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DECLARATION OF JENNIFER MILICI

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

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Jennifer Milici, D.C. Bar No. 987096

Joseph R. Baker, D.C. Bar No. 490802

Geoffrey M. Green, D.C. Bar No. 428392

Philip J. Kehl, D.C. Bar No. 1010284

Daniel Matheson, D.C. Bar No. 502490

Kenneth H. Merber, D.C. Bar No. 985703

Mark J. Woodward, D.C. Bar. No. 479537

Federal Trade Commission

600 Pennsylvania Avenue, N.W.

Washington, D.C. 20580

(202) 326-3695; (202) 326-3496 (fax)

jmilici@ftc.gov

Attorneys for Plaintiff Federal Trade Commission

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 MOTION TO EXCLUDE 

EXPERT TESTIMONY OF PROFESSOR 

AVIV NEVO

REDACTED VERSION OF DOCUMENT

SOUGHT TO BE SEALED

Date: October 18, 2018

Time: 1:30 p.m.

Courtroom: 8, 4th Floor

Judge: Hon. Lucy H. Koh

Case 5:17-cv-00220-LHK Document 790-1 Filed 08/30/18 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 attorney employed by the U.S. Federal Trade Commission (“FTC”). 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 motion to exclude 

expert testimony of Professor Aviv Nevo. 

3. Attached as Exhibit 1 is a true and correct copy of excerpts from the Rebuttal 

Report of Professor Aviv Nevo, Ph.D., dated June 28, 2018, and designated Highly 

Confidential—Attorneys’ Eyes Only by Qualcomm. 

4. Attached as Exhibit 2 is a true and correct copy of excerpts from the deposition of 

Aviv Nevo, which took place on August 10, 2018, and was designated Highly Confidential—

Attorneys’ Eyes Only by Qualcomm. 

5. Attached as Exhibit 3 is a true and correct copy of QAPPCMSD10051179, 

, designated Highly Confidential—

Attorneys’ Eyes Only by Qualcomm and produced to the Federal Trade Commission on June 22, 

2018. 

6. Attached as Exhibit 4 is a true and correct copy of QAPPCMSD00009236, 

, and designated Highly Confidential—

Attorneys’ Eyes Only by Qualcomm. 

7. Attached as Exhibit 5 is a true and correct copy of QAPPCMSD10052189, 

, designated Highly Confidential—

Attorneys’ Eyes Only by Qualcomm and produced to the Federal Trade Commission on June 28, 

2018. 

Case 5:17-cv-00220-LHK Document 790-1 Filed 08/30/18 Page 2 of 3
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DECLARATION OF JENNIFER MILICI

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

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8. Attached as Exhibit 6 is a true and correct copy of Q2017MDL1_03114062, 

, and designated Highly Confidential—Attorneys’ Eyes Only by 

Qualcomm.

9. Attached as Exhibit 7 is a true and correct copy of Q2017MDL1_02929368, 

, and 

designated Highly Confidential—Attorneys’ Eyes Only by Qualcomm.

10. Attached as Exhibit 8 is a true and correct copy of excerpts from the Rule 

30(b)(6) deposition of Qualcomm, through Fabian Gonell of Qualcomm, which took place on 

April 20, 2018, and was designated Highly Confidential—Attorneys’ Eyes Only by Qualcomm.

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

Executed this 30th day of August, 2018, in Washington, DC. 

 /s/ Jennifer Milici

JENNIFER MILICI

Case 5:17-cv-00220-LHK Document 790-1 Filed 08/30/18 Page 3 of 3