’s business practices do not cause anticompetitive harm; Qualcomm’s agreements
QX9072 1/31/2018 Apple APL-QC_04435205 APL-QC_04435205 Expert: Chipty, Tasneem; Watrous, BJ
By Quarter, CM & Product Model with Apple were not anticompetitive
Sauer, Matthias (Apple); Schafer, Aaron (Apple); Schell, Steve (Apple); Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9073 11/6/2017 Project _2014-4-22_Final key Apple APL-QC_04435808 APL-QC_04435827
Williams, Jeff (Apple) do not cause anticompetitive harm
QX9074 02/02/2008 Email regarding Re: 25 Jobs, Steve APL-QC_04536298 APL-QC_04536299 Williams, Jeff Qualcomm's agreements with Apple were not anticompetitive
Apple Rogers
QX9075 3/8/2017 Letter regarding licensing negotiations Rogers, Alex APL-QC-FTC_00003062 APL-QC-FTC_00003067 Rogers, Alex; Gonell, Fabian; Watrous, BJ Qualcomm's license agreements are not the result of coercion
0101
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Qualcomm Expert: Snyder, Edward; Expert: Williams, Tim; Sauer, Matthias
QX9076 7/17/2012 Email regarding Re: IMC Update Schafer, Aaron J APL-QC-FTC_00364563 APL-QC-FTC_00364564 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Schafer 0008 (Apple); Schafer, Aaron (Apple); Schell, Steve (Apple)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9077 2/18/2014 Email regarding 2nd cellular supplier in 2015? Mucke, Christian APL-QC-FTC_01561755 APL-QC-FTC_01561756 Sauer, Matthias (Apple)
do not cause anticompetitive harm
Qualcomm Email regarding IMC Follow up - Dinner Provided with Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX9078 10/1/2015 Mujtaba, Aon APL-QC-FTC_01622324 APL-QC-FTC_01622327 Sauer, Matthias (Apple); Schafer, Aaron (Apple)
Schafer 0033 attachment(s) Apple were not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9079 11/5/2013 Email regarding Fwd: Slides to show to Isabel with attachment(s) Mathias, Arun APL-QC-FTC_02111889 APL-QC-FTC_02111908 Expert: Williams, Tim
competitive; Qualcomm’s business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9080 6/3/2015 Email regarding Mediate RFP response with attachment(s) Sauer, Matthias APL-QC-FTC_03762468 APL-QC-FTC_03762494 Sauer, Matthias (Apple); Schafer, Aaron (Apple)
competitive; Qualcomm’s agreements with Apple were not anticompetitive
Blevins, Tony (Apple); Expert: Chipty, Tasneem; Expert: Williams, Tim; Modem chip business is highly competitive; Qualcomm's agreements with Apple were not
QX9081 7/22/2011 LTE RFP Summary Apple APL-QC-FTC_07150929 APL-QC-FTC_07150930
Schafer, Aaron (Apple); Schell, Steve (Apple); Williams, Jeff (Apple) anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9082 9/15/2013 Email regarding Intel cellular RFP reply for 2016 Srouji, Johny APL-QC-FTC_07815535 APL-QC-FTC_07815541 Expert: Williams, Tim; Schell, Steve
competitive; Qualcomm’s business practices do not cause anticompetitive harm
Blevins, Tony (Apple); Mansfield, Robert (Apple); Schafer, Aaron Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX9083 1/31/2013 Email regarding Re: IMC ? Schell, Steve APL-QC-FTC_07997482 APL-QC-FTC_07997484
(Apple); Schell, Steve (Apple); Williams, Jeff (Apple) Apple were not anticompetitive
Email regarding Re: IMC LTE chipset development status with Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9084 3/25/2012 Sauer, Matthias APL-QC-FTC_08013086 APL-QC-FTC_08013100 Sauer, Matthias (Apple); Schell, Steve (Apple)
attachment(s) do not cause anticompetitive harm
Mollenkopf,
QX9085 5/18/2012 Email regarding update APL-QC-FTC_08271742 APL-QC-FTC_08271744 Mollenkopf, Steven; Williams, Jeff; Amon, Cristiano Qualcomm’s license agreements are not the result of coercion
Steven
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9086 4/25/2013 Email regarding Re: GPU and SDR Core License Schell, Steve APL-QC-FTC_08700804 APL-QC-FTC_08700809 Mansfield, Robert (Apple); Schell, Steve (Apple) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive

8 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 10 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9087 4/23/2009 Email regarding BRCM issues slide for managers meeting Schell, Steve APL-QC-FTC_11453394 APL-QC-FTC_11453397 Expert: Snyder, Edward; Schell, Steve (Apple) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Email regarding IMC roadmap (was Re: IMC key milestone Expert: Chipty, Tasneem; Expert: Williams, Tim; Sauer, Matthias Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9088 10/17/2012 Sauer, Matthias APL-QC-FTC_11685968 APL-QC-FTC_11685973
update) with attachment(s) and translation(s) (Apple); Expert: Snyder, Edward do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding also irgendwie sollten wir uns da mal alignen,
QX9089 10/18/2012 Sauer, Matthias APL-QC-FTC_11686277 APL-QC-FTC_11686278 Sauer, Matthias (Apple) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
bevor du mit diesen requests vorprescht with translation(s)
anticompetitive
Qualcomm Email regarding BRCM cellular slippage: late -> later with Expert: Snyder, Edward; Expert: Williams, Tim; Sauer, Matthias Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9090 3/14/2012 Schell, Steve APL-QC-FTC_12356690 APL-QC-FTC_12356697
Schafer 0004 attachment(s) (Apple); Schafer, Aaron (Apple); Schell, Steve (Apple) do not cause anticompetitive harm
Email regarding Re: cellular support for iPad's in Fall'13 with Sanguinetti, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX9091 12/6/2012 APL-QC-FTC_15868783 APL-QC-FTC_15868797 Expert: Williams, Tim; Schell, Steve (Apple)
attachment(s) Louie Apple were not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9092 3/20/2013 Email regarding Re: IMC 7292 Sauer, Matthias APL-QC-FTC_16011505 APL-QC-FTC_16011506 Expert: Williams, Tim; Sauer, Matthias (Apple); Schell, Steve (Apple)
do not cause anticompetitive harm
Qualcomm's business practices are justified; Qualcomm's business practices do not cause
QX9093 04/26/2017 Email regarding Letter Attached with attachment(s) Sewell, Bruce APL-QC-FTC_16199937 APL-QC-FTC_16199939 Watrous, BJ; Rogers, Alex; Gonell, Fabian
anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Email regarding Wireless PORR for cellular with
QX9094 1/17/2013 Virk, Rob APL-QC-FTC_16370183 APL-QC-FTC_16370202 Sauer, Matthias (Apple); Schell, Steve (Apple) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
attachment(s)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9095 PX0355 5/12/2014 Email regarding Re: Updates Blevins, Tony APL-QC-FTC_18125393 APL-QC-FTC_18125396 Blevins, Tony (Apple); Mahe, Isabel (Apple); Schafer, Aaron (Apple)
do not cause anticompetitive harm
QX9096 12/4/2017 Qualcomm - iPhone WW Sales through Q4FY17 xlsx Apple APL-QC-FTC_19996982 APL-QC-FTC_19996982 Expert: Chipty, Tasneem; Watrous, BJ (Apple); Williams, Jeff (Apple) Qualcomm’s agreements with Apple were not anticompetitive
Qualcomm
Williams 0033;
QX9097 12/9/2016 Email regarding Reoccurring Cellular Sync Meetings Schafer, Aaron APL-QC-FTC_20218611 APL-QC-FTC_20218612 Schafer, Aaron; Blevins, Tony Modem chip industry is competitive
Qualcomm
Schafer 0034
QX9098 12/4/2017 iPhone, iPad and iPod LOB_throughQ4FY17 xlsx Apple APL-QC-FTC_20446622 APL-QC-FTC_20446622 Watrous, BJ (Apple); Williams, Jeff (Apple) Qualcomm’s business practices do not cause anticompetitive harm
QX9099 10/24/2011 Apple-NEC Cross License Proposal Apple APL-QC-FTC_20488589 APL-QC-FTC_20488626 Watrous, BJ Qualcomm's license agreements are not the result of coercion
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Expert: Snyder, Edward; Expert: Williams, Tim; Mansfield, Robert
QX9100 9/21/2010 Email regarding Re: Fwd: RE: Schell, Steve APL-QC-FTC_20614737 APL-QC-FTC_20614740 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
(Apple); Schell, Steve (Apple)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Blevins, Tony (Apple); Expert: Snyder, Edward; Schafer, Aaron (Apple);
QX9101 3/18/2014 Email regarding BRCM Schell, Steve APL-QC-FTC_21983392 APL-QC-FTC_21983392 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Schell, Steve (Apple)
anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
Blevins, Tony (Apple); Expert: Snyder, Edward; Schell, Steve (Apple);
QX9102 1/9/2008 Email regarding Can TI rebound in baseband? Schell, Steve APL-QC-FTC_22051158 APL-QC-FTC_22051167 do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
Williams, Jeff (Apple)
anticompetitive
QX9103 03/30/2015 Email regarding Letter from Ericsson to Apple with attachment(s) McLeroy, Luke APL-QC-FTC_22483059 APL-QC-FTC_22483064 Watrous, BJ; Williams, Jeff Qualcomm’s license agreements are not the result of coercion
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s agreements with
QX9104 11/6/2012 Email regarding Re: Intel CEO meeting Schell, Steve APL-QC-FTC_22591942 APL-QC-FTC_22591944 Mansfield, Robert (Apple); Schell, Steve (Apple); Expert: Williams, Tim
Apple were not anticompetitive
Schafer, Aaron (Apple); Schell, Steve (Apple); Watrous, BJ (Apple); Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9105 2/7/2012 Company Overview & Financials (Qualcomm Presentation) Apple APL-QC-FTC_25738857 APL-QC-FTC_25738857
Williams, Jeff (Apple) competitive; Qualcomm’s agreements with Apple were not anticompetitive
Blevins, Tony (Apple); Schafer, Aaron (Apple); Watrous, BJ (Apple);
QX9106 12/3/2014 Product Cost Cheat Sheets 2014-08-25 pdf Apple APL-QC-FTC_26165399 APL-QC-FTC_26165447 Qualcomm’s business practices do not cause anticompetitive harm
Williams, Jeff (Apple)
Email regarding Re: Rechtsstreit Apple / Avox with Schuster, Qualcomm’s business practices are justified; Qualcomm’s agreements with Apple were not
QX9107 12/3/2007 APL-QC-FTC_26574916 APL-QC-FTC_26574936 Watrous, BJ (Apple)
attachment(s) Reinhardt anticompetitive
Email regarding RE: Apple-NSN Licensing Discussions with
QX9108 11/17/2014 Patel, Dhiren APL-QC-FTC_26587896 APL-QC-FTC_26587907 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
attachment(s)
Email regarding Re: Performance Deltas, Notes, 11 Sanguinetti, Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9109 8/18/2016 APL-QC-FTC_27407265 APL-QC-FTC_27407267 Blevins, Tony (Apple); Sauer, Matthias (Apple); Schafer, Aaron (Apple)
AM, Thu, Aug 18, 2016 Louie do not cause anticompetitive harm
Email regarding Ericsson letter to Apple, April 10, 2015 with
QX9110 4/10/2015 Alfalahi, Kasim APL-QC-FTC_29503466 APL-QC-FTC_29503468 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
attachment(s)
QX9111 2/16/2011 Email regarding Re: slides? with attachment(s) Teksler, Boris APL-QC-FTC_29848928 APL-QC-FTC_29848943 Watrous, BJ (Apple) Qualcomm’s business practices are justified
Email regarding Letter from Apple to Ericsson 3/20/15 with
QX9112 3/20/2015 Risher, Jeff APL-QC-FTC_30330422 APL-QC-FTC_30330426 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
attachment(s)
Qualcomm’s business practices are justified; Qualcomm’s agreements with Apple were not
QX9113 11/15/2012 Apple powerpoint regarding licensing framework Apple APL-QC-FTC_32591244 APL-QC-FTC_32591253 Watrous, BJ (Apple); Williams, Jeff (Apple)
anticompetitive
QX9114 8/10/2006 ATT 2010 Distribution and Revenue Share Agreement pdf Apple APL-QC-FTC_32617239 APL-QC-FTC_32617366 Mansfield, Robert (Apple); Williams, Jeff (Apple) Qualcomm’s agreements with Apple were not anticompetitive

