| Expert Report of Thomas Austin Gafford dated Jan. 16, 2002. |
| Expert Report of Joseph V. Colaianni dated Jan. 22, 2002. |
| Expert Witness Report of Larry S. Nixon Pursuant to Fed.R.Civ.P. Rule 26(a)(2)(b) dated Mar. 4, 2002. |
| Expert Report of Dr. Sharad Malik Regarding Invalidity dated Mar. 4, 2002. |
| Linear Corporation's Identification of Prior Art dated Jan. 22, 2002. |
| Respondents Lynx Industries, Inc., Napoleon Spring Works, Inc., and Guardian Access Corporation's Identification of the Prior Art dated Jan. 11, 2002. |
| Respondent Martec Access Products, Inc., Identification of Prior Art dated Jan. 11, 2002. |
| Respondent Wayne-Dalton Corporation's Identification of Prior Art dated Jan. 11, 2002. |
| Assembler Language Programming: The IBM System 360, George Struble; Addison-Wesley Publishing 1971, pp. 148-151. |
| Introduction to Microcomputers and Microprocessors, Arpad Barna and Dan Porat; John Wiley & Sons, Inc. 1976; p. 18. |
| Microprocessor Software; Max Schindler 1980 pp. 65, 67. |
| The 8086 Family User Manual; Intel Corporation 1980 at 2-35. |
| The following Litigation Documents are cited herewith. |
| Respondent Wayne-Dalton Corp.'s Answer to Complaint and Notice of Investigation dated Aug. 6, 2001. |
| Respondents Lynx Industries, Inc., Napoleon Spring Works, Inc., and Guardian Access Corporation's Response to Verified Complaint Under Section 337 of the Tariff Act of 1930, as Amended, and Affirmative Defenses dated Aug. 8, 2001. |
| Guardian Access Corporation's Responses to Chamberlain's First Set of Interrogatories (Nos. 1-36) dated Aug. 17, 2001. |
| Lynx's Responses to chamberlain's First Set of Interrogatories (Nos. 1-34) dated Aug. 17, 2001. |
| Napoleon's Responses to Chamberlain's First Set of Interrogatories (Nos. 1-34) dated Aug. 17, 2001. |
| Respondent Innovative Home Products, Inc.'s Responses to First Set of Interrogatories from Complainant Chamberlain dated Aug. 31, 2001. |
| Linear Corporation's Responses to Chamberlain's First Set of Interrogatories dated Sep. 6, 2001. |
| Respondent Innovative Home Products Inc.'s Response to Amended Complaint and Notice of Investigation dated Sep. 7, 2001. |
| Verified Declaration of Wayne-Dalton Corp. dated Sep. 7, 2001. |
| Respondent Linear Corporation's Amended Response to the Amended Complaint Under Section 337 of the Tariff Act of 1930, as Amended, and Affirmative Defenses dated Sep. 12, 2001. |
| Respondent Innovative's Responses to the Commission Investigative Staff's First Set of Requests for the Production of Documents and Things to Respondents dated Sep. 14, 2001. |
| Verified Declaration of Innovative Home Products, Inc. dated Sep. 18, 2001. |
| Napoleon's Supplemental Response to Chamberlain's Interrogatory No. 9 dated Oct. 3, 2001. |
| Linear Corporation's Second Supplemental Response to Chamberlain's Interrogatory No. 13 and First Supplemental Response to Chamberlain's Interrogatory No. 7 dated Oct. 10, 2001. |
| Linear Corporation's First Supplemental Responses to Chamberlain's Interrogatories Nos. 8 and 12 dated Oct. 30, 2001. |
| Order No. 8: Denying Complainant's Motion to Set a Maximum Number of Interrogatories dated Nov. 21, 2001 (11 pages). |
| Respondent Wayne-Dalton Corp.'s Answers and Objections to the Third Set of Interrogatories from Chamberlain to Respondent Wayne-Dalton Corporation dated Nov. 26, 2001 (18 pages). |
| Linear Corporation's First Supplemental Responses to Chamberlain's Interrogatories Nos. 1 and 2 dated Nov. 27, 2001 (7 pages). |
| Commission Investigative Staff's First Set of Interrogatories to Respondent Computime dated Nov. 28, 2001 (14 pages). |
| Microchip Technology Incorporated's Petition for Review of Initial Determination Concerning Motion for Intervention and Statement of Reasons Supporting Limited Intervention by Microchip dated Nov. 28, 2001 (13 pages). |
