2132

This document is a stipulation between Rambus and Samsung agreeing that Samsung can file an opposition brief up to 30 pages in response to Rambus's 18.5 page motion. Rambus had filed a motion in limine to bar the use of privileged evidence at the upcoming trial. Samsung, having its first opportunity to respond to Rambus's arguments, requested additional pages for its opposition brief, to which Rambus agreed. The parties then submitted this stipulation and proposed order to the court requesting approval of the extended page limit.

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2132

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Case 5:05-cv-00334-RMW Document 2132 Filed 09/04/2008 Page 1 of 3

7
IN THE UNITED STATES DISTRICT COURT
8
NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION
9

10 RAMBUS, INC., Case No. C 05-00334 RMW

11 Plaintiff.
v. STIPULATION AND PROPOSED
12 ORDER TO EXCEED PAGE LIMIT FOR
HYNIX SEMICONDUCTOR INC., HYNIX OPPOSITION TO RAMBUS’S MOTION
13 SEMICONDUCTOR AMERICA INC., HYNIX IN LIMINE TO BAR USE OF
SEMICONDUCTOR MANUFACTURING PRIVILEGED EVIDENCE AT
14 AMERICA INC., SEPTEMBER 22, 2008 TRIAL
15 SAMSUNG ELECTRONICS CO., LTD.,
SAMSUNG ELECTRONICS AMERICA, INC.,
16 SAMSUNG SEMICONDUCTOR, INC.,
SAMSUNG AUSTIN SEMICONDUCTOR,
17 L.P.,
18 NANYA TECHNOLOGY CORPORATION,
NANYA TECHNOLOGY CORPORATION
19 U.S.A.,
20
Defendants.
21 RAMBUS, INC.,
Case No. C 05-02298 RMW
22 Plaintiff.
v.
23
SAMSUNG ELECTRONICS CO., LTD.,
24 SAMSUNG ELECTRONICS AMERICA, INC.,
SAMSUNG SEMICONDUCTOR, INC.,
25 SAMSUNG AUSTIN SEMICONDUCTOR,
L.P.,
26
Defendants.
27

28
Case No. C 05 00334 RMW
Stipulation and Proposed Order To Exceed Page Limit Case No. C 05 02298 RMW
Case 5:05-cv-00334-RMW Document 2132 Filed 09/04/2008 Page 2 of 3

1 WHEREAS, Rambus filed a Motion In Limine to Bar Use of Privileged Evidence at

2 September 22, 2008 Trial on August 27, 2008; and

3 WHEREAS, Rambus’s eighteen and a half-page motion incorporated by reference

4 portions of two of its previous briefs (its motion in limine from the January 2008 coordinated trial

5 and its motion to strike filed June 2008), thus effectively resulting in a much longer brief;

6 WHEREAS, this is Samsung’s first opportunity to respond to Rambus’s arguments on this

7 issue;

8 WHEREAS, Samsung intends to file an Opposition to Rambus’ Motion in Limine; and

9 WHEREAS, Rambus has agreed to Samsung’s request for five additional pages for its

10 Opposition;

11 NOW, THEREFORE, the parties stipulate and agree as follows:

12 Samsung’s opposition brief shall be no longer than 30 pages.

14
DATED: September 4, 2008 CAROLYN HOECKER LUEDTKE
15 MUNGER, TOLLES & OLSON LLP
16

17
By: /s/ _____________________________
18 Carolyn Hoecker Luedtke
19 ATTORNEY FOR RAMBUS INC.
20
DATED: September 4, 2008 DAVID J. HEALEY
21 WEIL, GOTSHAL & MANGES LLP
22

23
By: /s/______________________________
24 David J. Healey
25 Attorney for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
26 AMERICA, INC., SAMSUNG
SEMICONDUCTOR, INC., and SAMSUNG
27 AUSTIN SEMICONDUCTOR, L.P.
28