EXHIBIT B

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United States District Court 

Northern District of Californi

a

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 

PLAINTIFF FEDERAL TRADE 

COMMISSION’S WITNESS LIST

 

 

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PLAINTIFF FEDERAL TRADE COMMISSION’S WITNESS LIST 

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

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

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

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

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

attendance of the witness may be compelled by the Court. 

FACT WITNESSES BY LIVE TESTIMONY 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Chairman from approximately 2011 until his retirement in January 2014. 

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

semiconductor business, and previously held various other roles relating to 

Qualcomm’s semiconductor business since he started at Qualcomm in 1995. 

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

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

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

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

2007. 

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

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

2005. 

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

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

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

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

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

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

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

since 2008. 

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

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

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

since October 2016 and has worked at Qualcomm since 2001. 

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

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

lead for QCT. 

Live Witnesses Not Represented by Qualcomm: 

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

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

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

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

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

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

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

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

importance of FRAND commitments for SEPs; whether the effective royalties 

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

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

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

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

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

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

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

which he has knowledge.

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

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

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

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

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

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

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

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

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

Qualcomm or the FTC as to which she has knowledge.

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

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

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

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

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markets; the effects of Qualcomm’s policies and practices on competition, innovation, 

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

importance of FRAND commitments for SEPs; patent agreements and negotiations 

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

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

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

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

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

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

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

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

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

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

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

Qualcomm or the FTC as to which he has knowledge.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

importance of FRAND commitments for SEPs; whether the effective royalties 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

whether the effective royalties historically paid by Apple through its contract 

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

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

conditions extracted by Qualcomm in exchange for royalty relief; competitive 

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

Qualcomm’s policies and practices on competition, innovation, and consumers; any 

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other issues addressed in his deposition; or any documents or data introduced into 

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

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

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

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

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

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

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

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

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

importance of FRAND commitments for SEPs; whether the effective royalties 

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

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

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

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

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

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

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

which he has knowledge.

FACT WITNESSES BY DEPOSITION 

Each of the below-listed witnesses may testify about any issue addressed in the portions of his or 

her deposition designated pursuant to the FTC’s initial designations, supplemental designations, 

and subject to the cross-designation and counter-designation process as instructed by the Court 

or/and agreed to by the parties. 

20. Seungho Ahn is Head of Samsung’s IP Center and is responsible for all matters 

relating to intellectual property at Samsung. The FTC may present testimony from Mr. 

Ahn regarding the subjects of his deposition, including without limitation Samsung’s 

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agreements, communications, and negotiations with Qualcomm and with other 

intellectual property licensors and licensees; Qualcomm’s commitments to license 

standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory 

(“FRAND”) terms; and the effects of Qualcomm’s policies and practices on 

competition, innovation, and consumers.

21. Jeffrey (Jeff) Altman worked in Business Development within the QTL division from 

1998 until his retirement on January 3, 2018. He had previously been in various other 

roles since he started at Qualcomm in 1992. The FTC may present testimony from Mr. 

Altman regarding the subjects of his deposition, including without limitation 

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

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

and licensing; Qualcomm’s commitments to license standard essential patents (“SEPs”) 

on fair, reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets; 

Qualcomm’s market power; and the effects of Qualcomm’s policies and practices on 

competition, innovation, and consumers.

22. Richard Blaylock is a partner at Pillsbury Winthrop Shaw Pittman LLP and has 

represented ZTE in several negotiations with Qualcomm, including 2015 license 

negotiations. The FTC may present testimony from Mr. Blaylock regarding the 

subjects of his deposition, including without limitation ZTE’s negotiations regarding 

intellectual property license agreements with Qualcomm and others; ZTE’s agreements 

with Qualcomm, Qualcomm’s policies and practices related to product sales and 

licensing; Qualcomm’s commitments to license standard essential patents (“SEPs”) on 

fair, reasonable, and non-discriminatory (“FRAND”) terms; Qualcomm’s market 

power; and the effects of Qualcomm’s policies and practices on competition, 

innovation, and consumers. 

23. Marvin Blecker joined Qualcomm in 1992 and was President of QTL from the early 

2000s through 2008, and Senior Vice President in Qualcomm’s licensing business from 

1996 through his promotion to President, and again from 2008 until his retirement in 

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March 2014. Mr. Blecker served as a consultant to Qualcomm after his retirement. 

The FTC may present testimony from Mr. Blecker regarding the subjects of his 

deposition, including without limitation Qualcomm’s supply and licensing agreements; 

negotiations with actual and prospective customers and licensees; Qualcomm’s policies 

and practices related to product sales and licensing; Qualcomm’s commitments to 

license standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory 

(“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on competition, innovation, and consumers.

