Supplemental Declaration of Jason S. Angell in Support of Nanya and Nanya Usa'S Reply To Rambus Inc.'S Opposition To Nanya and Nanya Usa'S Motion To Compel Licensing Information

Case 5:05-cv-00334-RMW Document 2025 Filed 08/07/2008 Page 1 of 28
1 ROBERT E. FREITAS (STATE BAR NO. 80948)

rfreitas@orrick.com
2 CRAIG R. KAUFMAN (STATE BAR NO. 159458)
ckaufman@orrick.com
3 VICKIE L. FEEMAN (STATE BAR NO. 177487)
vfeeman@orrick.com
4 JASON S. ANGELL (STATE BAR NO. 221607)
jangell@orrick.com
5 ORRICK, HERRINGTON & SUTCLIFFE LLP
1000 Marsh Road
6 Menlo Park, CA 94025
Telephone: 650-614-7400
7 Facsimile: 650-614-7401
8 Attorneys for Defendants and Counterclaim Plaintiffs
NANYA TECHNOLOGY CORPORATION and
9 NANYA TECHNOLOGY CORPORATION USA
10
11 UNITED STATES DISTRICT COURT
12 NORTHERN DISTRICT OF CALIFORNIA
13 SAN JOSE DIVISION
14 RAMBUS INC., Case No. CV-05-00334 RMW

15 Plaintiff, SUPPLEMENTAL DECLARATION
OF JASON S. ANGELL IN SUPPORT
16 v. OF NANYA AND NANYA USA'S
REPLY TO RAMBUS INC.'S
17 HYNIX SEMICONDUCTOR INC.; HYNIX OPPOSITION TO NANYA AND
SEMICONDUCTOR AMERICA, INC.; NANYA USA'S MOTION TO
18 HYNIX SEMICONDUCTOR COMPEL LICENSING
MANUFACTURING AMERICA, INC., INFORMATION
19
SAMSUNG ELECTRONICS CO., LTD., Date: August 11, 2008
20 SAMSUNG ELECTRONICS AMERICA, Time: 4:00 p.m. (by telephone)
INC., SAMSUNG SEMICONDUCTOR, Judge: Hon. Read A. Ambler (Ret.)
21 INC., SAMSUNG AUSTIN
SEMICONDUCTOR, L.P.,
22
NANYA TECHNOLOGY CORPORATION,
23 NANYA TECHNOLOGY CORPORATION
USA,
24
Defendants.
25
26
27
28
SUPPL. DECL OF J. ANGELL ISO REPLY TO NANYA'S
OHS West:260489714.1 MOTION TO COMPEL LICENSING INFORMATION
CV-05-00334 RMW
1 I, Jason S. Angell, declare and state as follows:

2 1. I am an attorney at Orrick, Herrington & Sutcliffe LLP, counsel for Defendants
3 and Counterclaim Plaintiffs Nanya Technology Corporation (“Nanya”) and Nanya Technology
4 Corporation USA (“Nanya USA”) in this matter. The matters set forth herein are based on my
5 own personal knowledge, except where otherwise stated, and in those instances the matters set
6 forth herein are based on information and belief. If called as a witness, I could and would testify
7 competently to the matters set forth herein.
8 2. I am a member in good standing of the State Bar of California and am eligible to
9 practice before state and federal courts.
10 3. Attached hereto as Exhibit 1 is a true and correct copy of excerpts of the transcript
11 from the February 5, 2008 proceedings in the consolidated conduct trial; specifically, the excerpts
12 are from Rambus Inc.’s (“Rambus”) opening statement. The transcript excerpts are followed by
13 true and correct copies of demonstratives Rambus used in the coordinated conduct proceedings
14 and/or served on the Manufacturers.
15 4. Attached hereto as Exhibit 2 are true and correct copies of documents produced by
16 Rambus bearing numbers R475000-005, R4450500-01, and R8089718-21. On information and
17 belief, Rambus prepared these materials for purposes of litigation and contends that they contain
18 information about royalty payments made to Rambus by certain of its licensees. The materials in
19 Exhibit 2 have been designated “Confidential – Outside Counsel Eyes Only” and "Special
20 Confidential/Highly Confidential" by Rambus.
21 5. Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the transcript
22 from the March 15, 2006 proceedings in the Hynix I patent trial; specifically, the excerpts are
23 from Rambus's opening statements.
24 6. Attached hereto as Exhibit 4 is a true and correct copy of the letter dated August 5,
25 2008 from me to Rollin Ransom, counsel for Rambus.
26 7. Attached hereto as Exhibit 5 is a true and correct copy of the letter dated August 7,
27 2008 from Rollin Ransom, counsel for Rambus to me.
28
-1- MOTION TO COMPEL LICENSING INFORMATION
CV-05-00334 RMW
1 I declare under penalty of perjury under the laws of the United States that the foregoing is
2 true and correct. Executed on this 7th day of August, 2008, at Menlo Park, California.
3
4 /s/ Jason S. Angell /s/

