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Case 5:05-cv-00334-RMW
1
Document 3045
Filed 01/09/2009
Page 1 of 8
Attorneys Listed on Signature Page
2 3 4 5 6 7 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, 12
SAMSUNG’S REVISED WITNESS LIST FOR JANUARY 19, 2009 TRIAL
v. 13 HYNIX SEMICONDUCTOR INC., et al., 14
Date: Location: Judge:
January 19, 2009 Courtroom 6, 4th floor Hon. Ronald M. Whyte
Defendants. 15 16 RAMBUS, INC., 17 18 19 20
Case No. C 05-02298 RMW
Plaintiff, v. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants.
21 22 23 24 25
RAMBUS, INC., Plaintiff,
Case No. C 06-00244 RMW
v. MICRON TECHNOLOGY INC., et al., Defendants.
26 27 28 SAMSUNG’S SUPPLEMENTAL IDENTIFICATION OF PRIOR ART PURSUANT TO 35 U.S.C. § 282
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
Document 3045
Filed 01/09/2009
Page 2 of 8
Pretrial Statement, Section F January 9, 2009 Case No. 05-00334-RMW; 05-02298-RMW
3
Pursuant to the Court’s Standing Order Re: Pretrial Preparation, Samsung hereby
4
submits this list of witnesses it will call, or may call to testify in the January 2009 Patent Trial in
5
the above captioned cases. The following list supplements the witnesses and intend-to-call / may-
6
call expectations that are identified in the Joint Manufacturers Witness List, incorporated herein
7
by reference, and reflect Samsung’s current expectations regarding which witnesses will and may
8
be called for additional, Samsung-specific live testimony in the validity, infringement, and
9
damages phases of the January 19, 2009 patent trial.
10
This list does not include (1) rebuttal witnesses, (2) witnesses to be called during
11
any trial on issues reserved for the Court, including willfulness, or (3) witnesses that may be
12
called by playing or reading prior sworn testimony. The following witness list was drafted based
13
on Samsung’s current expectations, and Samsung reserves the right to call or not to call any of
14
these witnesses based on Rambus’s witness list, time allocations, resolution of pretrial motions, or
15
other change of circumstance. Samsung expressly reserves the right to play testimony from any
16
listed witness that is unavailable pursuant to Federal Rule of Civil Procedure 32(a)(4). Samsung
17
also reserves the right to use prior testimony in addition to or as an alternative to live testimony,
18
consistent with Federal Rule of Civil Procedure 32 and any other applicable Federal Rule of Civil
19
Procedure or Federal Rule of Evidence.
20 21 22 23 24 25 26 27 28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
2
Case 5:05-cv-00334-RMW
1
Intend to Call Jay Shim J.B. Lee
4 5 6 7 8
Page 3 of 8
May Call depending on arguments made by Rambus: Jon Kang Charles Donohoe Y.H. Choi C.H. Kim K.H. Kyung J.W. Lee Seong Soo Kim Dong Yang Lee Mian Quddus
Infringement Phase Witnesses
9 10
Filed 01/09/2009
Validity Phase Witnesses
2 3
Document 3045
Intend to Call
May Call
J.B. Lee Michael Runas
11 12
Damages Phase Witnesses
13
Intend to Call Jay Shim J.B. Lee W. Christopher Bakewell
14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
May Call depending on arguments made by Rambus: Jon Kang Charles Donohoe Seong Soo Kim
depending on the outcome of pending motions: W.S. Chung Jane Kim Charles Yu Intend to call to establish admissibility of documents:1 Ira Blumberg Steve Chen John Danforth Craig Hampel Gary Harmon Sharon Holt Harold Hughes Avo Kanadjian Joel Karp David Mooring Jared Smith Laura Stark Neil Steinberg Geoff Tate 1
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 the event these witnesses are called live, Samsung reserves the right to elicit testimony on subject matter beyond the admissibility of exhibits as described in the descriptions of testimony for each respective witness below. C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
3
Case 5:05-cv-00334-RMW
1
Document 3045
Filed 01/09/2009
Page 4 of 8
Live Testimony Descriptions
2
Name
Subject Matter of Expected Testimony
3
Bakewell, W. Christopher [Expert Witness]
