Case 5:05-cv-00334-RMW Document 2184 Filed 09/12/2008 Page 1 of 4

1 GREGORY P. STONE (#78329)

KEITH HAMILTON (#252115)
2 MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, 35th Floor
3 Los Angeles, CA 90071-1560
Telephone: (213) 683-9100; Facsimile: (213) 687-3702
4 E-mail: gregory.stone@mto.com; keith.hamilton@mto.com
5 BURTON A. GROSS (#166285)
CAROLYN HOECKER LUEDTKE (#207976)
6 MIRIAM KIM (#238230)
MUNGER, TOLLES & OLSON LLP
7 560 Mission Street, 27th Floor
San Francisco, CA 94105-2907
8 Telephone: (415) 512-4000; Facsimile: (415) 512-4077
E-mail: burton.gross@mto.com; carolyn.luedtke@mto.com;
9 miriam.kim@mto.com
10 PIERRE J. HUBERT (Pro Hac Vice)
CRAIG N. TOLLIVER (Pro Hac Vice)
11 McKOOL SMITH PC
300 West 6th Street, Suite 1700
12 Austin, TX 78701
Telephone: (512) 692-8700; Facsimile: (512) 692-8744
13 E-mail: phubert@mckoolsmith.com;
ctolliver@mckoolsmith.com
14
Attorneys for Plaintiff RAMBUS INC.
15

16 UNITED STATES DISTRICT COURT

17 FOR THE NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

18 RAMBUS INC., CASE NO.: C 05-00334 RMW

19 Plaintiff, DECLARATION OF KEITH R. D.
HAMILTON IN SUPPORT OF RAMBUS
20 v. INC.’S OPPOSITION TO SAMSUNG’S
MOTION IN LIMINE TO EXCLUDE
21 HYNIX SEMICONDUCTOR INC., et al., PRIVILEGED DOCUMENTS PRODUCED
PURSUANT TO THE COURT’S IMPLIED
22 Defendants. WAIVER ORDER
23 [EXHIBITS C, D, E, G, I AND J
FILED UNDER SEAL]
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25 Date: September 16, 2008

Time: 2:00 p.m.
26
Location: Courtroom 5
27 Judge: Hon. Ronald M. Whyte

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5909206.1
HAMILTON DECL. I/S/O RAMBUS’S OPPOSITION TO SAMSUNG’S MOTION IN LIMINE TO EXCLUDE PRIVILEGED DOCUMENTS
PRODUCED PURSUANT TO THE COURT’S IMPLIED WAIVER ORDER; CASE NOS. 05-00334-RMW, 05-02298-RMW
 Case 5:05-cv-00334-RMW Document 2184 Filed 09/12/2008 Page 2 of 4

2 RAMBUS INC., CASE NO.: C 05-02298 RMW

3 Plaintiff,
v.
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SAMSUNG ELECTRONICS CO., LTD.,
5 et al.,
Defendants
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5909206.1 -2-
HAMILTON DECL. I/S/O RAMBUS’S OPPOSITION TO SAMSUNG’S MOTION IN LIMINE TO EXCLUDE PRIVILEGED DOCUMENTS
PRODUCED PURSUANT TO THE COURT’S IMPLIED WAIVER ORDER; CASE NOS. 05-00334-RMW, 05-02298-RMW
 Case 5:05-cv-00334-RMW Document 2184 Filed 09/12/2008 Page 3 of 4

1 DECLARATION OF KEITH R. D. HAMILTON

2 I, Keith R. D. Hamilton, do hereby declare and say:
3 1. I am an attorney with the law firm of Munger, Tolles & Olson LLP, counsel of
4 record for Rambus Inc. (“Rambus”) in this case, and am admitted to practice before this Court. I
5 submit this declaration in support of Rambus’s Opposition to Samsung’s Motion in Limine to
6 Exclude Privileged Documents Produced Pursuant to the Court’s Implied Waiver Order. I have
7 personal knowledge of the matters set forth herein and could and would testify competently to
8 each of them.
9 2. Attached as Exhibit A hereto is a true and correct copy of a letter sent by
10 Samsung’s counsel Mr. David Healey to the Court on November 2, 2007.
11 3. Attached as Exhibit B hereto is a true and correct copy of excerpts from the
12 December 13, 2007 hearing transcript in the above-captioned matters.
13 4. Attached as Exhibit C hereto is a true and correct copy of excerpts of the July 25,
14 2008 deposition of Han Yong Uhm. This exhibit is submitted under seal because it has been
15 designated “Confidential - Outside Counsel Only” pursuant to the protective order entered in the
16 above-captioned cases on June 21, 2007.
17 5. Attached as Exhibit D hereto is a true and correct copy of excerpts of the May 13,
18 2008 deposition of Charles Donohoe. This exhibit is submitted under seal because it has been
19 designated “Confidential - Outside Counsel Only” pursuant to the protective order entered in the
20 above-captioned cases on June 21, 2007.
21 6. Attached as Exhibit E hereto is a true and correct copy of excerpts of the May 14,
22 2008 deposition of Charles Donohoe. This exhibit is submitted under seal because it has been
23 designated “Confidential - Outside Counsel Only” pursuant to the protective order entered in the
24 above-captioned cases on June 21, 2007.
25 7. Attached as Exhibit F hereto is a true and correct copy of excerpts of the July 17,
26 2008 deposition of Jun Sung Park.
27 8. Attached as Exhibit G hereto is a true and correct copy of excerpts of the June 9,
28 2008 deposition of Jay Shim. This exhibit is submitted under seal because it has been designated
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5909206.1
HAMILTON DECL. I/S/O RAMBUS’S OPPOSITION TO SAMSUNG’S MOTION IN LIMINE TO EXCLUDE PRIVILEGED DOCUMENTS
PRODUCED PURSUANT TO THE COURT’S IMPLIED WAIVER ORDER; CASE NOS. 05-00334-RMW, 05-02298-RMW
 Case 5:05-cv-00334-RMW Document 2184 Filed 09/12/2008 Page 4 of 4

1 “Confidential - Outside Counsel Only” pursuant to the protective order entered in the above-
2 captioned cases on June 21, 2007.
3 9. Attached as Exhibit H hereto is a true and correct copy of excerpts of the July 16,
4 2008 deposition of Jun Sung Park.
5 10. Attached as Exhibit I hereto is a true and correct copy of excerpts of the July 28,
6 2008 deposition of Jinseong Park. This exhibit is submitted under seal because it has been
7 designated “Confidential - Outside Counsel Only” pursuant to the protective order entered in the
8 above-captioned cases on June 21, 2007.
9 11. Attached as Exhibit I hereto is a true and correct copy of excerpts of the July 24,
10 2008 deposition of Jeong Woo Lee. This exhibit is submitted under seal because it has been
11 designated “Confidential - Outside Counsel Only” pursuant to the protective order entered in the
12 above-captioned cases on June 21, 2007.
13

14 I declare under penalty of perjury under the laws of the United States that the
15 foregoing is true and correct.
16 Executed this 12th day of September, 2008 at Los Angeles, California.
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________/s/ Keith R.D. Hamilton________
18 Keith R. D. Hamilton
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5909206.1 --2--
HAMILTON DECL. I/S/O RAMBUS’S OPPOSITION TO SAMSUNG’S MOTION IN LIMINE TO EXCLUDE PRIVILEGED DOCUMENTS
PRODUCED PURSUANT TO THE COURT’S IMPLIED WAIVER ORDER; CASE NOS. 05-00334-RMW, 05-02298-RMW