9 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 11 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
QX9115 10/14/2008 Email regarding Qualcomm - Mavrakakis, Tom APL-QC-FTC_32700015 APL-QC-FTC_32700015 Williams, Jeff Qualcomm’s license agreements are not the result of coercion
QX9116 7/24/2015 Letter from Patel to Watrous Patel, Dhiren APL-QC-FTC_32706518 APL-QC-FTC_32706522 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
QX9117 10/13/2017 2014-04-23 Pegatron TFTC_final pdf Apple APL-QC-FTC_33221291 APL-QC-FTC_33221305 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
QX9118 1/17/2017 Email regarding Apple spreadsheet with attachment(s) Dillon, Sean APL-QC-FTC_34023809 APL-QC-FTC_34023811 Expert: Chipty, Tasneem; Schafer, Aaron (Apple) Qualcomm’s agreements with Apple were not anticompetitive
QX9119 10/14/2010 Nokia-Apple Discussion Apple APL-QC-FTC_36179603 APL-QC-FTC_36179619 Watrous, BJ (Apple); Williams, Jeff (Apple) Qualcomm’s business practices are justified
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
QX9120 8/8/2011 Email regarding Fwd: Memos Watrous, BJ APL-QC-FTC_36180552 APL-QC-FTC_36180566 Blevins, Tony (Apple); Watrous, BJ (Apple) not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s agreements
with Apple were not anticompetitive
Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies;
QX9121 8/31/2011 RF Essentials Google-MMI Discussion Apple APL-QC-FTC_36180704 APL-QC-FTC_36180704 Watrous, BJ (Apple); Williams, Jeff (Apple) Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
are justified
Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies;
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9122 12/13/2011 Email regarding deviceco v1 2 pptx with attachment(s) Teksler, Boris APL-QC-FTC_37083028 APL-QC-FTC_37083043 Watrous, BJ (Apple)
are justified; Qualcomm’s business practices do not cause anticompetitive harm; Device-level
licensing is consistent with Qualcomm’s FRAND commitments and not anticompetitive
Froessl, Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9123 5/18/2015 Email regarding IDCC materials with attachment(s) APL-QC-FTC_37115297 APL-QC-FTC_37115602 Watrous, BJ (Apple)
Alexandra are justified; Qualcomm’s agreements with Apple were not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9124 9/26/2014 Email regarding Nortel with attachment(s) Andeer, Kyle APL-QC-FTC_37235270 APL-QC-FTC_37235310 Watrous, BJ (Apple); Williams, Jeff (Apple)
Qualcomm’s FRAND commitments and not anticompetitive
QX9125 1/19/2017 Ericsson-Apple SEP Licensing Discussions Apple APL-QC-FTC_37267309 APL-QC-FTC_37267312 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
QX9126 7/7/2014 Email regarding follow up Srouji, Johny APL-QC-FTC_38255002 APL-QC-FTC_38255004 Schell, Steve Modem chip industry is competitive; Reasons for Qualcomm's success in the industry
Mansfield, Robert (Apple); Sauer, Matthias (Apple); Schell, Steve Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
QX9127 7 21 08_Unslow mp4 Apple APL-QC-Vid_000176 APL-QC-Vid_000176
(Apple); Watrous, BJ (Apple) not the result of coercion; Qualcomm’s business practices are justified
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9128 Ericsson ERC-CID-00000220 ERC-CID-00000241 Judicial Notice
Qualcomm’s FRAND commitments and not anticompetitive
QX9129 10/26/2014 Alfalahi, Kasim ERIC-QCOM-00020662 ERIC-QCOM-00020669 Watrous, BJ Qualcomm’s license agreements are not the result of coercion
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9130 Ericsson ERIC-QCOM-00040884 ERIC-QCOM-00040947 Expert: Snyder, Edward; Zander, Martin (Ericsson) do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Marsee, Andrew Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9131 9/23/2013 Email regarding 7160 comp assessment with attachment(s) INTEL-QCOM000006881 INTEL-QCOM000006912 Expert: Williams, Tim; Evans, Aichatou
S competitive; Qualcomm’s business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9132 3/7/2017 Email regarding 5G Milestones slide - final with attachment(s) Topol, Robert J INTEL-QCOM005068031 INTEL-QCOM005068043 Evans, Aichatou
competitive; Qualcomm’s business practices do not cause anticompetitive harm
Apple Wolff
QX9133 10/17/2011 Email regarding FW: PLBP with attachment(s) Straub, Alexander INTEL-QCOM007880973 INTEL-QCOM007881014 Expert: Snyder, Edward; Wolff, Stefan (Intel) Qualcomm’s business practices do not cause anticompetitive harm
0002
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX9134 9/1/2015 Marvell MRVL-00000059 MRVL-00000082 Judicial Notice anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9135 8/11/2013 Lee, TL MTK_00153976 MTK_00153980 Expert: Williams, Tim; Moynihan, Finbarr
competitive; Qualcomm’s business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9136 12/8/2017 Bhushan, Mohit MTK_00755121 MTK_00755130 Expert: Snyder, Edward; Moynihan, Finbarr (MediaTek) competitive; Qualcomm’s business practices do not cause anticompetitive harm; Qualcomm’s
agreements with Apple were not anticompetitive
Qualcomm’s business practices do not cause anticompetitive harm; Device-level licensing is
QX9137 10/22/2009 Hartogs, Michael MTKFTC_00002068 MTKFTC_00002070 Hartogs, Michael
consistent with Qualcomm’s FRAND commitments and not anticompetitive
QX9138 3GPP TDoc R1-162192_Frequency scalable NR design doc N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
QX9139 3GPP TDoc R1-162193_Forward compatibility doc N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
QX9140 3GPP TDoc R1-162199_waveform_candidates docx N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
QX9141 3GPP TDoc R1-162207_Frame_Structure_Candidates docx N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
3GPP TDoc R4-120667_Carrier Aggregation Bandwidth
QX9142 N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Combination doc
QX9143 3GPP TDoc RP-120335 LTE CA BW v2 doc N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies

10 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 12 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party

CX7472;
CX7473;
CX7474;
3GPP TSG RAN WG1 Meeting #61-bis R1-104157; 3GPP TSG-
CX7475;
CT WG1 Meeting #67 Change Request; 3GPP TSG-RAN #55 RP-
CX7478;
120213; 3GPP TSG RAN WG1 #80 R1-150477; 3GPP TSG SA
CX7479;
WG2 Meeting #78 TD S2-101530; 3GPP TSG SA WG2 Meeting
CX7480;
#78 TD 52-101536; SA WG2 Temporary Document TD S2-
CX7481;
101537 was S2-101242; 3GPP TSG SA WG2 Meeting #78 TD S2-
CX7482;
101538; 3GPP TSG SA WG2 Meeting #78 TD S2-101539; 3GPP
CX7483;
QX9144 TSG SA WG2 Meeting #76 TD S2-097122; 3GPP TSG SA WG2 N/A N/A Casaccia, Lorenzo Qualcomm is a leading contributor of cellular technologies
CX7484;
Meeting #76 TD S2-097123; 3GPP TSG SA WG2 Meeting #76
CX7485;
TD S2-097127; 3GPP TSG SA WG2 Meeting #76 TD S2-097128;
CX7486;
3GPP TSG SA WG2 Meeting #76 TD S2-097129; 3GPP TSG SA
CX7487;
WG2 Meeting #76 TD S2-097130; 3GPP TSG-RAN WG1#44 R1-
CX7488;
060465; 3GPP TSG-RAN WG1 #44 R1-060461; 3GPP TSG-RAN
CX7489;
WG1 Meeting #53 R1-081891; 3GPP TSG-RAN WG2 Meeting
CX7490;
#89 R2-150587; 3GPP TSG CT WG1 Meeting #70 C1-111448
CX7491;
CX7492;
CX7493
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
5G License Agreements Signed Between OEMs and Qualcomm not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9145 Qualcomm N/A N/A Expert: Nevo, Aviv; Gonell, Fabian; Rogers, Alex
Summary Pursuant to Federal Rule of Evidence 1006 practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies;
QX9146 4/26/2016 Apple Q2 2016 Earnings Call Transcript Apple N/A N/A Watrous, BJ (Apple)
Qualcomm’s license agreements are not the result of coercion
Brief for Nokia Corporation and Nokia Inc as Amici Curiae in Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9147 4/4/2013 Nokia N/A N/A Expert: Huber, Bertram
Support of Reversal And in Support of Neither Party Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
CDMA and WCDMA License Agreements Signed Between OEMs
Aberle, Derek; Expert: Nevo, Aviv; Gonell, Fabian; Hartogs, Michael; not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9148 and Qualcomm Summary Pursuant to Federal Rule of Evidence Qualcomm N/A N/A
Rogers, Alex practices do not cause anticompetitive harm; Device-level licensing is consistent with
1006
Qualcomm’s FRAND commitments and not anticompetitive
QX9149 CDMA Network Activation Retirement Verizon N/A N/A Expert: Chipty, Tasneem Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9150 1/8/1993 Collective Letter 629 Gnetti, Attilio N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia) are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
not anticompetitive
Commission of
Communication from the EU Commission, Intellectual Property Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9151 10/27/1992 the European N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Rights and Standardization Qualcomm’s FRAND commitments and not anticompetitive
Communities
Content of the Settlement Transcript - Taiwan Fair Trade Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9152 N/A N/A Rogers, Alex
Commission Qualcomm’s FRAND commitments and not anticompetitive
DEFENDANTS TELEFONAKTIEBOLAGET LM ERICSSON &
ERICSSON INC ’S
MOTION UNDER FED R CIV P 44 1 FOR DETERMINATION
Qualcomm's business practices are justified; Qualcomm's business practices do not cause
OF FOREIGN LAW
QX9153 10/31/2018 Ericsson N/A N/A Judicial Notice anticompetitive harm; Device-level licensing is consistent with Qualcomm's FRAND
ON REQUIRING SSPPU IN GLOBAL PATENT LICENSE
commitments and not anticompetitive
AGREEMENTS; HTC Corp , et ano v Telefonaktiebolaget LM
Ericsson, et ano , No 18-cv-00243 (E D Tex Oct 31, 2018) (ECF
No 212)
Down to the Wireless - Stakes High as Rivals Race to Provide Altman, Steven; Expert: Andrews, Jeffrey; Jacobs, Irwin; Thompson,
QX9154 5/20/1996 Kraul, Chris N/A N/A Qualcomm is a leading contributor of cellular technologies
Next Generation of Cellular Gear (LA Times) James
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9155 8/11/2003 LG N/A N/A LG
do not cause anticompetitive harm
ETSI GA 15 (93) 34 [Draft Minutes of the 15th ETSI General Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9156 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Assembly] Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9157 10/19/1994 ETSI GA 21 (94) 3 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive

11 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 13 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9158 ETSI GA 21 (94) 39 Rev 2 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9159 3/18/1993 ETSI March 1993 ETSI IPR Policy and Undertaking N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9160 2003 ETSI-GA 42(03)20 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9161 8/14/2003 ETSI-GA 42(03)20 rev 1 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9162 3/1/2004 ETSI-GA 42(03)34 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9163 9/14/2006 ETSI-GA-IPRR06(06)24 rev1 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX9164 12/10/2015 ETSIIPR15(23)16 rev 2 Rodriguez, Carole N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia) anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
6/28/2018; Expert report by Bénédicte Fauvarque-Cosson; Executed Device-level licensing is consistent with Qualcomm’s FRAND commitments and not
QX9165 CX0057; N/A Qualcomm N/A N/A Federal Rule of Civil Procedure 44 1
9/28/2018 Declaration of Bénédicte Fauvarque-Cosson anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
First Quarter of Royalties Reported for Handsets by OEMs and
Aberle, Derek; Expert: Nevo, Aviv; Gonell, Fabian; Hartogs, Michael; not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9166 Contract Numbers Summary Pursuant to Federal Rule of Evidence Qualcomm N/A N/A
Rogers, Alex practices do not cause anticompetitive harm; Device-level licensing is consistent with
1006
Qualcomm’s FRAND commitments and not anticompetitive
How to lead the evolution and expansion of the 3GPP ecosystem
QX9167 8/2/2017 Qualcomm N/A N/A Cassacia, Lorenzo; Jacobs, Irwin Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
(from www qualcomm com)
Rosenbrock, Karl Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9168 1993 IBM Comments, ETSI Collective Letter No 640 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Heinz Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9169 5/1/2004 Implementation of the ETSI IPR Policy, GSC-9/GTSC-2/GRSC-2 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Intel Accelerates Timing for Intel XMM 8160 5G Multimode
The cellular Industry is thriving; Modem chip business is highly competitive; Qualcomm’s
Modem, https://newsroom intel com/news/intel-accelerates-timing-
QX9170 11/12/2018 Intel N/A N/A Expert: Snyder, Edward; Expert: Chipty, Tasneem; Evans, Aichatou business practices do not cause anticompetitive harm; Qualcomm’s agreements with Apple
intel-xmm-8160-5g-multimode-modem-support-broad-global-5g-
were not anticompetitive
rollouts/
QX9171 1/4/2017 Intel Announces World's First Global 5G Modem Intel N/A N/A Expert: Chipty, Tasneem Modem chip business is highly competitive
IPR(12)12_002r2, Status, of, discussions: overview of the possible
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9172 9/26/2012 scenarios, associated historical information and wording proposals Dirk Weiler N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
where appropriate
IPR(15)23 006, Guidance on the Meaning of Fair and Reasonable Cisco Systems Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9173 10/13/2015 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
in ETSI IPR Policy Belgium, et al Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9174 5/3/2016 IPR(15)23_016r4, Meeting Report Dirk Weiler N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX9175 8/1/2006 IPRR01(06)08, Proposal for IPR Policy Reform Ericsson, et al N/A N/A Expert: Huber, Bertram anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
QX9176 3/5/2018 Letter from Dept of Treasury, Re CFIUS Case 18-036 Mir, Aimen N N/A N/A Mollenkopf, Steven; Rogers, Alex Qualcomm is a leading contributor of cellular technologies
Letters from ETSI Members regarding the signature of the ETSI Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9177 6/4/1993 N/A N/A Expert: Huber, Bertram; Weiler, Dirk (Nokia)
IPR Undertaking Qualcomm’s FRAND commitments and not anticompetitive
LG G4 Commercial
QX9178 LGE N/A N/A Achour, Baaziz; Amon, Cristiano; Kressin, Keith Qualcomm’s business practices are justified
(https://www youtube com/watch?v=e2eW01eMHcc)
QX9179 LISTSERV 16 5 - 3GPP_TSG_RAN_WG2 Archives N/A N/A Casaccia, Lorenzo; Malladi, Durga Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
LTE-Only License Agreements Signed Between OEMs and not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9180 Qualcomm N/A N/A Gonell, Fabian; Expert: Nevo, Aviv; Rogers, Alex; Aberle, Derek
Qualcomm Summary Pursuant to Federal Rule of Evidence 1006 practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
QX9181 1/17/2018 Now Xiaomi's a chipmaker, too, for its very own phones C-Net N/A N/A Expert: Chipty, Tasneem Modem chip business is highly competitive
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9182 Product brief Intel XMM 7560 Intel N/A N/A Expert: Chipty, Tasneem do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive; Modem chip business is highly competitive
Qualcomm CDMA Technologies Announces High-Speed Data
QX9183 10/26/2000 Qualcomm N/A N/A Chen, Liren; Jacobs, Irwin; Malladi, Durga; Thompson, Jim Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Cell Site

