2063
This document was uploaded by user and they confirmed that they have the permission to share it. If you are author or own the copyright of this book, please report to us by using this DMCA report form. Report DMCA
Overview
Download & View 2063 as PDF for free.
More details
- Words: 1,219
- Pages: 5
Case 5:05-cv-00334-RMW
1
Document 2063
Filed 08/19/2008
Page 1 of 5
Attorney list on signature page
2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION
8 9 10
RAMBUS, INC., Plaintiff,
11 12 13 14 15 16 17 18 19 20 21 22
v. HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA INC., HYNIX SEMICONDUCTOR MANUFACTURING AMERICA INC., SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, L.P., NANYA TECHNOLOGY CORPORATION, NANYA TECHNOLOGY CORPORATION U.S.A., Defendants. RAMBUS, INC.,
24
v.
25
SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, L.P., Defendants.
27 28
DECLARATION OF CARMEN E. BREMER IN SUPPORT OF SAMSUNG’S OPPOSITION TO RAMBUS INC.’S MOTION TO COMPEL SAMSUNG TO PRODUCE DISCOVERY RELATING TO (1) SALES OF ACCUSED PRODUCTS; AND (2) MEMORY CONTROLLERS
Hearing Date: Time: Location: Judge:
August 25, 2008 8:30 a.m. Telephonic Hon. Read Ambler (Ret.)
Plaintiff,
23
26
Case No. C 05-00334 RMW
Case No. C 05-02298 RMW
Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
Document 2063
Filed 08/19/2008
Page 2 of 5
DECLARATION OF CARMEN E. BREMER
1 2
I, Carmen E. Bremer, do hereby declare and say:
3
1.
I am an attorney with the law firm of Weil, Gotshal & Manges, LLP. I submit
4
this declaration pursuant to Civil Local Rule 7-5(a) and in support of Samsung’s Opposition to
5
Rambus Inc.’s Motion to Compel Discovery Relating to (1) Sales of Accused Products and (2)
6
Memory Controllers.
7
2.
Attached hereto as Exhibit 1 is a true and correct copy of an SDR/DDR IC and
8
SDR/DDR Memory Module Patent License Agreement Between Rambus Inc. and Samsung
9
Elecs. Co., Ltd., dated October 20, 2000. [FILED UNDER SEAL]
10 11 12 13 14 15 16
3.
Attached hereto as Exhibit 2 is a true and correct copy of SEC’s Royalty Statement
for 4Q, 2000. [FILED UNDER SEAL] 4.
Attached hereto as Exhibit 3 is a true and correct copy of an Email from I.
Blumberg to J. Shim, dated February 20, 2005. [FILED UNDER SEAL] 5.
Attached hereto as Exhibit 4 is a true and correct copy of a Letter from J. Danforth
to “To Whom It May Concern,” dated June 6, 2005. [FILED UNDER SEAL] 6.
Attached hereto as Exhibit 5 is a true and correct copy of Rambus’s First Amended
17
Complaint for Patent Infringement and Jury Demand, Rambus Inc. v. Hynix Semiconductor Inc.,
18
et al. C 05-00334, dated June 6, 2005.
19
7.
Attached hereto as Exhibit 6 is a true and correct copy of Rambus’s Disclosure of
20
Asserted Claims and Preliminary Infringement Contentions Pursuant to Patent Local Rules,
21
Rambus Inc. v. Samsung Elecs. Co., Ltd., C 05-02298, dated April 3, 2006.
22
8.
Attached hereto as Exhibit 7 is a true and correct copy of Rambus’s Disclosure of
23
Asserted Claims and Preliminary Infringement Contentions Pursuant to Patent Local Rules,
24
Rambus Inc. v. Hynix Semiconductor Inc., et al. C 05-00334, dated February 23, 2007.
25
9.
Attached hereto as Exhibit 8 is a true and correct copy of Rambus’s Supplemental
26
Disclosure of Asserted Claims and Preliminary Infringement Contentions Pursuant to Patent
27
Local Rules, Rambus Inc. v. Hynix Semiconductor Inc., et al. C 05-00334, dated July 20, 2007.
28
10.
Attached hereto as Exhibit 9 is a true and correct copy of Rambus’s First Set of
Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
2
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
Document 2063
Filed 08/19/2008
Page 3 of 5
1
Requests for Production of Documents to Samsung, Rambus Inc. v. Samsung Elecs. Co., Ltd., C
2
05-02298, dated October 13, 2005.
3
11.
Attached hereto as Exhibit 10 is a true and correct copy of Samsung’s Responses
4
to Rambus’s First Set of Requests for Production, Rambus Inc. v. Samsung Elecs. Co., Ltd., C 05-
5
02298, dated March 23, 2007.
6 7
12.
to D. Healey, A. Kadala, C. Bremer, and A. Cappella, dated July 14, 2008.
8 9 10
13.
Hynix Semiconductor Inc., et al. C 05-00334, dated August 4, 2008. 14.
15.
16.
Attached hereto as Exhibit 15 is a true and correct copy of an Email from C.