Rambus’s damages claims; matters relating to the Georgia-Pacific factors; the amount of a reasonable royalty that would have resulted from a hypothetical negotiation between Samsung and Rambus; the reduction of Rambus’s damages claims due to patent exhaustion; and other matters disclosed by Mr. Bakewell during expert discovery. Rambus’s business, Rambus’s licensing practices and agreements, Rambus’s license negotiations, the determination of royalty rates, and the fees and royalties Rambus has received under its license agreements, in addition to subjects discussed during his previous testimony in Rambus-related matters. RDRAM sales and promotion; the DRAM market; and Samsung's promotion of the RDRAM standard. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung’s sales of the Accused Products; and the costs associated with Samsung’s design, development, manufacture, and sale of memory products. Rambus’s business, Rambus’s licensing practices and agreements and Rambus’s license negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, and the DRAM industry, in addition to subjects discussed during his previous testimony in Rambus-related matters. Samsung and Samsung’s memory business and operations; the DRAM market and industry; Samsung’s design and development of memory products; the costs associated with design, development, manufacture, and sale of memory products; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; and Samsung’s licensing practices with Rambus and others in the industry. Rambus’s efforts to cover the JEDEC specification, in addition to subjects discussed during his previous testimony in Rambus-related matters. Rambus’s licenses and licensing practices, the DRAM market and industry, Rambus’s financials, the fees and royalties Rambus has received under its license agreements, and the value of Rambus’s alleged inventions, in addition to subjects discussed during his previous testimony in Rambus-related matters. Rambus’s licenses and licensing practices, the DRAM market and industry, secondary indicia of obviousness in rebuttal, and the value of Rambus’s alleged inventions, in addition to subjects discussed during his previous testimony in Rambus-related matters.
4 5 6
Blumberg, Ira
7 8 Chen, Steve 9 10
Choi, Y.H.
11 12 13 14 15 16
Chung, W.S. Danforth, John
17 18 19
Donohoe, Charles
20 21 22 23 24
Hampel, Craig
Harmon, Gary
25 26 27 28
Holt, Sharon
C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
4
Case 5:05-cv-00334-RMW
1 2
Name Hughes, Harold
3 4 5 6
Kanadjian, Avo Kang, Jon
7 8 9 10
Karp, Joel
11 12 13 14
Kim, C.H.
15 16 17 18 19 20 21 22 23 24 25
Kim, Jane Kim, S.S.
Document 3045
Filed 01/09/2009
Page 5 of 8
Subject Matter of Expected Testimony Rambus’s business, Rambus’s licensing, licensing practices and negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, and the DRAM industry, in addition to subjects discussed during his previous testimony in Rambus-related matters. The relationship and history of Samsung and Rambus; the DRAM market and industry; and Rambus public relations and marketing. Samsung and Samsung’s memory business and operations; the DRAM market and industry; Samsung’s design and development of memory products; the costs associated with design, development, manufacture, and sale of memory products; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; and Samsung’s licensing practices with Rambus and others in the industry. Rambus’s business, Rambus’s licensing practices and agreements, Rambus’s license negotiations, Rambus’s efforts to amend claims to cover JEDEC standards, the determination of royalty rates, Mr. Karp’s relationship with Samsung, Samsung’s JEDEC activities in the mid-90’s, the Samsung-TI litigation, prior art, knowledge of prior art, and disclosure of prior art to the Patent Office, in addition to subjects discussed during his previous testimony in Rambus-related matters. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung’s sales of the Accused Products; and the costs associated with Samsung’s design, development, manufacture, and sale of memory products. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value.
26 27 28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
5
Case 5:05-cv-00334-RMW
1 2
Name Kyung, K.H.
3 4 5 6 7
Lee, D.Y.
