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I. NEEL CHATTERJEE (STATE BAR NO. 173985) nchatterjee@orrick.com THERESA A. SUTTON (STATE BAR NO. 211857) tsutton@orrick.com ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, California 94025 Telephone: 650-614-7400 Facsimile: 650-614-7401 DAVID M. GOLDSTEIN (STATE BAR NO. 142334) dgoldstein@orrick.com 405 Howard Street San Francisco, CA 94105 Telephone: 415-773-5700 Facsimile: 415-773-5759 Attorneys for Defendant and Cross-Complainant NVIDIA Corporation UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

RAMBUS INC., Plaintiff, v. NVIDIA CORPORATION, Defendant.

Case No. C-08-03343 SI Consolidated with C-08-05500 SI CORRECTED DECLARATION OF I. NEEL CHATTERJEE IN SUPPORT OF NVIDIA CORPORATIONS MOTION TO COMPEL DISCLOSURES PURSUANT TO PATENT LOCAL RULES 3-1 AND 32, FOR PROTECTIVE ORDER, AND TO STAY NVIDIA CORPORATIONS PATENT LOCAL RULE 3-3 AND 3-4 INVALIDITY CONTENTIONS Date: Time: Judge: TBD 9:00 A.M. Hon. Edward Infante (ret.)

NVIDIA CORPORATION, Cross-Complainant, v. RAMBUS INC., Cross-Defendant.

CORRECTED CHATTERJEE DECL. IN SUPPORT OF NVIDIAS MOTION TO COMPEL CASE NO. C-08-03343 SI

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I, I. Neel Chatterjee, declare: 1. I am an attorney licensed to practice law in the State of California and am a

Partner at Orrick, Herrington & Sutcliffe LLP, and counsel for NVIDIA Corporation (NVIDIA) in this action. Unless stated on information and belief, I make this declaration based on my own personal knowledge and if called to testify to the truth of the matters herein, I could and would do so competently. 2. On May 12, 2011, Rambus Inc. (Rambus) served to NVIDIA Rambus Incs

Disclosure of Asserted Claims and Infringement Contentions (Civil L.R. 3-1) (Disclosure), a true and correct copy of which is attached hereto as Exhibit A. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 3. A true and correct copy of Exhibit A to Rambuss Disclosure is attached hereto as

Exhibit B. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 4. On June 28, 2011, I sent Trent Campione, counsel for Rambus, a letter

summarizing identified deficiencies in Rambuss Disclosure. A true and correct copy of this letter is attached hereto as Exhibit C. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 5. A true and correct copy of Rambuss July 8, 2011 letter to NVIDIA responding to

NVIDIAs June 28, 2011 letter is attached hereto as Exhibit D. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 6. A true and correct copy of Exhibits 1A and 1B to Rambuss Disclosure, claim

charts for U.S. Patent No. 6,260,097, is attached hereto as Exhibit E. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 7. A true and correct copy of Exhibits 2A and 2B to Rambuss Disclosure, claim

charts for U.S. Patent No. 6,304,937, is attached hereto as Exhibit F. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 8. A true and correct copy of Exhibits 3A and 3B to Rambuss Disclosure, claim

charts for U.S. Patent No. 6,564,281, is attached hereto as Exhibit G. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] -1CORRECTED CHATTERJEE DECL. IN SUPPORT OF NVIDIAS MOTION TO COMPEL CASE NO. C-08-03343 SI

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9.

A true and correct copy of Exhibits 4A and 4B to Rambuss Disclosure, claim

charts for U.S. Patent No. 6,715,020, is attached hereto as Exhibit H. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 10. A true and correct copy of Exhibits 5A and 5B to Rambuss Disclosure, claim

charts for U.S. Patent No. 6,751,696, is attached hereto as Exhibit I. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 11. A true and correct copy of Exhibits 6A and 6B to Rambuss Disclosure, claim

charts for U.S. Patent No. 7,209,997, is attached hereto as Exhibit J. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 12. A true and correct copy of Exhibit 7 to Rambuss Disclosure, claim charts for U.S.

Patent No. 7,360,050, is attached hereto as Exhibit K. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 13. A true and correct copy of Exhibit 8 to Rambuss Disclosure, claim charts for U.S.

Patent No. 7,287,119, is attached hereto as Exhibit L. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 14. A true and correct copy of Exhibit 9 to Rambuss Disclosure, claim charts for U.S.

Patent No. 7,330,952, is attached hereto as Exhibit M. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 15. A true and correct copy of Exhibit 10 to Rambuss Disclosure, claim charts for

U.S. Patent No. 7,330,953, is attached hereto as Exhibit N. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] I declare under penalty of perjury that the foregoing is true and correct. Executed this 30th day of July, 2011, at Menlo Park, California.

Respectfully submitted, /s/ I. Neel Chatterjee /s/ I. Neel Chatterjee

CORRECTED CHATTERJEE DECL. IN SUPPORT OF NVIDIAS MOTION TO COMPEL CASE NO. C-08-03343 SI

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CERTIFICATE OF SERVICE I hereby certify that this document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on July 30, 2011. Dated: July 30, 2011 Respectfully submitted, /s/ Josette Romero /s/ Josette Romero

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CORRECTED CHATTERJEE DECL. IN SUPPORT OF NVIDIAS MOTION TO COMPEL CASE NO. C-08-03343 SI