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K&L GATES LLP
Michael J. Bettinger (Bar No. 122196)
mike.bettinger@klgates.com
Stephen M. Everett (Bar No. 121619)
stephen.everett@klgates.com
Curt Holbreich (Bar No. 168053)
curt.holbreich@klgates.com
Elaine Y. Chow (State Bar No. 194063)
elaine.chow@klgates.com
Four Embarcadero Center, Suite 1200
San Francisco, CA 94111
Tel: (415) 882-8200
Fax: (415) 882-8220

QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Sean Pak (Bar No. 219032)
seanpak@quinnemanuel.com
Peter A. Klivans (Bar No. 236673)
peterklivans@quinnemanuel.com
50 California Street, 22
nd
Floor
San Francisco, California 94111-4788
Telephone: (415) 875-6600
Facsimile: (415) 875-6700

QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Michael D. Powell (Bar No. 202850)
mikepowell@quinnemanuel.com
555 Twin Dolphin Drive, 5
th
Floor
Redwood Shores, CA 94065
Telephone: (650) 801-5000
Facsimile: (650) 801-5100
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Thomas D. Pease (Bar No. 2671741 (NY))
thomaspease@quinnemanuel.com
51 Madison Avenue, 22
nd
Floor
New York, NY 10010
Telephone: (212) 849-7000
Facsimile: (212) 849-7100

QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Robert J. Becher (Bar No. 193431)
robertbecher@quinnemanuel.com
865 S. Figueroa St., 10th Floor
Los Angeles, California 90017
Telephone: (213) 443-3000
Facsimile: (213) 443-3100

MICHAEL J. BETTINGER (STATE BAR NO. 122196)
mike.bettinger@klgates.com
STEPHEN M. EVERETT (STATE BAR NO. 121619)
stephen.everett@klgates.com
CURT HOLBREICH (STATE BAR NO. 168053)
curt.holbreich@klgates.com
ELAINE Y. CHOW (STATE BAR NO. 194063)
elaine.chow@klgates.com
K &L GAT ES L LP
Four Embarcadero Center, Suite 1200
San Francisco, CA 94111
Tel: (415) 882-8200
Fax: (415) 882-8220
Attorneys for Defendants & Counterclaimants
STMICROELECTRONICS N.V. and
STMICROELECTRONICS, INC.

I N T HE UNITED STATES DISTRICT COURT
F OR T HE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

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RAMBUS INC.,

Plaintiff,
v.

STMICROELECTRONICS N.V.;
STMICROELECTRONICS INC.,
Defendants.
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Case No. 3:10-cv-05449-RS

ST MI CROE L E CTRONI CS N. V. AND
STMICROELECTRONICS, INC.`S
FI RST AMENDED ANSWER T O
COMPL AI NT AND C OUNT ERCL AI MS


DE MAND F OR JURY TRI AL
Defendants STMicroelectronics N.V. and STMicroelectronics, Inc. (collectively,
'STMicro¨) answer plaintiII Rambus Inc.`s Complaint Ior Patent InIringement ('Complaint¨) as
follows:
!"#
I.
T HE PARTI ES
1. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
2. STMicroelectronics N.V. admits that it is a Netherlands corporation with a principal
place of business at 39, Chemin de Champ des Filles, 1228 Plan-Les-Ouates, Geneva,
Switzerland.
3. STMicroelectronics, Inc. admits that it is a Delaware corporation and an indirect,
wholly-owned subsidiary of STMicroelectronics N.V., having a place of business at
1310 Electronics Dr., Carrollton, Texas 75006.
4. STMicroelectronics, Inc. admits that it has contacts and transacts business in this
judicial district and elsewhere in the United States. Except as so admitted, STMicro
denies each and every remaining allegation of this paragraph.
5. Unless specifically stated otherwise, STMicro denies the acts complained of were
committed by, on behalf of, and/or for the benefit of STMicro.
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!!"#
I I.
NATURE OF T HE A C TI ON
6. STMicro admits that the Complaint purports to be an action for patent infringement.
7. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro denies each and every remaining allegation of this paragraph.
!!!"#
I I I.
JURISDI CTI ON AND VENUE
8. STMicro admits that this action arises under 35 U.S.C. § 1 et seq., including 35 U.S.C.
§ 271, and that this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331
and 1338(a). Except as so admitted, STMicro denies each and every remaining
allegation of this paragraph.
