EXHIBIT A

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Joint Stipulation Regarding Undisputed Facts 

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FEDERAL TRADE COMMISSION 

Jennifer Milici 

J. Alexander Ansaldo 

Joseph R. Baker 

Elizabeth A. Gillen 

Daniel Matheson 

Mark Woodward 

600 Pennsylvania Avenue, N.W. 

Washington, D.C. 20580 

Tel.: (202) 326-2912 

Fax: (202) 326-3496 

jmilici@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

CRAVATH, SWAINE & MOORE LLP 

Gary A. Bornstein (pro hac vice) 

gbornstein@cravath.com 

Yonatan Even (pro hac vice) 

yeven@cravath.com 

825 Eighth Avenue 

New York, New York 10019-7475 

Telephone: (212) 474-1000 

Facsimile: (212) 474-3700 

KEKER, VAN NEST & PETERS LLP 

Robert A. Van Nest (SBN 84065) 

rvannest@keker.com 

Eugene M. Paige (SBN 202849) 

epaige@keker.com 

Justina Sessions (SBN 270914) 

jsessions@keker.com 

633 Battery Street 

San Francisco, CA 94111-1809 

Telephone: (415) 391-5400 

Facsimile: (415) 397-7188 

MORGAN, LEWIS & BOCKUS LLP 

Richard S. Taffet (pro hac vice) 

richard.taffet@morganlewis.com 

101 Park Avenue 

New York, New York 10178-0060 

Tel: (212) 309-6000 

Fax: (212) 309-6001 

Attorneys for Defendant 

QUALCOMM INCORPORATED 

Additional Counsel in the Signature Block

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

vs. 

QUALCOMM INCORPORATED, a Delaware 

corporation, 

Defendant. 

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

JOINT STIPULATION REGARDING 

UNDISPUTED FACTS

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Plaintiff the Federal Trade Commission (“FTC”) and Defendant Qualcomm Incorporated 

(“Qualcomm”) (collectively, the “Parties”) respectfully submit this Joint Stipulation Regarding 

Undisputed Facts. 

The following facts are undisputed, and the Parties hereby stipulate to them for 

incorporation into the trial record without the necessity of supporting testimony or exhibits. 

However, the Parties agree that neither Party will object to the presentation of evidence in support 

of these stipulated facts at trial on the ground that such facts were the subject of this stipulation. 

The Parties agree that the stipulation of facts below is made without prejudice to each Party’s 

ability to bring any motions in limine. 

For purposes of the stipulated facts below: “Cellular Handsets” shall refer to complete 

cellular end-user cellular telephones, including feature phones and smartphones. 

1. QUALCOMM Incorporated (“Qualcomm”) is headquartered in San Diego, 

California. 

2. Since at least 1989, Qualcomm has been, and is now, a corporation. 

3. Since at least 1989, Qualcomm has been, and is now, engaged in interstate and 

international commerce. 

4. Qualcomm’s operating segment relating to its chip and software business is called 

Qualcomm CDMA Technologies (“QCT”). Qualcomm’s operating segment relating to the 

licensing of its patents is called Qualcomm Technology Licensing (“QTL”). 

5. In 2012, Qualcomm created Qualcomm Technologies, Inc. (“QTI”), a wholly 

owned subsidiary of Qualcomm. QTI operates substantially all of Qualcomm’s products and 

services businesses, including QCT, as well as substantially all of Qualcomm’s engineering, 

research and development functions. Qualcomm continues to operate QTL. 

6. Qualcomm CDMA Technologies Asia -Pacific Pte. Ltd. (“QCTAP”), a Singapore 

company, is a wholly owned indirect subsidiary of Qualcomm. 

7. Cellular communications depend on widely distributed networks that implement 

cellular communications standards. 

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8. Some OEMs have purchased multimode modem chips for use in Cellular Handsets 

intended for operation on the major U.S. wireless networks. 

9. Cellular Handsets are designed, marketed, and sold by original equipment 

manufacturers (“OEMs”) such as Samsung, Huawei, Apple, Xiaomi, Oppo, Vivo, Google, 

Lenovo/Motorola Mobility, and LG. 