| Linear Corporation's First Set of Requests for Admission to Complainant Chamberlain dated Nov. 30, 2001 (19 pages). |
| Complainant Chamberlain's Supplemental Answer to Respondents Napoleon et al.'s Interrogatory No. 1 dated Nov. 30, 2001 (7 pages). |
| Wayne-Dalton Corp's Supplemental Answers and Objections to Certain of Chamberlain's Interrogatories dated Dec. 3, 2001 (22 pages). |
| Defendant Interlogix, Inc.'s Answer, Affirmative Defenses, and Counterclaims dated Nov. 2, 2001 (28 pages). |
| Defendant Interlogix, Inc.'s First Set of Requests for Admission to Plaintiff the Chamberlain Group, Inc. dated Nov. 13, 2001 (51 pages). |
| Chamberlain's Reply to Interlogix's Counterclaims dated Nov. 27, 2001 (21 pages). |
| Defendant's Motion for Leave to File Defendant's Supplemental Brief Opposing Plaintiff the Chamberlain Group, Inc's Motion for Sanctions dated Dec. 3, 2001 (35 pages). |
| Notice of Decision by U.S International Trade Commission dated Nov. 13, 2001 (3 pages). |
| Notice of Initial Determination by ALJ on Remand from U.S. International Trade Commission dated Nov. 21, 2001 (3 pages). |
| Verified Declaration of Wayne-Dalton Corp. dated Nov. 9, 2001 (1 page). |
| Wayne-Dalton Corp.'s Answers and Objections to Chamberlain's First Set of Interrogatories dated Nov. 9, 2001 (16 pages). |
| Chamberlain's Answers to Wayne-Dalton's First Set of Interrogatories dated Nov. 28, 2001 (11 pages). |
| Answer, Affirmative Defenses and Counterclaim to Amended Complaint dated Nov. 16, 2001 (14 pages). |
| First Set of Interrogatories from Chamberlain to Pittway Corporation dated Nov. 21, 2001 (8 pages). |
| Amended Answer, Affirmative Defenses and Counterclaim to Amended Complaint dated Nov. 21, 2001 (13 pages). |
| International Publication No. WO 85/01980 dated May 9, 1985, to Pinnow. |
| The following Litigation Documents are cited herewith. |
| Chamberlain's Answer to Third Amended Complaint for Declaratory Judgment and Counterclaim dated Mar. 15, 2000 (15 pgs.). |
| No Commercial Offer for Sale: Shindler's Deposition—pp. 385-386, Wilmott Deposition—pp. 348-353, Lovegrove Deposition—pp. 77-91, Schorling Deposition—pp. 74-79, 84-101, 103-123. |
| Demonstration of Prototype GDO Without Capability to Learn Multiple Transmitters: Schindler Deposition—pp. 173-180, 184-188, 353-362, 382-384, 386-389, Wilmott Deposition—pp. 330-348, 353-356, 430-434, 436-440, 452-455, 487-492, Schorling Deposition—pp. 102-123. |
| Documents: Deposition Exhibits 117, 159, 161, 162, 120 and 191. |
| “Remote Security System”, R. Kath et al., IBM Technical Disclosure Bulletin, vol. 16, No. 7 Dec. 1973, pp. 2427-2428. |
| MOS Databook from National Semiconductor, pp. 1-25-3-64. |
| In connection with the pending litigation, The Chamberlain Group, Inc. v. Lynx Industries, Inc. and Napoleon Spring Works, Civil Action No. 00 CV 0454, in the U.S. District Court for the Northern District of Illinois Eastern Division, the following documents are submitted herewith. |
| Defendant Lynx Industries, Inc. and Napoleon Spring Works, Inc. Answer in Opposition to Plaintiff Chamberlain's Motion for a Preliminary Injuction dated Nov. 30, 2000. |
| Reply Memorandum in Support of Chamberlin's Motion for Preliminary Injuction dated Dec. 15, 2000, which includes the following Exhibits. |
| Ex. 15—Second Declaration for Dr. V. Thomas Rhyne. |
| Ex. 17—Intro. to Microprocessors: Software, Hardware, Programming. |
| Ex. 18—Transcript Depositon of Wayne Schindler, vol. IV, pp. 393-398, 435-440, 483-488, 519-524, 537-554. |
| Ex. 19—Letter dated May 26, 2000 from David M. Frischkorn (for Lynx Industries) to Karl Fink (for Chamberlain Group, Inc.). |