9. STMicroelectronics, Inc. admits that this Court has personal jurisdiction over it in this
action. Except as so admitted, STMicro denies each and every remaining allegation of
this paragraph.
10. STMicroelectronics, Inc. admits that venue is proper in this Court as to it. Except as so
admitted, STMicro denies each and every remaining allegation of this paragraph.
!$"#
I V.
F A CTUAL BAC K GROUND
A. Rambus
11. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
12. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
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13. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
14. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
15. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
B. Asserted Patents
16. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
17. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
18. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
1. Farmwald/ Horowitz Patents
19. STMicro admits that U.S. Patent No. 6,034,918 is titled 'Method oI Operating a
Memory Having a Variable Data Output Length and a Programmable Register,¨ issued
on March 7, 2000, and names Michael Farmwald and Mark Horowitz as inventors.
Except as so admitted, STMicro denies each and every remaining allegation of this
paragraph.
20. STMicro admits that U.S. Patent No. 6,038,195 is titled 'Synchronous Memory Device
Having a Delay Time Register and Method oI Operating Same,¨ issued on March 14,
2000, and names Michael Farmwald and Mark Horowitz as inventors. Except as so
admitted, STMicro denies each and every remaining allegation of this paragraph.
21. STMicro admits that U.S. Patent No. 6,260,097 is titled 'Method and Apparatus Ior
Controlling a Synchronous Memory Device,¨ issued on July 10, 2001, and names
Michael Farmwald and Mark Horowitz as inventors. Except as so admitted, STMicro
denies each and every remaining allegation of this paragraph.
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22. STMicro admits that U.S. Patent No. 6,304,937 is titled 'Method oI Operation oI a
Memory Controller,¨ issued on October 16, 2001, and names Michael Farmwald and
Mark Horowitz as inventors. Except as so admitted, STMicro denies each and every
remaining allegation of this paragraph.
23. STMicro admits that U.S. Patent No. 6,426,916 is titled 'Memory Device Having a
Variable Data Output Length and a Programmable Register,¨ issued on July 30, 2002,
and names Michael Farmwald and Mark Horowitz as inventors. Except as so admitted,
STMicro denies each and every remaining allegation of this paragraph.
24. STMicro admits that U.S. Patent No. 6,564,281 is titled 'Synchronous Memory Device
Having Automatic Precharge,¨ issued on May 13, 2003, and names Michael Farmwald
and Mark Horowitz as inventors. Except as so admitted, STMicro denies each and
every remaining allegation of this paragraph.
25. STMicro admits that U.S. Patent No. 6,584,037 is titled 'Memory Device Which
Samples Data AIter an Amount oI Time Expires,¨ issued on June 24, 2003, and names
Michael Farmwald and Mark Horowitz as inventors. Except as so admitted, STMicro
denies each and every remaining allegation of this paragraph.
26. STMicro admits that U.S. Patent No. 6,715,020 is titled 'Synchronous Integrated
Circuit Device,¨ issued on March 30, 2004, and names Michael Farmwald and Mark
Horowitz as inventors. Except as so admitted, STMicro denies each and every
remaining allegation of this paragraph.
27. STMicro admits that U.S. Patent No. 6,751,696 is titled 'Memory Device Having a
Programmable Register,¨ issued on June 15, 2004, and names Michael Farmwald and
Mark Horowitz as inventors. Except as so admitted, STMicro denies each and every
remaining allegation of this paragraph.
28. STMicro admits that U.S. Patent No. 7,209,997 is titled 'Controller Device and
Method Ior Operating Same,¨ issued on April 24, 2007, and names Michael Farmwald
and Mark Horowitz as inventors. Except as so admitted, STMicro denies each and
every remaining allegation of this paragraph.
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29. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
30. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
2. Barth Patents
31. STMicro admits that U.S. Patent No. 6,470,405 is titled 'Protocol Ior Communication
with Dynamic Memory,¨ issued on October 22, 2002, and names Richard M. Barth as
inventor. Except as so admitted, STMicro denies each and every remaining allegation
of this paragraph.
32. STMicro admits that U.S. Patent No. 6,591,353 is titled 'Protocol Ior Communication
with Dynamic Memory,¨ issued on July 8, 2003, and names Richard M. Barth as
inventor. Except as so admitted, STMicro denies each and every remaining allegation
of this paragraph.
