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DECLARATION OF JENNIFER MILICI

Case No. 17-cv-00220-LHK-NMC

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff

v.

QUALCOMM INCORPORATED, a Delaware 

Corporation,

Defendant.

Case No. 5:17-cv-00220-LHK-NMC

DECLARATION OF JENNIFER MILICI 

IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S OPPOSITION TO 

QUALCOMM’S MOTION TO EXCLUDE 

EXPERT REPORTS OF

RICHARD L. DONALDSON

DATE: October 18, 2018

TIME: 1:30 p.m.

CTRM: 8, 4th Floor

JUDGE: Hon. Lucy H. Koh

Case 5:17-cv-00220-LHK Document 1022-1 Filed 12/18/18 Page 1 of 3
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DECLARATION OF JENNIFER MILICI

Case No. 17-cv-00220-LHK-NMC

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I, Jennifer Milici, do hereby declare and state as follows: 

1. I am an active member in good standing with the District of Columbia Bar. I am

employed by the Federal Trade Commission (“FTC”), an agency of the United States

government. I am one of the attorneys of record in this matter for the FTC. I have personal 

knowledge of the matters set forth in this declaration, and if called upon as a witness I could and 

would testify competently.

2. I respectfully submit this declaration in support of the FTC’s Opposition to

Qualcomm’s Motion to Exclude Expert Reports of Richard L. Donaldson. 

3. Attached as Exhibit 1 is a true and correct copy of Excerpts from Deposition of

Richard Donaldson conducted in this litigation. 

4. Attached as Exhibit 2 is a true and correct copy of Excerpts from the Deposition

of Jeffrey G. Andrews conducted in this litigation.

5. Attached as Exhibit 3 is a true and correct copy of Excerpts from the Deposition

of Dr. Bertram Huber conducted in this litigation. 

6. Attached as Exhibit 4 is a true and correct copy of an excerpt of 

QAPPCMSD07786307 (Strategy Analytics “Global Handset Revenue, ASP and Profit in Q2 

2017”), as produced by Qualcomm in this litigation. 

7. Attached as Exhibit 5 is a true and correct copy of portions of

Q2014FTC04150166 (“FY18-22 Strat Plan” May 24th, 2017), as produced by Qualcomm in this 

litigation. 

8. Attached as Exhibit 6 is a true and correct copy of portions of

Q2017MDL1_02944278 (“HS Market Share by Vendor”), also marked as Q2014FTC00045280, 

as produced by Qualcomm in this litigation. 

9. Attached as Exhibit 7 is a true and correct copy of Q2017MDL1_01736777

(Email from Eric Reifschneider (Qualcomm) to Derek Aberle (Qualcomm), Apr. 9, 2013), as 

produced by Qualcomm in this litigation. 

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DECLARATION OF JENNIFER MILICI

Case No. 17-cv-00220-LHK-NMC

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10. Attached as Exhibit 8 is a true and correct copy of Q2014FTC03470494 (Email 

from Eric Reifschneider (Qualcomm) to Huawei, May 6, 2013), also marked as 

Q2017MDL1_01197694, as produced by Qualcomm in this litigation.

11. Attached as Exhibit 9 is a true and correct copy of Excerpts from the Deposition 

of Cristiano Amon conducted in this litigation.

12. Attached as Exhibit 10 is a true and correct copy of QNDCAL02199665 (Email of 

Michael Hartogs (Qualcomm), Sept. 9, 2003), as produced by Qualcomm in this litigation.

13. Attached as Exhibit 11 is a true and correct copy of Q2017MDL1_02843092 

(Email from Eric Reifschneider (counsel for Qualcomm) to Sony, Feb. 20, 2012), also marked as 

Q2014FTC03025677, as produced by Qualcomm in this litigation.

14. Attached as Exhibit 12 is a true and correct copy of Q2017MDL1_02697467 

(Email from Steve Altman, Qualcomm, Feb. 27, 2008), also marked as Q2014FTC02865767, as 

produced by Qualcomm in this litigation.

15. Attached as Exhibit 13 is a true and correct copy of Q2014FTC03584363

(Qualcomm presentation, Nov. 16, 2015), as produced by Qualcomm in this litigation. 

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 24th day of September.

/s/ Jennifer Milici 

Jennifer Milici

Case 5:17-cv-00220-LHK Document 1022-1 Filed 12/18/18 Page 3 of 3