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Case 5:05-cv-00334-RMW
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Document 2540
Attorneys for Defendants and Counterclaim Plaintiffs NANYA TECHNOLOGY CORPORATION and NANYA TECHNOLOGY CORPORATION U.S.A. UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
12 13 14 15 16 17 18 19 20 21 22
Page 1 of 3
ROBERT E. FREITAS (STATE BAR NO. 80948) CRAIG R. KAUFMAN (STATE BAR NO. 159458) VICKIE L. FEEMAN (STATE BAR NO. 177487) KRISTIN S. CORNUELLE (STATE BAR NO. 245728) ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 Facsimile: 650-614-7401
8
11
Filed 11/14/2008
SAN JOSE DIVISION RAMBUS INC.,
Case No. CV-05-00334 RMW Plaintiff,
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.,
DECLARATION OF KRISTIN S. CORNUELLE IN SUPPORT OF MANUFACTURERS’ OPPOSITION TO RAMBUS INC.’S DAUBERT NO. 2 AND MOTION IN LIMINE TO EXCLUDE CERTAIN TESTIMONY OF PETER HEUSER Date: Time: Location: Judge:
December 11, 2008 2:00 p.m. Courtroom 6 Hon. Ronald M. Whyte
NANYA TECHNOLOGY CORPORATION, NANYA TECHNOLOGY CORPORATION U.S.A., Defendants.
23 24
AND RELATED ACTIONS.
25 26 27 28
DECL. OF KRISTIN CORNUELLE ISO MFGS’ OPPO CASE NO. C 05 00334 RMW; CASE NO. C 05 02298 RMW; CASE NO. C 06 00244 RMW
Case 5:05-cv-00334-RMW
Document 2540
Filed 11/14/2008
1
I, Kristin S. Cornuelle, declare as follows:
2
1.
Page 2 of 3
I am an attorney admitted to practice in the State of California and the U.S.
3
District Court for the Northern District of California. I am an associate with Orrick, Herrington
4
& Sutcliffe LLP, counsel of record for Defendants and Counterclaim Plaintiffs Nanya
5
Technology Corporation (“NTC”) and Nanya Technology Corporation USA (“Nanya USA”).
6
I have personal knowledge of the facts set forth in this declaration and, if called to testify as a
7
witness, could and would do so under oath.
8 9 10
1.
Attached hereto as Exhibit A is a true and correct copy of excerpts from
Mr. Peter Heuser’s deposition testimony in the above-captioned case, dated October 14, 2008. 2.
Attached hereto as Exhibit B is a true and correct copy of excerpts from the
11
Markman hearing in Rambus, Inc. v. Infineon Technologies AG, Civil Action No. 3:00cv524
12
(Eastern District of Virginia), dated February 26, 2001.
13
3.
Attached hereto as Exhibit C is a true and correct copy of an excerpt from
14
the trial transcript in Rambus, Inc. v. Infineon Technologies AG, Civil Action No. 3:00cv524
15
(Eastern District of Virginia), dated April 24, 2001.
16
4.
Attached hereto as Exhibit D is a true and correct copy of excerpts from the
17
trial transcript in Hynix Semiconductor Inc. v. Rambus, Inc. (Hynix I), Civil Case No. C-00-20905
18
RMW (Northern District of California), dated April 12, 2006.
19 20 21
5.
Attached hereto as Exhibit E is a true and correct copy of an excerpt from
the trial transcript in the above-captioned case, dated March 11, 2008. 6.
Attached hereto as Exhibit F is a true and correct copy of excerpts from the
22
trial transcript in Rambus, Inc. v. Infineon Technologies AG, Civil Action No. 3:00cv524 (Eastern
23
District of Virginia), dated April 23, 2001 and May 8, 2001.
24
7.
Attached hereto as Exhibit G is a true and correct copy of excerpts from the
25
trial transcript in Hynix Semiconductor Inc. v. Rambus, Inc. (Hynix I), Civil Case No. C-00-20905
26
RMW (Northern District of California), dated March 15, 2006 and April 13, 2006.
27 28 1
DECL. OF KRISTIN CORNUELLE ISO MFGS’ OPPO CASE NO. C 05 00334 RMW; CASE NO. C 05 02298 RMW; CASE NO. C 06 00244 RMW
Case 5:05-cv-00334-RMW
1 2
8.
Document 2540
Filed 11/14/2008
Page 3 of 3
Attached hereto as Exhibit H is a true and correct copy of an excerpt from
the trial transcript in the above-captioned case, dated March 25, 2008.
3
9.
I viewed the video entitled “An Introduction to the Patent System”
4
produced by the Federal Judicial Center in 2002. The video contains no discussion of restriction
5
requirements, nor does it provide any background as they relate to Patent and Trademark Office
6
procedure.
7 8 9
I declare under penalty of perjury of the laws of the Unites States of America that the foregoing is true and correct to the best of my knowledge. Executed this the 14th day of November, 2008 in Menlo Park, California.
