Case 5:05-cv-00334-RMW Document 2225-2 Filed 09/18/2008 Page 1 of 2

EX HIBI T A
Case 5:05-cv-00334-RMW Document 2225-2 Filed 09/18/2008 Page 2 of 2

Samsung’s Witness List

September 18, 2008
Case No. 05-00334-RMW; 05-02298-RMW

In view of the Court’s direction at the September 16, 2008, pre-trial conference,
Samsung submits the following list of witnesses it presently intends to call, or may call,
to testify in its case in chief.

Will Call

1. Jay Shim: Samsung will call Mr. Shim to testify regarding the license
negotiations between Samsung and Rambus, the license negotiations of the 2000
SDR/DDR License, the 2001 Amendment Number 1 to that License, and renewal
negotiations of the 2000 SDR/DDR License, Rambus’s June 6, 2005 termination of the
2000 SDR/DDR License, as well as industry customs and practices in licensing and
Rambus’s audit of Samsung's royalties as well as the business relationship between
Rambus and Samsung.

2. Keith Ugone: Samsung will call Dr. Ugone, an economics and damages expert,
to testify regarding the comparability of differing licensing payment terms and the relief
sought by Samsung under the SDR/DDR License Agreement.

3. Carl Sechen: Samsung will call Dr. Sechen, as an expert witness to testify
regarding the application of the 2000 SDR/DDR License to improvements to DDR,
which include DDR2, and other products asserted by Rambus to be beyond the scope of
the license.

4. David Mooring: Samsung will call Mr. Mooring to testify as an adverse witness
to authenticate certain documents regarding Rambus’s licenses and licensing practices,
license negotiations between Samsung and Rambus.

5. Jared Smith: Samsung will call Mr. Smith to testify as an adverse witness to
authenticate certain documents regarding Rambus’s licenses and licensing practices, and
license negotiations between Samsung and Rambus in 2004-2005.

6. Joel Karp: Samsung will call Mr. Karp to testify as an adverse witness regarding
the documents he produced per the Court’s May 7, 2008, Order.

May Call

1. Gil Young Heo: Samsung may call Mr. Heo to testify regarding Rambus’s audit
of Samsung’s royalties.