8 9 10 11 12
Lee, J.B.
13 14 15 16 17 18
Lee, J.W.
19 20 21 22 23 24 25 26
Mooring, David
Document 3045
Filed 01/09/2009
Page 6 of 8
Subject Matter of Expected Testimony Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; the location and nature of manufacturing and/or testing of Samsung Accused Products; Samsung’s patents; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value; and the use of Samsung’s memory products with third-party memory controllers. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Rambus’s business, Rambus’s licensing practices, licenses, and agreements, Rambus’s licensing negotiations, the determination of royalty rates, dissemination of information regarding Rambus’s technology, the alleged value of Rambus’s inventions, the fees and royalties Rambus has received under its license agreements, and the DRAM industry and economic conditions, in addition to subjects discussed during his previous testimony in Rambus-related matters.
27 28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
6
Case 5:05-cv-00334-RMW
1 2
Name Quddus, Mian
3 4 5 6 7 8
Runas, Michael [Expert Witness]
9 Shim, Jay 10 11 12 13 Smith, Jared 14 Stark, Laura 15 16 17
Page 7 of 8
Subject Matter of Expected Testimony Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Non-infringement of Rambus’s patent claims by the Samsung Accused Products; the lack of evidence regarding alleged indirect infringement by Samsung; and other matters disclosed by Mr. Runas during expert discovery. Samsung and Samsung’s memory business and operations; the DRAM market and industry; Samsung’s design and development of memory products; the costs associated with design, development, manufacture, and sale of memory products; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; and Samsung’s licensing practices with Rambus and others in the industry. RDRAM sales and promotion; the DRAM market; and Samsung's promotion of the RDRAM standard. Rambus’s business, Rambus’s licensing practices and agreements and Rambus’s license negotiations, the determination of royalty rates, and the DRAM industry, in addition to subjects discussed during her previous testimony in Rambus-related matters. Rambus’s business, Rambus’s licensing practices and agreements, Rambus’s licensing negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, prosecution of Rambus’s patents, efforts to amend Rambus’s patents to cover JEDEC standards, prior art, knowledge of prior art, disclosure of prior art to the Patent Office, and Mr. Steinberg’s relationship with Samsung, in addition to subjects discussed during his previous testimony in Rambus-related matters.
Tate, Geoffrey
Rambus’s understanding of its inventions, Rambus’s strategy and efforts to obtain patents on industry standards, Rambus’s business plans, Rambus’s business, Rambus’s licensing practices, licenses and agreements, license negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, the DRAM market and industry, auto precharge, the value of Rambus’s alleged inventions prior art, knowledge of prior art, and disclosure of prior art to the Patent Office, in addition to subjects discussed during his previous testimony in Rambus-related matters. Samsung’s sales of the Accused Products, including the logistics of shipping, warehousing, and inventory management.
19 20 21
23 24 25 26 27
Filed 01/09/2009
Steinberg, Neil
18
22
Document 3045
Yu, Charles
28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
7
Case 5:05-cv-00334-RMW
1
Dated: January 9, 2009
Document 3045
Filed 01/09/2009
Page 8 of 8
WEIL, GOTSHAL & MANGES LLP
2 3
By:
4
MATTHEW D. POWERS (Bar No. 104795) Email: [email protected] STEVEN S. CHERENSKY (Bar No. 168275) Email: [email protected] WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 Facsimile: (650) 802-3100
5 6 7 8 9 10 11 12 13 14
/s/ Matthew D. Powers
ROBERT S. BEREZIN (pro hac vice) Email: [email protected] MATTHEW J. ANTONELLI (pro hac vice) Email: [email protected] WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007
15 16 17 18
Attorneys for Defendants SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR, L.P.
