3044

Case 5:05-cv-00334-RMW Document 3044 Filed 01/09/2009 Page 1 of 16
1 Attorneys Listed On Signature Page

2
8 IN THE UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION
10 RAMBUS INC., Case No. C 05-00334 RMW

11 Plaintiff, JOINT MANUFACTURERS’
v. REVISED WITNESS LIST FOR
12
JANUARY 19, 2009 TRIAL
HYNIX SEMICONDUCTOR INC., HYNIX
13 SEMICONDUCTOR AMERICA INC., HYNIX
Date: January 19, 2009
SEMICONDUCTOR MANUFACTURING
14 Courtroom: 6
AMERICA INC.,
Judge: Hon. Ronald M. Whyte
15
SAMSUNG ELECTRONICS CO., LTD.,
16 SAMSUNG ELECTRONICS AMERICA, INC.,
SAMSUNG SEMICONDUCTOR, INC.,
17 SAMSUNG AUSTIN SEMICONDUCTOR,
18 L.P.,
19 NANYA TECHNOLOGY CORPORATION,

NANYA TECHNOLOGY CORPORATION U.S.A.,
20
Defendants.
21
22
23
24
25
26
27
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

JOINT MANUFACTURERS’ WITNESS LIST 05-02298-RMW
1 RAMBUS INC., Case No. C 05-02298 RMW

2 Plaintiff,
3 v.
4 SAMSUNG ELECTRONICS CO., LTD.,

SAMSUNG ELECTRONICS AMERICA, INC.,
5 SAMSUNG SEMICONDUCTOR, INC.,
SAMSUNG AUSTIN SEMICONDUCTOR,
6
L.P.,
7
Defendants.
8 Case No. C 06-00244 RMW
RAMBUS INC.,
9
Plaintiff,
10
v.
11
MICRON TECHNOLOGY, INC. and MICRON
12 SEMICONDUCTOR PRODUCTS, INC.,
13 Defendants.
14
15
16
17
18
19
20
21
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23
24
25
26
27
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

JOINT MANUFACTURERS’ WITNESS LIST 05-02298-RMW
Pretrial Statement, Section F

1 Joint Witness List
2 Case Nos. 06-00244-RMW; 05-00334-RMW; 05-02298-RMW
3 Pursuant to the Court’s Standing Order Re: Pretrial Preparation, the Manufacturers
4 submit this list of “joint” witnesses. Joint witnesses are witnesses that more than one
5 Manufacturer expect to call live, or may call live to testify in their case in chief during the
6 January 2009 Patent Trial in the above captioned cases. This list does not include (1) rebuttal
7 witnesses, (2) witnesses to be called during any trial on willfulness, or (3) witnesses that may be
8 called only by playing or reading prior sworn testimony. The following witness list was drafted
9 based on the Manufacturers’ current expectations, and the Manufacturers reserve the right to call
10 or not to call any of these witnesses based on Rambus’s witness list, time allocations, resolution
11 of pretrial motions, or other change of circumstance. The Manufacturers expressly reserve the
12 right to play testimony from any listed witness that is unavailable pursuant to Federal Rule of
13 Civil Procedure 32(a)(4). The Manufacturers also reserve the right to use prior testimony in
14 addition to or as an alternative to live testimony, including any Rambus admissions, consistent
15 with Federal Rule of Civil Procedure 32 and any other applicable Federal Rule of Civil Procedure
16 or Federal Rule of Evidence. The Manufacturers currently expect to authenticate and/or establish
17 the admissibility of documents through live testimony of certain Rambus witnesses. Live
18 testimony from many of these witnesses may be avoided with appropriate stipulations from
19 Rambus regarding admissibility of documents.
20
21
22
23
24
25
26
27
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