12 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 14 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Qualcomm CDMA Technologies Announces On-Time Shipment
of World's First End-to-End Wireless Megabit Data Rate Chipset
QX9184 10/15/2001 Qualcomm N/A N/A Chen, Liren; Jacobs, Irwin; Malladi, Durga; Thompson, Jim Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Solutions to Support Commercial Deployment of CDMA2000
1xEVDO Worldwide
Qualcomm Hits The Big Time Pushing a little-known digital
QX9185 5/15/2000 Nee, Eric N/A N/A Altman, Steven; Jacobs, Irwin Qualcomm is a leading contributor of cellular technologies
cellulartechnology from surf's-up San Diego
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9186 7/12/2004 LG N/A N/A LG
do not cause anticompetitive harm
Qualcomm Now Demonstrating Products Based on LTE TDD Amon, Cristiano; Expert: Nevo, Avi; Kressin, Keith; Achour, Baaziz; Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies;
QX9187 9/8/2010 Qualcomm N/A N/A
Technology Expert: Chipty, Tasneem Reasons for Qualcomm’s success in the modem chip business
QX9188 Qualcomm pdQ Digital Smartphone Qualcomm N/A N/A Jacobs, Irwin Qualcomm is a leading contributor of cellular technologies
Qualcomm CDMA Technologies
QX9189 10/4/2001 Qualcomm N/A N/A Expert: Nevo, Aviv; Expert: Chipty, Tasneem Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Announces Availability of WCDMA Technology Solution
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9190 MediaTek N/A N/A Judicial Notice
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX9191 9/24/2018 Response to KFTC questionnaire for chipset manufacturers Broadcom N/A N/A Judicial Notice anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
Samsung Announces Exynos Modem 5100, Industry's First 5G
Multi-mode Modem Fully Compliant with 3GPP,
https://www samsung com/semiconductor/minisite/exynos/newsro Modem chip business is highly competitive; Qualcomm’s license agreements are not the result
QX9192 8/15/2018 Samsung N/A N/A Kalkman, John; Expert: Chipty, Tasneem
om/pressrelease/samsung-announces-exynos-modem-5100- of coercion
industrys-first-5g-multi-mode-modem-fully-compliant-with-3gpp-
standards/
QX9193 The Mobile Broadband Standard 5G 3gpp N/A N/A Cassacia, Lorenzo Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
U S Patent No 5,930,230; U S Patent No 6,185,246 B1; U S
Patent No 6,298,051 B1; U S Patent No 6,396,804 B2; U S
Patent No 6,535,739 B1; U S Patent No 7,280,467 B2; U S
Patent No 7,567,502 B2; U S Patent No 7,623,442 B2; U S
Patent No 7,961,700 B2; U S Patent No 8,068,530 B2; U S
Patent No 8,165,026 B2; U S Patent No 8,213,483 B2; U S
Patent No 8,223,625; U S Patent No 8,374,161 B2; U S Patent
No 8,521,207 B2; U S Patent No 8,576,894 B2; U S Patent No
QX9194 8,577,377 B2; U S Patent No 8,626,162 B2; U S Patent No N/A N/A Casaccia, Lorenzo; Chen, Liren; Expert: Andrews, Jeff; Malladi, Durga Qualcomm is a leading contributor of cellular technologies
8,693,383 B2; U S Patent No 8,705,441 B2; U S Patent No
8,705,506 B2; U S Patent No 8,711,785 B2; U S Patent No
8,737,517 B2; U S Patent No 8,787,143 B2; U S Patent No
8,885,628 B2; U S Patent No 8,942,192 B2; U S Patent No
9,019,902 B2; U S Patent No 9,036,538 B2; U S Patent No
9,065,714 B2; U S Patent No 9,106,389 B2; U S Patent No
9,125,072 B2; U S Patent No 9,209,933 B2; U S Patent No
9,622,230 B2; U S Patent No 9,912,438 B2
1/10/2012;
6/14/2011;
U S Patent No 8,094,595; U S Patent No 7,961,700 B2; U S
1/17/2012;
QX9195 Patent No 8,098,635 B2; U S Patent No 8,588,319 B2; U S N/A N/A Chen, Liren; Malladi, Durga Qualcomm is a leading contributor of cellular technologies
11/19/2013;
Patent No 8,059,608 B2
11/15/2011;
1/10/2012
QX9196 8/2/2017 Understanding 3GPP (from www qualcomm com) Qualcomm N/A N/A Cassacia, Lorenzo Qualcomm is a leading contributor of cellular technologies
QX9197 11/14/2017 Verizon is heading toward a Gigabit, CDMA-Free Future Segan, Sascha N/A N/A Expert: Chipty, Tasneem Cellular Industry is thriving; Qualcomm's business practices do not cause anticompetitive harm
Video - The HTC One A9 Powered by Qualcomm Snapdragon
QX9198 HTC N/A N/A Kressin, Keith; Thompson, James Qualcomm's business practices are justified
technology (https://www youtube com/watch?v=krmiKCHvgBY)
QX9199 10/1/1999 World Telecommunication Development Report 1999 N/A N/A Expert: Andrews, Jeffrey; Jacobs, Irwin Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
YouTube Video - Apple Special Event, September 2012 Mansfield, Robert (Apple); Sauer, Matthias (Apple); Schell, Steve Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
QX9200 9/1/2012 Apple N/A N/A
(https://www youtube com/watch?v=e3QyK13BZ-0) (Apple); Watrous, BJ (Apple) not the result of coercion; Qualcomm’s business practices are justified
YouTube Video - Apple WWDC, 2008 Mansfield, Robert (Apple); Sauer, Matthias (Apple); Schell, Steve Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
QX9201 2008 Apple N/A N/A
(https://www youtube com/watch?v=706cHuer0mk) (Apple); Watrous, BJ (Apple) not the result of coercion; Qualcomm’s business practices are justified

13 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 15 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
YouTube Video - CNBC Mad Money, Tim Cook Interview, May Mansfield, Robert (Apple); Sauer, Matthias (Apple); Schell, Steve Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
QX9202 5/1/2016 CNBC N/A N/A
2016 (https://www youtube com/watch?v=kFdUa_WeTcQ) (Apple); Watrous, BJ (Apple) not the result of coercion; Qualcomm’s business practices are justified
Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
Aberle, Derek; Altman, Steven; Hartogs, Michael; Gonell, Fabian;
QX9203 9/16/2010 Qualcomm Q2014FTC00005142 Q2014FTC00005185 are justified; Qualcomm's business practices do not cause anticompetitive harm; Device-level
Rogers, Alex; Expert: Nevo, Aviv
licensing is consistent with Qualcomm’s FRAND commitments and not anticompetitive
Achour, Baaziz; Amon, Cristiano; Expert: Chipty, Tasneem; Kressin, Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9204 6/6/2014 QCT Strategic Plan 2013 Qualcomm Q2014FTC00014377 Q2014FTC00014377
Keith; Mollenkopf, Steven; Thompson, James competitive
Ablerle, Derek; Altman, Steven; Cassacia, Lorenzo; Expert: Andrews,
Email regarding Fwd: Re: Privileged & Confidential with
QX9205 2/24/2008 Jacobs, Irwin Q2014FTC00349249 Q2014FTC00349285 Jeffrey; Hartogs, Michael; Jacobs, Irwin; Lupin, Louis; Malladi, Durga; Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
attachment(s)
Thompson, James
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Gonell, Fabian; Hartogs, not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9206 2/19/2014 Email regarding RE: 4G License with attachment(s) Dwight, Deborah Q2014FTC00415060 Q2014FTC00415065
Michael; Reifschneider, Eric; Rogers, Alex practices do not cause anticompetitive harm;Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9207 7/13/2014 Email regarding FW: 3-Mode Letters with attachment(s) Qian, Kun Q2014FTC00490169 Q2014FTC00490174 Reifschneider, Eric
are justified
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Email regarding 2012-10-01 pdf Kerendian, Aberle, Derek; Chen, Liren; Gonell, Fabian; Hartogs, Michael; not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9208 9/2/2014 Q2014FTC00660708 Q2014FTC00660770
with attachment(s) Naseem Reifschneider, Eric; Rogers, Alex; Expert: Nevo, Aviv practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
QX9209 1/20/2011 Email regarding Draft with attachment(s) Williams, Jeff Q2014FTC00786755 Q2014FTC00786761 Mollenkopf, Steven; Williams, Jeff (Apple) Qualcomm’s agreements with Apple were not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9210 3/21/2008 Email regarding RE: March 27th meeting Altman, Steve Q2014FTC01069992 Q2014FTC01069997 Aberle, Derek; Altman, Steven; Hartogs, Michael; Rogers, Alex
are justified; Qualcomm’s business practices do not cause anticompetitive harm
Email regarding Fw: Suggested Template for Account Team
QX9211 7/23/2012 Kwon, O H Q2014FTC01091249 Q2014FTC01091251 Amon, Cristiano; Expert: Chipty, Tasneem; Wyatt, William Cellular Industry is thriving; Modem chip business is highly competitive
Reviews with attachment(s)
QX9212 8/4/2015 Email regarding Re: Exhaustion Amon, Cristiano Q2014FTC01216680 Q2014FTC01216681 Aberle, Derek; Amon, Cristiano; Gonell, Fabian; Reifschneider, Eric Qualcomm’s business practices are justified
Email regarding : 6/25 update with Qualcomm's business practices are justified; Qualcomm's business practices do not cause
QX9213 7/6/2007 Mehta, Sanjay Q2014FTC01270025 Q2014FTC01270053 Amon, Cristiano; Mollenkopf, Steven
attachment(s) anticompetitive harm
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Reifschneider,
QX9214 7/15/2013 Email regarding RE: Re: Issue Q2014FTC01356936 Q2014FTC01356938 Aberle, Derek; Reifschneider, Eric anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
Eric
commitments and not anticompetitive
QX9215 4/26/2013 Email regarding FW: RE: Company Name Follow up Blecker, Marv Q2014FTC01358674 Q2014FTC01358680 Aberle, Derek; Gonell, Fabian Qualcomm’s business practices are justified
Mollenkopf, Steven; Aberle, Derek; Amon, Cristiano; Reifschneider, Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
QX9216 11/7/2012 Email regarding Fw: Thanks Salvatori, Enrico Q2014FTC01360291 Q2014FTC01360296
Eric; Gonell, Fabian are justified; Qualcomm's business practices do not cause anticompetitive harm
Email regarding last round - impact to fy13 budget Mollenkopf, Amon, Cristiano; Expert: Chipty, Tasneem; Mollenkopf, Steven; Wyatt, Qualcomm's agreements with Apple were not anticompetitive; Qualcomm's business practices do
QX9217 1/9/2013 Q2014FTC01610401 Q2014FTC01610406
(prelim) + vs strat plan for 14 and 15 Steven William not cause anticompetitive harm
QX9218 10/4/2008 Email regarding Requests for LGE concerns Yang, Jeffrey Q2014FTC01628960 Q2014FTC01628964 Amon, Cristiano; Expert: Chipty, Tasneem; Mollenkopf, Steve Cellular Industry is thriving; Modem chip business is highly competitive
Email regarding Fw: (Pls read) RE: Samsung's disappointment Amon, Cristiano; Expert: Chipty, Tasneem; Mollenkopf, Steven; Wyatt,
QX9219 12/11/2009 Lederer, Jim Q2014FTC01845278 Q2014FTC01845280 Cellular Industry is thriving; Modem chip business is highly competitive
wirh 2010 Pricing proposal William
QX9220 1/10/2013 Email regarding RE: Language on Pricing Lederer, Jim Q2014FTC02110079 Q2014FTC02110082 Mollenkopf, Steven; Amon, Cristiano; Expert: Chipty, Tasneem Qualcomm’s agreements with Apple were not anticompetitive
Email regarding RE: - latest product outlook
QX9221 12/19/2012 Mehta, Sanjay Q2014FTC02110227 Q2014FTC02110233 Expert: Chipty, Tasneem; Mollenkopf, Steven; Amon, Cristiano Qualcomm’s agreements with Apple were not anticompetitive
(tablet/phone) - competitive updates
Email regarding Reifschneider,
QX9222 CX5226 6/28/2014 Q2014FTC02112879 Q2014FTC02112884 Aberle, Derek; Amon, Cristiano; Gonell, Fabian; Reifschneider, Eric Qualcomm’s license agreements are not the result of coercion
with attachment(s) Eric
QX9223 1/14/2016 Email regarding QC/Meizu discussions - next steps Snyder, Mark Q2014FTC02199823 Q2014FTC02199833 Aberle, Derek; Gonell, Fabian; Reifschneider, Eric; Rogers, Alex Qualcomm’s license agreements are not the result of coercion
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9224 CX5237 07/14/2011 Email regarding Re: Re: proposal of conference call Aberle, Derek Q2014FTC02364180 Q2014FTC02364187 Aberle, Derek; Gonell, Fabian
are justified
Amon, Cristiano; Achour, Baaziz; Kressin, Keith; Expert: Chipty,
QX9225 12/21/2012 Email regarding FW: Important * * * Wyatt, Will Q2014FTC02380741 Q2014FTC02380743 Qualcomm’s agreements with Apple were not anticompetitive
Tasneem; Mollenkopf, Steven; Wyatt, William
Email regarding FW: Q&A for the 3-mode letter with Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9226 7/10/2014 Qian, Kun Q2014FTC02699110 Q2014FTC026991124 Amon, Cristiano; Gonell, Fabian; Reifschneider, Eric
attachment(s) are justified
Email regarding ETSI/IPR(15)23_015r1 + ETSI/IPR(15)23_016 -
Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9227 11/27/2015 Draft Actions concerning transparency after IPR#23 + Meeting Rey, Geraldine Q2014FTC02805312 Q2014FTC02805334 Expert: Huber, Bertram; Gonell, Fabian; Weiler, Dirk (Nokia)
Qualcomm’s FRAND commitments and not anticompetitive
Report with attachment(s)
Email regarding Qualcomm Completes Review of Corporate and Aberle, Derek; Amon, Cristiano; Wise, David; Jacobs, Paul; Mollenkopf,
QX9228 12/15/2015 Amezcua, Claudia Q2014FTC02860152 Q2014FTC02860157 Qualcomm’s business practices are justified
Financial Structure with attachment(s) Steven
Email regarding RE: CDMA Pricing - What's Our Position? with
QX9229 11/20/2008 Mehta, Sanjay Q2014FTC02886824 Q2014FTC02886828 Amon, Cristiano; Expert: Chipty, Tasneem; Mollenkopf, Steve Cellular Industry is thriving; Modem chip business is highly competitive
attachment(s)

