EXHIBIT C 

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DEFENDANT QUALCOMM INCORPORATED’S WITNESS LIST

Defendant Qualcomm Incorporated (“Qualcomm”) discloses its list of witnesses, 

including a summary of each witness, that it may call at trial, other than for impeachment or 

rebuttal, identifying which witnesses it expects to call live and which it expects to call by 

deposition. Qualcomm reserves the right to: (1) add or remove witnesses or deposition testimony 

as necessary, including, but not limited to, in response to witness testimony, exhibits or other 

evidence that the Federal Trade Commission (“FTC”) may proffer; (2) call witnesses or use 

deposition testimony that may be necessary to lay the foundation for the admissibility of evidence 

if the Parties are unable to agree to the admissibility of such evidence; (3) call additional 

witnesses or use deposition testimony not on this list for the purposes of rebuttal or impeachment; 

and (4) call any witness identified by the FTC on its live or by-designation witness lists or use 

any deposition testimony designated by the FTC. By including witnesses on its lists, Qualcomm 

assumes no obligation to call or make available any witness at trial.

In the event that a witness from whom Qualcomm anticipates offering live testimony is 

unavailable to testify at trial, Qualcomm reserves the right to use deposition testimony given by 

such witness. For witnesses as to which Qualcomm currently believes it to be reasonably possible 

that the witness will not be available for trial and not within 100 miles of the courthouse, 

Qualcomm has listed the witness both as a live witness and as a witness by deposition. In the 

event that the FTC objects to the use of Qualcomm’s deposition designations at trial, Qualcomm 

reserves the right to call the deponent to provide live testimony. 

Qualcomm further reserves the right to update the subjects on which the persons identified 

as witnesses may testify based on new information (including any newly produced documents); 

and to question the persons identified herein on any topics on which that person testified in a 

deposition or investigational hearing, or regarding any matter that is discussed in any document to 

which that person had access and that is designated as an exhibit by either party.

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Live Witnesses

Derek Aberle was President of Qualcomm Incorporated until January 2018. 

Mr. Aberle may testify about Qualcomm’s licensing program, practices and negotiations, 

Qualcomm’s business relationships with cellular device makers, Qualcomm’s corporate strategy,

and any other issues addressed in Mr. Aberle’s deposition or investigational hearing or any 

documents or data introduced into evidence by Qualcomm or the FTC as to which he has 

knowledge.

Baaziz Achour is Senior Vice President of Engineering at Qualcomm 

Technologies, Inc. (“QTI”). He has been in this role for approximately ten years, and has worked 

at Qualcomm since 1993. Mr. Achour may testify regarding modem chip engineering, 

Qualcomm’s contributions to and innovations relating to cellular and non-cellular technologies, 

Qualcomm’s research and development efforts, Qualcomm’s investments with respect to 

particular technologies, projects, and/or customers, and any other issues addressed in 

Mr. Achour’s deposition or documents or data introduced into evidence by Qualcomm or the FTC 

as to which he has knowledge.

Jeffrey Andrews is the Cullen Trust for Higher Education Endowed Professor in 

the Electrical and Computer Engineering Department of the University of Texas at Austin. 

Dr. Andrews may testify about the opinions disclosed in his expert reports and deposition.

Steven Altman was Vice Chairman of Qualcomm Incorporated until January 

2014. Mr. Altman may testify about Qualcomm’s licensing program, practices and negotiations, 

Qualcomm’s business relationships with cellular device makers, Qualcomm’s corporate strategy, 

and any other issues addressed in Mr. Altman’s deposition or documents or data introduced into 

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

Cristiano Amon is President of Qualcomm, and responsible for oversight of 

Qualcomm’s semiconductor business. He was previously Executive Vice President and President 

of Qualcomm CDMA Technologies (“QCT”). 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 