Jason S. Angell
5
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MOTION TO COMPEL LICENSING INFORMATION
-2- CV-05-00334 RMW
OHS WEST:260489714.1
Exhibit 1
Exhibit 2
Document Filed Under Seal
Exhibit 3
<;i
1 UNITED STATES DISTRICT COURT
2 NORTHERN DISTRICT OF CALIFORNIA
3 SAN JOSE DIVISION

"z"r"
4
J
5 HYNIX SEMICONDUCTOR INC., ) C’00-20905 RMW
HYNIX SEMICONDUCTOR )
6 AMERICA INC., HYNIX ) SAN JOSE, CALIFORNIA
SEMICONDUCTOR U.K. LTD., )
7 AND HYNIX SEMICONDUCTOR ) MARCH 15, 2006
DEUTSCHLAND GMBH, )
"8 ) VOLUME 1
PLAINTIFFS, )
9: ) PAGES 1-14’4
" VS.
i0 )
RAMBUS, INC., )
ii )
DEFENDANT. ~)
12 )
{i T ¸¯.,.
~r,
13 TRANSCRIPZ OF PROCEEDINGS¯
.. ’~
BEFORE THE HONORABLE RONALD M. WHYTE
14 UNITED STATES ¯DISTRICT JUDGE
15 A P P E A R A N C E S:
16 FOR THE PLAINTIFF: TOWNSEND & ¯TOWNSEND & CREW

BY: THEODORE G. BROWN, III,
17 DANIEL J. FURNISS, AND
JORDAN TRENT JONES
18 379 LYTTON A~ENUE
PALO ALTO, CALIFORNIA 94301
19
THELEN, REID & PRIEST
20 BY: KENNETH L. NISSLY AND:
SusAN VAN KEULEN
21 225 WEST SANTA CLARA STREET
SUITE.1200
22 SAN JOSE, CALIFORNIA 95113
23 APPEARANCES CONTINUED ON NEXT PAGE¯
24 OFFICIAL COURT REPORTER: LEE-ANNE SHORTRIDGE, CSR" CRR

CERTIFICATE NUMBER 9595
25 IRENE RODRIGUEZ, CSR, CRR
CER’TIFICATE NUMBER 8076.
:S~~ ¯
2 APPEARANCES CONTINUED)
4 SHE DEFENDANTf MUNGER, TOLLES & OLSON

