Professional Documents
Culture Documents
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Gregory P. Stone (SBN 078329) Steven M. Perry (SBN 106154) MUNGER TOLLES & OLSON LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071-1560 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 Email: gregory.stone@mto.com; steven.perry@mto.com Peter A. Detre (SBN 182619) MUNGER TOLLES & OLSON LLP 560 Mission Street, 27th Floor San Francisco, California 94105 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 Email: peter.detre@mto.com Attorneys for RAMBUS INC.
Rollin A. Ransom (SBN 196126) SIDLEY AUSTIN LLP 555 West Fifth Street, Suite 4000 Los Angeles, CA 90013-1010 Telephone: (213) 896-6000; Facsimile: (213) 896-6600 Email: rransom@sidley.com
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
CASE NO. CV 00-20905 RMW DECLARATION OF STEVEN M. PERRY IN SUPPORT OF RAMBUSS BRIEF REGARDING THE COURTS DETERMINATION OF A RAND RATE PURSUANT TO ITS SEPTEMBER 21, 2012 ORDER Date: Time: Ctrm: Judge: December 19, 2012 2:00 p.m. 6 Hon. Ronald M. Whyte
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DECL. OF STEVEN M. PERRY ISO BRIEF RE THE COURTS DETERMINATION OF THE RAND RATE, CASE NO. CV 00-20905 RMW
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I, Steven M. Perry, do hereby declare and say: 1. I am a member of Munger, Tolles & Olson LLP, counsel of record for
Rambus Inc. in the above-captioned cases. I submit this declaration in support of Rambuss Brief Regarding the Courts Determination of a Rand Rate Pursuant to its September 21, 2012 Order. I have personal knowledge of the matters set forth herein and could and would testify competently to each of them. 2. Attached as Exhibit A are true and correct copies of certain pages from the
Conduct Trial phase in this matter cited in Rambuss brief. 3. Exhibit 4028. 4. Exhibit 6155. 5. Exhibit 3193. 6. Exhibit 6120. 7. Exhibit 3078. 8. Exhibit 6121. 9. Exhibit 3613. 10. Attached as Exhibit I are true and correct copies of certain pages from the Attached as Exhibit H is a true and correct copy of admitted Conduct Trial Attached as Exhibit G is a true and correct copy of admitted Conduct Trial Attached as Exhibit F is a true and correct copy of admitted Conduct Trial Attached as Exhibit E is a true and correct copy of admitted Conduct Trial Attached as Exhibit D is a true and correct copy of admitted Conduct Trial Attached as Exhibit C is a true and correct copy of admitted Conduct Trial Attached as Exhibit B is a true and correct copy of admitted Conduct Trial
Unclean Hands Trial phase in this matter cited in Rambuss brief. 11. Attached as Exhibit J are true and correct copies of certain pages from the
Patent Trial phase in this matter cited in Rambuss brief. 12. Attached as Exhibit K is a true and correct copy of the Conduct Trial
testimony of Mr. Ron Maltiel in this matter on March 13, 2008 and March 17, 2008.
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DECL. OF STEVEN M. PERRY ISO BRIEF RE THE COURTS DETERMINATION OF THE RAND RATE, CASE NO. CV 00-20905 RMW
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13.
I am informed and believe that attached as Exhibit L are true and correct
copies of the demonstratives used with Mr. Ron Maltiel during the Conduct Trial phase in this matter. 14. Attached as Exhibit M is a true and correct copy of the Conduct Trial
testimony of Dr. Richard Rapp in this matter on March 18, 2008 and March 19, 2008. 15. I am informed and believe that attached as Exhibit N are true and correct
copies of the demonstratives used with Dr. Richard Rapp during the Conduct Trial phase in this matter. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed this 13th day of November 2012 , at Los Angeles, California.
MUNGER, TOLLES & OLSON LLP SIDLEY AUSTIN LLP By: /s/ Steven M. Perry Steven M. Perry Attorneys for RAMBUS, INC.
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DECL. OF STEVEN M. PERRY ISO BRIEF RE THE COURTS DETERMINATION OF THE RAND RATE, CASE NO. CV 00-20905 RMW