Affidavit

Beginning of Legal Text

CAUSE NO. 199 596 97

BEFORE ME, the undersigned authority, on this date personally appeared Evan Brown who, being by me first duly sworn, upon his oath deposed and stated as follows:

1. My name is Evan Brown. I am the Defendant in the above-captioned case. I am over 21 years of age, have never been convicted of a felony or a crime of moral turpitude and am otherwise competent to make this Affidavit. I have personal knowledge of the facts recited in this Affidavit, and they are all true and correct.

2. From 1970 to 1978, I was an undergraduate student at Texas A&M University and received a Bachelors of Science degree in Computer Science in 1978. While attending Texas A&M University, I worked as a computer programer for several university departments including the Data Processing Department (Computer Operator), Civil Engineering (Student Programmer for Dr. Ed Martinez), Texas Petroleum Research Center (Student Programer for Dr. Paul Crawford), Physics Department (Student Programmer for Dr. George Katawar) and Mechanical Engineering Department (Student Programmer for Dr. Swiki Anderson). Since my graduation, I have been employed by the Texas Engineering Extension Service as a programmer for the Center for Energy and Mineral Resources at Texas A&M University, Swiki Anderson Consulting, Texas Instruments, Time Energy Systems, Evan Brown Consulting and DSC Communications.

3. During my employment at Texas A&M University as a Student Programmer, I converted computer programs written in Control Data Corporation (CDC) Fortran to run on a IBM 360/65 OS-Rel-21 mainframe computer and later to Amdahl 470 SVS mainframe computer. I also converted Univac COBOL to IBM/Amdahl COBOL and later to IBM's PL/I programming language. Part of my work for Dr. Paul Crawford included re-writing a CDC Fortran program (BLKSOLV4) into IBM Assembly language to expand computational capacity, greatly reduce computation time and improve computational accuracy. Part of my work for the Mechanical Engineering Department under the direction of Dr. Swiki Anderson included converting the NECAP program written in CDC Fortran to IBM Fortran, integrating the NECAP with NBSLD program and writing an IBM Assembly Language front end to handle input data processing. My work on the NBSLD and NECAP programs was shared with the US Air Force Academy and required me to convert the programs back and forth between IBM and Boroughs. To help automate the conversion process between CDC, Univac, Boroughs and IBM computers, I wrote several conversion utilities in PL/I and IBM Assembly to handle the common conversion problems, leaving me to finish the final conversion problems by hand.

4. During a trip to El Paso in 1976, Jack Coats, who was working for El Paso Natural Gas Co. as a computer programmer, mentioned that their mainframe computer was busy running a simulator for an obsolete computer program. When I asked why they didn't just re-write the software for the obsolete computer program, Jack informed me that the obsolete computer program had passed extensive State Audits and his company didn't want to go through the time and expense of re-writing the computer program and going through the audit process again. This conversion planted the seed to my idea to automatically convert old obsolete computer programs into modem computer programming languages. I recognized the usefulness of my idea, but lacked the resources to develop and implement my idea at that time. I continued to re-think my idea over the years and try to find a way to implement my idea on my own.

5. During my employment at the Center for Energy and Mineral Resources (1978-1979) working under the direction of Dr. Swiki Anderson, I worked on the conversion of the "Building Loads and System Thermodynamics" (BLAST) program from the Civil Engineering Research Laboratory (CERL) in Champaign, Illinois which was written on a CDC Cyber 7600 computer in Fortran. The CERL software developers used a great deal of CDC Cyber 7600 machine dependent hardware code to improve performance. The machine dependent hardware code was not compatible with the IBM hardware and manual conversion of the code was not practical. I wrote an IBM PL/I program to convert the machine dependent hardware code from the CDC Cyber 7600 to IBM compatible code. Funding was terminated before the IBM PL/I conversion program was completed.

6. During my employment with Texas Instruments (1981-1983), I worked for the Energy Management Group under the direction of Kirby Nelson. I performed data collection and ran numerical simulation to evaluate energy savings. I also worked with the group to design and install control systems to help reduce energy consumption. While working with the control systems, I experimented with converting the machine executable code of the PM-550 (TI programmable controller) to the BASIC programming language. The conversion worked but TI never developed a controller that used the BASIC programming language so I dropped my conversion effort.

7. During my employment with Time Energy Systems (1983-1985), I worked under the direction of Tom Bell and with Roger Ansted to program industrial controllers. My work included the development of software/firmware for a Zilog (Z80) microprocessor controllers. The software/firmware I developed for the EIL controller hardware included a real time operating system, a BASIC programming language interpreter, upload/download facilities, alarm controls, modem control, reporting and diagnostics. I was able to utilize parts of my conversion idea in my implementation of the embedded BASIC interpreter.

8. As an independent consultant (1985-1987), I designed, built and programmed a single board Z80 microprocessor controller to control ice making machines for Turbo Refrigeration. I implemented a BASIC interpreter with specific functions to control refrigeration equipment. This implementation also utilize parts of my conversion idea.

9. I was hired by DSC Communications on April 21, 1987 into the position of Senior Member Technical Staff under the direction of Jinx Smith. My job assignment was to maintain the "Fault Isolation and Test" (FISO) subsystem of the Signal Transfer Point (STP) product. The FISO subsystem software was written entirely in Zilog Z8000 assembly language using cross development tools on a Digital Equipment Corporation VAX computer cluster. DSC hired me as an assembly language programmer to develop and maintain the FISO subsystem for the STP product and for no other stated purpose.

10. At no time during my employment with DSC was I assigned the job or task of developing a computer program to convert machine executable code to high level source. Prior to my employment with DSC, I have spent many years converting computer programs between different computer hardware platforms. Also, on several occasions prior to my employment with DSC, I have partially implemented automated conversion processes to handle computer hardware differences.

FURTHER AFFIANT SAITH NOT.

___________________________
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EVAN BROWN

Sworn and subscribed before me on this _1_ day of December, 1998, to certify which witness my hand and seal of office.

___________________________
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