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

Mr. Amon may testify regarding Qualcomm’s research and development efforts, Qualcomm’s 

contributions to and innovations relating to cellular and non-cellular technologies, Qualcomm’s 

modem chip sales, competition for sales of modem chips, Qualcomm’s business relationships 

with OEMs, specific negotiations relating to the sale of chips, Qualcomm’s investments with 

respect to particular technologies, projects, and/or customers, and any other issues addressed in 

Mr. Amon’s deposition or investigational hearing or documents or data introduced into evidence 

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

Lorenzo Casaccia is Vice President of Technical Standards of Qualcomm Europe 

Inc. Mr. Casaccia may testify about Qualcomm’s role and history in the development of cellular 

standards and the cellular standardization process, and any other issues addressed in 

Mr. Casaccia’s depositions or documents or data introduced into evidence by Qualcomm or the 

FTC as to which he has knowledge. Mr. Casaccia has been designated as a fact witness who may 

give expert opinions in this case and may testify about the opinions and topics disclosed in his 

expert disclosure, served pursuant to Fed R. Civ. P. 26(a)(2)(C), and depositions.

Liren Chen is Senior Vice President of Engineering and Legal Counsel at QTL. 

Mr. Chen may testify about Qualcomm’s contributions to and innovations relating to cellular and 

non-cellular technologies, Qualcomm’s practices regarding patent prosecution and licensing, the 

scope and history of Qualcomm’s patent portfolio, including its patented cellular technologies and 

patented non-cellular technologies, and any other issues addressed in Mr. Chen’s deposition or 

documents or data introduced into evidence by Qualcomm or the FTC as to which he has 

knowledge.

Tasneem Chipty is the Founder and Managing Principal at Matrix Economics. 

Dr. Chipty is an economist who has studied antitrust and competition economics, econometrics, 

and industrial organization for over twenty years. Dr. Chipty may testify about the opinions 

disclosed in her expert report and deposition.

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

QTL. Mr. Gonell may testify about Qualcomm’s licensing program, practices and negotiations, 

Qualcomm’s business relationships with cellular device makers and patent licensing pools and 

platforms, and any other issues addressed in Mr. Gonell’s depositions or investigational hearing, 

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

he has knowledge.

Michael Hartogs was Senior Vice President and Division Counsel at QTL until 

January 2012. Mr. Hartogs may testify about Qualcomm’s licensing program, practices and 

negotiations, Qualcomm’s business relationships with cellular device makers, and any other 

issues addressed in Mr. Hartogs’s deposition or documents or data introduced into evidence by 

Qualcomm or the FTC as to which he has knowledge.

Bertram Huber is a Principal of IP*SEVA and is a Lecturer at the University of 

Tübingen/Germany on Laws of IPRs, International IP Strategy and Management and License 

Agreements/Licensing Law. He has extensive negotiation and technology licensing experience, 

and has participated in the elaboration of IPR/patent policies at ETSI. Dr. Huber may testify 

regarding the subject matter of his expert report.

Irwin Jacobs is the co-founder and former CEO, Chairman and Director of 

Qualcomm. Mr. Jacobs may testify about the founding of Qualcomm, the development and rollout of CDMA technology, Qualcomm’s fundamental contributions to cellular and non-cellular 

technologies, Qualcomm’s post-CDMA innovations, Qualcomm’s licensing program, practices 

and negotiations, any other issues addressed in his deposition, and any documents or data 

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

Chris Johnson is a partner at Bain & Company, where he has worked since 2010. 

Mr. Johnson may testify about work that Bain performed for Intel Corporation, and any issues 

addressed in his deposition or documents or data introduced into evidence by Qualcomm or the 

FTC as to which he has knowledge.

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Keith Kressin is Senior Vice President, Product Management at QTI. Mr. Kressin 

may testify about Qualcomm’s contributions to and innovations relating to cellular and noncellular technologies, Qualcomm’s product roadmap, competition for sales of modem chips, 

Qualcomm’s relationship with OEMs, and any other issues addressed in Mr. Kressin’s deposition 

or documents or data introduced into evidence by Qualcomm or the FTC as to which he has 

knowledge.

