Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-01371-JJF Document 568 Filed 10/17/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
POR Tl-IE DISTRICT OF DELAWARE
POWER INTEGRATIONS, INC., a
Delaware corporation,
Plaintifi
V' C.A. No. 04-1371 JJF
FAIRCHILD SEMICONDUCTOR
INTERNATIONAL, INC., a Delaware
corporation, and FAIRCHILD
SEMICONDUCTOR CORPORATION, a
Delaware corporation,
Defendants.
DECLARATION OF ROBERT BLAUSCHILD
I, Robert Blauschild, declare as follows:
1. I have been asked to give expert opinions and testimony regarding Power
Integrations, Inc.’s ("Power Integrations") U.S. Patent Nos. 6,229,366 Bl ("the ’366
patent"), 6,249,876 Bl ("the ’876 patent"), and 6,107,851 ("the ’85l patent"),
collectively the "circuit patents." ·
2. I provided testimony and opinions in expert reports, depositions, and
during the jury trials in this matter that the Power Integrations circuit patents are valid
and are infringed by certain Fairchild PWM controller products. More specifically, the
circuits in those products associated with the "soft sta1t" and "frequency modulation"
(also known as "frequency jitter") functions infringed one or more claims of the circuit
patents.
3. Fairchild has introduced additional PWM controller products that I did not
have the opportunity to evaluate earlier that include the relevant functions but which were
not specifically discussed at the_ trial. Many of the products share similar part numbers
and appear to be new versions of the same products already determined to infringe.

Case 1 :04-cv-01371-JJF Document 568 Filed 10/17/2007 Page 2 of 3
4. Based on my review of publicly available information from Fairchild in
the form of data sheets, these new products appear to incorporate substantially the same
circuits for performing soft start and frequency modulation as those already found to
infiinge. The representations of the functions and the circuits associated with them, in
the form of block diagrams and text descriptions in the data sheets, are similar and in
some cases substantially identical to the corresponding descriptions in the data sheets
associated with the parts already found to infringe.
5. Accordingly, based on my review of information available to me as of this
declaration, at least the following additional Fairchild products also infringe one or more
of the asserted claims of the ’366, ’85l and/or ’876 patents:
FAN7602 FAN7602B FSDMl0l
FSDH0l70RNB FSDM0l70RNB FSCQOl70RNA
FSDH0270RNB FSDM0270RNB FSCQ0270RNA
FSDH0370RNB FSDM0370RNB FSCQ0370RNA
FSCM0465R
FSQl00 FSQ2ll FSQ3 11
FSQ32l FSQ32lL
FSQ5l0 FSQSIOH
FSQ0165RN FSQ0l65RL
FSQ0265RN FSQ0265RL
FSQ0365RN FSQ0365RL
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
Executed this éjjth day of October, 2007, at Redwood City, California.
[ ...e.. _ ,....
Robert Blauschild
2

Case 1:04—cv—01371-JJF Document 568 Filed 10/17/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on October 17, 2007, I electronically filed with the Clerk of
Court DECLARATION OF DECLARATION OF ROBERT BLAUSCHILD using
CM/ECE which will send electronic notification of such fi1ing(s) to the following
counsel.
BY HAND DELIVERY Attorneys for Defendants
Steven J. Balick FAIRCHILD SEMICONDUCTOR
John G. Day INTERNATIONAL, INC. and
Ashby & Geddes FAIRCI-IILD SEMICONDUCTOR
500 Delaware Avenue, 8th Floor CORPORATION, and third party
P. O. Box 1150 INTERSIL CORPORATION
Wilmington, DE 19899
BY E-MAIL AND FEDERAL EXPRESS Attorneys for Defendants
G. Hopkins Guy, III FAIRCHILD SEMICONDUCTOR
Bas de Blank INTERNATIONAL, INC. and
. Orrick, Herrington & Sutcliffe, LLP FAIRCHILD SEMICONDUCTOR
1000 Marsh Road CORPORATION
» Menlo Park, CA 94025
/s/ William J Marsden, Jr.
William J. Marsden, Jr.