JOINT MANUFACTURERS’ WITNESS LIST 1 05-02298-RMW
Liability Trial Witnesses

1
Intend to Call May Call
2
Richard Crisp Paul Anderson
3 Anthony Diepenbrock Andreas Bechtolsheim
Billy Garrett William Davidow
4 David Gustavson Mark Johnson
William Hoffman*1 Joel Karp
5 Joseph McAlexander Ilan Krashinsky
6 David Mooring Joe Macri
John P. Moussouris Jose Moniz
7 Neil Steinberg Earnest Powell
Howard Sussman Allen Roberts
8 Geoffrey Tate Gilbert Russell
Lester Vincent Hans Wiggers
9
10
Intend to call to establish admissibility of May call to establish admissibility of documents:
11 documents:2 Richard Barth
Craig Hampel Bruce Dunlevie
12 Desi Rhoden Charles Furnweger
Frederick Ware Harlan Lau
13 Michael McGowan
14 Kit Sang Tam
David Tuckerman
15 Steven Woo
Foreign language translators
16
17 Patent Exhaustion Witnesses

18
19 Graham Allan
Sharon Holt
20 Harold Hughes
David Mooring
21 Roy Weinstein3
22
23 1
Witnesses designated with a “*” will be called only if infringement is tried during the liability
24 trial.
2
25 Live testimony from many of the witnesses designated for document admissibility purposes may
be avoided with appropriate stipulations from Rambus regarding admissibility of documents. In
26 the event these witnesses are called live, the Manufacturers reserve the right to elicit testimony on
subject matter beyond the admissibility of exhibits.
27
3
Mr. Weinstein will be called as a witness for Micron and Hynix only.
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