10. Consumers purchase Cellular Handsets for a variety of reasons, including for 

(a) their ability to transmit and receive data at high-speeds over cellular networks, such as those 

implementing LTE, the highest-speed cellular standard which has been widely commercialized to 

date, and (b) their ability to perform voice calls. 

11. The Third Generation Partnership Project (“3GPP”) and the Third Generation 

Partnership Project 2 (“3GPP2”) are global collaborative partnerships of standards 

development/standards-setting organizations (“SDOs” or “SSOs”) and other industry participants 

that develop technical specifications for cellular standards. 

12. The current “organizational partners” of 3GPP are seven regional SDOs, 

specifically: the European Telecommunications Standards Institute (“ETSI”), the Alliance for 

Telecommunications Industry Solutions (“ATIS”), the Association of Radio Industries and 

Businesses, Japan (“ARIB”), the Telecommunication Technology Committee, Japan (“TTC”), the 

China Communications Standards Association (“CCSA”), the Telecommunications Standards 

Development Society, India (“TSDSI”), and the Telecommunications Technology Association, 

Korea (“TTA”). 

13. The current organizational partners of 3GPP2 are five regional SDOs, specifically: 

the Telecommunications Industry Association (“TIA”), ARIB, TTC, CCSA, and TTA. 

14. Cellular communications standards have evolved over “generations,” including 

second-generation (“2G”), third-generation (“3G”), and fourth-generation (“4G”) standards. 

15. 2G cellular standards include the Global System for Mobile (“GSM”) and 

cdmaOne (also sometimes called “TIA/EIA/IS-95” or “IS-95”). 

16. ETSI adopted GSM as a cellular standard. ETSI also adopted General Packet 

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Radio Service (“GPRS”) and Enhanced Data Global Evolution (“EDGE”) as improvements to 

GSM. These are considered 2G standards. 

17. GSM uses time division multiple access (“TDMA”) technology. 

18. TIA adopted cdmaOne as a cellular standard. TIA also adopted IS-95A and 

IS-95B as improvements to cdmaOne. These are considered 2G standards. 

19. cdmaOne uses code division multiple access (“CDMA”) technology.

20. 3G cellular standards include the Universal Mobile Telecommunications System 

(“UMTS”) and CDMA2000. 

21. UMTS is an umbrella term for three 3G cellular air interfaces standardized within 

3GPP: UTRA-FDD, commonly called Wideband CDMA (“WCDMA”), used worldwide; UTRATDD High Chip Rate, having little deployment; and UTRA-TDD Low Chip Rate, commonly 

called Time Division-Synchronous CDMA (“TD-SCDMA”), used primarily in China. The term 

HSDPA refers to certain additional UMTS features included in Release 5. HSUPA refers to 

certain additional UMTS features included in Release 6. The combination of HSDPA and 

HSUPA is commonly called HSPA, and HSPA/HSPA+ refers to certain additional UMTS 

features included in Release 7 and beyond. 

22. Included within the CDMA2000 family of standards are CDMA2000 1x, often 

called 1xRTT, and High Rate Packet Data, often called 1xEV-DO or EV-DO. 

23. CDMA2000 was standardized by 3GPP2. 

24. In the United States, AT&T and T-Mobile have operated WCDMA networks. 

Verizon and Sprint have operated CDMA2000 networks. 

25. All four major U.S. carriers (Verizon, AT&T, T-Mobile and Sprint) have deployed 

Long Term Evolution (“LTE”), which also encompasses the LTE Advanced, or “LTE-A,” 

standard), as their 4G standard. 

26. LTE uses orthogonal frequency division multiple access (“OFDMA”) technology 

for downlink transmissions and single-carrier frequency division multiple access (“SC-FDMA”) 

technology for uplink transmissions. 

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this role for approximately ten years, and has worked at Qualcomm since 1993. 

113. Jeffrey (Jeff) Altman worked in Business Development within QTL from 1998 

until his retirement on January 3, 2018. He joined Qualcomm in 1992. 