BY: GREGORY P. STONE¯
5 355 SOUTH GRAND AVE., 35TH FLOOR
LOS ANGELES, ¯CALIFORNIA 90071
6
BY: PETER A DETRE
7 560 MISSION’ ST , 27TH FLOOR
SAN FRANCISCO, CALIFORNIA 94105
"8
SIDLEY, AUSTIN, LLP
9 BY: V. BRYAN MEDLOCK, JR.
717 NORTH HARWOOD, SUITE 3400
i0 DALLAS, TEXAS 75201
ii DEWEY BALLANTINE
BY: PIERRE J. HUBERT
12 401 CONGRESS AVENUE, SUITE 3200
AUSTIN, TEXAS 78701
13
14
15
16
17
18
19
2O
21
22
23
24
25
2
1 THIS IS NOT A CASE ABOUT RDRAM.
2 THERE WAS SOMETHING INTERESTING ABOUT
3 RAMBUS’S PLANS FOR RDRAM THAT I THINK YOU WILL
4 APPRECIATE. IT WAS -- RAMBUS HAD ALL THESE
5 DIFFERENT IDEAS AND THEY WANTED THEM TO BE USED IN
6 THE BEST WAY. THEY DIDN’T WANT SOMEBODY TO TAKE
7 THEIR IDEAS AND JUST SORT OF USE SOME OF THEM.
18 THEY DIDN’T WANT THEM TO JUST SORT OF CHERRY PICK
9 THE IDEA THEY LIKED AND LEAVE THE OTHER IDEAS OUT
I0 OF IT. THEY WANTED A DEVICE THAT HAD ALL THEIR
ii IDEAS IN IT.
12 SO THEIR LICENSES FOR RDRAM HAD A VERY
13 INTERESTING PROVISION IN THEM, AND THIS IS TRUE OF
14 THE LICENSES, I THINK, OF ALMOST ALL THE COMPANIES
15 TODAY WHO COULD MAKE IT
16 THEY -- THE LICENSES SAID, YOU CAN USE
i7 ALL OF OUR INVENTIONS AND ALL OF OUR PATENTS TO
18 MAKE THE PRODUCT RDRAM, JUST THAT ONE PRODUCT, JUST
19 THAT ONE WAY. YOU CAN’T USE OUR PATENTS AND OUR
20 INVENTIONS TO MAKE OTHER PRODUCTS.
21 SO THEY RESTRICTED THE USE OF IT. THEY
22 SAID OUR PATENTS ALLOW US TO THE EXCLUSIVE RIGHT TO
23 OUR INVENTIONS, AND WE’RE GOING TO SHARE THOSE
24 INVENTIONS WITH YOU ONLY IF YOU USE THEM ONE WAY,
25 THE RDRAM WAY, AND NOT IF YOU USE THEM IN ANY OTHER
65
1 WAYS, AND THAT’S THE LICENSE THAT HYNIX HAS TODAY.
2 BUT RDRAM WAS AHEAD OF ITS TIME. RDRAM
3 WAS GOING AT 500 MEGAHERTZ, AND THAT WAS A LOT
4 FASTER THAN WAS NEEDED.
5 SO WE HAD RDRAM AT 500¯ BUT WE HAD A
6 NEED OUT THERE FOR COMPUTERS IN THE LATER PART OF
7 THE SECOND HALF OF THE ’90S THAT WERE¯ ONLY GOING AT
I8 133 OR 266 MEGAHERTZ. THEY DIDN’T NEED A MEMORY
9 THAT WENT THIS FAST. THEY DIDN’T NEED A MEMORY
I0 THAT WAS THIS FAST AS 500 MEGAHERTZ.
II AND THE PRODUCTS THAT ARE INVOLVED IN
12 THIS CASE ARE PRODUCTS THAT DON’T GO THAT FAST.
13 THE PRODUCTS INVOLVED IN THIS CASE ARE
14 SDRAM AND DDR SDRAM, AND YOU HEARD THOSE IN THE
15 INSTRUCTIONS YOU WERE GIVEN THIS MORNING.
16 THOSE ARE THE PRODUCTS INVOLVED IN THIS
17 CASE.
18 HYNIX DOES NOT HAVE A LICENSE TO MAKE
19 SDRAM OR DDR SDRAM. IT HAS NOT GOTTEN PERMISSION
20 FROM RAMBUS TO DO SO, AND IT ¯DOES NOT PAY A ROYALTY
21 FOR ALL OF THE PRODUCTS THAT IT’S SELLING. THE
22 SDRAM AND DDR PRODUCTS THAT IT SELLS, IT DOESN’T
23 PAY A ROYALTY TO¯RAMBUS.
24 IT WAS OFFERED AN OPPORTUNITy TO TAKE A
25 LICENSE. IT WAS OFFERED AN OPPORTUNITY TO GET
66
1 PERMISSION IN RETURN FOR A ROYALTY AND IT REFUSED.