Inequitable Conduct Witnesses

1
2
Paul Anderson
3 Paul Michael Farmwald
David Gustavson
4 Mark Horowitz
Joseph McAlexander
5 Jose Moniz
6 John P. Moussouris
Neil Steinberg
7 Lester Vincent
8
Live Testimony Descriptions
9
Expert Witnesses
10
11 Graham Allan – In addition to subjects discussed during his previous testimony in
12 Rambus-related matters, Mr. Allan is expected to testify as to JEDEC history and procedures,
13 DRAM industry background, the design and operation of DRAMs, patent exhaustion, the impact
14 of patent exhaustion on alleged damages, and other matters disclosed by Mr. Allan during expert
15 discovery.
16 William Hoffman – In addition to subjects discussed during his previous testimony
17 in Rambus-related matters, Mr. Hoffman is expected to testify as to noninfringement of Rambus’s
18 patent claims by the Manufacturers’ accused products, rebuttal of Robert Murphy’s Infringement
19 Report and Supplemental Infringement Reports, and other matters disclosed by Mr. Hoffman
20 during expert discovery.
21 Joseph McAlexander – In addition to subjects discussed during his previous
22 testimony in Rambus-related matters, Mr. McAlexander is expected to testify as to the invalidity
23 of Rambus’s patent claims, prior art, the state of the art, alternatives to the accused features and
24 their relative utility, the nature of Rambus’s inventions, the materiality of prior art references that
25 were withheld from the Patent Office, and other matters disclosed by Mr. McAlexander during
26 expert discovery, in his Supplemental Expert Report, and in his Second Supplemental Expert
27 Report. Mr. McAlexander also will rebut Mr. Murphy’s Validity Report and Supplemental
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 Validity Report (to the extent Mr. Murphy is allowed to testify concerning his Supplemental
2 Validity Report).
3 Roy Weinstein – In addition to subjects discussed during his previous testimony in
4 Rambus-related matters, Mr. Weinstein is expected to testify as to patent exhaustion, the impact
5 of patent exhaustion on alleged damages, and other matters disclosed by Mr. Weinstein during
6 expert discovery.
7 Fact Witnesses
8 Paul Anderson – In addition to the subjects discussed during his previous
9 testimony in Rambus-related matters, Mr. Anderson may testify as to the prosecution of the
10 patents in suit, Rambus’s efforts to amend patents to cover JEDEC standards, prior art,
11 knowledge of prior art, and disclosure of prior art to the Patent Office.
12 Richard Barth – In addition to subjects discussed during his previous testimony in
13 Rambus-related matters, Mr. Barth may testify as to Rambus’s efforts to amend patent claims to
14 cover JEDEC standards, Rambus’s awareness of JEDEC standards, and auto precharge.
15 Andreas Bechtolsheim – In addition to subjects discussed during his previous
16 testimony in Rambus-related matters, Mr. Bechtolsheim may testify as to the value of Rambus’s
17 technology and whether Rambus’s technology was considered revolutionary.
18 Richard Crisp – In addition to subjects discussed during his previous testimony in
19 Rambus-related matters, Mr. Crisp is expected to testify as to invalidity issues, Rambus’s
20 amendment of its patent claims, Rambus’s continuation and divisional practice, Rambus’s
21 knowledge of JEDEC standardization, Rambus’s original patent application, and Rambus’s
22 efforts to secure claims that cover industry standards.
23 John Danforth – In addition to subjects discussed during his previous testimony in
24 Rambus-related matters, Mr. Danforth is expected to testify as to Rambus’s business, Rambus’s
25 licensing practices and agreements and Rambus’s license negotiations, the determination of
26 royalty rates, the fees and royalties Rambus has received under its license agreements, and the
27 DRAM industry.
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 William Davidow – In addition to subjects discussed during his previous
2 testimony in Rambus-related matters, Mr. Davidow may testify as to the founding of Rambus,
3 Rambus’s business plan, Rambus’s licensing practices and agreements, and Rambus’s license
4 negotiations.
5 Anthony Diepenbrock – In addition to subjects discussed during his previous
6 testimony in Rambus-related matters, Mr. Diepenbrock is expected to testify as to Rambus’s
7 patent prosecution, Rambus’s original patent application, efforts to amend patent claims to cover
8 JEDEC standards, prior art, knowledge of prior art, and disclosure of prior art to the Patent
9 Office.
10 Bruce Dunlevie – In addition to subjects discussed during his previous testimony
11 in Rambus-related matters, Mr. Dunlevie may testify as to the founding of Rambus, Rambus’s
12 business plan, Rambus’s licensing practices and agreements, and Rambus’s license negotiations.
13 Paul Michael Farmwald – In addition to subjects discussed during his previous
14 testimony in Rambus-related matters, Mr. Farmwald is expected to testify as to his assignment
15 obligation to MIPS, his work at Faster Than Light (“FTL”), MIPS, and the University of Illinois,
16 the R6000 and related projects at MIPS, including their confidentiality, Rambus’s founding,
17 Rambus’s general business background, Rambus’s business plans, Rambus’s alleged inventions
18 and technology, what he regarded as Rambus’s inventions, drafting and filing of the original
19 patent application, Rambus’s strategy of filing patents to cover industry standards, dissemination
20 of information regarding Rambus’s technology, RDRAM licenses, the performance of RDRAM,