24. Ira Blumberg has been Vice President of Intellectual Property at Lenovo since 2012. 

The FTC may present testimony from Mr. Blumberg regarding the subjects of his 

deposition, including without limitation Lenovo’s agreements with Qualcomm; the 

negotiation of patent licenses and supply agreements with Qualcomm and others; 

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

commitments to license standard essential patents (“SEPs”) on fair, reasonable, and 

non-discriminatory (“FRAND”) terms; modem chip markets; Qualcomm’s market 

power; barriers to entry and expansion in modem chip markets; and the effects of 

Qualcomm’s policies and practices on competition, innovation, and consumers.

25. Hwi-Jae Cho is Director of the Intellectual Property Center at LGE in charge of all 

patent licensing matters at LGE, and has worked at LGE since 2000. Mr. Cho may 

testify about any issue addressed in the designated portions of his sworn testimony 

provided in response to written questions propounded by the FTC and Qualcomm 

pursuant to the Hague Convention on Evidence. The FTC may present testimony from 

Mr. Cho regarding the subjects of his sworn testimony, including without limitation 

LGE’s agreements with Qualcomm; the negotiation of patent licenses and supply 

agreements with Qualcomm and others; Qualcomm’s policies and practices related to 

product sales and licensing; Qualcomm’s commitments to license standard essential 

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

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

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

competition, innovation, and consumers.

26. Brian Chong is chief of the medical business development center and chief of new 

technology development and product planning at Wistron. The FTC may present 

testimony from Mr. Chong regarding the subjects of his deposition, including without 

limitation Wistron’s agreements with Qualcomm; the negotiation of patent licenses and 

supply agreements with Qualcomm and others; Qualcomm’s policies and practices 

related to product sales and licensing; Qualcomm’s commitments to license standard 

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

terms; modem chip markets; the effects of Qualcomm’s licensing practices on 

Qualcomm’s licensees and chip competitors; Qualcomm’s market power; barriers to 

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

and practices on competition, innovation, and consumers.

27. Mark Davis was the director of the wireless design center of LSI Logic and later 

served as the chief technology officer of VIA Telecom until 2015. The FTC may 

present testimony from Mr. Davis regarding the subjects of his deposition, including 

without limitation, Via’s agreements with Qualcomm; Qualcomm’s policies and 

practices related to product sales and licensing; Qualcomm’s commitments to license 

standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory 

(“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on competition, innovation, and consumers.

28. Jianxin (Jason) Ding is Vice President and Head of Intellectual Property Rights for 

Huawei Technology. The FTC may present testimony from Mr. Ding regarding the 

subjects of his deposition, including without limitation the volume of Huawei’s handset 

sales; Huawei’s agreements with Qualcomm; the negotiation of patent licenses and 

supply agreements with Qualcomm and others; Qualcomm’s policies and practices 

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related to product sales and licensing; Qualcomm’s commitments to license standard 

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

terms; modem chip markets; Qualcomm’s market power; barriers to entry and 

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

practices on competition, innovation, and consumers. 

29. John Grubbs is Senior Director of IP Transactions at BlackBerry. The FTC may 

present testimony from Mr. Grubbs regarding the subjects of his deposition, including 

without limitation Blackberry’s agreements with Qualcomm; the negotiation of patent 

licenses and supply agreements with Qualcomm and others; Qualcomm’s policies and 

practices related to product sales and licensing; Qualcomm’s commitments to license 

standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory 

(“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on competition, innovation, and consumers. 

30. Andrew Hong has worked at Samsung since 2003. He is an attorney in the Global 

Legal Affairs group at Samsung, and previously was an attorney within Samsung’s IP 

Center, and before that within Samsung’s Semiconductor IP team. The FTC may 

present testimony from Mr. Hong regarding the subjects of his deposition, including 

without limitation Samsung’s agreements with Qualcomm; the negotiation of patent 

licenses and supply agreements with Qualcomm and others; Qualcomm’s policies and 

practices related to product sales and licensing; Qualcomm’s commitments to license 

standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory 

(“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on actual and potential modem chip rivals, competition, innovation, and 

consumers. 

31. Hojin Kang is the former Director of Purchasing at Samsung Mobile, and was 

employed by Samsung from 1987 to 2016. The FTC may present testimony from Mr. 

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Kang regarding the subjects of his deposition, including without limitation Samsung’s 

agreements with Qualcomm; Qualcomm’s policies and practices related to product 

sales and licensing; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on competition, innovation, and consumers.