19 20 21 22 23 24 25 26 27 28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
8
1
Document 3045
Filed 01/09/2009
Page 1 of 8
Attorneys Listed on Signature Page
2 3 4 5 6 7 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, 12
SAMSUNG’S REVISED WITNESS LIST FOR JANUARY 19, 2009 TRIAL
v. 13 HYNIX SEMICONDUCTOR INC., et al., 14
Date: Location: Judge:
January 19, 2009 Courtroom 6, 4th floor Hon. Ronald M. Whyte
Defendants. 15 16 RAMBUS, INC., 17 18 19 20
Case No. C 05-02298 RMW
Plaintiff, v. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants.
21 22 23 24 25
RAMBUS, INC., Plaintiff,
Case No. C 06-00244 RMW
v. MICRON TECHNOLOGY INC., et al., Defendants.
26 27 28 SAMSUNG’S SUPPLEMENTAL IDENTIFICATION OF PRIOR ART PURSUANT TO 35 U.S.C. § 282
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
Document 3045
Filed 01/09/2009
Page 2 of 8
Pretrial Statement, Section F January 9, 2009 Case No. 05-00334-RMW; 05-02298-RMW
3
Pursuant to the Court’s Standing Order Re: Pretrial Preparation, Samsung hereby
4
submits this list of witnesses it will call, or may call to testify in the January 2009 Patent Trial in
5
the above captioned cases. The following list supplements the witnesses and intend-to-call / may-
6
call expectations that are identified in the Joint Manufacturers Witness List, incorporated herein
7
by reference, and reflect Samsung’s current expectations regarding which witnesses will and may
8
be called for additional, Samsung-specific live testimony in the validity, infringement, and
9
damages phases of the January 19, 2009 patent trial.
10
This list does not include (1) rebuttal witnesses, (2) witnesses to be called during
11
any trial on issues reserved for the Court, including willfulness, or (3) witnesses that may be
12
called by playing or reading prior sworn testimony. The following witness list was drafted based
13
on Samsung’s current expectations, and Samsung reserves the right to call or not to call any of
14
these witnesses based on Rambus’s witness list, time allocations, resolution of pretrial motions, or
15
other change of circumstance. Samsung expressly reserves the right to play testimony from any
16
listed witness that is unavailable pursuant to Federal Rule of Civil Procedure 32(a)(4). Samsung
17
also reserves the right to use prior testimony in addition to or as an alternative to live testimony,
18
consistent with Federal Rule of Civil Procedure 32 and any other applicable Federal Rule of Civil
19
Procedure or Federal Rule of Evidence.
20 21 22 23 24 25 26 27 28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
2
Case 5:05-cv-00334-RMW
1
Intend to Call Jay Shim J.B. Lee
4 5 6 7 8
Page 3 of 8
May Call depending on arguments made by Rambus: Jon Kang Charles Donohoe Y.H. Choi C.H. Kim K.H. Kyung J.W. Lee Seong Soo Kim Dong Yang Lee Mian Quddus
Infringement Phase Witnesses
9 10
Filed 01/09/2009
Validity Phase Witnesses
2 3
Document 3045
Intend to Call
May Call
J.B. Lee Michael Runas
11 12
Damages Phase Witnesses
13
Intend to Call Jay Shim J.B. Lee W. Christopher Bakewell
14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
May Call depending on arguments made by Rambus: Jon Kang Charles Donohoe Seong Soo Kim
depending on the outcome of pending motions: W.S. Chung Jane Kim Charles Yu Intend to call to establish admissibility of documents:1 Ira Blumberg Steve Chen John Danforth Craig Hampel Gary Harmon Sharon Holt Harold Hughes Avo Kanadjian Joel Karp David Mooring Jared Smith Laura Stark Neil Steinberg Geoff Tate 1
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 the event these witnesses are called live, Samsung reserves the right to elicit testimony on subject matter beyond the admissibility of exhibits as described in the descriptions of testimony for each respective witness below. C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
3
Case 5:05-cv-00334-RMW
1
Document 3045
Filed 01/09/2009
Page 4 of 8
Live Testimony Descriptions
2
Name
Subject Matter of Expected Testimony
3
Bakewell, W. Christopher [Expert Witness]
