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GREGORY P. STONE (SBN 078329) gregory.stone@mto.com KATHERINE K. HUANG (SBN 219798) katherine.huang@mto.com PETER E. GRATZINGER (SBN 228764) peter.gratzinger@mto.com KEITH R.D. HAMILTON (SBN 252115) keith.hamilton@mto.com DAVID H. PENNINGTON (SBN 272238) david.pennington@mto.com MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071-1560 Telephone: (213) 683-9100 Facsmile: (213) 687-3702 PETER A. DETRE (SBN 182619) peter.detre@mto.com MUNGER, TOLLES & OLSON LLP 560 Mission Street, 27th Floor San Francisco, CA 94105 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 Attorneys for Plaintiff RAMBUS INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION RAMBUS INC., Plaintiff, v. LSI CORPORATION, Defendant. RAMBUS INC., Plaintiff, v. STMICROELECTRONICS N.V.; STMICROELECTRONICS INC., Defendants.
DETRE DECL. IN SUPPORT OF RAMBUSS REPLY CLAIM CONSTRUCTION BRIEF CASE NOS. 3:10-CV-05446, 3:10-CV-05449

Case No. 3:10-cv-05446 RS DECLARATION OF PETER A. DETRE IN SUPPORT OF RAMBUS INC.S REPLY TO DEFENDANTS RESPONSIVE CLAIM CONSTRUCTION BRIEF

Case No. 3:10-cv-05449 RS

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I, Peter A. Detre, declare as follows: 1. I am an attorney with the law firm of Munger, Tolles & Olson LLP, counsel for

Rambus Inc. in the above-captioned actions. The contents of this declaration are within my personal knowledge or are matters of public record, and, if called as a witness, I could and would testify competently thereto. 2. Attached hereto as Exhibit A is a document containing the text of the 35 claims

from the Farmwald/Horowitz patents that are currently asserted in these cases. Claims in italics are not among the asserted claims, but are included because asserted claims depend from them. 3. Attached hereto as Exhibit B is a true and correct copy of excerpts from the

deposition of Robert Murphy, taken on April 25, 2005, in Hynix Semiconductor Inc., et al. v. Rambus Inc., No. 00-cv-20905-RMW (N.D. Cal.) (Hynix I). 4. Attached hereto as Exhibit C is a true and correct copy of Exhibit B to LSI

Corporations Patent Local Rule Preliminary Invalidity Contentions, served on March 30, 2012. 5. Attached hereto as Exhibit D is a true and correct copy of Exhibit B to

STMicroelectronics N.V. and STMicroelectronics Inc.s Patent Local Rule 3-3 and 3-4 Invalidity Contentions, served on March 30, 2012. 6. Attached hereto as Exhibit E is a true and correct copy of excerpts from the

deposition of Steven Przybylski, taken on August 18, 2011, in In the Matter of Certain Semiconductor Chips and Products Containing Same, ITC Investigation No. 337-TA-753. 7. Attached hereto as Exhibit F is a true and correct copy of excerpts from the

NextBus Specification, as produced by STMicrolectronics in this litigation. 8. Attached hereto as Exhibit G is a true and correct copy of an excerpt from Joint

Appendix A to the Joint Claim Construction and Prehearing Statement filed on July 11, 2007, by the parties in Rambus Inc. v. Hynix Semiconductor Inc., et al., No. 05-cv-00334-RMW (N.D. Cal.); Rambus Inc. v. Samsung Electronics Co. Ltd. et al., No. 05-cv-02298-RMW (N.D. Cal.); and Rambus Inc. v. Micron Technology, Inc. et al., No. 06-cv-00244-RMW (N.D. Cal.) (the Coordinated Actions).

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DETRE DECL. IN SUPPORT OF RAMBUSS REPLY CLAIM CONSTRUCTION BRIEF CASE NOS. 3:10-CV-05446, 3:10-CV-05449

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9.

Attached hereto as Exhibit H is a true and correct copy of an excerpt from Betty

Prince, High Performance Memories (1996). 10. Attached hereto as Exhibit I is a true and correct copy of the Federal Circuits

opinion in In re Rambus Inc., No. 2011-1247, issued on August 15, 2012.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that this declaration was executed on August 15, 2012, at San Francisco, California.

DATED: August 15, 2012 By: /s/ Peter A. Detre PETER A. DETRE

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DETRE DECL. IN SUPPORT OF RAMBUSS REPLY CLAIM CONSTRUCTION BRIEF CASE NOS. 3:10-CV-05446, 3:10-CV-05449