| Ex. 20—Letter dated Jun. 14, 2000 from A. Blair Hughes (for Lynx Industries) to Karl Fink (for Chamberlain Group, Inc.). |
| Defendants' Supplemental Brief in Support of Its Motion for Summary Judgment of Non-Infringement and Its Opposition to Chamberlain's Motion for Preliminary Injuction dated Feb. 12, 2001, which includes the following Exhibits. |
| Ex. A—Copy of U.S. Ct. of Appeals, Federal Circuit case: Festo Corporation v. Shoketsu Kinzoku Kogyo Kabushiki Co., Ltd. |
| Ex. B—File History of U.S. Pat. No. 4,750,118 dated Jun. 7, 1988, Heitschel et al. |
| Ex. C—Comparison of Originally filed “Memory Selection Switch” Claim Element to Issued Claims Showing Narrowing Amendments. |
| Defendants' Supplemental Brief Opposing Plaintiff's Motion for Preliminary Injuction dated Feb. 22, 2001, which includes the following Exhibits. |
| Ex. A—Copy of Overhead Door's Emergency Motion for Judgment as a Matter of Law as to Inequitable Conduct . . . (in Overhead Door Corporation and GMI Holdings, Inc. v. The Chamberlain Group, Inc.). |
| Ex. B—Office Action dated Jun. 13, 1990 in Heitschel et al. S.N. 07/398,379. |
| Ex. C—Amendment and Request for Reconsideration dated Oct. 17, 1990 in Heitschel et al. S.N. 07/398,379. |
| Ex. D—Transcript of Telephonic Conference Before the Honorable Sidney A. Fitzwater, U.S. District Judge (in Overhead Door Corporation and GMI Holdings, Inc. v. The Chamberlain Group, Inc.). |
| Chamberlain's Supplemental Reply Memorandum in Support of Chamberlain's Motion for Preliminary Injunction dated Mar. 13, 2001, which includes the following attachments and Exhibits: F & G Scrolling v. IBM, MPEP, Seventh Edition, 715.02 (2000). |
| Ex. 1—Copy of the four claims contained in the Chamberlain application filed Aug. 24, 1989 to reissue the '118 patent. |
| Ex. 2—First Office Action dated Jun. 13, 1990 in Heitschel et al. S.N. 07/398,379. |
| Ex. 3—Examiner Interview Summary Record dated Sep. 23, 1990. |
| Ex. 4—Amendment and Request for Reconsideration dated Oct. 17, 1990. |
| Ex. 5—A) Declaration of Wayne Schindler Under 37 C.F.R. § 1.31 dated Oct. 3, 1990, B) Declaration of Colin Wilmott Under 37 C.F.R. § 1.131 dated Oct. 15, 1990, C) Declaration of Carl Heitschel Under 37 C.F.R. § 1.131 dated Oct. 1, 1990, D) Diagram dated Jul. 17, 1984, E) Chamberlain Inter-House Correspondence: Minutes of 1984 GDO Meeting and New Electronic Products, F) Chamberlain Inter-House Correspondence: Proposed Up GDO. |
| Ex. 6—Amendment dated Oct. 22, 1992. |
| Ex. 7—PTO-1449 Form, signed and dated Feb. 21, 1995 by Examiner Ruggiero. |
| Ex. 8—Decision on Appeal of Carl Heitschel, Colin Willmott, and Wayne Schindler in Appeal No. 1999-0880. |
| Ex. 9—a) Transcript Depos. of Wayne Schindler, pp. 2-5, 62-69, 393-398, 531-536 and Transcript Depos. of Colin Wilmott p. 191-196, 311-316 (both in Overhead Door v. Chamberlain) b) Depos. of Colin Wilmott dated Dec. 13, 1996, pp. 1-8, 160-167, 167-173, 191-196, 323-328. |
| Ex. 10—Suppl. Expert Report of Dr. V. Thomas Rhyne (in Overhead Door v. Chamberlain). |
| Ex. 11—Third Suppl. to Expert Witness Report of Edward G. Fiorito (in Overhead Door v. Chamberlain). |
| Ex. 12—Chamberlain's Suppl. Answers to Interrogatories (in Overhead Door v. Chamberlain). |
| Ex. 13—Chamberlain's Proposed Findings of Fact and Conclusions of Law With Respect to Inequitable Conduct (in Overhead Door v. Chamberlain). |
| Ex. 14—Letter dated Sep. 29, 1990 to Scott Clark at Chamberlain from Richard B. Wakely (in Overhead Door v. Chamberlain). |
| Ex. 15—Copy of Office Action dated Dec. 24, 1990. |
| Lynx Industries Inc. and Napoleon Spring Works, Inc.'s First Amended Answer and Counterclaims to the First Amended Complaint dated Mar. 13, 2001. |