Rambus’s damages claims; matters relating to the Georgia-Pacific factors; the amount of a reasonable royalty that would have resulted from a hypothetical negotiation between Samsung and Rambus; the reduction of Rambus’s damages claims due to patent exhaustion; and other matters disclosed by Mr. Bakewell during expert discovery. Rambus’s business, Rambus’s licensing practices and agreements, Rambus’s license negotiations, the determination of royalty rates, and the fees and royalties Rambus has received under its license agreements, in addition to subjects discussed during his previous testimony in Rambus-related matters. RDRAM sales and promotion; the DRAM market; and Samsung's promotion of the RDRAM standard. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung’s sales of the Accused Products; and the costs associated with Samsung’s design, development, manufacture, and sale of memory products. Rambus’s business, Rambus’s licensing practices and agreements and Rambus’s license negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, and the DRAM industry, in addition to subjects discussed during his previous testimony in Rambus-related matters. Samsung and Samsung’s memory business and operations; the DRAM market and industry; Samsung’s design and development of memory products; the costs associated with design, development, manufacture, and sale of memory products; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; and Samsung’s licensing practices with Rambus and others in the industry. Rambus’s efforts to cover the JEDEC specification, in addition to subjects discussed during his previous testimony in Rambus-related matters. Rambus’s licenses and licensing practices, the DRAM market and industry, Rambus’s financials, the fees and royalties Rambus has received under its license agreements, and the value of Rambus’s alleged inventions, in addition to subjects discussed during his previous testimony in Rambus-related matters. Rambus’s licenses and licensing practices, the DRAM market and industry, secondary indicia of obviousness in rebuttal, and the value of Rambus’s alleged inventions, in addition to subjects discussed during his previous testimony in Rambus-related matters.
4 5 6
Blumberg, Ira
7 8 Chen, Steve 9 10
Choi, Y.H.
11 12 13 14 15 16
Chung, W.S. Danforth, John
17 18 19
Donohoe, Charles
20 21 22 23 24
Hampel, Craig
Harmon, Gary
25 26 27 28
Holt, Sharon
C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
4
Case 5:05-cv-00334-RMW
1 2
Name Hughes, Harold
3 4 5 6
Kanadjian, Avo Kang, Jon
7 8 9 10
Karp, Joel
11 12 13 14
Kim, C.H.
15 16 17 18 19 20 21 22 23 24 25
Kim, Jane Kim, S.S.
Document 3045
Filed 01/09/2009
Page 5 of 8
Subject Matter of Expected Testimony Rambus’s business, Rambus’s licensing, licensing practices and negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, and the DRAM industry, in addition to subjects discussed during his previous testimony in Rambus-related matters. The relationship and history of Samsung and Rambus; the DRAM market and industry; and Rambus public relations and marketing. Samsung and Samsung’s memory business and operations; the DRAM market and industry; Samsung’s design and development of memory products; the costs associated with design, development, manufacture, and sale of memory products; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; and Samsung’s licensing practices with Rambus and others in the industry. Rambus’s business, Rambus’s licensing practices and agreements, Rambus’s license negotiations, Rambus’s efforts to amend claims to cover JEDEC standards, the determination of royalty rates, Mr. Karp’s relationship with Samsung, Samsung’s JEDEC activities in the mid-90’s, the Samsung-TI litigation, prior art, knowledge of prior art, and disclosure of prior art to the Patent Office, in addition to subjects discussed during his previous testimony in Rambus-related matters. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung’s sales of the Accused Products; and the costs associated with Samsung’s design, development, manufacture, and sale of memory products. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value.
26 27 28 C:\DOCUME~1\MORSE\LOCALS~1\TEMP\NOTES87C577\SAMSUNG WITNESS LIST - JANUARY 2009 PATENT TRIAL_#303271.DOC
5
Case 5:05-cv-00334-RMW
1 2
Name Kyung, K.H.
3 4 5 6 7
Lee, D.Y.
8 9 10 11 12
Lee, J.B.