21 secondary considerations of obviousness, prior art, including SCI, knowledge of prior art, and
22 disclosure of prior art to the Patent Office.
23 Charles Furnweger – In addition to subjects discussed during his previous
24 testimony in Rambus-related matters, Mr. Fernweger may testify as to certain NEC documents
25 and documents found in possession of NEC and/or Elpida, NEC’s participation at JEDEC, and
26 NEC’s reports from JEDEC.
27
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 Billy Garrett – In addition to subjects discussed during his previous testimony in
2 Rambus-related matters, Mr. Garrett is expected to testify as to Rambus’s knowledge of JEDEC
3 standardization and reports of JEDEC meetings that he attended on behalf of Rambus.
4 David Gustavson – In addition to subjects discussed during his previous testimony
5 in Rambus-related matters, Mr. Gustavson is expected to testify as to prior art, including SCI
6 prior art, SCI standardization, SCI publications and papers, distribution of SCI publications and
7 papers, SCI meetings, and SCI mailing lists.
8 Craig Hampel – In addition to subjects discussed during his previous testimony in
9 Rambus-related matters, Mr. Hampel is expected to testify as to Rambus’s efforts to cover the
10 JEDEC specification.
11 Sharon Holt – In addition to subjects discussed during her previous testimony in
12 Rambus-related matters, Mrs. Holt is expected to testify as to Rambus’s licenses and licensing
13 practices, the DRAM market and industry, secondary indicia of obviousness in rebuttal, and the
14 value of Rambus’s alleged inventions.
15 Mark Horowitz – In addition to subjects discussed during his previous testimony
16 in Rambus-related matters, Mr. Horowitz is expected to testify as to MIPS and his consulting for
17 MIPS, Rambus’s founding, Rambus’s general business background, Rambus’s business plans,
18 Rambus’s alleged inventions and technology, what he regarded as Rambus’s inventions, drafting
19 and filing of the original patent application, Rambus’s strategy of filing patents to cover industry
20 standards, dissemination of information regarding Rambus’s technology, RDRAM licenses,
21 Rambus’s licensing practices, the determination of royalty rates, the fees and royalties Rambus
22 has received under its license agreements, the performance of RDRAM, secondary considerations
23 of obviousness, prior art, including SCI, knowledge of prior art, and disclosure of prior art to the
24 Patent Office.
25 Harold Hughes – In addition to subjects discussed during his previous testimony in
26 Rambus-related matters, Mr. Hughes is expected to testify as to Rambus’s business, Rambus’s
27 licensing, licensing practices and negotiations, the determination of royalty rates, the fees and
28 royalties Rambus has received under its license agreements, and the DRAM industry.
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 Mark Johnson – In addition to subjects discussed during his previous testimony in
2 Rambus-related matters, Mr. Johnson may testify as to Rambus’s business, Rambus’s founding,
3 MIPS, and prior art.
4 Joel Karp – In addition to subjects discussed during his previous testimony in
5 Rambus-related matters, Mr. Karp may testify as to Rambus’s business, Rambus’s licensing
6 practices and agreements, Rambus’s license negotiations, Rambus’s efforts to amend claims to
7 cover JEDEC standards, the determination of royalty rates, Mr. Karp’s relationship with
8 Samsung, Samsung’s JEDEC activities in the mid-90’s, the Samsung-TI litigation, prior art,
9 knowledge of prior art, and disclosure of prior art to the Patent Office.
10 Ilan Krashinsky – In addition to subjects discussed during his previous testimony
11 in Rambus-related matters, Mr. Krashinksy may testify as to JEDEC, Hewlett-Packard’s
12 attendance at JEDEC, and JEDEC approaches to changes in technology.
13 Harlan Lau – In addition to subjects discussed during his previous testimony in
14 Rambus-related matters, Mr. Lau may testify as to Rambus technology and Rambus’s documents
15 regarding Rambus technology.
16 Joe Macri – In addition to subjects discussed during his previous testimony in
17 Rambus-related matters, Mr. Macri may testify as to JEDEC standards and the standardization
18 process, prior art from JEDEC meetings, and secondary indicia of obviousness, including whether
19 JEDEC copied Rambus’s inventions.
20 Michael McGowan – In addition to subjects discussed during his previous
21 testimony in Rambus-related matters, Mr. McGowan may testify as to prior art, including the
22 Intel iAPX prior art references, the iAPX prior art product, and sales and marketing of the iAPX
23 prior art product.
24 David Mooring – In addition to subjects discussed during his previous testimony
25 in Rambus-related matters, Mr. Mooring is expected to testify as to Rambus’s business, Rambus’s
26 licensing practices, licenses, and agreements, Rambus’s licensing negotiations, the determination
27 of royalty rates, dissemination of information regarding Rambus’s technology, the alleged value
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 of Rambus’s inventions, the fees and royalties Rambus has received under its license agreements,
2 and the DRAM industry and economic conditions.
3 Jose Moniz – In addition to subjects discussed during his previous testimony in
4 Rambus-related matters, Mr. Moniz may testify as to the prosecution of the patents in suit,
5 Rambus’s efforts to amend patents to cover JEDEC standards, prior art, knowledge of prior art,
6 and disclosure of prior art to the Patent Office.
7 John P. Moussouris – In addition to subjects discussed during his previous
