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Transport Room

Transport Room

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Published by sabatino123

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Published by: sabatino123 on Dec 19, 2012
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12/21/2012

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IN THEUNITED STATES COURT OF APPEALSFOR THE FEDERAL CIRCUIT
 RAMBUS
 
INC.,
 
 Appellant 
,v.INTERNATIONAL
 
TRADE
 
COMMISSION,
 Appellee
,andGARMIN INTERNATIONAL, INC., LSICORPORATION, SEAGATE TECHNOLOGYLLC, STMICROELECTRONICS N.V.,STMICROSELECTRONICS INC., CISCOSYSTEMS, INC., HGST, INC., and HEWLETT-PACKARD COMPANY,
 Intervenors.
 No. 2012-1677
APPELLANT RAMBUS INC.’S PARTIALLY UNOPPOSEDMOTION FOR A 60-DAY EXTENSION OF TIMETO FILE ITS OPENING BRIEF
Pursuant to Federal Rule of Appellate Procedure 26(b) and this Court’sLocal Rule 26(b), Appellant Rambus Inc. respectfully moves for a 60-dayextension of time to file its opening brief. The opening brief is currently due onJanuary 7, 2013. If this motion is granted, the opening brief will be due on March8, 2013. Appellant Rambus has not previously sought an extension for its opening brief. Counsel for Appellant Rambus has informed Appellee International Trade
Case: 12-1677 Document: 73 Page: 1 Filed: 12/17/2012
 
 2Commission and the Intervenors of the extension request. The International TradeCommission and Intervenors Garmin International, Inc. and HGST, Inc. haveindicated that they do not oppose the motion. Intervenors LSI Corporation,Seagate Technology LLC, STMicroelectronics N.V., STMicroelectronics Inc.,Cisco Systems, Inc., and Hewlett-Packard Company offered no response toRambus’s requests for consent to the motion.The case is an appeal from a final determination of the International TradeCommission (the “Commission”), in an investigation concerning U.S. Patent Nos.6,470,405, 6,591,353, 7,287,109, 7,602,857, 7,602,858, and 7,715,494. The appealinvolves complex technological and legal issues, and the underlying record isextremely large. For example: The hearing before the Commission lasted sevendays and produced 2,577 transcript pages; there are 8,745 admitted exhibits thattake up 19.5 GB of hard drive space; and the Certified List itself is 172 pages longand lists 780 documents. Lead counsel in this Court did not participate in the proceedings before the Commission and was retained only afterward for purposesof this appeal.The additional time is necessary for counsel of record to further familiarizehimself with the legal and factual issues raised by this case, and because counselhas been heavily engaged with the press of other matters. The additional time isalso necessary because of the proximity of the current due date to the holiday period. Several of Rambus’s attorneys with significant responsibility for the
Case: 12-1677 Document: 73 Page: 2 Filed: 12/17/2012
 
 3appeal will be traveling during the holidays with limited availability, and Rambusitself will be closed in the week between Christmas and New Year’s. Pursuant tothis Court’s Local Rule 26(b)(5), a declaration in support of this motion isattached.Accordingly, Appellant Rambus respectfully requests a 60-day extension of time to file its opening brief, to and including March 8, 2013.December 17, 2012 Respectfully submitted,/s/ Jeffrey A. LamkenJeffrey A. Lamken
Counsel of Record 
 M
OLO
L
AMKEN
LLPThe Watergate, Suite 660600 New Hampshire Avenue, N.W.Washington, D.C. 20037(202) 556-2000 (telephone)(202) 556-2001 (facsimile) jlamken@mololamken.com
Counsel for Appellant Rambus Inc.
Case: 12-1677 Document: 73 Page: 3 Filed: 12/17/2012

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