13 14 15 16 17 18
Lee, J.W.
19 20 21 22 23 24 25 26
Mooring, David
Document 3045
Filed 01/09/2009
Page 6 of 8
Subject Matter of Expected Testimony Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; the location and nature of manufacturing and/or testing of Samsung Accused Products; Samsung’s patents; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value; and the use of Samsung’s memory products with third-party memory controllers. Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Rambus’s business, Rambus’s licensing practices, licenses, and agreements, Rambus’s licensing negotiations, the determination of royalty rates, dissemination of information regarding Rambus’s technology, the alleged value of Rambus’s inventions, the fees and royalties Rambus has received under its license agreements, and the DRAM industry and economic conditions, in addition to subjects discussed during his previous testimony in Rambus-related matters.
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Case 5:05-cv-00334-RMW
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Name Quddus, Mian
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Runas, Michael [Expert Witness]
9 Shim, Jay 10 11 12 13 Smith, Jared 14 Stark, Laura 15 16 17
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Subject Matter of Expected Testimony Samsung and Samsung’s memory business and operations; the DRAM market and industry; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; Samsung’s design and development of memory products, and the technology contained therein; Rambus’s technology, patents, and patent claims; differences between Rambus’s technology and the accused products; the JEDEC standardization process and Samsung’s participation in it; prior art, the accused features, alternatives thereto, and their relative value. Non-infringement of Rambus’s patent claims by the Samsung Accused Products; the lack of evidence regarding alleged indirect infringement by Samsung; and other matters disclosed by Mr. Runas during expert discovery. Samsung and Samsung’s memory business and operations; the DRAM market and industry; Samsung’s design and development of memory products; the costs associated with design, development, manufacture, and sale of memory products; the commercial and licensing relationship between Samsung and Rambus; the scope, and disclosures of what constituted, Rambus’s technology; and Samsung’s licensing practices with Rambus and others in the industry. RDRAM sales and promotion; the DRAM market; and Samsung's promotion of the RDRAM standard. Rambus’s business, Rambus’s licensing practices and agreements and Rambus’s license negotiations, the determination of royalty rates, and the DRAM industry, in addition to subjects discussed during her previous testimony in Rambus-related matters. Rambus’s business, Rambus’s licensing practices and agreements, Rambus’s licensing negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, prosecution of Rambus’s patents, efforts to amend Rambus’s patents to cover JEDEC standards, prior art, knowledge of prior art, disclosure of prior art to the Patent Office, and Mr. Steinberg’s relationship with Samsung, in addition to subjects discussed during his previous testimony in Rambus-related matters.
Tate, Geoffrey
Rambus’s understanding of its inventions, Rambus’s strategy and efforts to obtain patents on industry standards, Rambus’s business plans, Rambus’s business, Rambus’s licensing practices, licenses and agreements, license negotiations, the determination of royalty rates, the fees and royalties Rambus has received under its license agreements, the DRAM market and industry, auto precharge, the value of Rambus’s alleged inventions prior art, knowledge of prior art, and disclosure of prior art to the Patent Office, in addition to subjects discussed during his previous testimony in Rambus-related matters. Samsung’s sales of the Accused Products, including the logistics of shipping, warehousing, and inventory management.
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Filed 01/09/2009
Steinberg, Neil
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Document 3045
Yu, Charles
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Case 5:05-cv-00334-RMW
1
Dated: January 9, 2009
Document 3045
Filed 01/09/2009
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WEIL, GOTSHAL & MANGES LLP
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By:
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MATTHEW D. POWERS (Bar No. 104795) Email: [email protected] STEVEN S. CHERENSKY (Bar No. 168275) Email: [email protected] WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Telephone: (650) 802-3000 Facsimile: (650) 802-3100
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/s/ Matthew D. Powers
ROBERT S. BEREZIN (pro hac vice) Email: [email protected] MATTHEW J. ANTONELLI (pro hac vice) Email: [email protected] WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007
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Attorneys for Defendants SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR, L.P.
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