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Published by Tim Pescatello

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Published by: Tim Pescatello on Jun 07, 2013
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04395.52001/5349452.3
 
Case No. Case No. C 10-05449
 
DECLARATION OF ROBERT J. BECHER IN SUPPORT OF
STMICRO’S
 MOTION FOR PARTIAL SUMMARY JUDGMENT
K&L GATES LLPMichael J. Bettinger (Bar No. 122196)mike.bettinger@klgates.comStephen M. Everett (Bar No. 121619)stephen.everett@klgates.comCurt Holbreich (Bar No. 168053)curt.holbreich@klgates.comElaine Y. Chow (State Bar No. 194063)elaine.chow@klgates.comFour Embarcadero Center, Suite 1200San Francisco, CA 94111Tel: (415) 882-8200Fax: (415) 882-8220QUINN EMANUEL URQUHART &SULLIVAN, LLPSean Pak (Bar No. 219032)seanpak@quinnemanuel.comPeter A. Klivans (Bar No. 236673) peterklivans@quinnemanuel.com50 California Street, 22
nd
Floor San Francisco, California 94111-4788Telephone: (415) 875-6600Facsimile: (415) 875-6700QUINN EMANUEL URQUHART &SULLIVAN, LLPMichael D. Powell (Bar No. 202850)mikepowell@quinnemanuel.com555 Twin Dolphin Drive, 5
th
Floor Redwood Shores, CA 94065Telephone: (650) 801-5000Facsimile: 650 801-5100QUINN EMANUEL URQUHART &SULLIVAN, LLPThomas D. Pease (admitted
 pro hac vice
)thomaspease@quinnemanuel.com51 Madison Avenue, 22
nd
Floor  New York, NY 10010Telephone: (212) 849-7000Facsimile: (212) 849-7100QUINN EMANUEL URQUHART &SULLIVAN, LLPRobert J. Becher (Bar No. 193431)robertbecher@quinnemanuel.com865 S. Figueroa St., 10th Floor Los Angeles, California 90017Telephone: (213) 443-3000Facsimile: (213) 443-3100Attorneys for Defendants & CounterclaimantsSTMICROELECTRONICS N.V. andSTMICROELECTRONICS, INC.UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISIONRAMBUS INC.,Plaintiff,vs.STMICROELECTRONICS N.V.;STMICROELECTRONICS INC.,Defendants.CASE NO. C 10-05449
DECLARATION OF ROBERT J. BECHER IN SUPPORT OFSTMICROELECTRONICS
NOTICE OFMOTION AND MOTION FOR PARTIALSUMMARY JUDGMENT ESTABLISHINGCERTAIN FINDINGS REGARDINGRAMBUS
S UNCLEAN HANDS BASEDON COLLATERAL ESTOPPEL
Date: July 11, 2013Time: 1:30 pmCrtrm.: Courtroom 3, 17
th
Floor 
Case3:10-cv-05449-RS Document179 Filed06/06/13 Page1 of 6
 
12345678910111213141516171819202122232425262728
04395.52001/5349452.3
 
Case No. Case No. C 10-05449
 
DECLARATION OF ROBERT J. BECHER IN SUPPORT OF STMICRO’S
MOTION FOR PARTIAL SUMMARY JUDGMENT
 
DECLARATION OF ROBERT J. BECHER 
I, Robert J. Becher, declare as follows:1. I am a member of the bar of the State of California and a member of QuinnEmanuel Urquhart & Sullivan LLP, attorneys for defendants & counterclaimantsSTMicroelectronics N.V. and STMicroelectronics Inc. I make this declaration of personal,firsthand knowledge, and if called and sworn as a witness, I could and would testify competentlythereto.2. On November 8-9 and 13-15, 2007, the Honorable Sue L. Robinson held a benchtrial on the first phase of the
 Micron Technology, Inc. v. Rambus Inc.
, Case No. 00-792 (D. Del.)action, which addressed Rambus
s spoliation of evidence and Micron
s affirmative defense of unclean hands. Almost three hundred exhibits were admitted into evidence during the phase onetrial. Attached as Exhibit A is a true and correct copy of the Joint List of Admitted Exhibits
 – 
 Unclean Hands Trial, dated December 6, 2007, from the Delaware action.3. Additionally, the Court heard testimony during trial (either live or by deposition)from more than twenty witnesses including from Rambus witnesses who live beyond the subpoena power of the Delaware court (such as Joel Karp, Lester Vincent, Sean Cunningham, Allen Robertsand Dan Johnson). A true and correct copy of excerpts from the reporter 
s transcript of theDelaware trial on November 8, 2007 is attached as Exhibit B.4. A true and correct copy of excerpts from the reporter 
s transcript of the Delawaretrial on November 9, 2007 is attached as Exhibit C.5. A true and correct copy of excerpts from the reporter 
s transcript of the Delawaretrial on November 13, 2007 is attached as Exhibit D.6. A true and correct copy of excerpts from the reporter 
s transcript of the Delawaretrial on November 14, 2007 is attached as Exhibit E.7. A true and correct copy of excerpts from the reporter 
s transcript of the Delawaretrial on November 15, 2007 is attached as Exhibit F.
Case3:10-cv-05449-RS Document179 Filed06/06/13 Page2 of 6
 
12345678910111213141516171819202122232425262728
04395.52001/5349452.3
 -3-
Case No. Case No. C 10-05449
 
DECLARATION OF ROBERT J. BECHER IN SUPPORT OF STMICRO’S
MOTION FOR PARTIAL SUMMARY JUDGMENT
8. After the trial in the first phase of the Delaware proceedings was completed, the parties submitted additional testimony that became part of the trial record. A true and correctcopy of excerpts from the deposition testimony designated pursuant to this procedure in theDelaware trial is attached as Exhibit G.9. Following trial, the Court received two rounds of post-trial briefing and heard tworounds of closing arguments.10. Attached as Exhibit H is a true and correct copy of the Judgment in a Civil Case,dated February 25, 2013 in the
 Micron v. Rambus
case.11. Attached as Exhibit I is a true and correct copy of Rambus
s Notice of Appeal,dated March 28, 2013 in the
 Micron v. Rambus
case.12. Attached as Exhibit J
is a true and correct copy of Micron’s Motion for Summary
Judgment of Unenforceability Based on Collateral Estoppel, dated January 19, 2009.13. Attached as Exhibit K is a true and correct copy of the docket report from the
 Micron v. Rambus
case printed from PACER.14. Attached as Exhibit L is a true and correct copy of the
 Micron
 
Court’s Scheduling
Order Re-Setting Case for Trial, dated March 16, 2006.15. A true and correct copy of excerpts from the reporter 
s transcript of the
 Hynix
trialon October 17, 2005 is attached as Exhibit M.16. A true and correct copy of excerpts from the reporter 
s transcript of the
 Hynix
trialon October 18, 2005 is attached as Exhibit N.17. A true and correct copy of excerpts from the reporter 
s transcript of the
 Hynix
trialon October 19, 2005 is attached as Exhibit O.18. A true and correct copy of excerpts from the reporter 
s transcript of the
 Hynix
trialon October 24, 2005 is attached as Exhibit P.19. A true and correct copy of excerpts from the reporter 
s transcript of the
 Hynix
trialon October 25, 2005 is attached as Exhibit Q.20. A true and correct copy of excerpts from the reporter 
s transcript of the
 Hynix
trialon October 26, 2005 is attached as Exhibit R.
Case3:10-cv-05449-RS Document179 Filed06/06/13 Page3 of 6

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