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Itc Complaint 1[1]

Itc Complaint 1[1]

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November 6,2008
VIA-HAND
DELIVERY
The Honorable Marilyn AbbottSecretary
U.S.
International Trade Commission500 E Street,
S.W.
Washington, D.C. 20436
Secretary
lnt’l
Trade
Commission
CHRISTINE
.
LEHMAN
202.408.4270
&N@FINNEGAN.COM
Re:
Memory Controllers and Products Containing Same, Including Graphics
Cards
-
and Motherboards
--..
_X
Dear Secretary Abbott:
,.
*-,-2
Enclosed for filing on behalf of complainant Rambus Inc. are the following docurnzk insuppod of Complainant’s request that the Commission commence an investigation pursuant toSection 337 of the Tariff Act of 1930,
as
amended. A request for confidential treatment ofConfidential Exhibits 46 and 47 is included with this filing.Accordingly, Complainant submits the following documents for filing:1.An original and twelve
(1
2) copies
of
the verified Complaint and anoriginal and six
(6)
copies
of
the accompanying exhibits, with theConfidential Exhibits segregated from the other material submitted(original and one
(1)
copy unbound, without tabs) (Rules 201.6(c),210.4(f)(3)(i), and 210.8(a)(l)(i));2. Seventeen
(1
7) additional copies of the Complaint and accompanyingNon-Confidential and Confidential Exhibits for service upon the proposedrespondents (Rules 210.4(f)(3)(i), 210.8(a)(l)(iii), and 210.1 1(a));3.Certified copies of United States Letters Patent
Nos.
7,177,998 (“the ’998patent”), 7,2 10,016 (“the ’016 patent”), 6,470,405 (“the ’405 patent”),6,591,353 (“the ’353 patent”), 7,287,109 (“the ’109 patent”), 7,2873 19(“the
119 patent”), 7,330,952 (“the ’952 patent”), 7,330,953 (“the ’953patent”), and 7,360,050 (“the
’050
patent”) (collectively “the AssertedPatents”), included respectively as Exhibits
1
,
2, 6, 7,
8,
13, 14, 15, and 16in the original Complaint, and copies thereof included respectively asExhibits
1
,
2, 6, 7,
8,
13, 14, 15, and 16 in all copies of the Complaint(Rule 210.12(a)(9)(9);
901 NEW
YORK
AVENUE, NW
I
WASHINGTON,
DC
20001-4413PHONE: 202.408.4000
I
FAX: 202.408.4400
 
The Honorable Marilyn AbbottNovember 6,2008Page 24. Certified copies of the assignments involving the Asserted Patentsincluded as Exhibits
3, 9,
and 17 in the original Complaint, and copiesthereof included as Exhibits
3,9,
and 17 in all copies of the Complaint(Rule 210.12(a)(9)(ii));
5.
An identification of each license agreement for the Asserted Patents thatComplainant relies upon to support its domestic industry contentions,included as Confidential Exhibit 46 (Rule 210.12(a)(9)(iv)) (certainagreements have been withheld in accordance with notification provisionsin the agreements; Complainant will provide these agreements in asupplement);
6.
Certified copies and three
(3)
copies thereof of the prosecution histories ofthe Asserted Patents are included as Appendices A2, A4,
B3,
B4,
B7, C5,C6, C7, and C8 (Rule 210.12(~)(1));7. Four (4) copies of each reference document mentioned in the prosecutionhistories of applications leading to the issuance of the Asserted Patentsincluded as Appendix
D
(Rule 2 10.12(~)(2)one non-patent technicalreference could not be obtained and is not available from the United StatesPatent and Trademark Office);
8.
Two (2) additional copies of the Complaint and the accompanying non-confidential exhibits for service upon the embassies in Washington, D.C.of the countries of the foreign respondents (Rules 210.8(a)(l)(iv) and210.1 I(a)(l)(ii)); and
9.
A letter and certification pursuant to Commission Rules 201.6(b) and2 10.5(d) requesting confidential treatment of Confidential Exhibits
46
and
47.
Thank you for your attention to this matter.Christine E. LehmanEnclosures
FINNEGAN, HENDERSON, FARABOW, GARRETT
&
DUNNER,
LLP
 
DERSON,
FARABOW, GARFiETT
&
DUKNER,
Lip
CHRISTINE.
LEHMAN
202.408.4270
christine.iehman@finnegan.com
November 6,2008
VIA HAND DELIVERY
The Honorable Marilyn AbbottSecretary
U.S.
International Trade Commission
500
E
Street, S.W.Washington, D.C. 20436Re:
Certain Semiconductor Chips Having Svnchronous Dynamic Random AccessMemory Controllers and Products Containing Same, Inclzidinr Graphics Cardsand Motherboards
Dear Secretary Abbo t
:
This firm represents Complainant Rambus Inc., who is concurrently filing a complaintpursuant to Section 337 of the Tariff Act of 1930, as amended, 19
U.S.C.
0
1337.
In
accordance with Commission Rules 201.6,210.5, 19
C.F.R.
$0
201.6 and 210.5,Complainant requests confidential treatment of the business information contained inConfidential Exhibits 46-47.The information for which confidential treatment is sought is proprietary commercialinformation not otherwise publicly available. Specifically, these Exhibits contain proprietarycommercial information concerning Complainant’s licensing of the Asserted Patents andinvestments in the domestic industry.The information described above qualifies as confidential business information pursuantto Rule 210.6(a) because:
1.
it is not available to the public;2. unauthorized disclosure of such information could cause substantial harmto the competitive position of Complainant; and
3.
the disclosure of which could impair the Commission’s ability to obtaininformation necessary to perform its statutory function.
901NEW
YORK
AVENUE, NW
I
WASHINGTON,
DC
20001-4413PHONE: 202.408.4000
I
FAX: 202.408.4400

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