14 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 16 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
QX9230 8/11/2014 LTE Claim Charts_8-6-14 pptx Qualcomm Q2014FTC02979811 Q2014FTC02979811 Chen, Liren Qualcomm is a leading contributor of cellular technologies
QX9231 8/11/2014 QTL Presentation regarding Claim Mapping Qualcomm Q2014FTC02979814 Q2014FTC02979814 Chen, Liren Qualcomm is a leading contributor of cellular technologies
Email regarding Fwd: Licensing Discussion 09-30-2010 (this is a Qualcomm’s business practices are justified; Qualcomm’s agreements with Apple were not
QX9232 10/27/2010 Rosenberg, Don Q2014FTC03070576 Q2014FTC03070593 Aberle, Derek; Altman, Steven; Hartogs, Michael
large file - takes a minute to open) with attachment(s) anticompetitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
Reifschneider,
QX9233 6/24/2013 Email regarding discussion with Roger Brooks - privileged Q2014FTC03077212 Q2014FTC03077214 Aberle, Derek; Reifschneider, Eric anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
Eric
commitments and not anticompetitive
w encls -
QX9234 3/18/2016 Gonell, Fabian Q2014FTC03095246 Q2014FTC03097221 Gonell, Fabian; Chen, Liren; Rogers, Alex; Aberle, Derek Qualcomm's license agreements are not the result of coercion
fgl pdf
Gonell, Fabian; Reifscheider, Eric; Aberle, Derek; Amon, Cristiano;
QX9235 1/1/2016 Strategic Fund & Indemnity Agmt Qualcomm Q2014FTC03119647 Q2014FTC03119669 Qualcomm's business practices do not cause anticompetitive harm
Expert: Nevo, Aviv
Email regarding signed QC Qualcomm's license agreements are not the result of coercion Qualcomm's business practices
QX9236 12/27/2016 Qian, Kun Q2014FTC03294120 Q2014FTC03294204 Aberle, Derek; Rogers, Alex; Gonell, Fabian
! with attachment(s) are justified Qualcomm's business practices do not cause anticompetitive harm
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9237 8/6/2012 Email regarding RFP to 8 6 12 with attachment(s) Badal, Michelle Q2014FTC03646413 Q2014FTC03646429 Expert: Williams, Tim; Schafer, Aaron (Apple)
do not cause anticompetitive harm
QX9238 9/2/2011 Email regarding RE: Urgent - LTE CA situation? Achour, Baaziz Q2014FTC03666974 Q2014FTC03666975 Achour, Baaziz Reasons for Qualcomm’s success in the modem chip business
Email regarding kick-off docs - please review
QX9239 1/8/2016 Felke, Magnus Q2014FTC03896735 Q2014FTC03896737 Gonell, Fabian; Reifschneider, Eric Qualcomm's business practices do not cause anticompetitive harm
one more time with attachment(s)
Email regarding Friday meeting - Subject to Apple-Qualcomm Chen, Liren; Expert: Andrews, Jeffrey; Gonell, Fabian; Malladi, Durga;
QX9240 7/11/2016 Chen, Liren Q2014FTC03978229 Q2014FTC03978275 Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Mutual Confidentiality Agreement with attachment(s) Rogers, Alex; Thompson, James
QX9241 12/5/2001 Email regarding Re: Pending Issues Aberle, Derek Q2014FTC04151885 Q2014FTC04151885 Aberle, Derek; Hartogs, Michael; Lupin, Louis; Altman, Steven Qualcomm's business practices are justified
Qualcomm's license agreements are not the result of coercion Qualcomm's business practices
QX9242 11/14/2014 Email regarding Fwd: TCL issue Lam, Benson Q2014FTC04182068 Q2014FTC04182069 Reifschneider, Eric; Gonell, Fabian
are justified Qualcomm's business practices do not cause anticompetitive harm
QX9243 4/7/2011 Email regarding account strategy Koliander, Eric Q2014FTC04277421 Q2014FTC04277425 Mollenkopf, Steven Qualcomm’s agreements with Apple were not anticompetitive
Aberle, Derek; Expert: Andrews, Jeffrey; Malladi, Durga; Mollenkopf,
QX9244 10/23/2014 Email regarding 5G R&D - more than meets the eye Grob, Matt Q2014FTC04771203 Q2014FTC04771203 Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Steven; Jacobs, Paul; Thompson, James
Email regarding FW: 5G white paper for BOD - 1st cut with Cassacia, Lorenzo; Expert: Andrews, Jeffrey; Malladi, Durga;
QX9245 12/3/2015 Grob, Matt Q2014FTC04774606 Q2014FTC04774609 Qualcomm is a leading contributor of cellular technologies
attachment(s) Mollenkopf, Steven; Thompson, James
Casaccia, Lorenzo; Expert: Andrews, Jeff; Malladi, Durga; Thompson,
QX9246 9/12/2006 Email regarding strat plan slides with attachment(s) Grob, Matt Q2014FTC04778810 Q2014FTC04778811 Qualcomm is a leading contributor of cellular technologies
James
Chen, Liren; Expert: Chipty, Tasneem; Expert: Snyder, Edward; Rogers,
QX9247 11/3/2016 Modem Update Sinha, Pranesh Q2014FTC04798967 Q2014FTC04799054 Reasons for Qualcomm’s success in the modem chip business
Alex; Expert: Nevo, Aviv; Kressin, Keith
Qualcomm is a leading contributor of cellular technologies; Reasons for Qualcomm’s success in
QX9248 2/12/2016 Email regarding Analyst Day Slides with attachment(s) Young, Kathleen Q2014FTC04825956 Q2014FTC04826095 Aberle, Derek; Amon, Cristiano; Mollenkopf, Steven; Thompson, James
the modem chip business; Qualcomm’s business practices do not cause anticompetitive harm
Email regarding Fwd: Licensing Slide from 1999 Analyst Meeting Altman, Steven; Expert: Nevo, Aviv; Hartogs, Michael; Jacobs, Irwin; Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9249 11/4/2005 Altman, Steve Q2014FTC04845623 Q2014FTC04845624
with attachment(s) Lupin, Louis; Rogers, Alex are justified; Qualcomm’s business practices do not cause anticompetitive harm
Email regarding FW: Margin Analysis - Work in progress with Expert: Chipty, Tasneem; Amon, Cristiano; Kressin, Keith; Wyatt,
QX9250 11/29/2010 Mehta, Sanjay Q2014FTC04856452 Q2014FTC04856455 Cellular Industry is thriving; Modem chip business is highly competitive
attachment(s) William
Email regarding RE: QCT Strategic Plan Financials with Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9251 CX6009 06/15/2013 Oberst, Andy Q2014FTC04878756 Q2014FTC04878763 Expert: Chipty, Tasneem; Wyatt, Will
attachment(s) competitive; Qualcomm’s business practices do not cause anticompetitive harm
Email regarding Fw: RIM Confidential--Protected Settlement
Aberle, Derek; Hartogs, Michael; Gonell, Fabian; Lupin, Louis; Altman, Qualcomm's license agreements are not the result of coercion Qualcomm's business practices
QX9252 11/12/2009 Communication Subject to FRE 408 and conditions agreed upon Hartogs, Mike Q2014FTCBB00002704 Q2014FTCBB00002705
Steve are justified Qualcomm's business practices do not cause anticompetitive harm
between RIM and Qualcomm by email communications
PX0590; Cassacia, Lorenzo; Chen, Liren; Expert: Andrews, Jeffrey; Hartogs,
QX9253 11/7/2007 Email regarding Fwd: RE: with attachment(s) Hartogs, Mike Q2017MDL1_00411156 Q2017MDL1_00411372 Qualcomm is a leading contributor of cellular technologies
PX0148 Michael; Jacobs, Irwin; Malladi, Durga; Thompson, James; Weiler, Dirk
Mollenkopf, Modem chip business is highly competitive; Qualcomm’s business practices do not cause
QX9254 12/30/2013 Email regarding Re: Latest on Apple - 2016 RFP Q2017MDL1_01663580 Q2017MDL1_01663584 Blevins, Tony; Amon, Cristiano
Steven anticompetitive harm
Email regarding RE: Kerendian,
QX9255 12/12/2014 Q2017MDL1_01780257 Q2017MDL1_01780262 Amon, Cristiano; Reifschneider, Eric Qualcomm’s business practices are justified
Naseem
QX9256 11/12/2012 Email regarding Roadmap Help with attachment(s) Kressin, Keith Q2017MDL1_01910522 Q2017MDL1_01910525 Expert: Chipty, Tasneem; Kressin, Keith; Wyatt, William Qualcomm’s agreements with Apple were not anticompetitive
Mollenkopf, Amon, Cristiano; Expert: Chipty, Tasneem; Mollenkopf, Steven; Wyatt,
QX9257 10/30/2010 Email regarding FW: New proposal with attachment(s) Q2017MDL1_01950378 Q2017MDL1_01950380 Qualcomm’s agreements with Apple were not anticompetitive
Steven William
PX0358; Email regarding FW: LTE leadership claims from Ericsson with Casaccia, Lorenzo; Chen, Liren; Aberle, Derek; Gonell, Fabian; Hartogs,
QX9258 1/9/2012 Martin, Roger Q2017MDL1_02777874 Q2017MDL1_02777910 Qualcomm’s license agreements are not the result of coercion
CX6376 attachment(s) Michael
Aberle, Derek; Amon, Cristiano; Hartogs, Michael; Mollenkopf, Steven; Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
QX9259 2/23/2012 Email regarding RE: E divestiture of SEMC Gonell, Fabian Q2017MDL1_02894745 Q2017MDL1_02894755
Lupin, Louis; Reifschneider, Eric are justified; Qualcomm's business practices do not cause anticompetitive harm
QX9260 3/31/2011 Strategic Relationship Agreement (3/31/2011) Qualcomm Q2017MDL1_02931423 Q2017MDL1_02931429 Wyatt, Will; Amon, Cristiano; Mollenkopf, Steven Qualcomm's business practices do not cause anticompetitive harm
QX9261 12/27/2011 Amendment to Strategic Relationship Agreement (12/27/2011) Qualcomm Q2017MDL1_02931430 Q2017MDL1_02931430 Wyatt, Will; Amon, Cristiano; Mollenkopf, Steven Qualcomm's business practices do not cause anticompetitive harm