114. Steven (Steve) Altman was President of Qualcomm from 2005 to 2011, and Vice 

Chairman from November 2011 until his retirement in January 2014. Prior to those roles, he had 

worked at Qualcomm since 1989, in various roles including General Counsel, Senior Vice 

President and Vice President. 

115. Cristiano Amon is President of Qualcomm, a position he has held since January 

2018, and oversees Qualcomm’s semiconductor business. He was previously Executive Vice 

President and President of QCT from 2015 to December 2018, and was Executive Vice President 

and Co-President of QCT from 2012 to 2015. He started at Qualcomm in 1995 and since then, 

excluding a period from June 1999 to November 2001 during which he was not employed by 

Qualcomm, has held various other roles relating to Qualcomm’s semiconductor business. 

116. Robert (Xiaopeng) An was Senior Director of Business Development at QTL, 

located in Beijing, until August 2018. He began working at Qualcomm in approximately 2010. 

117. Marvin (Marv) Blecker was Senior Vice President of QTL from April 1995 to 

April 2005 and General Manager of QTL from November 2001 to April 2005, and then President 

of QTL from April 2005 through October 2008, also serving as Executive Vice President of 

Qualcomm from 2006 through October 2008. He also served as Senior Vice President of QTL 

from October 2008 until his retirement in February 2014. He joined Qualcomm in 1992. 

118. Lorenzo Casaccia is Vice President of Technical Standards at Qualcomm Europe 

Inc. He has been the lead for Qualcomm’s 3GPP technical standards efforts since 2008. He 

joined Qualcomm in 2001. 

119. Yunhui Chae-Banks is Vice President of Business Development at QTL a position 

she has held since 2016. Prior to her current role, she was an attorney for QTL and other 

Qualcomm business units since she started at Qualcomm in 2003. 

120. Anand Chandrasekher was Senior Vice President and General Manager for 

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Qualcomm’s Datacenter Technologies Inc. from December 2015 until departing Qualcomm in 

July 2018. He previously was Senior Vice President for Business Development of the Data 

Center Group from October 2013 to December 2015, and was Senior Vice President and Chief 

Marketing Officer from August 2012, when he joined Qualcomm, until October 2013. 

121. Liren Chen is Senior Vice President of Engineering and Legal Counsel in QTL, 

where he leads QTL’s technology and product management team. He has been a Senior Vice 

President of Engineering and Legal Counsel since October 2015; prior to that, from February 

2009, he was Vice President of Engineering and Legal Counsel in the Intellectual Property and 

Strategic IP departments. He joined Qualcomm in 1996. 

122. Victoria (Vicky) Chen is Senior Vice President, Legal Counsel at QTI. She started 

at Qualcomm in 1998 as Attorney in the subscriber unit group. That group was sold to Kyocera 

Wireless in 2000, and she re-joined Qualcomm in 2004. 

123. David Cianflone is Senior Vice President, Finance at QTL. Prior to his current 

position, he has held various finance roles for different Qualcomm business units since he started 

in 1998. 

124. George Davis is Executive Vice President and Chief Financial Officer for 

Qualcomm, and has been since he joined Qualcomm in March 2013. 

125. Jim Doh was Vice Chairman, Qualcomm Asia, from approximately 2014 until his 

retirement in January 2017. He previously held various other roles, including Senior Vice 

President of Worldwide Sales, President of QCT Asia, and Senior Vice President and President of 

QCT, since he started at Qualcomm in 1997. 

126. Deborah Dwight is Vice President, Division Counsel at QTL, a position she has 

held since May 2017. She previously held various other roles as an attorney in QTL and in 

Qualcomm’s Corporate Legal department since starting at the company in 2001. 

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

QTL and has been in this role since 2017. Prior to his current role, he has held roles as Division 

Counsel and as an attorney in QTL since 2009, and as an attorney in Qualcomm’s Corporate 

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Legal department from 2007 to 2009. 