8 testimony in Rambus-related matters, Dr. Moussouris is expected to testify as to prior art,
9 including SCI prior art, publications, and presentations, his work and publications related to
10 memory interfaces on DRAMs, his work and that of others at MIPS and MicroUnity, MIPS’s and
11 MicroUnity’s business, technology, products, and development projects, the R6000 and related
12 projects, the confidentiality of the R6000 and related projects, and employee obligations to assign
13 ideas and inventions to MIPS.
14 Earnest Powell – In addition to subjects discussed during his previous testimony
15 in Rambus-related matters, Mr. Powell may testify as to memory system bandwidth, solutions to
16 memory system bandwidth problems, and his publications regarding memory system bandwidth.
17 Desi Rhoden – In addition to subjects discussed during his previous testimony in
18 Rambus-related matters, Mr. Rhoden is expected to testify as to JEDEC standards, the JEDEC
19 standardization process, the evolutionary nature of technology development at JEDEC, prior art
20 from JEDEC meetings (including Unisys presentations on C-DRAM), and secondary indicia of
21 obviousness.
22 Allen Roberts – In addition to subjects discussed during his previous testimony in
23 Rambus-related matters, Mr. Roberts may testify as to MIPS, the R6000 and related projects, the
24 work of Drs. Farmwald and Horowitz at MIPS, and prior art.
25 Gilbert Russell – In addition to subjects discussed during any previous testimony
26 in Rambus-related matters, Mr. Russell may testify as to prior art, including the SCI prior art
27 reference, dissemination of information regarding Rambus technology to DRAM industry
28 participants and industry reaction thereto, alleged knowledge of Rambus’s intellectual property
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 within the industry, existence or nonexistence of economically viable non-infringing alternatives,
2 potential scope of patent coverage of Rambus’s inventions, Rambus’s patents and technology,
3 and the DRAM industry.
4 Neil Steinberg – In addition to subjects discussed during his previous testimony in
5 Rambus-related matters, Mr. Steinberg is expected to testify as to Rambus’s business, Rambus’s
6 licensing practices and agreements, Rambus’s licensing negotiations, the determination of royalty
7 rates, the fees and royalties Rambus has received under its license agreements, prosecution of
8 Rambus’s patents, efforts to amend Rambus’s patents to cover JEDEC standards, prior art,
9 knowledge of prior art, disclosure of prior art to the Patent Office, and Mr. Steinberg’s
10 relationship with Samsung.
11 Howard Sussman – In addition to subjects discussed during his previous testimony
12 in Rambus-related matters, Mr. Sussman is expected to testify as to JEDEC standards, prior art
13 from JEDEC meetings (including Unisys presentations on C-DRAM), his work on SDRAM, and
14 secondary considerations of obviousness.
15 Kit Sang Tam – In addition to subjects discussed during his previous testimony in
16 Rambus-related matters, Mr. Tam may testify as to MoSys documents and DRAM technology,
17 including the MoSys Technology White Papers.
18 Geoffrey Tate – In addition to subjects discussed during his previous testimony in
19 Rambus-related matters, Mr. Tate is expected to testify as to Rambus’s understanding of its
20 inventions, Rambus’s strategy and efforts to obtain patents on industry standards, Rambus’s
21 business plans, Rambus’s business, Rambus’s licensing practices, licenses and agreements,
22 license negotiations, the determination of royalty rates, the fees and royalties Rambus has
23 received under its license agreements, the DRAM market and industry, auto precharge, the value
24 of Rambus’s alleged inventions prior art, knowledge of prior art, and disclosure of prior art to the
25 Patent Office.
26 David Tuckerman – In addition to subjects discussed during any previous
27 testimony in Rambus-related matters, Mr. Tuckerman may testify as to prior art, including the
28 SCI prior art references.
CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 Lester Vincent – In addition to subjects discussed during his previous testimony in
2 Rambus-related matters, Mr. Vincent is expected to testify as to the prosecution of Rambus’s
3 patent claims and Rambus’s efforts to amend its patents to cover JEDEC standards.
4 Frederick Ware – In addition to subjects discussed during his previous testimony
5 in Rambus-related matters, Mr. Ware is expected to testify as to Rambus’s awareness of JEDEC
6 standards, Rambus’s efforts to amend its patents to cover JEDEC standards, auto precharge, and
7 Rambus’s alleged inventions and technology.
8 Hans Wiggers – In addition to subjects discussed during his previous testimony in
9 Rambus-related matters, Mr. Wiggers may testify as to prior art, including the SCI prior art, SCI
10 standardization, SCI publications and papers, distribution of SCI publications and papers, SCI
11 meetings, and SCI mailing lists.
12 Steven Woo – In addition to subjects discussed during his previous testimony in
13 Rambus-related matters, Mr. Woo may testify as to processor-memory performance and
14 Rambus’s presentations regarding Rambus technology and processor-memory performance.
15 To the extent Rambus does not stipulate to the authenticity of the following
16 translated documents, and the Court deems necessary, the Manufacturers may call witnesses to
17 verify the translations of the following foreign-language documents into English:
18 • Japanese Patent No. S56-047996, issued to Yoshida, on April 30, 1981 -