15 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 17 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Gonell, Fabian; Hartogs,
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9262 8/23/1992 CDMA Technology License Agreement (8/23/1992) Qualcomm Q2017MDL1_03032604 Q2017MDL1_03032628 Michael; Jacobs, Irwin; Lupin, Louis; Reifschneider, Eric; Rogers, Alex;
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Expert: Nevo, Aviv
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Gonell, Fabian; Hartogs, not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9263 3/20/2009 Subscriber Unit License Agreement (3/20/2009) Qualcomm Q2017MDL1_03037870 Q2017MDL1_03037923
Michael; Reifschneider, Eric; Rogers, Alex; Expert: Nevo, Aviv practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Hartogs, Michael; Jacobs,
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9264 9/22/2000 Amendment to Subscriber Unit License Agreement (9/22/2000) Qualcomm Q2017MDL1_03045682 Q2017MDL1_03045686 Irwin; Lupin, Louis; Reifschneider, Eric; Rogers, Alex; Expert: Nevo,
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Aviv
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Hartogs, Michael; not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9265 4/30/1997 Subscriber Unit License Agreement dated April 30, 1997 Qualcomm Q2017MDL1_03045687 Q2017MDL1_03045727
Reifschneider, Eric; Rogers, Alex; Expert: Aviv Nevo practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Chen, Liren; Gonell, Fabian; Reifschneider, Eric; Rogers, not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9266 1/1/2016 Chinese Patent License Agreement (1/1/2016) Qualcomm Q2017MDL1_03114539 Q2017MDL1_03114590
Alex; Expert: Nevo, Aviv practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9267 8/11/2015 PRC Meeting Qualcomm Q2017MDL1_03164410 Q2017MDL1_03164410 Amon, Cristiano; Expert: Chipty, Tasneem; Wyatt, William
competitive
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9268 6/23/2015 Email regarding FW: Qualcomm/VIVO with attachment(s) Altman, Jeff Q2017MDL1_03327980 Q2017MDL1_03327983 Aberle, Derek; Gonell, Fabian; Reifschneider, Eric
are justified; Qualcomm's business practices do not cause anticompetitive harm
Amendment to Infrastructure and Subscriber Unit License and Reifschneider, Eric; Aberle, Derek; Gonell, Fabian; Altman, Steven;
QX9269 9/1/2012 Qualcomm Q2017MDL3_00017820 Q2017MDL3_00017823 Qualcomm's license agreements were not the result of coercion
Technical Assistance Agreement Expert: Nevo, Aviv
Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
QX9270 8/23/2005 Letter Agreement regarding ASIC Patent License Agreement Qualcomm Q2017MDL3_00019183 Q2017MDL3_00019186 Aberle, Derek; Altman, Steven; Hartogs, Michael are justified; Qualcomm's business practices do not cause anticompetitive harm; Device-level
licensing is consistent with Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9271 6/19/2009 Email regarding Fwd: Summary for major open issues Lee, Heungmo Q2017MDL3_00040410 Q2017MDL3_00040412 Aberle, Derek; Lee, Injung (Samsung); Gonell, Fabian are justified; Device-level licensing is consistent with Qualcomm’s FRAND commitments and
not anticompetitive
Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
Amendment to Infrastructure and Subscriber Unit License and Aberle, Derek; Altman, Steven; Hartogs, Michael; Gonell, Fabian;
QX9272 1/1/2007 Qualcomm Q2017MDL3_00045474 Q2017MDL3_00045499 are justified; Qualcomm's business practices do not cause anticompetitive harm; Device-level
Technical Assistance Agreement Rogers, Alex; Expert: Nevo, Aviv
licensing is consistent with Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s agreements with
QX9273 4/27/2005 Email regarding Fwd: Re: Fwd: Apple— Chipset Review Taylor, Kristin Q2017MDL5_04235794 Q2017MDL5_04235795 Expert: Nevo, Aviv; Jacobs, Paul
Apple were not anticompetitive
Altman, Steven; Aberle, Derek; Hartogs, Michael; Lupin, Louis; Jacobs, Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9274 7/5/2004 Email regarding Fwd: LGE_Proposal with attachment(s) Doh, Jim Q2017MDL5_04810421 Q2017MDL5_04810422
Irwin do not cause anticompetitive harm
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9275 3/25/1999 Qualcomm/Ericsson Press Conference Qualcomm Q2017MDL5_06050911 Q2017MDL5_06050911 Altman, Steven; Hartogs, Michael; Jacobs, Irwin; Lupin, Louis
are justified; Qualcomm’s business practices do not cause anticompetitive harm
Altman, Steven; Cassacia, Lorenzo; Expert: Andrews, Jeffrey; Expert: Qualcomm is a leading contributor of cellular technologies; Reasons for Qualcomm’s success in
QX9276 11/23/1996 Memo regarding a system design for high speed packet data Qualcomm Q2017MDL5_10411696 Q2017MDL5_10411711
Snyder, Edward; Jacobs, Irwin; Malladi, Durga; Thompson, James the modem chip business
QX9277 4/20/1998 Letter to ETSI White, Harvey P Q2017MDL8_00001080 Q2017MDL8_00001081 Jacobs, Irwin; Lupin, Louis Qualcomm is a leading contributor of cellular technologies
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Gonell, Fabian; Hartogs,
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9278 7/26/1991 Subscriber Unit License Agreement (7/26/1991) Qualcomm QAPPCMSD00009378 QAPPCMSD00009405 Michael; Jacobs, Irwin; Lupin, Louis; Reifschneider, Eric; Rogers, Alex;
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Expert: Nevo, Aviv
Qualcomm’s FRAND commitments and not anticompetitive
Cellular Industry is thriving; Reasons for Qualcomm’s success in the modem chip business;
QX9279 3/15/2017 Email regarding Notes from Modem Offsite with attachment(s) Asghar, Ziad QAPPCMSD01272320 QAPPCMSD01272361 Kressin, Keith; Expert: Chipty, Tasneem
Modem chip business is highly competitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9280 CX6629 1/1/2018 Qualcomm QAPPCMSD02163083 QAPPCMSD02163097 Chen, Liren; Gonell, Fabian; Rogers, Alex
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
NLU Intellectual Property and Competition Policy Course | Qualcomm’s business practices are justified; Device-level licensing is consistent with
QX9281 7/28/2015 Shrove, Jenna QAPPCMSD03076455 QAPPCMSD03077233 Expert: Huber, Bertram; Weiler, Dirk (Nokia)
August 2015 with attachment(s) Qualcomm’s FRAND commitments and not anticompetitive
Email regarding - CR&D Program Review - slide Cassacia, Lorenzo; Expert: Andrews, Jeffrey; Malladi, Durga;
QX9282 7/24/2017 Ang, Rolando QAPPCMSD03112272 QAPPCMSD03112368 Qualcomm is a leading contributor of cellular technologies
distribution with attachment(s) Thompson, James

16 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 18 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9283 10/11/2017 Email regarding FW: Letter from Qualcomm with attachment(s) Boy, Gaby QAPPCMSD03734920 QAPPCMSD03734924 Ahn, Seungho; Rogers, Alex; Aberle, Derek; Gonell, Fabian
are justified; Qualcomm's business practices do not cause anticompetitive harm
Apple Chen Gonell, Fabian; Chen, Liren; Aberle, Derek; Gonell, Fabian; Rogers, Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9284 1/25/2017 Email regarding Re: patent meetings with attachment(s) Chen, Liren QAPPCMSD07412667 QAPPCMSD07412672
0003 Alex are justified
8/3/2015; QAPPCMSD08220764; QAPPCMSD08220892;
8/3/2015; Emails regarding re: Qualcomm patent lists and representative QAPPCMSD08488872; QAPPCMSD08488967; Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9285 Rouse, Tom Aberle, Derek; Gonell, Fabian; Reifschneider, Eric
8/4/2015; claim charts QAPPCMSD09829213; QAPPCMSD09829316; are justified
8/4/2015 QAPPCMSD09829317 QAPPCMSD09829416
Chen, Liren; Expert: Andrews, Jeffrey; Malladi, Durga; Mollenkopf, Qualcomm is a leading contributor of cellular technologies; Qualcomm’s business practices are
QX9286 3/22/2017 Email regarding two requests with attachment(s) Chen, Liren QAPPCMSD08656194 QAPPCMSD08656195
Steven; Thompson, James justified
Email regarding RE: 5G NR URLLC Design, Performance, Cassacia, Lorenzo; Expert: Andrews, Jeffrey; Malladi, Durga;
QX9287 1/19/2018 Smee, John QAPPCMSD09012384 QAPPCMSD09012539 Qualcomm is a leading contributor of cellular technologies
and Standards Update with attachment(s) Thompson, James
QX9288 10/18/2017 Email regarding QTL, QSIO sync-up with attachment(s) Singh, Damanjit QAPPCMSD09037925 QAPPCMSD09037934 Chen, Liren; Gonell, Fabian; Casaccia, Lorenzo Qualcomm is a leading contributor of cellular technologies
Letter from Qualcomm re: OFDMA Subscriber Unit Patent
QX9289 3/1/2018 Rogers, Alex QAPPCMSD09088904 QAPPCMSD09088916 Rogers, Alex Qualcomm’s business practices are justified
License Agreement (10/26/2011)
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Altman, Steven; Chen, Liren; Gonell, Fabian; Hartogs, not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9290 3/31/2005 Subscriber Unit License Agreement (3/31/2005) Qualcomm QAPPCMSD09101874 QAPPCMSD09101905
Michael; Reifschneider, Eric; Rogers, Alex; Expert: Nevo, Aviv practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies;
Email regarding FW: Qualcomm 5G NR Royalty Terms Statement -
QX9291 11/20/2017 Ping, Cindy QAPPCMSD09500210 QAPPCMSD09500214 Chen, Liren; Gonell, Fabian; Rogers, Alex Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
privileged and confidential with attachment(s)
are justified
Qualcomm Transaction Logs (Actuals-TransLog Detailed Data -
5/11/2018; QAPPCMSD09835535; QAPPCMSD09835535;
CY2017Q4 xlsx; Actuals-TransLog Detailed Data - CY1996-2010
11/1/2017; QNDCAL01103273; QNDCAL01103273;
Extract xlsx; Actuals-TransLog Detailed Data - CY2011
11/1/2017; QNDCAL01103274; QNDCAL01103274;
Extract xlsx; Actuals-TransLog Detailed Data - CY2012
11/1/2017; QNDCAL01103275; QNDCAL01103275;
Extract xlsx; Actuals-TransLog Detailed Data - CY2013
QX9292 11/1/2017; Qualcomm QNDCAL01103276; QNDCAL01103276; Rogers, Alex; Gonell, Fabian; Expert: Nevo, Aviv Qualcomm's business practices do not cause anticompetitive harm
Extract xlsx; Actuals-TransLog Detailed Data - CY2014
11/1/2017; QNDCAL01103277; QNDCAL01103277;
Extract xlsx; Actuals-TransLog Detailed Data - CY2015
11/1/2017; QNDCAL01103278; QNDCAL01103278;
Extract xlsx; Actuals-TransLog Detailed Data - CY2016
11/1/2017; QNDCAL01103279; QNDCAL01103279;
Extract xlsx; Actuals-TransLog Detailed Data - CY2017Q1-
3/9/2018 QNDCAL04878274 QNDCAL04878274
Q3 xlsx)
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9293 1/1/2018 Qualcomm QAPPCMSD10051179 QAPPCMSD10051214 Chen, Liren; Gonell, Fabian; Rogers, Alex; Expert: Nevo, Aviv
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9294 4/1/2018 Complete Terminal Patent License Agreement (4/1/2018) Qualcomm QAPPCMSD10052189 QAPPCMSD10052225 Chen, Liren; Gonell, Fabian; Rogers, Alex; Expert: Nevo, Aviv
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9295 4/2/2012 Email regarding DOCOMO's Joint Venture Altman, Jeff QAPPCMSD10052361 QAPPCMSD10052361 Amon, Cristiano; Mollenkopf, Steven; Wyatt, Will
are justified; Qualcomm's business practices do not cause anticompetitive harm
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9296 1/1/2018 Complete Terminal Patent License Agreement (1/1/2018) Qualcomm QAPPCMSD10052453 QAPPCMSD10052481 Chen, Liren; Gonell, Fabian; Rogers, Alex; Expert: Nevo, Aviv
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9297 4/1/2018 Complete Terminal Patent License Agreement (4/1/2018) Qualcomm QAPPCMSD10052852 QAPPCMSD10052884 Chen, Liren; Gonell, Fabian; Rogers, Alex; Expert: Nevo, Aviv
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9298 10/1/2018 Complete Terminal Patent License Agreement (10/1/2018) Qualcomm QAPPCMSD10053345 QAPPCMSD10053384 Chen, Liren; Gonell, Fabian; Rogers, Alex; Expert: Nevo, Aviv
practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
Email regarding Re: July meeting and Qualcomm's proposal with
QX9299 8/20/2009 Aberle, Derek QNDCAL00045615 QNDCAL00045647 Aberle, Derek; Altman, Steven; Hartogs, Michael Qualcomm is a leading contributor of cellular technologies
attachment(s)
QX9300 3/16/2017 Email regarding request Rose, Elliott QNDCAL00189833 QNDCAL00189835 Mollenkopf, Steve Qualcomm’s agreements with Apple were not anticompetitive