2 NOW, RDRAM, AS I TOLD YOU, USED MOST OF
3 THE INVENTIONS, AND THAT’S WHAT GOT YOU TO
4 500 MEGAHERTZ.
5 YOU COULD, IF YOU WANTED, USE SOME
6 INVENTIONS AND YOU COULD GET SOME OF THE SPEED,
7 LIKE 133. OR YOU COULD USE MORE OF THE INVENTIONS
!8 AND GET MORE OF THE SPEED, MAYBE 266.
9 IF YOUREMEMBER ONE THING, IF YOU
I0 REMEMBER ONE THING ABOUT MY OPENING STATEMENT,
Ii REMEMBER THIS, REMEMBER THIS ONE THING: IF YOU
12 NEED MORE SPEED, YOU USE MORE INVENTIONS.
/ 13 THE MIRACLE OF WHAT MIKEkFARMWALD AND
14 MARK HOROWITZ DID WAS THEY CAME UP WITH SO MANY
15 DIFFERENT INVENTIONS THAT YOU COULD, IN FACT, USE
16 SOME OF THEM AND GET SOME OF THE BENEFITS AND SOME
17 OF THE SPEED. YOU COULD USE MORE OF THEM AND GET
18 MORE OF THE BENEFITS AND MORE OF THE SPEED. OR YOU
19 COULD USE ALMOST ALL OF THEM AND GET 500 MEGAHERTZ.
2O THE EVIDENCE WILL SHOW THAT THAT’S
21 EXACTLY, EXACTLY WHAT HYNIX DID. THEY TOOK SOME OF
22 THE INVENTIONS AND PUT THEM IN A PRODUCT THEY
23 CALLED SDRAM, AND THEY GOT SOME OF THE SPEED.
24 THEY TOOK MORE OF THE INVENTIONS AND PUT
25 THEM IN A PRODUCT THEY CALLED DDR SDRAM, AND THEY
67
1 GOT MORE OF THE SPEED.
2 AND WHEN DID THIS HAPPEN? THEY STARTED
3 SELLING SDRAM IN 1997. THEY STARTED SELLING DDR
4 SDRAM IN 1999.
5 AS THE COMPUTER INDUSTRY WANTED MORE
6 SPEED, THIS IS WHERE THEY WENT TO GET IT.
7 REMEMBER, THESE ARE THE PRODUCTS THAT THEY HAVE
"8 REFUSED TO PAY A ROYALTY ON.
9 SO WHAT -- WHILE ALL THIS WAS HAPPENING,
I0 WHAT ABOUT THE PATENTS? WHAT ABOUT THE PATENT
ii APPLICATION?
12 WELL, THE PATENT APPLICATION, AND I’M
13 SURE YOU’LL HEAR MORE ABOUT THIS, THE PATENT
14 APPLICATION WAS BEING PROSECUTED IN THE PATENT
15 OFFICE.
16 WHOOPS, I’VE GOT TO WATCH OUT FOR THIS
17 MIKE.
18 AND IN 1999, THE FIRST OF THE PATENTS
19 THAT IS INVOLVED IN THIS CASE AND THE FIRST OF THE
2O PATENTS THAT COVERS THE USE OF THE INVENTIONS IN
21 SDRAM OR DDR SDRAM HAD ISSUED IN 1999.
22 AND BY 2000, RAMBUS FELT THAT IT HAD¯
23 ENOUGH PATENTS THAT IT COULD GO OUT INTO THE WORLD
24 AND SAY TO COMPANIES WHO WERE MAKING THESE
25 PRODUCTS, NOT JUST HYNIX, BUT OTHER COMPANIES, SAY
68
4 CERTIFICATE OF REPORTERS
8 WE, THE UNDERSIGNED OFFICIAL COURT REPORTERS OF THE
9 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF
I0 CALIFORNIA, 280 SOUTH FIRST STREET, SAN JOSE, CALIFORNIA, DO
ii HEREBY CERTIFY:
12 THAT THE FOREGOING TRANSCRIPT, CERTIFICATE INCLUSIVE,
13 CONSTITUTES A TRUE, FULL AND CORRECT TRANSCRIPT OF OUR SHORTHAND
14 NOTES TAKEN AS SUCH OFFICIAL COURT REPORTER OF THE PROCEEDINGS
15 HEREINBEFORE ENTITLED AND REDUCED BY COMPUTER’AIDED
16 TRANSCRIPTION TO THE BEST OF OUR ABILITY.
17
18
19
20
21
22
7LU~E-i~E SH’O-~TI~IDGE,’--~.
23 CERTIFICATE NUMBER 959~-J
24
25
Exhibit 4
Exhibit 5
SIDLEY AUSTIN LLP BEIJING LOS ANGELES