33. STMicro admits that U.S. Patent No. 7,287,109 is titled 'Method oI Controlling a
Memory Device Having a Memory Core,¨ issued on October 23, 2007, and names
Richard M. Barth as inventor. Except as so admitted, STMicro denies each and every
remaining allegation of this paragraph.
34. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
35. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
3. Dally Patents
36. STMicro admits that U.S. Patent No. 6,542,555 is titled 'Digital Transmitter with
Equalization,¨ issued on April 1, 2003, and names William J. Dally as inventor. Except
as so admitted, STMicro denies each and every remaining allegation of this paragraph.
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37. STMicro admits that U.S. Patent No. 7,099,404 is titled 'Digital Transmitter,¨ issued
on August 29, 2006, and names William J. Dally as inventor. Except as so admitted,
STMicro denies each and every remaining allegation of this paragraph.
38. STMicro admits that U.S. Patent No. 7,580,474 is titled 'Digital Transmitter,¨ issued
on August 25, 2009, and names William J. Dally as inventor. Except as so admitted,
STMicro denies each and every remaining allegation of this paragraph.
39. STMicro admits that U.S. Patent No. 7,602,857 is titled 'Digital Transmitter,¨ issued
on October 13, 2009, and names William J. Dally as inventor. Except as so admitted,
STMicro denies each and every remaining allegation of this paragraph.
40. STMicro admits that U.S. Patent No. 7,602,858 is titled 'Digital Transmitter,¨ issued
on October 13, 2009, and names William J. Dally as inventor. Except as so admitted,
STMicro denies each and every remaining allegation of this paragraph.
41. STMicro admits that U.S. Patent No. 7,715,494 is titled 'Digital Transmitter,¨ issued
on May 11, 2010, and names William J. Dally as inventor. Except as so admitted,
STMicro denies each and every remaining allegation of this paragraph.
42. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
43. STMicro lacks sufficient knowledge or information to form a belief as to the truth of
the allegations of this paragraph and, on that basis, denies them.
C. STMicro`s Acts of Infringement
44. STMicroelectronics, Inc. admits that certain STMicro products include memory
controllers that may be used with DDR-and/or LPDDR memory. STMicroelectronics,
Inc. further admits that certain STMicro products are imported into the UntiedUnited
States by STMicroelectronics, Inc. Except as so admitted, STMicro denies each and
every remaining allegation of this paragraph
45. STMicroelectronics, Inc. admits that certain STMicro products include interfaces.
STMicroelectronics, Inc. further admits that certain STMicro products containing
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interfaces are imported into the United States by STMicroelectronics, Inc. Except as so
admitted, STMicro denies each and every remaining allegation of this paragraph.
46. STMicro admits that Rambus reIers to certain products collectively as the 'Accused
Products.¨ Except as so admitted, STMicro denies each and every remaining
allegation of this paragraph.
47. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
48. STMicroelectronics, Inc. admits that it had contact with Rambus in 2008 and 2009
regarding certain Rambus patents. STMicroelectronics, Inc. further admits that
Rambus informed STMicroelectronics, Inc. as to the existence of the patents
referenced in this paragraph on or about the date referenced in this paragraph. Except
as so admitted, STMicro denies each and every remaining allegation of this paragraph.
49. STMicro denies each and every allegation of this paragraph.
50. STMicroelectronics, Inc. admits that Rambus provided certain nonpublic information
to STMicroelectronics, Inc. regarding the patents referenced in this paragraph on or
about the date referenced in this paragraph. Except as so admitted, STMicro denies
each and every remaining allegation of this paragraph.
51. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro denies each and every remaining allegation of this paragraph.
52. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro denies each and every remaining allegation of this paragraph.
53. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro denies each and every remaining allegation of this paragraph.
54. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
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55. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
$"#
V.
CL AI MS F OR RE LI E F
COUNT I
(I nf ringement of U.S. Patent No. 6,034,918 under 35 U.S. C. § 271, et seq.)
56. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
57. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
////
COUNT I I
(I nf ringement of U.S. Patent No. 6,038,195 under 35 U.S. C. § 271, et seq.)
58. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
59. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT I I I
(I nf ringement of U.S. Patent No. 6,260,097 under 35 U.S. C. § 271, et seq.)
60. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
61. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
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COUNT I V
(I nf ringement of U.S. Patent No. 6,304,937 under 35 U.S. C. § 271, et seq.)
62. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
63. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT V
(I nf ringement of U.S. Patent No. 6,426,916 under 35 U.S. C. § 271, et seq.)
64. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
65. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT VI
(I nf ringement of U.S. Patent No. 6,564,281 under 35 U.S. C. § 271, et seq.)
66. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
67. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT VI I
(I nf ringement of U.S. Patent No. 6,584,037 under 35 U.S. C. § 271, et seq.)
68. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
69. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
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COUNT VI I I
(I nf ringement of U.S. Patent No. 6,715,020 under 35 U.S. C. § 271, et seq.)
70. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
71. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT I X
(I nf ringement of U.S. Patent No. 6,751,696 under 35 U.S. C. § 271, et seq.)
72. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
73. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT X
(I nf ringement of U.S. Patent No. 7,029,997 under 35 U.S. C. § 271, et seq.)
74. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
75. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
////
////
COUNT XI
(I nf ringement of U.S. Patent No. 6,470,405 under 35 U.S. C. § 271, et seq.)
76. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
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77. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XI I
(I nf ringement of U.S. Patent No. 6,591,353 under 35 U.S. C. § 271, et seq.)
78. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
79. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XI I I
(I nf ringement of U.S. Patent No. 7,287,109 under 35 U.S. C. § 271, et seq.)
80. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
81. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XI V
(I nf ringement of U.S. Patent No. 6,542,555 under 35 U.S. C. § 271, et seq.)
82. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
83. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XV
(I nf ringement of U.S. Patent No. 7,099,404 under 35 U.S. C. § 271, et seq.)
84. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
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85. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XVI
(I nf ringement of U.S. Patent No. 7,580,474 under 35 U.S. C. § 271, et seq.)
86. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
87. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XVI I
(I nf ringement of U.S. Patent No. 7,602,857 under 35 U.S. C. § 271, et seq.)
88. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
89. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XVI I I
(I nf ringement of U.S. Patent No. 7,602,858 under 35 U.S. C. § 271, et seq.)
90. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
91. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
COUNT XI X
(I nf ringement of U.S. Patent No. 7,715,494 under 35 U.S. C. § 271, et seq.)
92. STMicro incorporates its responses to the paragraphs above as though fully set forth
herein.
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93. To the extent that the allegations of this paragraph are legal conclusions, no answer is
required. STMicro otherwise denies each and every remaining allegation of this
paragraph.
////
////
$!"#
VI.
PRAYER F OR RE LI E F
STMicro denies the allegations of this paragraph and further denies that Rambus is
entitled any relief whatsoever in this action, either as requested in its Prayer for Relief or otherwise.
$!!"#
VI I.
JURY DE MAND
This paragraph contains no allegations.
%%%%
&''!()&*!$+#,+'+-.+.#
'!(.*#&''!()&*!$+#,+'+-.+ #
(Lack of Standing)
1. Upon information and belief, Rambus does not hold any ownership interest in U.S.
Patent Nos. 6,542,555; 7,099,404; 7,580,474; 7,602,857; 7,602,858; and 7,715,494 and,
therefore, lacks standing to assert any claim arising from these patents against
STMicro.
.+/0-,#&''!()&*!$+#,+'+-.+ #
(Failure to State a Claim)
2. The Complaint fails to state a claim upon which relief may be granted.
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*1!(,#&''!()&*!$+#,+'+-.+ #
(Non-I nf ringement of the Asserted Patents)
3. STMicro does not infringe and has not infringed (either directly, contributorily, by
inducement, jointly, literally, or under the doctrine of equivalents) any valid and/or
enforceable claim of U.S. Patent Nos. 6,034,918; 6,038,195; 6,260,097; 6,304,937;
6,426,916; 6,470,405; 6,542,555; 6,564,281; 6,584,037; 6,591,353; 6,715,020;
6,751,696; 7,099,404; 7,209,997; 7,287,109; 7,580,474; 7,602,857; 7,602,858; or
7,715,494 (collectively, 'Asserted Patents¨).
'02(*1#&''!()&*!$+#,+'+-.+ #
(I nvalidity of the Asserted Patents)
4. One or more claims of the Asserted Patents are invalid or void for failing to comply
with one or more of the conditions for patentability set forth in Part II of Title 35 of the
United States Code, including, but not limited to, §§ 101, 102, 103, and 112.