17 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5 No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.D. Cal.) Page 19 of 20
Qualcomm's Exhibit List

Author / Sender /
Trial Ex. No. Dep. Ex. No. Date Description Beginning Bates Ending Bates Sponsoring Witness Purpose
Producing Party
Reasons for Qualcomm’s success in the modem chip business; Modem chip business is highly
QX9301 6/27/2011 Email regarding RFP response prep with attachment(s) Sheoran, Gautam QNDCAL00191186 QNDCAL00191194 Expert: Williams, Tim
competitive; Qualcomm’s business practices do not cause anticompetitive harm
Casaccia,
QX9302 11/19/2009 Email regarding all hands with attachment(s) QNDCAL00284733 QNDCAL00284735 Casaccia, Lorenzo; Malladi, Durga; Thompson, James Qualcomm is a leading contributor of cellular technologies
Lorenzo
QX9303 8/3/2011 Email regarding QCT Roadmap, sensitive info with attachment(s) Scipione, Mario QNDCAL00299237 QNDCAL00299368 Thompson, James Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
QX9304 8/8/2006 _isw_aug_06 ppt Qualcomm QNDCAL00343280 QNDCAL00343280 Casaccia, Lorenzo; Malladi, Durga; Thompson, James Qualcomm is a leading contributor of cellular technologies
Email regarding Re: QSIO-QCT sync on R13 - LTE PHY with Casaccia,
QX9305 7/7/2015 QNDCAL00345175 QNDCAL00345190 Cassacia, Lorenzo Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
attachment(s) Lorenzo
Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
QX9306 2/10/2012 Email regarding FW: Follow up Salvatori, Enrico QNDCAL00423043 QNDCAL00423044 Aberle, Derek; Mollenkopf, Steven
are justified; Qualcomm's business practices do not cause anticompetitive harm
Mollenkopf, Steven; Amon, Cristiano; Aberle, Derek; Expert: Chipty,
QX9307 1/18/2013 Email regarding Weiser, Jonathan QNDCAL00649619 QNDCAL00649620 Qualcomm’s agreements with Apple were not anticompetitive
Tasneem
Qualcomm’s license agreements are not the result of coercion; Qualcomm’s business practices
QX9308 12/16/2003 Email regarding Fwd: Final with attachment(s) Altman, Steve QNDCAL00670231 QNDCAL00670241 Altman, Steven; Lupin, Louis; Rogers, Alex
are justified
Reasons for Qualcomm’s success in the modem chip business; Qualcomm’s business practices
QX9309 12/7/2015 Email regarding 5G materials with attachment(s) Grob, Matt QNDCAL00690964 QNDCAL00691150 Thompson, James do not cause anticompetitive harm; Qualcomm’s agreements with Apple were not
anticompetitive
Email regarding FW: follow up of National Leading Group on the
Altman, Steven; Cassacia, Lorenzo; Chen, Liren; Jacobs, Irwin; Rogers,
QX9310 11/4/2016 Fight against IPR Infringement and Counterfeiting meeting with Chen, Liren QNDCAL00714908 QNDCAL00714948 Qualcomm is a leading contributor of cellular technologies
Alex; Thompson, James
Qualcomm with attachment(s)
Qualcomm is a leading contributor of cellular technologies; Qualcomm’s license agreements are
Aberle, Derek; Chen, Liren; Gonell, Fabian; Reifschneider, Eric; Rogers, not the result of coercion; Qualcomm’s business practices are justified; Qualcomm’s business
QX9311 10/1/2016 Multiproduct Patent License Agreement (10/1/2016) Qualcomm QNDCAL01094864 QNDCAL01094913
Alex; Expert: Nevo, Aviv practices do not cause anticompetitive harm; Device-level licensing is consistent with
Qualcomm’s FRAND commitments and not anticompetitive
QX9312 10/11/2017 Qualcomm PowerPoint Rose, Elliott QNDCAL01098685 QNDCAL01098774 Amon, Cristiano; Expert: Chipty, Tasneem; Kressin, Keith Modem chip business is highly competitive
Qualcomm is a leading contributor of cellular technologies; Qualcomm's license agreements
QX9313 11/2009 Qualcomm presentation Qualcomm QNDCAL01916021 QNDCAL01916030 Altman, Steven; Lupin, Louis were not the result of coercion; Qualcomm's business practices are justified; Qualcomm's
business practices do not cause anticompetitive harm
QX9314 12/01/2014 Email regarding RE: Pre-Meeting with attachment(s) Sinder, Dan QNDCAL02463483 QNDCAL02463485 Thompson, Jim; Chen, Liren; Malladi, Durga Qualcomm is a leading contributor of cellular technologies
Email regarding R13 proposals (LTE) from Ooredoo with
QX9315 4/16/2015 Yassin, Hani QNDCAL02670581 QNDCAL02670636 Cassacia, Lorenzo; Thompson, James Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
attachment(s)
CDMA and premium LTE are not appropriate antitrust markets; Modem chip business is highly
QX9316 11/29/2016 ODM Brand Strategy Session v1 0 Weiner, Joel QNDCAL02983685 QNDCAL02983710 Expert: Chipty, Tasneem; Aberle, Derek; Gonell, Fabian; Rogers, Alex
competitive
Qualcomm’s business practices are justified; Qualcomm’s business practices do not cause
QX9317 10/27/2016 Email regarding Nokia submission with attachment(s) Antush, Ron QNDCAL02989684 QNDCAL02989693 Gonell, Fabian anticompetitive harm; Device-level licensing is consistent with Qualcomm’s FRAND
commitments and not anticompetitive
Email regarding FW: Feedback on ZUC Ciphering, 2-wire coex
QX9318 2/23/2012 Sinha, Pranesh QNDCAL03064493 QNDCAL03064494 Schell, Steve (Apple) Qualcomm’s agreements with Apple were not anticompetitive
interface, and RxD for TDSCDMA
Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies; Modem
QX9319 3/1/2004 QCT Product Roadmap Qualcomm QNDCAL03213303 QNDCAL03213318 Thompson, James; Kressin, Keith chip business is highly competitive; Reasons for Qualcomm's success in the modem chip
business
Email regarding FW: BusinessWeek Briefing Sheet and final
QX9320 CX6193 7/13/2017 Gorostiza, Ryan QNDCAL03441593 QNDCAL03441610 Expert: Andrews, Jeffrey; Malladi, Durga; Thompson, James Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
agenda with attachment(s)
Cassacia, Lorenzo; Expert: Andrews, Jeffrey; Malladi, Durga;
QX9321 4/25/2016 Email regarding PR deck with attachment(s) Koymen, Ozge QNDCAL03448862 QNDCAL03448863 Cellular Industry is thriving; Qualcomm is a leading contributor of cellular technologies
Thompson, James
Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9322 6/14/2012 Email regarding Meizu Amon, Cristiano QNDCAL03554065 QNDCAL03554065 Aberle, Derek; Amon, Cristiano; Reifschneider, Eric
are justified; Qualcomm's business practices do not cause anticompetitive harm
Qualcomm's license agreements were not the result of coercion; Qualcomm's business practices
QX9323 2/23/2012 Email regarding Re: E divestiture of SEMC Weiser, Jonathan QNDCAL03555809 QNDCAL03555812 Aberle, Derek; Gonell, Fabian
are justified; Qualcomm's business practices do not cause anticompetitive harm

18 of 19
Case 5:17-cv-00220-LHK Document
Federal Trade Commission 946-5No.Filed
vs. Qualcomm, 11/29/18
17-cv-0220 (N.O. Cal.) Page 20 of 20
Qualcomm's Exhibit List

---- .... - --- - - --- --- - - �
QNOCAL03630058; QNDCAL03630058;
QNOCAL03630074; QNDCAL03630074;
QNOCAL03630076; QNDCAL03630076;
QNOCAL03630077; QNDCAL03630077;
QNOCAL03630079; QNDCAL03630079;
QNOCAL03630080; QNDCAL03630080;
Engineering photos (Dcp_0345 _mid jpg; MVC_373F jpg; QNOCAL03630083; QNDCAL03630083;
MVC_387F jpg; :MVC_393F jpg; MVC_475F jpg; QNOCAL03630085; QNDCAL03630085;
MVC_476F jpg; :MVC_492F jpg; MVC_495F jpg; QNOCAL03630086; QNDCAL03630086;
QX9324 10/19/2017 MVC_497F jpg; :MVC_504F jpg; MVC_631F jpg; Qualcomm QNOCAL03630088; QNDCAL03630088; Jacobs, Irwin; Thompson,James Qualcomm is a leading contnbutor of cellular rechnologies
MVC_633F jpg; oov_02_99_02 jpg; nov _02 _99_26 jpg; QNOCAL03630102; QNDCAL03630102;
nov_05_99_08 jpg; oov_ l 2_99 _70 jpg; oct_20_99_18 jpg; QNOCAL03630103; QNDCAL03630103;
oct_23_99_02 jpg; sep_l8_99_40 jpg) QNOCAL03630110; QNDCAL03630110;
QNOCAL03630112; QNDCAL03630112;
QNOCAL03630121; QNDCAL03630121;
QNOCAL03630125; QNDCAL03630125;
QNOCAL03630131; QNDCAL03630131;
QNOCAL03630132; QNDCAL03630132;
QNOCAL03630138 QNDCAL03630138
QX9325 7/23/2010 Aberle,Derek QNOCAL04400458 QNDCAL04400461 Aberle, Derek; Emert: A,"iv,Nevo Qualcomm's business oractices are iustified
QX9326 2/17/2017 QC Portfolio Over -SEPs+NSEPS odf Chen, Liren QNOCAL04499067 QNDCAL04499133 Chen, Liren; Gonell, Fabian Qualcomm is a leadi= contnbutor of cellular rechnololties
;-�
Email regarding FW meeting on Monday - pris"ileged Aberle, Derek; Allman, Steven; Amon, Cristiano; Expert: Chipty,
QX9327 12/12/2012 Weiser, Jonathan QNOCAL04499243 QNDCAL04499244 Qualcomm's agreemenls with Apple were not anticompetitive
communication Tasneem; Jacobs, Paul; Mollenkoof, Steven
Aberle, Derek; Allman, Steven; Cben, Liren; Gonell, Fabian; Hartogs,Qualcomm's license agreements are oot the result ofcoercion; Qualcomm's business practices
QX9328 2/27/2018 Accrued balance spreadsbeet Barrie,Rosie QNOCAL04823595 QNDCAL04823595 ..
Michael; Jacobs, Irwin; T >=in. Louis; Reifschneider, Eric; Ro2ers, Alex
are iuslilied; Quaicomm's agreements with Aoole were oot ve
Qualcomm's license agreements are oot the result ofcoercion; Qualcomm's business practices
QX9329 2/27/2018 QCT spreadsheet of agreements Silvennan, Daniel QNOCAL04823596 QNDCAL04823596 Achour, Baaziz; Amon, Cristiaoo; Kressin, Keith ..
are iuslilied; Quaicomm's agreements with Aoole were oot ve
Quaicomm's business practices are justified; Qualcomm's business practices do not cause
QX9330 2/27/2018 ZTE Submission for Seoul High Court (Final Signed) pdf Qualcomm QNOCAL04860471 QNDCAL04860473 Expert: Nevo, A,"iv; Gonell, Fabian; Rogen, Alex anticompetitive hlllm; Device-level licensing is consistent with Qualcomm's FRAND
commitments and not anlicomnetitive
Expert: Cbipty, Tasneem; Expert: Snyder, Edward; Kalkman, John Modem chip business is highly competitive; Quaicomm's business practices do not cause
QX9331 3/16/2016 Email regarding CDMA with attachment(s) and translation(s) Oh, Sangjin SFT-07228694 SFT-07228697
'Samsung) anlir�titive hamt
Email regarding Weekly report of :1,,fatketing I Group (2012/3/16) Ahn,Seungho (Samsung); Hojin Kang, Alex (Samsung); Kalkman, John Qualcomm's license agreements are oot the result ofcoercion; Qualcomm's business practices
QX9332 3/16/2012 Lee,D S SFT-17861702 SFT-17861719
with attachment(s) 'Samsung); Lee, In�·-• r�m�,n•\ are iuslilied
Report on How to Calculate Reasonable Royalties with Qualcomm is a leading contnbutor of cellular rechnologies; Qualcomm's business practices are
QX9333 12/7/2009 Samsung SFT-2641469 SFT-2641483 Expert: Nevo, A,"iv; Kalkman, John (Samsung); Lee, lnjung (Samsung)
1ranslatiorusl ru.stified
Qualcomm's license agreements are oot the result ofcoercion; Qualcomm' s business practices
QX9334 1/17/2013 Email regarding License for A4WP SEPs with 1ranslation(s) Pad:, Seho SFT-3114943 SFT-3114944 Ahn, Seungho (Samsung); Kalkman, John (Samsung) are juslilied; Device-level licensing is consistent with Qualcomm's FRAND commitments and
not antir,nnwv,,titive
SONYQC-000006492; SONYQC-000006543;
SONYQC-000006544; SONYQC-000006761; Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9335 8/18/2014 Rouse, Tom Aberle, Derek; Gonell, Fabian; Reifschneider, Eric
SONYQC-000006762; SONYQC-000007000; are juslilied