555 WEST FIFTH STREET BRUSSELS NEW YORK
LOS ANGELES, CA 90013 CHICAGO SAN FRANCISCO
(213) 896 6000 DALLAS SHANGHAI
(213) 896 6600 FAX FRANKFURT SINGAPORE
GENEVA SYDNEY
HONG KONG TOKYO
LONDON WASHINGTON, D.C.
rransom@sidley.com
(213) 896-6047 FOUNDED 1866
August 7, 2008
VIA E-MAIL
Jason S. Angell, Esq.

Orrick, Herrington & Sutcliffe LLP
1000 Marsh Road
Menlo Park, California 04025
Re: Rambus Inc. v. Hynix Semiconductor, Inc. (CV-05-0334 RMW)
Dear Jason:
This will respond to your letter dated August 5, in which you ask that Rambus “confirm”
that Nanya has compiled a “complete list” of certain license agreements and “related
agreements” from Rambus’s document production.
As reflected in our opposition to Nanya’s motion to compel, your assertion that “Rambus
does not dispute that it has the ability to simply tell us where in Rambus’s production we may
find the requested information” is simply incorrect. For Rambus to attempt to respond to
Nanya’s inquiry, it would have to undertake the effort of searching and reviewing its production
for the information sought by Nanya, and then compiling its own list of such information. There
is no basis in fact or law to impose upon Rambus the obligation of creating (or confirming) lists
of various categories of documents for its litigation opponent. Rambus would also be forced to
accept the risk that it has a different understanding than Nanya of the ambiguous phrase “licenses
and related agreements” used in your letter, or that it has inadvertently overlooked or failed to
include any particular document. We are unwilling to accept either the burden or the risk
associated with Nanya’s request.
We also repeat another point raised in our opposition brief (which point I also made in
our earlier meet and confer), namely, that Nanya should turn to its co-defendants, rather than its
adversary, in connection with this request. In addition to the Hynix production log about which
Mr. Brown testified (which log I assume Hynix continues to maintain), there are expert reports,
declarations, and exhibit lists that reflect and/or discuss various license agreements to which
Rambus is a party. Nanya should utilize these resources, as well as its own review of Rambus’s
document production, to obtain the information that it seeks, rather than attempting to shift the
burden over to Rambus.
Sidley Austin LLP is a limited liability partnership practicing in affiliation with other Sidley Austin partnerships
Jason S. Angell, Esq.

August 7, 2008
Page 2
Notwithstanding the foregoing, if there are particular, specifically-identified documents

that Nanya has reason to believe have been or should have been produced, but which Nanya is
unable to locate in Rambus’s production, we are willing, within reason, to assist Nanya in
identifying such documents. Indeed, at Micron’s request, we recently directed Micron to three
specifically-identified license agreements that it had been unable to locate. To that end, in your
letter, you indicated that you have been unable to locate Rambus’s recently-announced
agreement with Qimonda. As we have previously advised you, this agreement will be included
in the supplemental production that we will be sending out by the end of this week. As soon as I
can confirm the bates number, I will advise you.
Very truly yours,
/s/
Rollin A. Ransom

Supplemental Declaration of Jason S. Angell in Support of Nanya and Nanya Usa'S Reply To Rambus Inc.'S Opposition To Nanya and Nanya Usa'S Motion To Compel Licensing Information

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Case 5:05-cv-00334-RMW Document 2025 Filed 08/07/2008 Page 1 of 28

