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EXHIBIT C

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EXHIBIT D

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EXHIBIT E

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EXHIBIT F

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EXHIBIT G

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EXHIBIT H

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EXHIBIT I

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(

Micron Technology, Inc. v. Rambus, Inc.

Trial Volume 5 November 15, 2007

'(
Hawkins Reporting Service 715 N King Street Suite 3 Wilmington, DE 19801 (302) 658-6697
Original File MICRON-l.TXT, 335 Pages Min-U-Script® File ID: 2147962101

Word Index included with this Min-U-Script®

(

Trial Volume 5 5:05-cv-00334-RMW Case November 15, 2007
objecting to that. We're not compmining [5] about that. [6] We're contending there was a pmn [7[ for litigation. Mr. Karp, carrying out that [8] pmn, instructed his lawyers to destroy their [9] meso [10] That's our complaint. [11] MR. CAULEY: And Your Honor, I [12] think the testimony that's come in orthe [13] argument that's been made by Micron is that the [14] licensing inherently leads to litigation. And I [15] think an expert who would talk about cleaning [16] patent mes in the context of a licensing [17] program is relevant. [18] THE COURT: Well, I'll tell you [19] what. I'll take a look at his report. [20] I'll take a look at the master. [21] He can't come on yet. He wasn't called and they [22] might not be ready for it. [23] So let me spend some time doing [24] that, and you can do whatever else you would do.
Paga1426

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Micron Page 48 of 58 Filed 01/26/2009 Technology, Inc. v.
[20]

Rambus, Inc.

[9] MR. STONE:That concludes the [10] read in,Your Honor.Thank you. [11] MR. CAULEY:Your Honor, our next

Q: What is your security audit?

[21] A: A security audit is going in and [22] looking at the way that a company

witness
[13]

[121

is Alan Brill.

secures its

[23]

assets. In my case

I

look

THE COURT: AIl right. [14[ THE CLERK: Please remain standing [15] and pmce your hand on the Bible. Please state [16] and spell your name for the record. [17] THE WITNESS: My name is Alan [18] Edward Brill. SpelledA-L-A-N E-D-W-A-RD B as [19] in boy R-I-L-L.
Paga1428
[I] ALAN EDWARD BRILL, [2] the deponent herein, having first [3] been duly

primarily at the way [24] that they secure
information assets to determine
Paga1430

whether they are taking the steps necessary to [2] appropriately protect it. [3] Q: And how long have you been [4] conducting security audits for your
[I]

clients?
[5] A: I have been doing securityaudits [6] since the mid I 970s. [7] Q: Did Kroll do work for Rambus? [8] A: Kroll did. [9] Q: And when did Kroll do work for [10] Rambus? [11] A: I believe it was in the earlypart [12] ofl998. [13] Q: Were you personally involved in [14] that work? [15] A: Yes, sir, I was. [16] Q: What type of work did Kroll [17] perform, or did you personally perform for [lB] Rambus as a representative of Kroll? [19] A: I performed a brief on site [20]

sworn on oath, was

[4]

examined and

And I'll make a decision momentarily. [2] MR. CAULEY:Thank you, Your [3] Honor. [4] Should we call our next witness, [5] Your Honor? [6] THE COURT: Sure. [7] MR. STONE: Your Honor, transition [8] statement to a brief read-in from a deposition 19] ofMr. Crisp.Yesterday you will recall there [10] was an issue or the day before raised as to when [11] it was known, in connection with Mr. Roberts' [12] 2001 deposition, when it was known that Rambus [13] was a member of]EDEC. And the testimony we [14] would read bears on the question ofwhen it was [15] known that Rambus was a member of ]EDEC. [16] The deposition from which we will [17] read is a deposition taken ofRichard Crisp on [18] November8th of2000 inthe Infineon case. And [19] we will read from that deposition at Page 213, [20] Line 3 through 8. And Mr. McAIeenan will read [21] the answer if I can read the question. It's so [22] shorts, we'll just do it from here, if you like. [23] THE COURT: All right. That's [24] fine.
[I]

testified as follows: [5] DIRECT EXAMINATION [6] BY MR. CAULEY: [7] Q: Mr.Brill,where are you currently [B] employed? [9] A: I'm employed by Kroll Ontrack, [10] Inc. [11] Q: What is Kroll Ontrack? [12] A: Kroll Ontrack is the technology [13] portion of our Kroll, Incorporated. [14] Q: What is your position at Kroll [15] Ontrack? [l6] A: I'm a senior managing director. [17] Q: Were you a managing director of [IB] Kroll back in 1998, which is the time period [19] relevant to the litigation? f20] A: Yes, sir, I was. [21] Q: What services do you personally [22] provide to clients of Kroll? [23] A: My field is computer security. I [24] work in helping clients to deal with computer
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[I]

information security review.
[21] [22]