| In connection with the pending litigation, Overhead Door Corporation and GMI Holdings, Inc. v. The Chamberlain Group, Inc., Civil Action No. 3:95-CV-1648-D, in the U.S. District Court for the Northern District of Texas, Dallas Division, the following documents are submitted herewith. |
| Third Amended Complaint for Declaratory Judgment dated Mar. 1, 2000. |
| Expert Report of A. Sidney Katz dated Aug. 1, 2000, which includes the following Exhibits. |
| Ex. A—Curriculum Vitae of A. Sidney Katz. |
| Ex. B—List of Cases in which A. Sidney Katz has served as a Patent Expert. |
| Expert Report of M. Ray Mercer, Ph.D. dated Aug. 1, 2000, which includes the following Exhibits. |
| Ex. A—Curriculum Vitae of M. Ray Mercer. |
| Ex. B—List of Previous Expert Witness Work of M. Ray Mercer. |
| Ex. C—Sources Consulted. |
| Plaintiff's Notice of Videotaped Depositions dated Aug. 30, 2000. |
| Fourth Amended Complaint for Declaratory Judgment dated Aug. 31, 2000. |
| Expert Report of Joseph C. McAlexander dated Sep. 18, 2000, which includes the following Exhibits. |
| Ex. A—Detailed Expert Report of Joseph C. McAlexander on the Re. 35,364 Patent. |
| Ex. A.1—Claims of Chamberlain's Re. 35,364 Patent. |
| Ex. B—Documents Relied Upon. |
| Ex. C—Curriculum Vitae of Joseph C. McAlexander. |
| Ex. D—List of Cases in which Joseph C. McAlexander has testified as an expert. |
| Ex. E—Compensation. |
| Rebuttal Expert Report of A. Sidney Katz dated Sep. 18, 2000. |
| Plaintiff's Second Supplemental Responses to Defendant's Interrogatories Nos. 1-3, 14 and 20 dated Nov. 2, 2000. |
| Plaintiff's Second Supplemental Notice Pursuant to 35 U.S.C. § 282 dated Nov. 3, 2000. |
| In connection with the pending litigation, The Chamberlain Group, Inc. v. Innovative Home Products, Inc. Civil Action No. 00-C-0360, in the U.S. District Court for the Northern District of Illinois Eastern Division, the following documents are submitted herewith. |
| Innovative's Further Supplement Response to Chamberlain's Interrogatory No.'s 1, 2 and 5 and Notice of Prior Art Under 35 U.S.C. § 282 date Nov. 20, 2000. |
| Innovative's Fourth Supplemental Answers to Chamberlain's Contention Interrogatories dated Dec. 15, 2000. |
| Defendant's Response to Plaintiff's Third Set of Interrogatories dated Mar. 21, 2001. |
| Articles and German Opposition Materials. |
| Meyer-Staufenbiel, Torsten. “Garagentoantrieb mit Funkfernsteuerung”, pp. 115-117, 1975. |
| Alltronik Opposition Brief of Aug. 7, 1990, (with translation), corresponding to German Patent No. 36 25 555 including. |
| a) Exhibit E4, Prior Publication and Prior Public Use of Corresponding Transmitter/Receiver System. |
| b) A corresponding Description. |
| c) A Second Corresponding Description. |
| d) Two invoices. |
| e) An Illustration by the Opposer. |
| Dorma Opposition Brief of Aug. 8, 1990 of corresponding to German Patent No. 36 25 555. This includes eight (8) Exhibits which are identified in German as follows. |
| a. Bedienungs—und Einbauanweisung für den Multisender S 43-25 (Drunckschrift 102 der Fa. Th. Düppe KG in Essen). |
| b. Schreiben von 5. März an das FTZ in Darmstadt. |
| c. Bedienungsanleitung für UHF-Funksteurerung F 43 vom 05.09.1984. |
| d. Prospekt der Fa. Düppe (Druckschrift Nr. 63—Tormatic macht das Tor auf). |
| e. Prospekt der fa. Düppe von Apr. 1983—Tormatic UHF Funksteuerung. |
| f. Prospekt der Fa. Düppe, Title: Tormatic öffnet alle Tore. |
| g. Der Elektroniker, Heft 11 von Nov. 1981, Seite 11-19. |
| e. Elektronik 1975. Heft 10, Seite 104-105 (einfache Fernsteuerung für 9 Kanäle). |
| Pp. 36 and 37 of an undated dealer reference manual for the AT&T Security System 8000. |
| Installation And Operation Manual SS-32 Supervised Security System, 1984. |