exh. 16517;
19 • Japanese Patent No. 57-210495, issued to Inagaki, on December 24, 1982 -
15547;
20 • Japanese Patent No. 63-239676, issued to Yamaguchi, on October 5, 1988 -
108;
21 • JP Laid Open Patent Publication No. Sho 64/1989-29951 (Kumagai)
[Appl. No. Sho 62/1987-185253, July 24, 1987] - 146;
22 • Translation of the March 31, 2003 minutes of a hearing held on March 27,
2003 before the GPTO in the proceedings relating to German Utility Model
23 Gbm 91 17 296 - 16545; and
• Translation of the Decision of the GPTO dated May 28, 2003 in the
24 proceedings relating to German Utility Model Gbm 91 17 296 - 15502.
25
26
Dated: January 9, 2009
27 WEIL, GOTSHAL & MANGES, LLP
28 By: /s/
CASE NOS. 06-00244-RMW; 05-00334-RMW;
John D. Beynon (Bar No. 233581)

1 Email: john.beynon@weil.com
2 JARED BOBROW (Bar No. 133712)
Email: jared.bobrow@weil.com
3 SVEN RAZ (Bar No. 222262)
Email: sven.raz@weil.com
4 JOHN D. BEYNON (Bar No. 233581)
Email: john.beynon@weil.com
5 WEIL GOTSHAL & MANGES LLP
201 Redwood Shores Parkway
6 Redwood Shores, CA 94065
Telephone: (650) 802-3034
7 Facsimile: (650) 802-3100
8 ELIZABETH STOTLAND WEISWASSER
Email: elizabeth.weiswasser@weil.com
9 DAVID LENDER
Email: david.lender@weil.com
10 WEIL, GOTSHAL & MANGES LLP
New York Office
11 767 Fifth Avenue
New York, NY 10153
12 Telephone: (212) 310-8000
13 WILLIAM C. PRICE (Bar No. 108542)
Email: william.price@quinnemanuel.com
14 HAROLD A. BARZA (Bar No. 80888)
Email: halbarza@quinnemanuel.com
15 JON R. STEIGER (Bar No. 229814)
Email: jonsteiger@quinnemanuel.com
16 ROBERT J. BECHER (Bar No. 193431)
Email: robertbecher@quinnemanuel.com
17
18 By: /s/
DANIEL J. FURNISS (Bar No. 73531)
19 Email: difurniss@townsend.com
20 THEODORE G. BROWN, III (Bar No. 114672)
Email: tgbrown@townsend.com
21 JULIE H. HAN (Bar No. 215279)
Email: jjhan@townsend.com
22 TOWNSEND and TOWNSEND and CREW LLP
379 Lytton Avenue
23 Palo Alto, CA 94301
24 Telephone: (650) 326-2400
Facsimile: (650) 326-2422
25
KENNETH L NISSLY (Bar No. 77589)
26 Email: knissly@omm.com
SUSAN van KEULEN (Bar No. 136060)
27
Email: svankeulen@omm.com
28 SUSAN D. ROEDER (Bar No. 160897)
CASE NOS. 06-00244-RMW; 05-00334-RMW;