Luedtke to S. Barrows, dated July 18. 2008.
17 18
Attached hereto as Exhibit 14 is a true and correct copy of an Email Chain
between R. Berezin and A. Jeffries, dated August 7-8, 2008.
15 16
Attached hereto as Exhibit 13 is a true and correct copy of a Letter from R.
Berezin to A. Jeffries, dated July 31, 2008.
13 14
Attached hereto as Exhibit 12 is a true and correct copy of Samsung’s Objections
and Responses to Rambus’s Sixth Set of Requests for Production of Documents, Rambus Inc. v.
11 12
Attached hereto as Exhibit 11 is a true and correct copy of a Letter from B. Ward
17.
Attached hereto as Exhibit 16 is a true and correct copy of a Letter from A. Jeffries
to R. Berezin, dated July 30, 2008.
19
18.
Attached hereto as Exhibit 17 is a true and correct copy of Rambus’s Disclosure of
20
Asserted Claims and Final Infringement Contentions, Rambus Inc. v. Hynix Semiconductor Inc.,
21
et al. C 05-00334, dated August 1, 2008.
22
19.
Attached hereto as Exhibit 18 is a true and correct copy of the Claim Construction
23
Order for the Farmwald/Horowitz Patents and Order Denying the Manufacturers’ Motions for
24
Summary Judgment of Non-Infringement and Invalidity Depending on Claim Construction,
25
Rambus Inc. v. Hynix Semiconductor Inc., et al. C 05-00334, dated July 10, 2008.
26
20.
Attached hereto as Exhibit 19 is a true and correct copy of the Expert Report of
27
David J. Teece, Hynix v. Rambus CV 00-20905 RMW, dated January 4, 2005. [FILED UNDER
28
SEAL] Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
3
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
1
21.
Document 2063
Filed 08/19/2008
Page 4 of 5
Attached hereto as Exhibit 20 is a true and correct copy of the Declaration of
2
Huiman Lee In Support of Samsung’s Opposition to Rambus’s Motion to Compel Samsung to
3
Produce Discovery Relating to (1) Sales of Accused Products; and (2) Memory Controllers, dated
4
August 18, 2008. [FILED UNDER SEAL]
5 6 7 8
22.
Attached hereto as Exhibit 21 is a true and correct copy of an Email from David
Yang to Judge R. Ambler. I declare under the penalty of perjury under the laws of the United States that the foregoing is true and correct.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
4
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
Document 2063
Filed 08/19/2008
Page 5 of 5
1
Document 2063
Filed 08/19/2008
Page 1 of 5
Attorney list on signature page
2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION
8 9 10
RAMBUS, INC., Plaintiff,
11 12 13 14 15 16 17 18 19 20 21 22
v. HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA INC., HYNIX SEMICONDUCTOR MANUFACTURING AMERICA INC., SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, L.P., NANYA TECHNOLOGY CORPORATION, NANYA TECHNOLOGY CORPORATION U.S.A., Defendants. RAMBUS, INC.,
24
v.
25
SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, L.P., Defendants.
27 28
DECLARATION OF CARMEN E. BREMER IN SUPPORT OF SAMSUNG’S OPPOSITION TO RAMBUS INC.’S MOTION TO COMPEL SAMSUNG TO PRODUCE DISCOVERY RELATING TO (1) SALES OF ACCUSED PRODUCTS; AND (2) MEMORY CONTROLLERS
Hearing Date: Time: Location: Judge:
August 25, 2008 8:30 a.m. Telephonic Hon. Read Ambler (Ret.)
Plaintiff,
23
26
Case No. C 05-00334 RMW
Case No. C 05-02298 RMW
Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
Document 2063
Filed 08/19/2008
Page 2 of 5
DECLARATION OF CARMEN E. BREMER
1 2
I, Carmen E. Bremer, do hereby declare and say:
3
1.
I am an attorney with the law firm of Weil, Gotshal & Manges, LLP. I submit
4
this declaration pursuant to Civil Local Rule 7-5(a) and in support of Samsung’s Opposition to
5
Rambus Inc.’s Motion to Compel Discovery Relating to (1) Sales of Accused Products and (2)
6
Memory Controllers.
7
2.
Attached hereto as Exhibit 1 is a true and correct copy of an SDR/DDR IC and
8
SDR/DDR Memory Module Patent License Agreement Between Rambus Inc. and Samsung
9
Elecs. Co., Ltd., dated October 20, 2000. [FILED UNDER SEAL]
10 11 12 13 14 15 16
3.
Attached hereto as Exhibit 2 is a true and correct copy of SEC’s Royalty Statement
for 4Q, 2000. [FILED UNDER SEAL] 4.
Attached hereto as Exhibit 3 is a true and correct copy of an Email from I.
Blumberg to J. Shim, dated February 20, 2005. [FILED UNDER SEAL] 5.
Attached hereto as Exhibit 4 is a true and correct copy of a Letter from J. Danforth
to “To Whom It May Concern,” dated June 6, 2005. [FILED UNDER SEAL] 6.