JIIIIIIIIIII
SONYQC-000007181 SONYQC-000007334
CX3945; Qualcomm's license agreements are not the result of coercion; Qualcomm's business practices
QX9336 06/24/2015 Yan, Ellen ZTE55425 ZTE55429 Aberle, Derek; Shen,Spencer
CX3945A are iuslilied; Quaicomm's business oractices do not cause anli�titive haml
Letter Re: Intellectual Property Rights on arr-2000 Radio Cassacia, I..orenz.o; Expert: Andrews, Jeffrey; Jacobs, Irwin; Lupin,
QX9337
6/2511999 Transmission Technolo2ies lnffln LouisM Q2017MDL8 00001097 Q2017MDL8 00001097 Louis; Tb�son, James Qualcomm is a lead;n• contnbutor of cellular rechnolo2ies
Palkhiwala, Amon, Cristiano; Expert: Cbipty, Tasneem; Kressin. Keith; Wyatt , Reasons for Qualcomm's success in the modem chip business; Modem chip business is highly
QX9338
5/13/2017 Email regarding FW: final strat deck with attachment(sl Akash Q2014FTC03955153 Q2014FTC03955154 William conmetitive

19of 19
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 1 of 7

EXHIBIT F
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 2 of 7
Federal Trade Commission vs. Qualcomm, No. 17-cv-0220 (N.D. Cal.)
Joint Exhibit List - Redacted Version

Trial Ex. No. Date Description Producing Party Bates - Begin Bates - End Sponsoring Witness Purpose Also Marked As Also Produced As
JX0001 7/3/1990 Qualcomm Q2017MDL5_04724160 Q2017MDL5_04724190 Qualcomm executives See description CX7676
JX0002 7/3/1990 Qualcomm Q2017MDL3_00018471 Q2017MDL3_00018487 Qualcomm executives See description
Motorola or/and Qualcomm
JX0003 9/26/1990 Qualcomm Q2017MDL1_03041982 Q2017MDL1_03041995 See description CX5615
executives
Motorola or/and Qualcomm
JX0004 9/26/1990 Qualcomm Q2017MDL1_02928410 Q2017MDL1_02928446 See description CX7660
executives
Nokia or/and Qualcomm
JX0005 4/9/1992 Qualcomm Q2017MDL1_00688470 Q2017MDL1_00688512 See description
executives

Samsung or/and Qualcomm
JX0006 8/31/1993 Samsung SFT-0000061 SFT-0000098 See description CX2661
executives

CX7870;
JX0007 6/27/1997 Qualcomm Q2017MDL3_00019207 Q2017MDL3_00019241 Qualcomm executives See description
QX0059
Ericsson or/and Qualcomm CX4132; Q2017MDL5_04724861-
JX0008 3/24/1999 Ericsson; Qualcomm ERC-CID-00000262 ERC-CID-00000276 See description
executives CX8180 Q2017MDL5_04724875
Ericsson or/and Qualcomm
JX0009 3/24/1999 Qualcomm Q2014FTC04838817 Q2014FTC04838836 See description CX6833
executives
Compal or/and Qualcomm
JX0010 2/10/2000 Qualcomm QNDCAL01090082 QNDCAL01090121 See description QX2151
executives

JX0011 9/29/2000 Qualcomm Q2017MDL1_03040664 Q2017MDL1_03040672 Qualcomm executives See description

JX0012 12/2/2000 Qualcomm Q2017MDL3_00019097 Q2017MDL3_00019159 Qualcomm executives See description
Nokia or/and Qualcomm
JX0013 7/2/2001 Qualcomm Q2017MDL1_02928693 Q2017MDL1_02928739 See description
executives
JX0014 8/31/2001 Email from I. Jacobs to S. Altman re: Fwd: K.T. Lee's Response Qualcomm Q2017MDL5 12371006 Q2017MDL5 12371007 Qualcomm executives See description CX6736
JX0015 1/7/2002 Qualcomm Q2017MDL1_03043121 Q2017MDL1_03043154 Qualcomm executives See description
Intel or/and Qualcomm
JX0016 8/22/2002 Intel 86600DOC000729 86600DOC000750 See description CX1500
executives

JX0017 8/22/2002 Qualcomm Q2017MDL1_03048269 Q2017MDL1_03048309 Qualcomm executives See description
JX0018 9/1/2002 3GPP2, Partnership Project Description (2002) Public N/A N/A Qualcomm executives See description
JX0019 10/15/2002 Qualcomm QAPPCMSD00007198 QAPPCMSD00007230 Qualcomm executives See description
Blackberry or/and Motorola
JX0020 1/1/2003 Blackberry (RIM) BB_FTC_00049269 BB_FTC_00049332 See description QX0873
executives
Motorola
Motorola or/and Qualcomm or/and
JX0021 4/11/2003 Qualcomm Q2017MDL1_02928479 Q2017MDL1_02928480 CX7947
executives Qualcomm
executives

Huawei and/or Q2017MDL1_00469461-
Huawei and/or Qualcomm CX1018;
JX0022 5/29/2003 Huawei; Qualcomm FTC-HUAWEI-0000704 FTC-HUAWEI-0000732 Qualcomm Q2017MDL1_00469519;
executives Apple Irwin Jacobs 0001
executives Q2017MDL1_02927276-
Q2017MDL1_02927334

Page 1 of 6
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 3 of 7
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 4 of 7
Federal Trade Commission vs. Qualcomm, No. 17-cv-0220 (N.D. Cal.)
Joint Exhibit List - Redacted Version

Trial Ex. No. Date Description Producing Party Bates - Begin Bates - End Sponsoring Witness Purpose Also Marked As Also Produced As
Wistron or/and Qualcomm CX7983;
JX0042 5/23/2007 Qualcomm Q2017MDL1_03051474 Q2017MDL1_03051509 See description
executives QX2053
Compal or/and Qualcomm
JX0043 6/22/2007 Qualcomm Q2017MDL1_03035452 Q2017MDL1_03035455 See description
executives
PX178; ERIC-QCOM-00019871-
JX0044 1/14/2008 Apple AAPL-FTC-00005282 AAPL-FTC-00005301 Apple executives See description
QX2885 ERIC-QCOM-00019889
Meeting Minutes: Qualcomm's Board of Directors Meeting
JX0045 2/28/2008 Qualcomm Q2017MDL1_00026705 Q2017MDL1_00026707 Qualcomm executives See description CX7252
(February 28, 2008)

Nokia or/and Qualcomm
JX0046 7/22/2008 Qualcomm Q2017MDL10_00081203 Q2017MDL10_00081246 See description CX7728
executives

Samsung or/and Qualcomm CX2591; Q2017MDL1_02929103-
JX0047 1/1/2009 Samsung; Qualcomm SFT-0000113 SFT-0000199 See description
executives CX7665 Q2017MDL1_02929189

JX0048 4/26/2009 Qualcomm Q2017MDL3_00018539 Q2017MDL3_00018634 Qualcomm executives See description

JX0049 8/31/2009 Qualcomm Q2017MDL1_03043074 Q2017MDL1_03043109 Qualcomm executives See description
Mediatek or/and Qualcomm
JX0050 11/19/2009 Qualcomm Q2017MDL1_01868300 Q2017MDL1_01868392 See description CX8168
executives
Mediatek or/and Qualcomm
JX0051 11/19/2009 Qualcomm Q2017MDL1_02928175 Q2017MDL1_02928212 See description CX8186
executives
Strategic Terms Agreement between Apple and Qualcomm Apple or/and Qualcomm
JX0052 12/6/2009 Apple AAPL-FTC-00008963 AAPL-FTC-00008979 See description CX0501
(Effective Dec. 16, 2009) executives
Pegatron or/and Qualcomm CX4405;
JX0053 4/29/2010 Pegatron Pegatron_0000000635 Pegatron_0000000687 See description
executives QX2553
Pegatron or/and Qualcomm
JX0054 6/1/2010 Qualcomm Q2017MDL1_03114839 Q2017MDL1_03114843 See description
executives
Email from Steven Mollenkopf to Derek Aberle, Don Rosenberg,
JX0055 12/20/2010 Qualcomm Q2017MDL1_02914747 Q2017MDL1_02914755 Qualcomm executives See description CX5362-B
Paul Jacobs, et al. re: *** privileged communication
Blackberry or/and Ericsson
JX0056 1/1/2011 Blackberry (RIM) BB_FTC_00000675 BB_FTC_00000702 See description QX0872
executives
Transition Agreement between Apple and Qualcomm (Effective
Apple or/and Qualcomm
JX0057 2/11/2011 Feb. 11, 2011) and First Amendment to Transition Agreement Apple FTC-APPLE-0000104 FTC-APPLE-0000116 See description CX0502
executives
between Apple and Qualcomm (Effective Jan 1, 2013)
Transition Agreement between Qualcomm and Apple (Effective Apple or/and Qualcomm
JX0058 2/11/2011 Qualcomm Q2017MDL1_01008968 Q2017MDL1_01008972 See description PX0071
Feb. 11, 2011) executives
Email from Jeffrey Williams to Bob Mansfield, Isabel Mahe, Qualcomm Williams 0012; AAPL-FTC-00077067-
JX0059 3/23/2011 Apple AAPL-FTC-00077067 AAPL-FTC-00077068 Apple executives See description
Steven Mollenkopf, et al. re: Challenge! QX1457 AAPL-FTC-00077068
CX5366; Q2014FTC00006959-
JX0060 7/1/2011 Qualcomm Q2017MDL1_02929831 Q2017MDL1_02929877 ZTE or/and Qualcomm executives See description
QX1153 Q2014FTC00007005
Broadcom Presentation: 3YP Phase V Mobile and Wireless Group
JX0061 8/20/2011 Broadcom BCRM000026 BCRM000071 Broadcom executives See description QX1008
BOD Presentation

Email from John Grubbs to Ram Menon
Blackberry or/and Qualcomm
JX0062 1/17/2012 Blackberry (RIM) BB_FTC_00023907 BB_FTC_00023985 See description CX3256
executives

Page 3 of 6
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 5 of 7
Federal Trade Commission vs. Qualcomm, No. 17-cv-0220 (N.D. Cal.)
Joint Exhibit List - Redacted Version

Trial Ex. No. Date Description Producing Party Bates - Begin Bates - End Sponsoring Witness Purpose Also Marked As Also Produced As
Sony or/and Qualcomm
JX0063 2/16/2012 Qualcomm Q2017MDL1_03030090 Q2017MDL1_03030121 See description CX7971
executives
Email from Jonathan Pearl to Eric Reifschneider, Derek Aberle,
JX0064 3/1/2012 Fabian Gonell, et al. re: w/Attach: Qualcomm Q2017MDL1_01855129 Q2017MDL1_01855141 Qualcomm executives See description CX7944

Email from Rob Virk to Achim Pantfoerder, Aaron Schafer, Tony
JX0065 3/26/2012 Blevins, et al. re: N6X/Steel - Notes w/Attach: Cellular Chipset Apple AAPL-FTC-00104207 AAPL-FTC-00104220 Apple executives See description QX1458
Vendor and Program Alignment 032612 v2.pdf

JX0066 5/7/2012 Apple APL-QC-FTC_07873707 APL-QC-FTC_07873710 Apple executives See description QX1470

Email from Rob Virk to Achim Pantfoerder, Aaron Schafer, Isabel
Mahe, et al. re: Cellular Chipset Options for 2014 - Notes QX1471; AAPL-FTC-00104902-
JX0067 6/7/2012 Apple AAPL-FTC-00104902 AAPL-FTC-00104914 Apple executives See description
w/Attach: Cellular Chipset Vendor and Program Alignment Qualcomm Schafer 0007 AAPL-FTC-00104914
060712 v1 .pdf
Email from Aaron Schafer to David Tom and Tony Blevins re:
CX0688; AAPL-FTC-00128294-
JX0068 6/29/2012 IMC RFQ vs. slide update w/Attach: IMC vs. 2014 Apple AAPL-FTC-00128294 AAPL-FTC-00128297 Apple executives See description
Qualcomm Schafer 0006 AAPL-FTC-00128297
Implementation 2nd round quote 6.28.12.key

JX0069 8/13/2012 Qualcomm Q2017MDL1_03044541 Q2017MDL1_03044579 Qualcomm executives See description

Email from S. Aon Mujtaba to Arun Mathias, Isabel Mahe, Inder
JX0070 8/16/2012 Apple APL-QC-FTC_07874977 APL-QC-FTC_07874979 Apple executives See description PX0347
Singh, et al. re: Innsbruck-N5x/Future Telephony --- status update