'!'*1#&''!()&*!$+#,+'+-.+ #
(Failure to Mar k)
5. Rambus`s claims Ior relieI are barred, in whole or in part, by Iailure oI Rambus and/or
its licensees to comply with the marking and/or notice provisions of 35 U.S.C. § 287.
.!3*1#&''!()&*!$+#,+'+-.+ #
(Unenforceability - Estoppel, Acquiescence, and Waiver)
6. Rambus is barred in whole or in part by the doctrines of estoppel, acquiescence, and
waiver Irom enIorcing the Asserted Patents against STMicro based on Rambus`s
participation in, interaction with, or communications with certain standards setting
organizations or bodies.
.+$+-*1#&''!()&*!$+#,+'+-.+ #
(Unenforceability - Patent Exhaustion, Patent Misuse, and Fi rst Sale Doctrine)
7. Rambus is barred in whole or in part by the doctrines of patent exhaustion, patent
misuse, and/or the first sale doctrine from enforcing the Asserted Patents against
STMicro because, upon inIormation and belieI, Rambus`s licensing program Ior the
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Accused Products is an attempt to secure double royalties and extend the physical and
temporal scope of the patent grant with anticompetitive effect.
+!41*1#&''!()&*!$+#,+'+-.+ #
(Unenforceability - I nequitable Conduct)
8. Upon information and belief, at least U.S. Patent Nos. 6,542,555; 7,099,404;
7,580,474; 7,602,857; 7,602,858; and 7,715,494 are invalid and unenforceable due to
the patentee`s inequitable conduct in their procurement. As described below, the
patentee violated his or her duty of candor and good faith by knowingly, intentionally,
and with the intent to deceive, failing to disclose to the United States Patent &
Trademark OIIice ('PTO¨) the co-inventor(s) of U.S. Patent Nos. 6,542,555;
7,099,404; 7,580,474; 7,602,857; 7,602,858; and 7,715,494.
9. William Dally ('Dally¨) and John Poulton ('Poulton¨) co-authored a paper titled
'Transmitter Equalization Ior 4Gb/s Signaling,¨ which was published in or around
August 1996.
10. Dally and Poulton co-authored a paper titled 'Transmitter Equalization Ior 4Gb/s
Signaling,¨ which was published in or around January 1997.
11. Upon information and belief, the papers referenced in the previous two paragraphs
were the foundation for Provisional Application No. 60/050,098, which was filed on
June 20, 1997, Patent Application No. 08/880,980, which was filed on June 23, 1997
and Patent Application No. 08/882,252, which was filed on June 25, 1997. Provisional
Application No. 60/050,098, Patent Application No. 08/880,980 and Patent
Application No. 08/882,252 were the basis for U.S. Patent Nos. 6,542,555; 7,099,404;
7,580,474; 7,602,857; 7,602,858; and 7,715,494.
12. Upon information and belief, the patentee violated his or her duty of candor and good
faith in dealing with the PTO by knowingly, intentionally, and with deceptive intent,
failing to disclose the identity, or falsely minimizing the contribution, of at least
Poulton as a co-inventor of Provisional Application No. 60/050,098, Patent
Application No. 08/880,980 and Patent Application No. 08/882,252.
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13. This deceptive and intentional withholding of material information regarding the
inventorship of U.S. Patent Nos. 6,542,555; 7,099,404; 7,580,474; 7,602,857;
7,602,858; and 7,715,494 constitutes inequitable conduct, thereby rendering these
patents invalid and unenforceable.
14. In or around 1985, Silicon Valley luminary Steve Jobs, along with others, formed
NeXT, Inc. ('NeXT¨) to develop and manuIacture hardware and soItware Ior use in
computer workstations. To great fanfare, NeXT released to the public its first
workstation in or around October 1988. The NeXT workstation was originally called
the 'NeXT Computer¨ or 'NeXT Cube¨ (the 'NeXT Systems and Products¨). On
information and belief, a later version of the NeXT Systems and Products were made
publicly available and sold no later than September 1989.
15. On information and belief, the NeXT Systems and Products utilized components such
as the Motorola MC68030 microprocessor, NeXT NextBus, and NeXT NextBus
Interface Chip. The NeXT Systems and Products utilized a synchronous, multiplexed,
and multimaster bus which was used to communicate with, among other things,
DRAM devices.