Louis Lupin was Legal Consultant for QTL until August 2014. Prior to that, 

Mr. Lupin was Executive Vice President and General Counsel of Qualcomm Incorporated until 

August 2007. Mr. Lupin may testify about Qualcomm’s licensing program, practices and 

negotiations, Qualcomm’s business relationships with cellular device makers, and any other 

issues addressed in Mr. Lupin’s deposition or documents or data introduced into evidence by 

Qualcomm or the FTC as to which he has knowledge.

Taraneh Maghame is Senior Director of Wireless Programs and Corporate 

Development at Via Licensing Corporation, and was a member of Apple’s patent licensing and 

strategy group from 2010 to 2016. Ms. Maghame may testify about Via Licensing’s licensing 

and business practices and any issues addressed in her deposition or documents or data introduced 

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

Durga Malladi is Senior Vice President Engineering and General Manager of 

4G/5G at QTI. Dr. Malladi may testify about Qualcomm’s research and development efforts and 

innovations, Qualcomm’s role in the development of cellular technologies and cellular standards, 

his patented inventions, and any other issues addressed in Dr. Malladi’s deposition or documents 

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

Robert Mansfield was the Senior Vice President of Hardware Engineering from 

fall 2005 to early 2012, and then was Senior Vice President of Technologies at Apple from 2012 

to 13. Mr. Mansfield 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, whether modem chip suppliers other than Qualcomm met Apple’s 

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technical and scheduling requirements for Apple cellular products from 2011 to 2014, and any 

other issues addressed in documents or data introduced into evidence by Qualcomm or the FTC as 

to which he has knowledge.

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 joined 

Qualcomm in 1994. Mr. Mollenkopf may testify about Qualcomm’s contributions to and 

innovations relating to cellular and non-cellular technologies, the development and 

commercialization of cellular technologies, competition for sales of modem chips, the rationale 

for and negotiation of various agreements with Apple, the superiority and differentiation of 

Qualcomm’s modem chip products, any other issues addressed in his deposition or investigational 

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

which he has knowledge.

Aviv Nevo is the George A. Weiss and Lydia Bravo Weiss University Professor at 

the Wharton School of Business and Department of Economics at the University of Pennsylvania. 

Professor Nevo is an economist who has studied antitrust and competition economics, 

econometrics, and industrial organization for over twenty years. Professor Nevo may testify 

about the opinions disclosed in his expert report and deposition.

Eric Reifschneider was Senior Vice President of QTL until July 2016. 

Mr. Reifschneider may testify about Qualcomm’s licensing program, practices and negotiations, 

Qualcomm’s business relationships with cellular device makers and any other issues addressed in 

Mr. Reifschneider’s deposition or investigational hearing or documents or data introduced into 

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

Alex Rogers is Executive Vice President of Qualcomm and President of QTL, 

positions he began in 2016. Mr. Rogers may testify about Qualcomm’s licensing program, 

practices and negotiations, Qualcomm’s recent licensing negotiations and programs, Qualcomm’s 

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relationships with OEMs, any other issues addressed in his deposition, and any documents or data 

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

Matthias Sauer held various positions at Infineon, including Director of Baseband 

Architecture, Head of Worldwide for Business Unit Feature Phone, and Senior Director for 

System Engineering for Business Line Smartphone and RF Engine, from 1998 to 2011. 

Mr. Sauer is now the Director of Cellular Systems at Apple. Mr. Sauer 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, whether 

modem chip suppliers other than Qualcomm met Apple’s technical and scheduling requirements 

for Apple cellular products from 2011 to 2016, and any other issues addressed in Mr. Sauer’s 

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

he has knowledge. Mr. Sauer may also testify about Infineon’s design, engineering, manufacture 

and sale of Infineon chipsets.

Mark Schankerman is Professor of Economics at the London School of 

Economics. Professor Schankerman is an economist who has specialized in intellectual property 

rights, innovation, university-technology transfer, industrial organization and emerging 

economics. Professor Schankerman may testify regarding the subject matter of his expert report.