32. Asha Keddy is the manager of Intel’s Next Generation and Standards team and has 

worked at Intel since 1999. The FTC may present testimony from Ms. Keddy 

regarding the subjects of her deposition, including without limitation Intel’s 

agreements with Qualcomm; Qualcomm’s policies and practices related to product 

sales and licensing; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on competition, innovation, and consumers.

33. Yooseok Kim is Vice President of the IP Center at Samsung and has worked at 

Samsung since 1995. The FTC may present testimony from Mr. Kim regarding the 

subjects of his deposition, including without limitation Samsung’s agreements with 

Qualcomm; the negotiation of patent licenses and supply agreements with Qualcomm 

and others; Qualcomm’s policies and practices related to product sales and licensing; 

Qualcomm’s commitments to license standard essential patents (“SEPs”) on fair, 

reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets; 

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

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

consumers. 

34. Injung Lee is the Head of the License Team at the IP Center at Samsung. The FTC 

may present testimony from Mr. Lee regarding the subjects of his deposition, including 

without limitation Samsung’s agreements with Qualcomm; the negotiation of patent 

licenses and supply agreements with Qualcomm and others; Qualcomm’s policies and 

practices related to product sales and licensing; Qualcomm’s commitments to license 

standard essential patents (“SEPs”) on fair, reasonable, and non-discriminatory 

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(“FRAND”) terms; modem chip markets; Qualcomm’s market power; barriers to entry 

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

practices on competition, innovation, and consumers. 

35. Thomas Lindner is Head of the Cellular Modem & Mobile Connectivity business line 

at Intel and has worked at Intel since 2011, after Intel acquired his former employer, 

Infineon. The FTC may present testimony from Mr. Lindner regarding the subjects of 

his deposition, including without limitation modem chip markets; Intel’s relationship 

with Apple; Qualcomm’s market power; barriers to entry and expansion in modem 

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

innovation, and consumers. 

36. Todd Madderom has been Director of Procurement at Motorola since 2012. The FTC 

may present testimony from Mr. Madderom regarding the subjects of his deposition, 

including without limitation Motorola’s agreements with Qualcomm; Qualcomm’s 

policies and practices related to product sales and licensing; modem chip markets; 

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

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

consumers. 

37. Isabel Mahe is Managing Director for Greater China at Apple, and was Vice President 

of Wireless Technology at Apple from 2008 to 2017. The FTC may present testimony 

from Ms. Mahe regarding the subjects of her deposition, including without limitation 

Apple’s purchasing processes and decisions; Apple’s design processes; modem chip 

markets; Apple’s products and product requirements; handset competition and market 

conditions; Apple’s negotiations and relationship with Intel, Qualcomm, and other 

suppliers; Apple’s agreements with Qualcomm; Qualcomm’s policies and practices 

related to product sales and licensing; Qualcomm’s market power; barriers to entry and 

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

practices on competition, innovation, and consumers.

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38. Scott McGregor was President and CEO of Broadcom until January 2016. The FTC 

may present testimony from Mr. McGregor regarding the subjects of his deposition, 

including without limitation competitive conditions and barriers to entry and expansion 

in modem chip markets; Broadcom’s efforts to compete with Qualcomm and 

relationship with Apple; modem chip and handset characteristics and markets; 

Broadcom’s agreements with Qualcomm; Qualcomm’s market power; and the effects 

of Qualcomm’s policies and practices on its rivals and potential rivals, competition, 

innovation, and consumers.

39. Shen Nan has been the Chief Intellectual Property Officer for ZTE since 2016 and 

previously served as ZTE’s Chief Licensing Officer. The FTC may present testimony 

from Mr. Nan regarding the subjects of his deposition, including without limitation 

ZTE’s agreements with Qualcomm; Qualcomm’s policies and practices related to 

product sales and licensing; modem chip markets; Qualcomm’s market power; barriers 

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

and practices on competition, innovation, and consumers.

40. Christina Petersson is a senior licensing attorney at Ericsson. The FTC may present 

testimony from Ms. Petersson regarding the subjects of her deposition, including 

without limitation Ericsson’s patent license negotiations and agreements with 

Qualcomm and others; Qualcomm’s policies and practices related to product sales and 

licensing; Qualcomm’s commitments to license standard essential patents (“SEPs”) on 

fair, reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets; 

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

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

consumers.

