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Published by: sabatino123 on Jun 02, 2012
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17517305.1
 
JOINT CLAIM CONSTRUCTION ANDPREHEARING STATEMENT
 (All parties and counsel listed on Signature Page)UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF CALIFORNIASAN FRANCISCO DIVISIONRAMBUS INC.,Plaintiff,v.LSI CORPORATION,Defendant.Case No. 3:10-cv-05446 RS
JOINT CLAIM CONSTRUCTION ANDPREHEARING STATEMENT
RAMBUS INC.,Plaintiff,v.STMICROELECTRONICS N.V.;STMICROELECTRONICS INC.,Defendants.Case No. 3:10-cv-05449 RS
Case3:10-cv-05449-RS Document92 Filed06/01/12 Page1 of 5
 
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17517305.1
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JOINT CLAIM CONSTRUCTION ANDPREHEARING STATEMENT
 Pursuant to Patent Local Rule 4-3, Plaintiff Rambus Inc. (“Rambus”) and Defendants LSICorporation (“LSI”) and STMicroelectronics N.V. and STMicroelectronics Inc. (collectively,“STMicro”) hereby submit this Joint Claim Construction and Prehearing Statement.
I.
 
UNDISPUTED CLAIM TERMS
The parties do not dispute the constructions of the claim terms included in the followingchart:
Term/Phrase/Clause Agreed Construction
1.
 
access time information information that indicates a time a devicemust wait from receiving a read request,write request, or operation code toresponding to that read request, writerequest, or operation code2.
 
access time register a register to store access time information3.
 
block size information information that specifies the total amount of data that is to be transferred on the bus inresponse to a read request, write request, oroperation code4.
 
bus a set of signal lines to which a number of devices are connected, and over whichinformation is transferred between devices5.
 
coupled to electrically (or otherwise) connected to allowthe transfer of signals6.
 
delay time an amount of time that must transpire beforecommencing an action7.
 
integrated circuit device a circuit constructed on a single monolithicsubstrate, commonly called a “chip”8.
 
read request a series of bits used to request a read of datafrom a memory device where the requestidentifies what type of read to perform9.
 
write request a series of bits used to request a write of datato a memory device
II.
 
PROPOSED CONSTRUCTION OF DISPUTED CLAIM TERMS
Joint Appendix A includes the disputed claim terms and the parties’ proposedconstructions for each such term.Appendices B-1 and B-2 set forth, respectively, Rambus’s and defendants’ identificationof intrinsic and extrinsic evidence in support of their proposed constructions.
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JOINT CLAIM CONSTRUCTION ANDPREHEARING STATEMENT
 
III.
 
IDENTIFICATION OF MOST SIGNIFICANT DISPUTED TERMS
The parties have agreed on the following list of ten terms (listed in alphabetical order)whose construction will be most significant to the resolution of these cases:1. clock signal2. controller/controller device3. external clock signal4. operation code5. precharge information6. register7. representative of 8. sample(s)/sampled/sampling9. synchronous dynamic random access memory device10. synchronously with respect toThe parties agree that there is no term whose construction will be case or claimdispositive.
IV.
 
ANTICIPATED LENGTH OF CLAIM CONSTRUCTION HEARING
As discussed at the Case Management Conference on May 10, 2012, the parties anticipatethat the claim construction hearing will be four hours in length, not including breaks, with eachside allotted two hours to present its claim construction positions.
V.
 
WITNESSES TO BE CALLED AT THE CLAIM CONSTRUCTION HEARING
As discussed the Case Management Conference on May 10, 2012, the parties do notintend to call witnesses at the claim construction hearing.
Case3:10-cv-05449-RS Document92 Filed06/01/12 Page3 of 5

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