1 ROBERT E. FREITAS (STATE BAR NO. 80948)

11 UNITED STATES DISTRICT COURT

12 NORTHERN DISTRICT OF CALIFORNIA

13 SAN JOSE DIVISION

14 RAMBUS INC., Case No. CV-05-00334 RMW

1 I, Jason S. Angell, declare and state as follows:

4 /s/ Jason S. Angell /s/

2 NORTHERN DISTRICT OF CALIFORNIA

3 SAN JOSE DIVISION

16 FOR THE PLAINTIFF: TOWNSEND & ¯TOWNSEND & CREW

23 APPEARANCES CONTINUED ON NEXT PAGE¯

24 OFFICIAL COURT REPORTER: LEE-ANNE SHORTRIDGE, CSR" CRR

4 SHE DEFENDANTf MUNGER, TOLLES & OLSON

1 THIS IS NOT A CASE ABOUT RDRAM.

2 THERE WAS SOMETHING INTERESTING ABOUT

3 RAMBUS’S PLANS FOR RDRAM THAT I THINK YOU WILL

4 APPRECIATE. IT WAS -- RAMBUS HAD ALL THESE

5 DIFFERENT IDEAS AND THEY WANTED THEM TO BE USED IN

6 THE BEST WAY. THEY DIDN’T WANT SOMEBODY TO TAKE

7 THEIR IDEAS AND JUST SORT OF USE SOME OF THEM.

18 THEY DIDN’T WANT THEM TO JUST SORT OF CHERRY PICK

I0 OF IT. THEY WANTED A DEVICE THAT HAD ALL THEIR

12 SO THEIR LICENSES FOR RDRAM HAD A VERY

13 INTERESTING PROVISION IN THEM, AND THIS IS TRUE OF

14 THE LICENSES, I THINK, OF ALMOST ALL THE COMPANIES

15 TODAY WHO COULD MAKE IT

16 THEY -- THE LICENSES SAID, YOU CAN USE

i7 ALL OF OUR INVENTIONS AND ALL OF OUR PATENTS TO

18 MAKE THE PRODUCT RDRAM, JUST THAT ONE PRODUCT, JUST

20 INVENTIONS TO MAKE OTHER PRODUCTS.

21 SO THEY RESTRICTED THE USE OF IT. THEY

22 SAID OUR PATENTS ALLOW US TO THE EXCLUSIVE RIGHT TO

23 OUR INVENTIONS, AND WE’RE GOING TO SHARE THOSE

24 INVENTIONS WITH YOU ONLY IF YOU USE THEM ONE WAY,

1 WAYS, AND THAT’S THE LICENSE THAT HYNIX HAS TODAY.

2 BUT RDRAM WAS AHEAD OF ITS TIME. RDRAM

3 WAS GOING AT 500 MEGAHERTZ, AND THAT WAS A LOT

4 FASTER THAN WAS NEEDED.

5 SO WE HAD RDRAM AT 500¯ BUT WE HAD A

6 NEED OUT THERE FOR COMPUTERS IN THE LATER PART OF

7 THE SECOND HALF OF THE ’90S THAT WERE¯ ONLY GOING AT

I8 133 OR 266 MEGAHERTZ. THEY DIDN’T NEED A MEMORY

9 THAT WENT THIS FAST. THEY DIDN’T NEED A MEMORY

I0 THAT WAS THIS FAST AS 500 MEGAHERTZ.

II AND THE PRODUCTS THAT ARE INVOLVED IN

12 THIS CASE ARE PRODUCTS THAT DON’T GO THAT FAST.

13 THE PRODUCTS INVOLVED IN THIS CASE ARE

14 SDRAM AND DDR SDRAM, AND YOU HEARD THOSE IN THE

15 INSTRUCTIONS YOU WERE GIVEN THIS MORNING.

16 THOSE ARE THE PRODUCTS INVOLVED IN THIS

18 HYNIX DOES NOT HAVE A LICENSE TO MAKE

19 SDRAM OR DDR SDRAM. IT HAS NOT GOTTEN PERMISSION

20 FROM RAMBUS TO DO SO, AND IT ¯DOES NOT PAY A ROYALTY

21 FOR ALL OF THE PRODUCTS THAT IT’S SELLING. THE

22 SDRAM AND DDR PRODUCTS THAT IT SELLS, IT DOESN’T

23 PAY A ROYALTY TO¯RAMBUS.

24 IT WAS OFFERED AN OPPORTUNITy TO TAKE A

25 LICENSE. IT WAS OFFERED AN OPPORTUNITY TO GET

1 PERMISSION IN RETURN FOR A ROYALTY AND IT REFUSED.

2 NOW, RDRAM, AS I TOLD YOU, USED MOST OF

3 THE INVENTIONS, AND THAT’S WHAT GOT YOU TO