16. As evidenced by numerous publications in the relevant time period, both NeXT and the
NeXT Systems and Products were well known and widely publicized. For example, in
or around November 1988 BYTE magazine, a widely circulated publication, published
a cover story regarding the NeXT Computer which including discussion of the
technical details of the NeXT Systems and Products. In addition, also in or around
November 1988, Unix World magazine published a cover story regarding the NeXT
Computer. Unix World touted the NeXT Bus as 'like nothing in the PC market today.¨
17. NeXT and the NeXT Systems and Products were so revolutionary and of interest to
members of the technical community that a book was published detailing the unique
Ieatures and Iunctions oI the NeXT Systems and Products. In or around 1989 'The
NeXT Book,¨ written by Bruce Webster, was published. The NeXT Book discussed
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many aspects of the hardware and software of the NeXT Systems and Products,
including discussion of the hardware architecture.
18. Upon information and belief, no later than April 1990, representatives from Rambus,
including at least named inventor Michael Farmwald, met with representatives from
NeXT, including at least Rich Page, to discuss Rambus and its memory protocol which
matured into the Farmwald/Horowitz patents at-issue in this litigation.
19. Upon information and belief, Rambus was thus aware of NeXT and the NeXT Systems
and Products no later than April 1990.
20. The NeXT Systems and Products constitute non-patent prior art to the
Farmwald/Horowitz patents. Upon information and belief, documents reflecting at
least Michael Farmwald`s knowledge oI the NeXT Systems and Products would have
reasonably been Iound in the Rambus`s internal inventor`s Iiles, including but not
limited to non-public documents such as notes, internal communications, and
communications with patent prosecution counsel, which Rambus has since destroyed.
21. Rambus`s bad Iaith spoliation oI documents related to its knowledge of the NeXT
Systems and Products constitutes an affirmative act of egregious misconduct.
22. Upon information and belief, during the prosecution of U.S. Patent Nos. 6,034,918;
6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,564,281; 6,584,037; 6,715,020;
6,751,696; and 7,209,997, the patentee failed to disclose to the U.S. PTO the NeXT
Systems and Products.
23. The NeXT Systems and Products are material to the patentability of U.S. Patent Nos.
6,034,918; 6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,564,281; 6,584,037;
6,715,020; 6,751,696; and 7,209,997, were known to the named inventor(s) and/or
those substantively involved in the prosecution of U.S. Patent Nos. 6,034,918;
6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,564,281; 6,584,037; 6,715,020;
6,751,696; and 7,209,997 prior to the issuance of those patents, and were withheld
from the PTO with intent to deceive the PTO.
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24. The inequitable conduct as alleged in paragraphs 14-23 so permeates the enforceability
of U.S. Patent Nos. 6,034,918; 6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,564,281;
6,584,037; 6,715,020; 6,751,696; and 7,209,997 that it renders them unenforceable

-!-*1#&''!()&*!$+#,+'+-.+ #
(Unclean Hands)
25. 14. Upon inIormation and belieI, Rambus`s assertion oI at least U.S. Patent Nos.
6,034,918; 6,038,195; 6,426,916; 6,304,937; 6,260,097; 6,564,281; 6,584,037;
6,715,020; 6,751,696; 7,209,997; 6,470,405; 6,591,353; and 7,287,109 against
STMicro is barred by the doctrine oI unclean hands due to Rambus`s bad Iaith
destruction of documents, as described below, that would have been relevant to
STMicro`s deIenses in this action.
26. 15. The scope of this action includes SDRAM products that Rambus alleges infringe
one or more claims of the Asserted Patents.
27. 16. SDRAM technology was at least in part developed by a standard-setting
organization known as the Joint Electronic DesignElectron Device Engineering
Counsel ('JEDEC¨), oI which, upon inIormation and belieI, Rambus was a member (or
in which it was otherwise a participant) from at least 1991 to until at least 1996.
28. 17. Various of the Asserted Patents, including U.S. Patent Nos. 6,034,918; 6,038,195;
6,426,916; 6,304,937; 6,260,097; 6,564,281; 6,584,037; 6,715,020; 6,751,696; and
7,209,997 claim an earliest effective filing date in 1990. Other Asserted Patents,
including the 6,470,405; 6,591,353; and 7,287,109, claim earliest effective filing dates
in either 1995 or 1997.