Steve Schell was the Senior Director of Wireless Systems Architecture from June 

2005 to February 2015 at Apple. Mr. Schell 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, whether modem chip suppliers other than 

Qualcomm met Apple’s technical and scheduling requirements for Apple cellular products from 

2011 to 2016, and any other issues addressed in Mr. Schell’s deposition or documents or data 

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

Edward Snyder is the Indra K. Nooyi Dean and William S. Beinecke Professor of 

Economics and Management at the Yale School of Management. Dr. Snyder began his 

professional career as an economist with the U.S. Department of Justice’s Antitrust Division. He 

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earned a Ph.D. in Economics and an M.A. in Public Policy from the University of Chicago. 

Qualcomm expects Dr. Snyder will testify regarding the subject matter of his expert reports, 

including the modem chip industry and Apple’s and the CMs’ theories of antitrust harm.

James Thompson is Executive Vice President of Engineering and Chief 

Technology Officer of QTI. Previously, he was Senior Vice President of QCT, and 

Mr. Thompson has overseen all of QCT engineering since 2004. Mr. Thompson may testify 

about Qualcomm’s contributions to and innovations relating to cellular and non-cellular 

technologies, modem chip engineering, Qualcomm’s research and development efforts, 

Qualcomm’s investments with respect to particular technologies, projects, and/or customers, 

competition for sales of modem chips, and any other issues addressed in Mr. Thompson’s 

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

he has knowledge.

Godavarthi Varadarajan is the Senior Partner and Managing Director of Boston 

Consulting Group (“BCG”). Mr. Varadarajan may testify about BCG’s work relating to strategic 

alternatives under consideration by a special committee of Qualcomm’s Board of Directors in and 

around 2015 and any other issues addressed in Mr. Varadarajan’s deposition or investigational 

hearing or any subject raised by Qualcomm or the FTC at trial as to which Mr. Varadarajan has 

knowledge.

B.J. Watrous has been Chief IP Counsel at Apple since he began at the company 

in June 2011. Mr. Watrous may testify about Apple’s business relationship with Qualcomm, the 

practice within the cellular industry of licensing cellular SEPs and/or other patents, Apple’s 

licensing practices, and any other issues addressed in Mr. Watrous’s deposition or documents or 

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

Dirk Weiler has been Nokia’s Head of Standards Policy since 2017. He was 

previously a Vice President and Manager at Siemens AG, which Nokia acquired in 2006. From 

that point onwards, he became Head of Standards Management at Nokia. Mr. Weiler was Chair 

of ETSI’s IPR Special Committee from 2008 through November 2018; was a member of the 

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ETSI Board from 2008 to the present, serving ex officio from 2010 to 2014, and as chairman 

from 2014 to the present. He was chair of ETSI’s General Assembly, ETSI’s highest ranking 

governance body, from 2010 to 2014. Mr. Weiler may testify about cellular industry licensing 

practices, including Nokia’s licensing practices, the ETSI Intellectual Property Rights Policy, and 

any other issues addressed in Mr. Weiler’s deposition or documents or data introduced into 

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

Tim Williams is the Chief Executive Officer of Beach Technologies, LLC, a 

consulting firm focused on technology, intellectual property, and business consulting. 

Dr. Williams may testify about the opinions disclosed in his expert reports and deposition.

David Wise is Senior Vice President and Treasurer at Qualcomm, positions he has 

held since December 2015. Mr. Wise may testify about strategic alternatives under consideration 

by a special committee of Qualcomm’s Board of Directors in and around 2015, documents on the 

FTC’s exhibit list that he drafted, revised, or received, and any other issues addressed in Mr. 

Wise’s deposition or documents or data introduced into evidence by Qualcomm or the FTC as to 

which he has knowledge.