10
/s/ Kristin S. Cornuelle Kristin S. Cornuelle
11 12
OHS West:260551124.1
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
DECL. OF KRISTIN CORNUELLE ISO MFGS’ OPPO CASE NO. C 05 00334 RMW; CASE NO. C 05 02298 RMW; CASE NO. C 06 00244 RMW
1 2 3 4 5 6 7
Document 2540
Attorneys for Defendants and Counterclaim Plaintiffs NANYA TECHNOLOGY CORPORATION and NANYA TECHNOLOGY CORPORATION U.S.A. UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
12 13 14 15 16 17 18 19 20 21 22
Page 1 of 3
ROBERT E. FREITAS (STATE BAR NO. 80948) CRAIG R. KAUFMAN (STATE BAR NO. 159458) VICKIE L. FEEMAN (STATE BAR NO. 177487) KRISTIN S. CORNUELLE (STATE BAR NO. 245728) ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 Facsimile: 650-614-7401
8
11
Filed 11/14/2008
SAN JOSE DIVISION RAMBUS INC.,
Case No. CV-05-00334 RMW Plaintiff,
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.,
DECLARATION OF KRISTIN S. CORNUELLE IN SUPPORT OF MANUFACTURERS’ OPPOSITION TO RAMBUS INC.’S DAUBERT NO. 2 AND MOTION IN LIMINE TO EXCLUDE CERTAIN TESTIMONY OF PETER HEUSER Date: Time: Location: Judge:
December 11, 2008 2:00 p.m. Courtroom 6 Hon. Ronald M. Whyte
NANYA TECHNOLOGY CORPORATION, NANYA TECHNOLOGY CORPORATION U.S.A., Defendants.
23 24
AND RELATED ACTIONS.
25 26 27 28
DECL. OF KRISTIN CORNUELLE ISO MFGS’ OPPO CASE NO. C 05 00334 RMW; CASE NO. C 05 02298 RMW; CASE NO. C 06 00244 RMW
Case 5:05-cv-00334-RMW
Document 2540
Filed 11/14/2008
1
I, Kristin S. Cornuelle, declare as follows:
2
1.
Page 2 of 3
I am an attorney admitted to practice in the State of California and the U.S.
3
District Court for the Northern District of California. I am an associate with Orrick, Herrington
4
& Sutcliffe LLP, counsel of record for Defendants and Counterclaim Plaintiffs Nanya
5
Technology Corporation (“NTC”) and Nanya Technology Corporation USA (“Nanya USA”).
6
I have personal knowledge of the facts set forth in this declaration and, if called to testify as a
7
witness, could and would do so under oath.
8 9 10
1.
Attached hereto as Exhibit A is a true and correct copy of excerpts from
Mr. Peter Heuser’s deposition testimony in the above-captioned case, dated October 14, 2008. 2.
Attached hereto as Exhibit B is a true and correct copy of excerpts from the
11
Markman hearing in Rambus, Inc. v. Infineon Technologies AG, Civil Action No. 3:00cv524
12
(Eastern District of Virginia), dated February 26, 2001.
13
3.
Attached hereto as Exhibit C is a true and correct copy of an excerpt from
14
the trial transcript in Rambus, Inc. v. Infineon Technologies AG, Civil Action No. 3:00cv524
15
(Eastern District of Virginia), dated April 24, 2001.
16
4.
Attached hereto as Exhibit D is a true and correct copy of excerpts from the
17
trial transcript in Hynix Semiconductor Inc. v. Rambus, Inc. (Hynix I), Civil Case No. C-00-20905
18
RMW (Northern District of California), dated April 12, 2006.
19 20 21
5.
Attached hereto as Exhibit E is a true and correct copy of an excerpt from
the trial transcript in the above-captioned case, dated March 11, 2008. 6.
Attached hereto as Exhibit F is a true and correct copy of excerpts from the
22
trial transcript in Rambus, Inc. v. Infineon Technologies AG, Civil Action No. 3:00cv524 (Eastern
23
District of Virginia), dated April 23, 2001 and May 8, 2001.
24
7.
Attached hereto as Exhibit G is a true and correct copy of excerpts from the
25
trial transcript in Hynix Semiconductor Inc. v. Rambus, Inc. (Hynix I), Civil Case No. C-00-20905
26
RMW (Northern District of California), dated March 15, 2006 and April 13, 2006.
27 28 1
DECL. OF KRISTIN CORNUELLE ISO MFGS’ OPPO CASE NO. C 05 00334 RMW; CASE NO. C 05 02298 RMW; CASE NO. C 06 00244 RMW
Case 5:05-cv-00334-RMW
1 2
8.
Document 2540
Filed 11/14/2008
Page 3 of 3
Attached hereto as Exhibit H is a true and correct copy of an excerpt from
the trial transcript in the above-captioned case, dated March 25, 2008.
3
9.
I viewed the video entitled “An Introduction to the Patent System”
4
produced by the Federal Judicial Center in 2002. The video contains no discussion of restriction
5
requirements, nor does it provide any background as they relate to Patent and Trademark Office
6
procedure.
7 8 9
I declare under penalty of perjury of the laws of the Unites States of America that the foregoing is true and correct to the best of my knowledge. Executed this the 14th day of November, 2008 in Menlo Park, California.
10
/s/ Kristin S. Cornuelle Kristin S. Cornuelle
11 12
OHS West:260551124.1
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
DECL. OF KRISTIN CORNUELLE ISO MFGS’ OPPO CASE NO. C 05 00334 RMW; CASE NO. C 05 02298 RMW; CASE NO. C 06 00244 RMW
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