Email: sroeder@omm.com
1 O’MELVENY & MYERS LLP
2 2765 Sand Hill Road
Menlo Park, CA 94025
3 Telephone: (650) 473-2600
Facsimile: (650) 473-2601
4
KENNETH R. O’ROURKE (Bar No. 120144)
5 Email: korourke@omm.com
6 WALLACE A. ALLAN (Bar No. 102054)
Email: tallan@omm.com
7 O’MELVENY & MYERS LLP
400 South Hope Street, Suite 1060
8 Los Angeles, CA 90071-2899
Telephone: (213) 430-6000
9 Facsimile: (213) 430-6407
10
11 Attorneys for
HYNIX SEMICONDUCTOR INC., HYNIX
12 SEMICONDUCTOR AMERICA INC., HYNIX
SEMICONDUCTOR MANUFACTURING
13 AMERICA INC., HYNIX SEMICONDUCTOR
U.K. LTD., and HYNIX SEMICONDUCTOR
14 DEUTSCHLAND GmbH
15 By: /s/
Vickie L. Feeman
16
ROBERT E. FREITAS (Bar No. 80948)
17 Email: rfreitas@orrick.com
CRAIG R. KAUFMAN (Bar No. 159458)
18 Email: ckaufman@orrick.com
VICKIE L. FEEMAN (Bar No. 177487)
19 Email: vfeeman@orrick.com
ORRICK, HERRINGTON & SUTCLIFFE LLP
20 1000 Marsh Road
Menlo Park, CA 94025
21 Telephone: (650) 614-7400
Facsimile: (650) 614-7401
22 Attorneys for Defendants
NANYA TECHNOLOGY
23 CORPORATION, and NANYA
TECHNOLOGY CORPORATION U.S.A.
24
25 By: /s/
Anne Cappella
26
27
28
CASE NOS. 06-00244-RMW; 05-00334-RMW;

MATTHEW D. POWERS
1 Email: matthew.powers @weil.com
STEVEN S. CHERENSKY
2 Email: steven.cherensky @weil.com
WEIL GOTSHAL & MANGES LLP
3 201 Redwood Shores Parkway
Redwood Shores, CA 94065
4 Telephone: (650) 802-3034
Facsimile: (650) 802-3100
5
ROBERT S. BEREZIN
6 Email: robert.berezin@weil.com
WEIL, GOTSHAL & MANGES LLP
7 New York Office
767 Fifth Avenue
8 New York, NY 10153
Telephone: (212) 310-8000
9
Attorneys for Defendants
10 SAMSUNG ELECTRONICS CO., LTD.,
SAMSUNG ELECTRONICS AMERICA, INC.,
11 SAMSUNG SEMICONDUCTOR, INC., and
SAMSUNG AUSTIN SEMICONDUCTOR, L.P.
12
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CASE NOS. 06-00244-RMW; 05-00334-RMW;

3
ATTESTATION CLAUSE REGARDING SIGNATURES
4
I hereby attest that I have on file permission to sign for co-counsel indicated by a
5
“conformed” signature (/S/) within this efiled document.
6
7 /s/ John Beynon

John Beynon (Bar No. 233581)
8 Email: john.beynon@weil.com
9
10
11
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CASE NOS. 06-00244-RMW; 05-00334-RMW;


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Case 5:05-cv-00334-RMW Document 3044 Filed 01/09/2009 Page 1 of 16

