Free Declaration - District Court of Delaware - Delaware

Case 1 :05-cv-00048-SLR Document 312 Filed 1 1/13/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HITACHI, LTD. and HITACHI AUTOMOTIVE )
PRODUCTS (USA), INC., )
)
Plaintiffs, _ )
. ) _
v. )
) Civil Action No. 05-048-SLR
BORGWARNER INC., )
and BORGWARNER MORSE TEC H\IC., )
)
Defendants. )

)
BORGWARNER INC., )
)
Countcrclaimant, )
)
v. )
)
HITACHI, LTD., and HITACHI AUTOMOTIVE ) -
PRODUCTS (USA), INC., )
)
Countcrdcfcndants. )
DECLARATION OF WILLIAM B. RIBBENS
_ IN SUPPORT OF BORGWARNER'S OPPOSITION S
` TO PLAINTIFFS' SUMMARY JUDGMENT MO'I`IONS

I Case 1:05-cv-00048-SLR Document 312 Filed 11/13/2006 Page 2 of 2 _
I, William B. Ribbens, do hereby declare and say as follows:
` 1. I have been retained by the law iirm of Sidley Austin LLP, which E
_ represents Defendants BorgWarner Inc. and Borgwamer Morse Tec Inc. (collectively
”BorgWamer") in this case, as an expert in automotive technologies, including electronic control in
l systems. `
h U " l _ 2. I submit this declaration in support of BorgWarner‘s Oppositions to E
· U . Plaintiffs Summary Judgment Motions. .
3. Attached hereto as Exhibit 1 is a true and correct copy of my Expert
_ Report Regarding Infringement of U.S. Patent No. 5,497,733, and to the best of my present
knowledge, the statements contained therein are true and accurate. i
_ 4. Attached hereto as Exhibit 2 is a true and correct copy of my Expert
U Report Regarding Validity of U.S. Patent No. 5,497,738, and to the best ofmy present U
knowledge, the statements contained therein are true and accurate.
5. Attached hereto as Exhibit 3 is a true and correct copy of my
Supplemental Expert Report Regarding Infringement of U.S. Patent No. 5,497,738, and to the
best of my present knowledge, the statements contained therein are true and accurate. U
I declare under penalty of perjury that the foregoing is true and correct to 1:he best l -
A U of my knowledge, information and belief {
Dated: November 13, 2006
William B. Ribbens E