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Case 5:05-cv-00334-RMW

Document 2225-2

Filed 09/18/2008

EX HIBI T A

Page 1 of 2

Case 5:05-cv-00334-RMW

Document 2225-2

Filed 09/18/2008

Page 2 of 2

Samsung’s Witness List September 18, 2008 Case No. 05-00334-RMW; 05-02298-RMW In view of the Court’s direction at the September 16, 2008, pre-trial conference, Samsung submits the following list of witnesses it presently intends to call, or may call, to testify in its case in chief. Will Call 1. Jay Shim: Samsung will call Mr. Shim to testify regarding the license negotiations between Samsung and Rambus, the license negotiations of the 2000 SDR/DDR License, the 2001 Amendment Number 1 to that License, and renewal negotiations of the 2000 SDR/DDR License, Rambus’s June 6, 2005 termination of the 2000 SDR/DDR License, as well as industry customs and practices in licensing and Rambus’s audit of Samsung's royalties as well as the business relationship between Rambus and Samsung. 2. Keith Ugone: Samsung will call Dr. Ugone, an economics and damages expert, to testify regarding the comparability of differing licensing payment terms and the relief sought by Samsung under the SDR/DDR License Agreement. 3. Carl Sechen: Samsung will call Dr. Sechen, as an expert witness to testify regarding the application of the 2000 SDR/DDR License to improvements to DDR, which include DDR2, and other products asserted by Rambus to be beyond the scope of the license. 4. David Mooring: Samsung will call Mr. Mooring to testify as an adverse witness to authenticate certain documents regarding Rambus’s licenses and licensing practices, license negotiations between Samsung and Rambus. 5. Jared Smith: Samsung will call Mr. Smith to testify as an adverse witness to authenticate certain documents regarding Rambus’s licenses and licensing practices, and license negotiations between Samsung and Rambus in 2004-2005. 6. Joel Karp: Samsung will call Mr. Karp to testify as an adverse witness regarding the documents he produced per the Court’s May 7, 2008, Order. May Call 1. Gil Young Heo: Samsung may call Mr. Heo to testify regarding Rambus’s audit of Samsung’s royalties.

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