128. Matthew Grob was Executive Vice President of Technology from April 2017 until 

May 2018. He previously was Qualcomm’s Chief Technology Officer from 2011 to March 2017, 

Senior Vice President of Engineering in Qualcomm’s Corporate R&D unit from 2006 to 2010, 

and held other engineering roles at Qualcomm since starting at the company in 1991. 

129. Kirti Gupta was Director of Economic Strategy within Qualcomm’s Strategic 

Intellectual Property group from approximately 2012 through 2016, when she assumed her 

current role as Senior Director of Economic Strategy within Qualcomm’s legal department. She 

previously held various other roles since starting in Qualcomm, with the exception of a brief 

period from late 2008 through early 2009, when she was not a Qualcomm employee. 

130. Michael Hartogs was Senior Vice President and Division Counsel of QTL from 

October 2006 until 2012, and was Vice President and Division Counsel of QTL from June 2005 

until February 2012. He held roles in Qualcomm’s Corporate Legal department when since he 

joined the company in 1999. 

131. Irwin Jacobs was a co-founder of Qualcomm in 1985. He has served as President, 

Chief Executive Officer and Chairman of the company. He left his role as Chief Executive 

Officer in 2005 and retired from Qualcomm in 2009. 

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

2009 to March 2014, as Executive Chairman of the Board of Directors from March 2014 to 

March 2018. Mr. Jacobs also served as a Director from June 2005 to March 2018. He served as 

Chief Executive Officer from June 2005 to March 2014. He began working at Qualcomm fulltime in 1990. 

133. Sanjay Jha was President of QCT from 2003 to 2008, as well as Chief Operating 

Officer of Qualcomm from 2006 to 2008. He also served as Executive Vice President of QCT 

from 2003 to 2006. He joined Qualcomm in 1994. 

134. Aliyar (Alex) Katouzian is Senior Vice President and General Manager of the 

Mobile Business Operations Unit at QTI. He joined Qualcomm in October 2002. 

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135. Eric Koliander is Vice President, Sales, in QCT. He joined Qualcomm in 2006. 

136. Keith Kressin is Senior Vice President of Product Management at QTI, a position 

he has held since 2015. He has held various other roles in QTI and QCT since he joined 

Qualcomm in 2008. 

137. James (Jim) Lederer was Executive Vice President and General Manager of QCT 

from May 2009 until his retirement in January 2014. He previously held other roles at 

Qualcomm since he joined the company in 1997. 

138. Louis (Lou) Lupin was Senior Vice President, General Counsel, from 2000 to 

2006, and Executive Vice President and General Counsel of Qualcomm from 2006 to August 

2007. He served as Legal Consultant from August 2007 until his retirement in August 2014. He 

previously held other roles at Qualcomm. He joined Qualcomm in 1995. 

139. Durga Malladi is Senior Vice President of Engineering and General Manager of 

4G/5G at QTI. He has held this role since June 2018. He held various other roles, including 

Senior Vice President, Vice President of Engineering, Senior Director of Engineering, and Senior 

Engineer, since he started at Qualcomm in 1998. 

140. Roger Martin was Senior Vice President, Chief IP Strategist at Qualcomm, from 

October 2008 until his retirement in March 2018. From April 2003 to October 2008 he served as 

Vice President, Patent Counsel, and has held various other roles since he joined Qualcomm in 

1993. 

141. Sanjay Mehta is Senior Vice President for Compute Products, a role has held since 

July 2018. He previously was Senior Vice President of QCT China from 2016 to July 2018, and 

held various other roles in QCT since he started at Qualcomm in 2004. 

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

has held since March 2014. Prior to being Chief Executive Officer, he was President from 

November 2011 to March 2014, Chief Operating Officer from approximately November 2011 to 

December 2013, and prior to that he was Executive Vice President and President of QCT. He 

previously held various other roles at Qualcomm since he started with the company in 1994. 

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143. Kun Qian is Vice President of Business Development at QTL. He has been in this 

role since April 2017. Prior to that role, he was Vice President, Account Management, from 

November 2016 to April 2017. Before 2016 he was responsible for QCT’s China sales, and he 

held various other sales roles since he started at Qualcomm in 2004. 