| IEEE Standard Dictionary of Electrical and Electronic Terms, Second Edition, Frank Jay editor-in-chief, Wiley-Interscience, 1977, pp. 324-325, 377-378, 384, 500 and 694. |
| U.S. Pat. No. 4,692,762 corresponds to EP 0 099 762 A1 and provides a concise explanation of its relevance. U.S. Pat. No. 4,750,118 corresponds to EP 0 319 781 A2 and DE 37 41 324 C2 and provides a concise explanation of their relevance. |
| Japanese Patent Office Translation of Japanese Patent Application Disclosure No. Sho 55-20830 to Tomoma, laid-open Feb. 14, 1980. |
| Japanese Patent Office Translation of Japanese Patent Application Disclosure No. Sho 59-80872 to Okuyama et al., laid-open May 10, 1984. |
| A copy and translation of a Japanese Patent Office action dated Oct. 20, 1992, received in a Japanese patent application related to the instant application and providing a concise explanation of the relevance of JP 55-114771 and JP 59-80872. |
| Translation of pertinent portions of JP 55-114771, (indicating that U.S. Pat. No. 4,328,540 substantially corresponds to this Japanese patent). |
| Derwent WPI Acc. No. 85-136225 provides an English abstract of EP 0 143 309 A2. |
| Derwent WPI Acc. No. 86-332914 provides an English abstract of EP 0 212 050 A2. |
| Derwent WPI Acc. No. 90-369740 provides an English abstract of EP 0 401 673 A1. |
| Derwent WPI Acc. No. 93-296664 provides an English abstract of EP 0 561 361 A1. |
| Derwent WPI Acc. No. 93-312974 provides an English abstract of EP 0 563 517 A1. |
| Derwent WPI Acc. No. 79-D6700B provides an English abstract of DE 27 46 532 A1. |
| Derwent WPI Acc. No. 80-G1895C provides an English abstract of DE 28 56 337 A1. |
| Derwent WPI Acc. No. 81-D1971D provides an English abstract of DE 29 39 589 A1. |
| Derwent WPI Acc. No. 81-B6887D provides an English abstract of DE 29 41 394 A1. |
| Derwent WPI Acc. No. 90-36974D provides an English abstract of DE 39 18 131 C2. |
| Special Master's Second Amended Report and Recommendation on Plaintiff's Motion for Summary Judgement of Patent Validity under 35 U.S.C. §103, filed Jan. 16, 1998, and Exhibits 1-3 thereto. |
| Special Master's Report for Summary Judgment of Infringement, filed Jan. 8, 1998, and Exhibits 1 and 3-9 thereto (certain portions of this report have been redacted and Exhibit 2 has been excluded, as being confidential pursuant to a protective order and cannot be disclosed except by court order). |
| Special Master's Report and Recommendation on Plaintiff's Motion for Partial Summary Judgement of Patent Invalidity under U.S.C. §251, filed Dec. 10, 1997, and Exhibits 1-11 thereto. |
| Special Master's Report and Recommendation on Plaintiff's Motion for Partial Summary Judgement of Assignor Estoppel, filed Dec. 12, 1997, and Tabs 2, 3, 5, 17, and 18 of Exhibit A and Exhibit C thereto (certain portions of this Report have been redacted and Exhibits A (including Tabs 1, 4, and 16) and b have been included, as being confidential pursuant to a protective order and cannot be disclosed except by court order). |
| Second Amended Complaint for Declaratory Judgment, filed Feb. 17, 1998, and Exhibits A-G thereto. |
| Plaintiff's Supplemental Notice Pursuant to 35 U.S.C. §282, filed May 18, 1998. |
| Letter from Kenneth R. Glaser to John F. Flannery dated Mar. 31, 1997 (redacted to delete references to the litigation). |
| Order of Apr. 30, 1998 adopting the Special Master's Reports and Recommendations. |
| Defendant-Appellant's Appeal Brief dated Aug. 24, 1998. |
| Plaintiff's-Appellees Appeal Brief dated Oct. 8, 1998. |
| Appellant's Reply Brief dated Oct. 26, 1998. |
| Opinion announcing Judgment of the Court dated Oct. 13, 1999. |
| Errata Sheet for the Opinion Announcing Judgement of the Court dated Oct. 15, 1999. |