29. 18. Upon information and belief, as early as 1996, Rambus was considering industry-
wide adoption oI its DRAM technology (reIerred to as 'Rambus DRAM¨ or
'RDRAM¨).
30. 19. Upon information and belief, in an aggressive approach to enforce its intellectual
property against, for example, entities considering or using competing DRAM
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technologies (e.g., SDRAM), Rambus (i) endeavored to create a 'patent mineIield¨ by
extending claims in its patents to cover SDRAM, DDR SDRAM, and other potentially
competing memory types and (ii) as of early 1998, anticipated and commenced plans
for litigation in order to enforce its intellectual property.
31. 20. Upon inIormation and belieI, based upon Rambus`s goals and under the
circumstances Rambus found itself in regarding the use of competing memory
technologies by potential licensees, it was at least reasonably foreseeable and at most
inevitable that litigation would take place between Rambus and one or more of the
potential licensees.
32. 21. Upon information and belief, the Rambus litigation strategy implemented in 1998
set Iorth a 'document retention policy¨ under which millions oI pages oI documents
were destroyed during so-called 'shred days,¨ that, upon inIormation and belieI,
occurred in at least 1998, 1999, and 2000. The purpose oI this 'policy¨ was to destroy
evidence in Rambus`s hands, which Rambus was aware could be used by
manufacturers of SDRAM to establish defenses, or claims or elements of defenses or
claims, including violation of the antitrust laws; estoppel; fraud; prosecution laches;
inadequate written description; inequitable conduct; equitable estoppel; lack of or
improper inventorship; invalidity over prior art; obviousness; unfair business practices;
reliance; and prejudice.
33. 22. More speciIically, upon inIormation and belieI, in expediting Rambus`s
'document retention policy¨ at a time when it was at least reasonably Ioreseeable to
Rambus that litigation would commence on one or more of its memory patents,
Rambus`s in-house counsel as well as its outside counsel under direction of Rambus
systematically purged Rambus`s patent Iiles. Upon inIormation and belieI, the
destroyed documents included, for example, documents Irom Rambus`s patent Iiles,
documents connected with licensing negotiations between Rambus and third parties
regarding Rambus`s patents and/or DRAM technology, documents connected with
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Rambus`s involvement with and/or participation in JEDEC, and documents
questioning the patentability oI Rambus`s purported inventions.
34. 23. Various courts that have adjudicated litigation involving Rambus and its memory
patents have found that Rambus engaged in the spoliation of evidence. In Rambus v.
Infineon, the United States District Court for the Eastern District of Virginia stated that:
It is settled that Rambus instituted a document destruction policy and thereby
intentionally destroyed documents. It is also settled that the destroyed
documents covered all of the major categories of documents generated in the
ordinary course oI Rambus`s business. Through depositions, InIineon has
established that Rambus`s document purging program resulted in the
destruction of evidence relevant to this action, including evidence related to:
the prosecution of the patents-in-suit, Rambus`s participation in JEDEC,
Rambus`s prosecution oI JEDEC-related patents, the relationship oI Rambus`s
patent applications and pending claims to JEDEC standards, presentations to
Rambus`s Board oI Directors regarding intellectual property, potentially
damaging or invalidating prior art, and Rambus`s SDRAM licensing
negotiations.
Rambus, Inc. v. Infineon Technologies AG, et al., 222 F.R.D. 280, 290 (E.D. Va. 2004)
(citations omitted).
1

35. 24. In Samsung Electronics Co., Ltd. v. Rambus Inc., the United States District Court
Ior the Eastern District oI Virginia Iound that '|t|he record proves that Rambus
engaged in pervasive document destruction in 1998 and 1999 while it anticipated
litigation, or reasonably should have anticipated litigation, and in 2000 while it was
actually engaged in litigation.¨ July 18, 2006 Memorandum Opinion in Samsung
Electronics Co., Ltd. v. Rambus Inc. (E.D. Va.), Civ. No. 3:05cv406, p. 80.
36. 25. In Micron Technology, Inc. v. Rambus, Inc., the United States District Court for the
District oI Delaware Iound that litigation concerning Rambus`s intellectual property
'was reasonably Ioreseeable |by Rambus| no later than December 1998¨ and that 'a
duty to preserve potentially relevant evidence arose in December 1998 and any
documents purged from that time forward are deemed to have been intentionally

1
It is noted that in connection with the Eastern District of Virginia Rambus v. Infineon litigation, the
United States Court of Appeals for the Federal Circuit reversed in part an earlier judgment in that
litigation. However, on remand, the district court noted that 'Rambus did not appeal the Iindings oI
litigation misconduct, including the finding that it had intentionally destroyed relevant documents in
anticipation oI litigation.¨ See id. at p. 286.