Sony or/and Qualcomm
JX0071 9/30/2012 Qualcomm Q2017MDL1_03030087 Q2017MDL1_03030087 See description CX7950
executives
Sony or/and Qualcomm
JX0072 10/1/2012 Qualcomm Q2014FTC00660709 Q2014FTC00660770 See description
executives
Email from Robinder Virk to Aaron Schafer, Achim Pantfoerder,
JX0073 10/1/2012 Aon Mujtaba, et al. re: IMC Status/Next Steps Exec Prep Meeting Apple APL-QC-FTC_33895231 APL-QC-FTC_33895249 Apple executives See description QX1462
w/Attach: Cellular Chipset Vendor schedule v5.pdf
Email from Robinder Virk to Achim Pantfoerder, Aaron Schafer,
JX0074 10/2/2012 Aon Mujtaba, et al. re: IMC status/next steps alignment - notes Apple APL-QC-FTC_34560911 APL-QC-FTC_34560931 Apple executives See description CX0561, QX1463
w/Attach: Cellular Chipset Vendor schedule v6.pdf
Email from Louis Sanguinetti to Stephan Schell re: feedback from
JX0075 10/31/2012 Apple APL-QC-FTC_29187125 APL-QC-FTC_29187127 Apple executives See description QX1531
2013 roadmap meeting w/ Phil
Email from Matthias Sauer to Stephan Schell and Louis
JX0076 11/6/2012 Apple APL-QC-FTC_12120519 APL-QC-FTC_12120521 Apple executives See description QX1534
Sanguinetti re: Intel CEO meeting
First Amendment to Transition Agreement Among Apple, Apple or/and Qualcomm
JX0077 1/1/2013 Apple AAPL-FTC-00128495 AAPL-FTC-00128502 See description CX0586
Qualcomm and QCTAP (Effective Jan. 1, 2013) executives
Business Cooperation and Patent Agreement between Apple and Apple or/and Qualcomm
JX0078 1/1/2013 Apple AAPL-FTC-00128520 AAPL-FTC-00128536 See description CX0587
Qualcomm (Effective Jan. 1, 2013) executives
Email from Sanjay Mehta to Steven Mollenkopf, Murthy
CX7811; Q2014FTC03858283-
JX0079 1/11/2013 Renduchintala, James Lederer, et al. re: language on pricing Qualcomm Q2014FTC03858283 Q2014FTC03858287 Qualcomm executives See description
Apple Mehta 0014 Q2014FTC03858287
w/Attach: walk away offer scenarios - Jan 10 post CES-v3.pptx
Email from Isabel Mahe to Stephan Schell and Robert Mansfield
JX0080 1/11/2013 Apple APL-QC-FTC_08027329 APL-QC-FTC_08027330 Apple executives See description PX348_Mahe
re: Hermann Eul
JX0081 1/31/2013 Email from Stephan Schell to Robert Mansfield re: Intel Apple APL-QC-FTC 12123224 APL-QC-FTC 12123226 Apple executives See description QX1356
Email from Scott McGregor to Henry Samueli re: Final LTE
JX0082 2/9/2013 Broadcom BRCM176319 BRCM176320 Broadcom executives See description QX1011
Materials

Page 4 of 6
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 6 of 7
Federal Trade Commission vs. Qualcomm, No. 17-cv-0220 (N.D. Cal.)
Joint Exhibit List - Redacted Version

Trial Ex. No. Date Description Producing Party Bates - Begin Bates - End Sponsoring Witness Purpose Also Marked As Also Produced As
Amended and Restated Strategic Terms Agreement between Apple or/and Qualcomm
JX0083 2/28/2013 Apple AAPL-FTC-00128467 AAPL-FTC-00128486 See description CX0588
Apple and Qualcomm (Effective Feb. 28, 2013) executives
Statement of Work for Qualcomm Chipsets for 7/8, 10,
Apple or/and Qualcomm
JX0084 2/28/2013 and 13 between Apple and Qualcomm(Effective Feb. 28, Apple AAPL-FTC-00128458 AAPL-FTC-00128466 See description CX0589
executives
2013)
JX0085 3/21/2013 Agreement for Subscriber Units (Effective Mar. 21, 2013) Qualcomm Q2017MDL1_03111128 Q2017MDL1_03111135 Qualcomm executives See description CX7613
Email from Sanjay Mehta to Steven Mollenkopf, Marc
McCloskey, James Lederer, et al. re: deck for board
JX0086 4/29/2013 Qualcomm Q2017MDL1_00435087 Q2017MDL1_00435092 Qualcomm executives See description CX5392
w/Attach: QCT TA Summary Slide for BOD
(042513)w_Financials5.pptx
Lenovo or/and Qualcomm CX7658;
JX0087 6/28/2013 Qualcomm Q2017MDL1_02927633 Q2017MDL1_02927635 See description
executives QX3655
Mediatek or/and Qualcomm
JX0088 7/1/2013 Mediatek MTKFTC_00000137 MTKFTC_00000159 See description CX3508
executives
SFT-0030236_Official SFT-0030270_Official CX2500A;
JX0089 9/23/2013 Report on Chipset Strategy (Qualcomm, S.LSI, Intel) Samsung Samsung executives See description SFT-0030236-SFT-0030270
Translation Translation CX2500
JX0090 10/9/2013 Samsung Presentation: 2014 Purchasing Strategy Samsung SFT-0030482 SFT-0030493 Samsung executives See description QX0523
JX0091 11/12/2013 Broadcom Presentation: Mobile and Wireless Broadcom BCRM000173 BCRM000205 Broadcom executives See description QX1015
Email from Cristiano Amon to Steven Mollenkopf, Murthy
JX0092 1/25/2014 Renduchintala, and Sanjay Mehta re: TD LTE licensing w/Attach: Qualcomm Q2017MDL1_02591816 Q2017MDL1_02591819 Qualcomm executives See description CX5299
China CY2014 LTE Impact.pptx
Email from Sarah Guichard to Steve Zipperstein and James Yersh
re: follow-up w/Attach:
Blackberry or/and Qualcomm
JX0093 3/7/2014 Blackberry (RIM) BB_FTC_00075179 BB_FTC_00075305 See description CX3268
executives

Email from Sarah Guichard to Steve Zipperstein and James Yersh
JX0094 3/7/2014 Blackberry (RIM) BB_FTC_00075179 BB_FTC_00075259 Blackberry executives See description QX0868
re: Follow-up
JX0095 5/30/2014 Broadcom Board of Directors Meeting Agenda (May 30, 2014) Broadcom BCRM000251 BCRM000307 Broadcom executives See description QX1002
JX0096 06/??/14 Qualcomm Presentation: 2014 Strategic Plan Financial Forecast Qualcomm Q2017MDL1 03031506 Q2017MDL1 03031506 Qualcomm executives See description CX7608
Huawei and/or Qualcomm
JX0097 7/1/2014 Huawei FTC-HUAWEI-0000650 FTC-HUAWEI-0000658 See description CX1023
executives
Huawei and/or Qualcomm
JX0098 7/1/2014 Huawei FTC-HUAWEI-0000572 FTC-HUAWEI-0000649 See description CX1024
executives
JX0099 8/1/2014 3GPP2 Working Procedures v17.0, August 2014 Public N/A N/A Qualcomm executives See description
JX0100 1/1/2015 ZTE ZQCS0000475 ZQCS0000502 ZTE or/and Qualcomm executives See description CX3932

JX0101 1/1/2015 Qualcomm Q2014FTC03105503 Q2014FTC03105523 Qualcomm executives See description
JX0102 1/1/2015 Qualcomm Q2017MDL1 03125643 Q2017MDL1 03125666 Qualcomm executives See description
JX0103 3/1/2015 ATIS Operating Procedures Public N/A N/A Qualcomm executives See description
Email from Asha Keddy to Feargal Moorhead re: MCM Updates
JX0104 6/25/2015 w/Attach: 1506018 SG CSD_FINAL.pptx; Unlicensed Intel INTEL-QCOM008124586 INTEL-QCOM008124663 Intel executives See description QX0074
LTEUnlicensed June15 2015 FINAL.pptx

JX0105 10/1/2015 Qualcomm Q2014FTC03101212 Q2014FTC03101346 Qualcomm executives See description CX7614
STA Assignment Agreement between Apple and Qualcomm Apple or/and Qualcomm
JX0106 12/7/2015 Apple AAPL-FTC-00128278 AAPL-FTC-00128287 See description CX0538
(Effective Dec. 7, 2015) executives

Page 5 of 6
Case 5:17-cv-00220-LHK Document 946-6 Filed 11/29/18 Page 7 of 7
Federal Trade Commission vs. Qualcomm, No. 17-cv-0220 (N.D. Cal.)
Joint Exhibit List - Redacted Version

Trial Ex. No. Date Description Producing Party Bates - Begin Bates - End Sponsoring Witness Purpose Also Marked As Also Produced As
Statement of Work for Qualcomm Chipsets for 11, 13.x, and
16: Under the Amended and Restated Strategic Terms Apple or/and Qualcomm
JX0107 12/7/2015 Apple AAPL-FTC-00128260 AAPL-FTC-00128277 See description CX0539
Agreement between Apple and Qualcomm (Effective Dec. 7, executives
2015)
Email from June Thanasophon to Carly Wyatt, Asha Keddy, Shira
JX0108 12/15/2015 Getzler, et al. re: 5G White Paper attached w/Attach: Intel and 5G - Intel INTEL-QCOM008077974 INTEL-QCOM008077987 Intel executives See description QX0073
Dec 2015 Update - vl 6.docx

JX0109 12/19/2015 Ericsson ERIC-QCOM-00019600 ERIC-QCOM-00019650 Apple and/or Ericsson executives See description QX2887
LGE or/and Qualcomm
JX0110 1/1/2016 Qualcomm PX397-001 PX397-023 See description PX0937
executives
JX0111 1/1/2016 Qualcomm Q2014FTC03100436 Q2014FTC03100439 Qualcomm executives See description
JX0112 1/1/2016 Qualcomm Q2014FTC03107397 Q2014FTC03107418 Qualcomm executives See description
JX0113 1/1/2016 Qualcomm Q2017MDL1_03125668 Q2017MDL1_03125691 Qualcomm executives See description
JX0114 4/1/2016 Qualcomm Q2014FTC03107419 Q2014FTC03107439 Qualcomm executives See description
Email from Alex Tobi to William Wyatt, Jacobs Magdaleno, and
JX0115 5/25/2016 Katie Arner re: strat slides w/Attach: FY17 Strat Plan Pricing Qualcomm Q2014FTC03957400 Q2014FTC03957401 Qualcomm executives See description CX7570
Deck v8.pptx

Email from Fabian Gonell to Larry Griffith and David Cianflone
Ericsson or/and Qualcomm
JX0116 7/27/2016 re: Avanci signed agreement w/Attach: 7-21-2016 side letter.pdf; Qualcomm QNDCAL00601110 QNDCAL00601249 See description CX6790
executives
Master LMA and appendices - signed by Ericsson and Avanci.pdf

Email from Aicha Evans to Murthy Renduchintala, Brice Hill,
JX0117 7/27/2016 Scott Fortmann, et al. re: iCDG PGBP PDF Deck for today's Intel INTEL-QCOM002458604 INTEL-QCOM002458670 Intel executives See description QX0093
meeting w.Attach: iCDG PGBP Final.pdf
Apple or/and Qualcomm
JX0118 10/1/2016 Apple APL-QC-FTC_30594551 APL-QC-FTC_30594749 See description CX0827
executives
QX1378; IDC-FTCQC-FTCSDT-000013-
JX0119 10/1/2016 Apple APL-QC_00451156 APL-QC_00451354 Apple executives See description
Apple McElvaine 0003 IDC-FTCQC-FTCSDT-000064
JX0120 10/14/2016 Ericsson's Responses to the CID Dated Aug. 25, 2016 Ericsson FTC-Ericsson-00000001 FTC-Ericsson-00000025 Ericsson executives See description QX2927
JX0121 10/20/2016 3GPP Working Procedures Public N/A N/A Qualcomm executives See description
CX6625;
Samsung or/and Qualcomm QAPPCMSD02163035-
JX0122 1/1/2018 Qualcomm QAPPCMSD02163037 QAPPCMSD02163068 See description QX0543;
executives QAPPCMSD02163133
CX2629
Qualcomm executives; Weiler,
JX0123 2/8/2018 ETSI Directives Public N/A N/A Dirk (Nokia); Expert: Huber, See description
Bertram
Qualcomm executives; Weiler,
JX0124 5/11/2018 3GPP - Partners Public N/A N/A Dirk (Nokia); Expert: Huber, See description
Bertram
Qualcomm executives; Weiler,
JX0125 9/21/2018 ATIS Member Listing Public N/A N/A Dirk (Nokia); Expert: Huber, See description
Bertram
Qualcomm executives; Weiler,
JX0126 9/21/2018 List of TIA Members Public N/A N/A Dirk (Nokia); Expert: Huber, See description
Bertram

Page 6 of 6