1 Attorneys Listed On Signature Page

8 IN THE UNITED STATES DISTRICT COURT

9 NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION

10 RAMBUS INC., Case No. C 05-00334 RMW

19 NANYA TECHNOLOGY CORPORATION,

CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 RAMBUS INC., Case No. C 05-02298 RMW

4 SAMSUNG ELECTRONICS CO., LTD.,

CASE NOS. 06-00244-RMW; 05-00334-RMW;

Pretrial Statement, Section F

14 addition to or as an alternative to live testimony, including any Rambus admissions, consistent

19 Rambus regarding admissibility of documents.

CASE NOS. 06-00244-RMW; 05-00334-RMW;

Liability Trial Witnesses

17 Patent Exhaustion Witnesses

CASE NOS. 06-00244-RMW; 05-00334-RMW;

Inequitable Conduct Witnesses

11 Graham Allan – In addition to subjects discussed during his previous testimony in

16 William Hoffman – In addition to subjects discussed during his previous testimony

17 in Rambus-related matters, Mr. Hoffman is expected to testify as to noninfringement of Rambus’s

20 during expert discovery.

21 Joseph McAlexander – In addition to subjects discussed during his previous

22 testimony in Rambus-related matters, Mr. McAlexander is expected to testify as to the invalidity

CASE NOS. 06-00244-RMW; 05-00334-RMW;

3 Roy Weinstein – In addition to subjects discussed during his previous testimony in

12 Richard Barth – In addition to subjects discussed during his previous testimony in

15 Andreas Bechtolsheim – In addition to subjects discussed during his previous

17 technology and whether Rambus’s technology was considered revolutionary.

18 Richard Crisp – In addition to subjects discussed during his previous testimony in

19 Rambus-related matters, Mr. Crisp is expected to testify as to invalidity issues, Rambus’s

21 knowledge of JEDEC standardization, Rambus’s original patent application, and Rambus’s

22 efforts to secure claims that cover industry standards.

23 John Danforth – In addition to subjects discussed during his previous testimony in

24 Rambus-related matters, Mr. Danforth is expected to testify as to Rambus’s business, Rambus’s

CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 William Davidow – In addition to subjects discussed during his previous

5 Anthony Diepenbrock – In addition to subjects discussed during his previous

6 testimony in Rambus-related matters, Mr. Diepenbrock is expected to testify as to Rambus’s

10 Bruce Dunlevie – In addition to subjects discussed during his previous testimony

13 Paul Michael Farmwald – In addition to subjects discussed during his previous

14 testimony in Rambus-related matters, Mr. Farmwald is expected to testify as to his assignment

20 of information regarding Rambus’s technology, RDRAM licenses, the performance of RDRAM,

22 disclosure of prior art to the Patent Office.

23 Charles Furnweger – In addition to subjects discussed during his previous

26 NEC’s reports from JEDEC.

CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 Billy Garrett – In addition to subjects discussed during his previous testimony in

2 Rambus-related matters, Mr. Garrett is expected to testify as to Rambus’s knowledge of JEDEC

3 standardization and reports of JEDEC meetings that he attended on behalf of Rambus.

4 David Gustavson – In addition to subjects discussed during his previous testimony

7 papers, SCI meetings, and SCI mailing lists.

8 Craig Hampel – In addition to subjects discussed during his previous testimony in

11 Sharon Holt – In addition to subjects discussed during her previous testimony in

14 value of Rambus’s alleged inventions.

15 Mark Horowitz – In addition to subjects discussed during his previous testimony

20 standards, dissemination of information regarding Rambus’s technology, RDRAM licenses,

25 Harold Hughes – In addition to subjects discussed during his previous testimony in

26 Rambus-related matters, Mr. Hughes is expected to testify as to Rambus’s business, Rambus’s

CASE NOS. 06-00244-RMW; 05-00334-RMW;

1 Mark Johnson – In addition to subjects discussed during his previous testimony in

3 MIPS, and prior art.

4 Joel Karp – In addition to subjects discussed during his previous testimony in

10 Ilan Krashinsky – In addition to subjects discussed during his previous testimony