Attached hereto as Exhibit 5 is a true and correct copy of Rambus’s First Amended
17
Complaint for Patent Infringement and Jury Demand, Rambus Inc. v. Hynix Semiconductor Inc.,
18
et al. C 05-00334, dated June 6, 2005.
19
7.
Attached hereto as Exhibit 6 is a true and correct copy of Rambus’s Disclosure of
20
Asserted Claims and Preliminary Infringement Contentions Pursuant to Patent Local Rules,
21
Rambus Inc. v. Samsung Elecs. Co., Ltd., C 05-02298, dated April 3, 2006.
22
8.
Attached hereto as Exhibit 7 is a true and correct copy of Rambus’s Disclosure of
23
Asserted Claims and Preliminary Infringement Contentions Pursuant to Patent Local Rules,
24
Rambus Inc. v. Hynix Semiconductor Inc., et al. C 05-00334, dated February 23, 2007.
25
9.
Attached hereto as Exhibit 8 is a true and correct copy of Rambus’s Supplemental
26
Disclosure of Asserted Claims and Preliminary Infringement Contentions Pursuant to Patent
27
Local Rules, Rambus Inc. v. Hynix Semiconductor Inc., et al. C 05-00334, dated July 20, 2007.
28
10.
Attached hereto as Exhibit 9 is a true and correct copy of Rambus’s First Set of
Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
2
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
Document 2063
Filed 08/19/2008
Page 3 of 5
1
Requests for Production of Documents to Samsung, Rambus Inc. v. Samsung Elecs. Co., Ltd., C
2
05-02298, dated October 13, 2005.
3
11.
Attached hereto as Exhibit 10 is a true and correct copy of Samsung’s Responses
4
to Rambus’s First Set of Requests for Production, Rambus Inc. v. Samsung Elecs. Co., Ltd., C 05-
5
02298, dated March 23, 2007.
6 7
12.
to D. Healey, A. Kadala, C. Bremer, and A. Cappella, dated July 14, 2008.
8 9 10
13.
Hynix Semiconductor Inc., et al. C 05-00334, dated August 4, 2008. 14.
15.
16.
Attached hereto as Exhibit 15 is a true and correct copy of an Email from C.
Luedtke to S. Barrows, dated July 18. 2008.
17 18
Attached hereto as Exhibit 14 is a true and correct copy of an Email Chain
between R. Berezin and A. Jeffries, dated August 7-8, 2008.
15 16
Attached hereto as Exhibit 13 is a true and correct copy of a Letter from R.
Berezin to A. Jeffries, dated July 31, 2008.
13 14
Attached hereto as Exhibit 12 is a true and correct copy of Samsung’s Objections
and Responses to Rambus’s Sixth Set of Requests for Production of Documents, Rambus Inc. v.
11 12
Attached hereto as Exhibit 11 is a true and correct copy of a Letter from B. Ward
17.
Attached hereto as Exhibit 16 is a true and correct copy of a Letter from A. Jeffries
to R. Berezin, dated July 30, 2008.
19
18.
Attached hereto as Exhibit 17 is a true and correct copy of Rambus’s Disclosure of
20
Asserted Claims and Final Infringement Contentions, Rambus Inc. v. Hynix Semiconductor Inc.,
21
et al. C 05-00334, dated August 1, 2008.
22
19.
Attached hereto as Exhibit 18 is a true and correct copy of the Claim Construction
23
Order for the Farmwald/Horowitz Patents and Order Denying the Manufacturers’ Motions for
24
Summary Judgment of Non-Infringement and Invalidity Depending on Claim Construction,
25
Rambus Inc. v. Hynix Semiconductor Inc., et al. C 05-00334, dated July 10, 2008.
26
20.
Attached hereto as Exhibit 19 is a true and correct copy of the Expert Report of
27
David J. Teece, Hynix v. Rambus CV 00-20905 RMW, dated January 4, 2005. [FILED UNDER
28
SEAL] Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
3
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
1
21.
Document 2063
Filed 08/19/2008
Page 4 of 5
Attached hereto as Exhibit 20 is a true and correct copy of the Declaration of
2
Huiman Lee In Support of Samsung’s Opposition to Rambus’s Motion to Compel Samsung to
3
Produce Discovery Relating to (1) Sales of Accused Products; and (2) Memory Controllers, dated
4
August 18, 2008. [FILED UNDER SEAL]
5 6 7 8
22.
Attached hereto as Exhibit 21 is a true and correct copy of an Email from David
Yang to Judge R. Ambler. I declare under the penalty of perjury under the laws of the United States that the foregoing is true and correct.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Bremer Decl ISO Samsung’s Opp to Rambus Inc’s MTC Discovery Relating to (1) Sales of Accused Products and (2) Memory Controllers
4
Case No. C 05-00334 Case No. C 05-02298
Case 5:05-cv-00334-RMW
Document 2063
Filed 08/19/2008
Page 5 of 5
Related Documents
2063
November 2019 9
2063
May 2020 4
2063
October 2019 19
Constitution 2063
May 2020 5
Pcs-2976-tps-2063
November 2019 5