Q: Who from Rambus first contacted

you about conducting a security A: It was Mt.]oel Karp. Q: When did Mr. Karp contact you?
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()

review?
[23] [24]

security incidents and I work in the MR. CAULEY:And can you hand the exhibit, the witness Exhibit 288. BY MR. CAULEY: Q: Mr. Brill, is this a copy of your 17]

area of [2] computer forensics.
[3] [4] [5]

[6]

curriculum vitae? [81 A: Yes, sir, it is. [9] Q: Is it accurate?

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[I] (Beginning of read-in deposition [2] excerpt:) [3] Q: But you do know that eventually [4] Rambus became a member of ]EDEC; right? [5] A: That's right. [6] Q: Do you know when that was? [7] A: Iknowwewereamemberbythe [8] time I started attending meetings in 1992.

A: I believe so, yes. Q: When did you join Kroll? [12] A: I joined Kroll in mid 1998. I'm [13] sorry, 1988. [14] Q: And I take it you conduct security [15] audits for companies? [16] A: Yes, sir. [17] Q: Over the years, how many companies [IB] have you provided security audits for? [19] A: Several hundred, I would say.
[10]

[11]

A: It would have been in the early [2] part of that year. [3] Q: What did Mr. Karp say to you when [4] he contacted you? [5] A: Mr. Karp told me that he felt that [6] it would be useful to have somebody take a look 17] at the security of information at Rambus, that [B] it was a remtively new organization that was [9] made up of a lot of people who had come from (10) academia and engineeting and that they were at a [11] point where they needed to have somebody look at [12] the level of protection that they were providing [13] to their intellectual property. [14] Q: And this conversation took pmce [15] in early 1998? [16] A: Yes, sir, that's correct. [17] Q: And when you spoke to Mr. Karp in [18] early 1998, did you have an understanding as to [19] how long he had been at Rambus? [20] A: My understanding was that it was [21] not long. [22] Q: Did Mr. Karp say anything to you
[I]

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sure the [8] transcript of the trial was done. So if you [9] need a little more time, that's fine, as long as [10] it's part of the record. [11] MR. PRICE: That is what we were [12] just talking about. [13] THE COURT: Well, before the 30th. [14] MR. STONE: With the Court's [15] indulgence, we will have them in well before the [16] 30th. But if we could have a little leeway from [17] Tuesday, that's fine. [18] MR. STONE: We'd appreciate it. [19] THE COURT: That's fine as long as [20] you do it as an agreed-upon package. [21] MR. PRICE: Yeah. [22] MR. STONE: Yeah. We understand. [231 THE COURT: All right.All right. [24] MR. STONE: Thank you,YourHonor.
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November 15, 2007

THE COURT: All right. Thank you [2] very much, counsel. And I've got to get out of [31 my computer,so go,home.Have a wonderful [4] Thanksgiving. [5] We'll see you on the 30th. [6] MR. STONE:You, too.Thank you. [7] (Deposition concluded at 3:50 [8] p.m.)
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Page 1711
Siale of Delaware)

New Castle County ) CERTIFICATE OF REPORTER I, Heather M. Triozzi, Registered Professional Reporter, Certified Shorthand Reporter,
and Notary Publlc, do hereby certify thai the

foregoing record, pages 1,3n to 1,711 Inclusive, Is
a true and accurate transcript of my stenographic

noles taken on November 15, 2007, in the
above-eaptioned matter.

IN WITNESS WHEREOF, J have hereunto sel my
hand and seal this 15th day of November, 2007, at

Wilmington.

Heather M. Triou!, RPR, GSA Cert. No. 184-PS

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EXHIBIT J

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