Testimony by Deposition

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

designated portions of his or her deposition testimony:

Derek Aberle was President of Qualcomm from 2014 until January 3, 2018, when 

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

company until April 2018. His prior roles at Qualcomm included Legal Counsel (2000-2005), 

General Manager of Licensing (2005-2011), and Group President of QTL (2011-2014).

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

relating to intellectual property at Samsung.

Steven Altman was President of Qualcomm from approximately 2005 to 2011, 

and Vice Chairman from approximately 2011 until his retirement in January 2014.

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Hermann Eul was corporate vice president and general manager of the Mobile 

and Communications Group at Intel Corporation until 2016, and had worked at Intel since 2011, 

after Intel acquired his former employer, Infineon.

John Grubbs is Senior Director of IP Transactions at BlackBerry.

Alex Hojin Kang is the former Director of Purchasing at Samsung Mobile, and 

was employed by Samsung from 1987 to 2016.

Sanjay Jha is the former CEO of GlobalFoundries and former chairman and CEO 

of Motorola Mobility. Mr. Jha was President of QCT from 2003 to 2008 and COO of Qualcomm 

from 2006 to 2008.

Chris Johnson is a partner at Bain & Company, where he has worked since 2010.

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

has worked at Intel since 1999.

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

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.

Taraneh Maghame is Senior Director of Wireless Programs and Corporate 

Development at Via Licensing Corporation, and was a member of Apple’s patent licensing and 

strategy group from 2010 to 2016.

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

President of Wireless Technology at Apple from 2008 to 2017.

Ranae McElvaine is Vice President and Deputy General Counsel of Intellectual 

Property at InterDigital, where she has worked as an in-house lawyer since 2008.

Christina Petersson has been Vice President of Intellectual Property Rights in 

Ericsson’s legal department since 2011. She was previously Senior Legal Counsel in the 

Intellectual Property Rights Legal Services group from 2003 to 2011.

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Ilkka Rahnasto is Vice President of Patent Licensing at Nokia. He previously 

served as an intellectual property lawyer at Nokia from 1997 to 2003, as Head of Intellectual 

Property from 2003 to 2010 and as Head of Legal for Nokia’s Smartphone Business from 2010 to 

2014.

Robert Rango is the former Executive Vice President and General Manager of 

Broadcom’s Mobile and Wireless Group. He held that position from 2011 to 2014. He also 

previously served as Vice President and General Manager of Broadcom’s Networking 

Infrastructure Group from 2002 to 2004, and as Executive Vice President and General Manager 

of the Wireless Connectivity Group from 2004 to 2011 (and Senior Vice President therein from 

2004 to 2005).

Spencer Shen has been the Chief Intellectual Property Officer for ZTE since 2016 

and previously served as ZTE’s Chief Licensing Officer.

Dirk Weiler has been Nokia’s Head of Standards Policy since 2017. He was 

previously a Vice President and Manager at Siemens AG, which Nokia acquired in 2006. From 

that point onwards, he became Head of Standards Management at Nokia. Mr. Weiler was Chair 

of ETSI’s IPR Special Committee from 2008 through November 2018; was a member of the 

ETSI Board from 2008 to the present, serving ex officio from 2010 to 2014, and as chairman 

from 2014 to the present. He was chair of ETSI’s General Assembly, ETSI’s highest ranking 

governance body, from 2010 to 2014.

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.

Martin Zander is Ericsson’s Vice President and Head of Strategic Initiatives and 

Eco-Systems. He assumed this role in 2017. He previously joined Ericsson in 2000 as Strategic 

Product Manager. In 2003, he became Product Marketing Manager, and in 2005, he became 

General Manager of Product Marketing. From 2006 to 2008, he served as Director of Product 

Management for Mobile Platforms, and from 2008 to 2009 as Director of Portfolio Management 

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and Technology. Between 2009 and 2011, he was ST-Ericsson’s Head of Portfolio Management. 

After ST-Ericsson dissolved, he rejoined Ericsson in 2015 as Vice President and Head of the 

Partnering & Strategy Program Office.

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