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Declaration of David C. Yang in Support of Rambus'S Motion To Compel The Deposition of Hynix, Samsung, and Micron On Design-Around and Alternatives As To Gddr5 and Ddr4
Declaration of David C. Yang in Support of Rambus'S Motion To Compel The Deposition of Hynix, Samsung, and Micron On Design-Around and Alternatives As To Gddr5 and Ddr4
Declaration of David C. Yang in Support of Rambus'S Motion To Compel The Deposition of Hynix, Samsung, and Micron On Design-Around and Alternatives As To Gddr5 and Ddr4
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YANG DECL. ISO MTC ON DESIGN-AROUND AND
ALTERNATIVES AS TO GDDR5 AND DDR4;
CASES NOS. C 05-00334, C 05-02298, 06-00244
Case 5:05-cv-00334-RMW Document 2333 Filed 10/02/2008 Page 2 of 4
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RAMBUS INC., CASE NO. C 05-02298 RMW
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Plaintiff,
3 v.
4 SAMSUNG ELECTRONICS CO., LTD., et al,
5 Defendants.
6 RAMBUS INC., CASE NO. C-06-00244 RMW
7 Plaintiff,
8 v.
9 MICRON TECHNOLOGY INC., et al,
10 Defendants.
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YANG DECL. ISO MTC ON DESIGN-AROUND AND
ALTERNATIVES AS TO GDDR5 AND DDR4;
CASES NOS. C 05-00334, C 05-02298, 06-00244
Case 5:05-cv-00334-RMW Document 2333 Filed 10/02/2008 Page 3 of 4
1 alternatives as to the accused features. I indicated that Rambus would review the documents and
2 advise the Manufacturers as to whether Rambus would seek 30(b)(6) testimony on design-around
3 and alternatives as to GDDR5 and DDR4. The Manufacturers agreed that they would not object
4 to any such request on the ground that it was after the August 29, 2008 discovery cutoff. As a
5 result of these agreements, Rambus withdrew its motions.
6 6. Attached as Exhibit C is a true and correct copy of a stipulation concerning
7 various discovery matters filed by the parties on September 16, 2008 and ordered by the Special
8 Master on September 29, 2008.
9 7. Hynix, Samsung, and Micron have each refused to provide a witness to testify
10 regarding design-around efforts and the consideration of alternatives as to GDDR5 and DDR4.
11 Attached as Exhibit D is a true and correct copy of an email I received from Ted Brown, counsel
12 for Hynix, on September 29, 2008. Attached as Exhibit E is a true and correct copy of an email I
13 received from John Beynon, counsel for Micron, on September 30, 2008. Matthew Antonelli,
14 counsel for Samsung, indicated Samsung’s refusal to produce a witness on a teleconference I held
15 with him on October 1, 2008.
16 8. Attached as Exhibit F is a true and correct copy of Rambus’s Notice of Rule
17 30(b)(6) Deposition of Hynix, served on June 19, 2008.
18 9. Attached as Exhibit G is a true and correct copy of Rambus’s Notice of Rule
19 30(b)(6) Deposition of Samsung, served on June 29, 2007.
20 10. Attached as Exhibit H is a true and correct copy of Rambus’s Notice of Rule
21 30(b)(6) Deposition of Samsung, served on June 19, 2008.
22 11. Attached as Exhibit I is a true and correct copy of Rambus’s Notice of Rule
23 30(b)(6) Deposition of Micron, served on June 19, 2008.
24 I declare under penalty of perjury under the laws of the United States that the
25 foregoing is true and correct.
26 Executed this 2nd day of October, 2008 at Los Angeles, California.
27 /s/ David C. Yang
David C. Yang
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YANG DECL. ISO MTC ON DESIGN-AROUND AND
-2- ALTERNATIVES AS TO GDDR5 AND DDR4;
CASES NOS. C 05-00334, C 05-02298, 06-00244