`Case 1:11—cv—00797—RGA Document 113
`Filed 01/24/12 Page 1 of 2 Page|D #: 731
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`FastVDO LLC,
`
`Plaintiff,
`
`C.A. No. 11-797-RGA
`
`v.
`
`[FILED UNDER SEAL]
`
`Apple Inc., et al.,
`
`JURY TRIAL DEMANDED
`
` Defendants.
`
`DECLARATION OF PANKAJ TOPIWALA IN SUPPORT OF FASTVDO LLC’S
`ANSWERING BRIEF TO EASTMAN KODAK COMPANY’S MOTION TO
`DISMISS OR IN THE ALTERNATIVE TO SEVER AND TRANSFER
`
`I, Pankaj Topiwala, declare as follows:
`
`1.
`
`I have personal knowledge of the facts contained in this declaration, and
`
`could and would testify competently to these facts if called upon to do so.
`
`2.
`
`I submit this Declaration in support of FastVDO LLC’S (“FastVDO”)
`
`Answering Brief to Eastman Kodak Company’s (“Kodak”) Motion to Dismiss or, in the
`
`alternative, to Sever and Transfer.
`
`3.
`
`I am the President of FastVDO, a company I founded in 1998 (initially as
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`F astVideo, a Sole Proprietorship).
`
`I earned my Ph.D in mathematics in 1985 and worked
`
`in the defense industry on applied mathematical concepts and video compression related
`
`technologies before founding FastVDO. FastVDO’s business focuses on developing
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`video compression and transmission technologies.
`
`4.
`
`I hired Dr. Trac Tran as FastVDO’s first employee. Dr. Tran and I
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`worked on the development of the technology that is claimed in U.S. Patent No. RE
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`40,081 (the “FastVDO patent”) during the summer of 1998. This work was done
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`primarily in Westford, Massachussetts.
`
`5.
`
`FastVDO opened its office in Columbia, Maryland in 1999, as FastVideo
`
`
`
`Case 1:11-cv-00797-RGA Document 113 Filed 01/24/12 Page 2 of 2 PageID #: 732
`Case 1:11—cv—00797—RGA Document 113
`Filed 01/24/12 Page 2 of 2 Page|D #: 732
`
`LLC, and later changed its name to FastVDO LLC in 2002. FastVDO’s Columbia,
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`Maryland office was its primary place of business until the company was moved to
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`Florida in late 2011.
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`6.
`
`In April 2001, I presented a proposal to the ITU/Video Coding Experts
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`Group, then working on H.26L (what eventually became H.264), titled “A 16-bit
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`architecture for H.26L, treating DCT transforms with quantization,” in Austin, Texas.
`
`This proposal was authored by Jie Liang, Dr. Trac Tran, and myself. A copy of this
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`proposal is attached as Exhibit 1 to my declaration. FastVDO has been active in working
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`with the H.264 and other video encoding standards committees since making this
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`proposal in 2001.
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`7.
`
`FastVDO is a relatively small company that has between‘
`
`employees at any given time. FastVDO’s 1'eve:iLie
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`I declare under the laws of the United States of America that the foregoing is true
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`and correct to the best of my knowledge.
`
`Dated: January 13, 2012
`
`
`
`Pankaj Topiwala
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