144. Eric Reifschneider was Senior Vice President at QTL from March 2016 until his 

departure from the company in July 2016. He previously served as Senior Vice President and 

General Manager of QTL from April 2012, when he started at Qualcomm, to March 2016. 

145. Hank Robinson worked at QCT in various sales positions from approximately 

2000 through 2015. His last position was Vice President of Sales in QCT. 

146. Alexander (Alex) Rogers is Executive Vice President of Qualcomm and President 

of QTL, positions he has held since 2016. He previously held other roles in QTL and 

Qualcomm’s Corporate Legal department since joining the company in 2001. 

147. Abbaseh Samimi is Vice President of Strategic Market Analysis and Contracts at 

QTL, a position she has held since October 2008. She has held other roles at Qualcomm since 

joining the company in 1996. 

148. James (Jim) Thompson is Executive Vice President of Engineering and Chief 

Technology Officer of QTI. Previously, he was Senior Vice President of Engineering within 

QCT’s Engineering Management unit, and Mr. Thompson has overseen all of QCT engineering 

since 2004. He joined Qualcomm in 1992. 

149. Edward (Ed) Tiedemann, Jr., is Senior Vice President, Engineering within the 

Qualcomm Standards and Industry Organization unit at QTI. 

150. Jonathan Weiser is Senior Vice President and Division Counsel at QTI, positions 

he has held since June 2011. He joined Qualcomm in 1994. 

151. Serge Willenegger is Senior Vice President and General Manager of Industrial 

IOT in QTI’s Swiss Department business unit. He joined Qualcomm in 1995. 

152. David (Dave) Wise is Senior Vice President and Treasurer at Qualcomm, positions 

he has held since December 2015. He held various other roles since he joined Qualcomm in 

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1997. 

153. William (Will) Wyatt is Vice President, Finance at QTI, a position he began in 

October 2012. He joined Qualcomm in 2005. 

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Dated: November 29, 2018 

 Respectfully submitted, 

 

FEDERAL TRADE COMMISSION, 

/s/ Jennifer Milici 

Jennifer Milici 

J. Alexander Ansaldo 

Joseph R. Baker 

Elizabeth A. Gillen 

Daniel Matheson 

Mark Woodward 

Federal Trade Commission 

600 Pennsylvania Avenue, N.W. 

Washington, D.C. 20580 

Tel.: (202) 326-2912 

Fax: (202) 326-3496 

jmilici@ftc.gov 

Attorneys for Plaintiff Federal Trade Commission

CRAVATH, SWAINE & MOORE LLP, 

/s/ Gary A. Bornstein 

Gary A. Bornstein 

Yonatan Even 

Worldwide Plaza 

825 Eighth Avenue 

New York, NY 10019 

Tel: (212) 474-1000 

Fax: (212) 474-3700 

gbornstein@cravath.com 

yeven@cravath.com 

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Robert A. Van Nest 

Eugene M. Paige 

Justina Sessions 

KEKER, VAN NEST & PETERS LLP 

633 Battery Street 

San Francisco, CA 94111-1809 

Tel: (415) 391-5400 

Fax: (415) 397-7188 

rvannest@keker.com 

epaige@keker.com 

jsessions@keker.com 

 

Richard S. Taffet 

MORGAN, LEWIS & BOCKIUS LLP 

101 Park Avenue 

New York, NY 10178-0060 

Tel: (212) 309-6000 

Fax: (212) 309-6001 

richard.taffet@morganlewis.com 

Willard K. Tom 

MORGAN, LEWIS & BOCKIUS LLP 

1111 Pennsylvania Ave. NW 

Washington, DC 20004-2541 

Tel: (202) 739-3000 

Fax: (202) 739 3001 

willard.tom@morganlewis.com 

Geoffrey T. Holtz 

MORGAN, LEWIS & BOCKIUS LLP 

One Market, Spear Street Tower 

San Francisco, CA 94105-1126 

Tel: (415) 442-1000 

Fax: (415) 442-1001 

geoffrey.holtz@morganlewis.com 

Attorneys for Defendant Qualcomm Incorporated

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