41. Robert Rango was Executive Vice President of Broadcom’s Wireless Connectivity 

Group until he retired in 2014. The FTC may present testimony from Mr. Rango 

regarding the subjects of his deposition, including without limitation competitive 

conditions and barriers to entry and expansion in modem chip markets; Broadcom’s 

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efforts to compete with Qualcomm and relationship with Apple; modem chip and 

handset characteristics and markets; Broadcom’s agreements with Qualcomm; 

Qualcomm’s market power; and the effects of Qualcomm’s policies and practices on its 

rivals and potential rivals, competition, innovation, and consumers.

42. Tony (Taekwon) Son is Deputy Senior Manager at LG Electronics, Inc. (“LGE”) in 

charge of mobile chipsets in the Mobile Communications semiconductor procurement 

team, and has worked at LGE since July 2004. Mr. Son may testify about any issue 

addressed in the designated portions of his sworn testimony provided in response to 

written questions propounded by the FTC and Qualcomm pursuant to the Hague 

Convention on Evidence, including without limitation LGE’s agreements with 

Qualcomm; the negotiation of patent licenses and supply agreements with Qualcomm 

and others; Qualcomm’s policies and practices related to product sales and licensing; 

Qualcomm’s commitments to license standard essential patents (“SEPs”) on fair, 

reasonable, and non-discriminatory (“FRAND”) terms; modem chip markets; 

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

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

consumers.

43. Richard Wang has been Huawei’s Director of Terminal Chipset Platform Planning 

since 2011. From 2004 through 2007, he was responsible for marketing wireless 

terminal products for HiSilicon. The FTC may present testimony from Mr. Wang 

regarding the subjects of his deposition, including without limitation HiSilicon’s 

negotiations and agreements with Qualcomm; Qualcomm’s policies and practices 

related to product sales and licensing; Qualcomm’s commitments to license standard 

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

terms; modem chip markets; Qualcomm’s market power; barriers to entry and 

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

practices on competition, innovation, and consumers.

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44. Stefan Wolff held several marketing and managerial positions at Infineon from 1996 

to 2011, including Vice President and General Manager for RF and Modem, and held 

similar roles at Intel from 2011 to approximately 2017. The FTC may present 

testimony from Mr. Wolff regarding the subjects of his deposition, including without 

limitation, Infineon’s agreements with Qualcomm; limitation modem chip markets; 

Infineon’s efforts to compete with Qualcomm; Qualcomm’s market power; barriers to 

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

and practices on competition, innovation, and consumers.

45. Monica Yang is a manager in Pegatron’s legal department. The FTC may present 

testimony from Ms. Yang regarding the subjects of her deposition, including without 

limitation Pegatron’s agreements with Qualcomm; the negotiation of patent licenses 

and supply agreements with Qualcomm and others; Qualcomm’s policies and practices 

related to product sales and licensing; Qualcomm’s commitments to license standard 

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

terms; modem chip markets; Qualcomm’s market power; barriers to entry and 

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

practices on competition, innovation, and consumers.

46. Nanfen (Nancy) Yu is Senior Legal Counsel at Huawei. The FTC may present 

testimony from Ms. Yu regarding the subjects of her deposition, including without 

limitation Huawei’s negotiations with and agreements with Qualcomm; Qualcomm’s 

policies and practices related to product sales and licensing; Qualcomm’s market 

power; and Qualcomm’s commitments to license standard essential patents (“SEPs”) 

on fair, reasonable, and non-discriminatory (“FRAND”) terms. 

EXPERT WITNESSES BY LIVE TESTIMONY 

47. Dr. Robert Akl is an Associate Professor at the University of North Texas and a 

Senior Member of IEEE, with over 20 years of experience with patents and technology 

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in the wireless and networking industry. Dr. Akl may testify about the opinions 

disclosed in his expert reports and deposition, including cellular patent portfolios. 

48. Richard Donaldson is a patent and licensing consultant and testifying expert. Mr. 

Donaldson spent 31 years as a licensing executive and patent attorney at Texas 

Instruments, Inc., where he developed global patent licensing strategies and negotiated 

patent licenses, including licenses to SEPs. Mr. Donaldson may testify about the 

opinions disclosed in his expert reports and deposition, including patent licensing. 

49. Michael J. Lasinski is a Managing Director and the Chief Executive Officer of 284 

Partners, LLC, a firm focused on intellectual property valuation, litigation consulting, 

IP strategy, and IP transactional services. Mr. Lasinski may testify about the opinions 

disclosed in his expert reports and deposition, including reasonable royalty rates.

50. Carl Shapiro is a Professor of the Graduate School at the University of California at 

Berkeley and is an economist who has studied antitrust, innovation, and competitive 

strategy for over thirty years. Prof. Shapiro may testify about the opinions disclosed in 

his expert reports and deposition, including market definition, market power, and harm 

to competition.

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