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destroyed, i.e., destroyed in bad Iaith.¨ January 9, 2009 Opinion in Micron Technology,
Inc. v. Rambus, Inc. (D. Del.), Civ. No. 00-702-SLR, pp. 31-32. The Court concluded
that 'the showing oIFederal Circuit affirmed the finding that Rambus destroyed
documents before the second shred day in violation of a duty to preserve them. Micron
Technology, Inc. v. Rambus, Inc., 645 F.3d 1316, 1322 (Fed. Cir. 2011). The District
Court subsequently concluded on January 2, 2013 that Rambus engaged in bad faith is
so clear and convincing¨ and 'the spoliation conduct was extensive, including within
its scope the destruction oI innumerable documents relating to all aspects oI Rambus`s
business . . . .¨ Id. at p. 33.spoliation of evidence that prejudiced Micron Technology,
Inc. and Micron Semiconductor Products, Inc. This resulted in the Court ruling the
twelve Rambus patents asserted in that litigation as being unenforceable against
Micron Technology, Inc. and Micron Semiconductor Products, Inc.
37. 26. Upon information and belief, the adjudged mass spoliation of evidence by Rambus
included the destruction of non-public documents that would have been relevant and/or
material to STMicro`s deIenses in this action, including at least deIenses asserting:
unenforceability due to patent misuse and violation of antitrust and unfair competition
laws; equitable estoppel; and inequitable conduct.
38. 27. Moreover, upon information and belief, due to the (a) relatedness among the timing
of the Asserted Patents, the accused technologies in this action, and other Rambus
litigations in which spoliation has been found; and (b) the period of time associated
with Rambus`s destruction oI documents, such as those documents connected with
Rambus`s prosecution oI JEDEC-related patents, Rambus`s SDRAM licensing
negotiations, and the relationship of Rambus`s patent applications and pending claims
to JEDEC standards, Rambus has destroyed documents that would have been relevant
to the validity, enforceability, and/or interpretation of the Asserted Patents.
39. 28. Rambus, therefore, comes into this Court with unclean hands and, at a minimum, is
barred from enforcing at least the U.S. Patent Nos. 6,034,918; 6,038,195; 6,426,916;
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6,304,937; 6,260,097; 6,564,281; 6,584,037; 6,715,020; 6,751,696; 7,209,997;
6,470,405; 6,591,353; and 7,287,109.
*+-*1#&''!()&*!$+#,+'+-.+ #
(Prosecution History Estoppel)
40. 29. By reason of admissions, arguments, and/or amendments made by or on behalf of
the applicants during the proceedings in the U.S. Patent & Trademark Office during
prosecution of each of the applications that resulted in the issuance of the Asserted
Patents, Rambus is estopped, in whole or in part, under the doctrine of prosecution
history estoppel from construing any claim of the Asserted Patents to include any
STMicro product, process, or method
+5+$+-*1#&''!()&*!$+#,+'+-.+ *+-*1#&''!()&*!$+#,+'+-.+##
(Prosecution Laches)
41. 30. Rambus is barred in whole or in part from asserting at least U.S. Patent Nos.
6,034,918; 6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,564,281; 6,584,037;
6,715,020; 6,751,696; 7,209,997; 6,470,405; 6,591,353; 7,602,857; 7,602,858; and
7,715,494 on the ground of prosecution laches because these patents were granted to
the patentee(s) after an unreasonable and unexplained delay in prosecution.
*6+5'*1#&''!()&*!$+#,+'+-.+ +5+$+-*1#&''!()&*!$+#,+'+-.+##
(License)
42. 31. Upon information and belief, through licenses granted by Rambus, STMicro has
rights to one or more of the Asserted Patents and/or is licensed to make, use, sell,
and/or offer for sale within the United States and/or import into the United States the
products accused of infringement by Rambus.
*1!(*++-*1#&''!()&*!$+#,+'+-.+ *6+5'*1#&''!()&*!$+#,+'+-.+##
(Collateral Estoppel)
43. 32. Rambus is estopped from asserting at least U.S. Patent Nos. 6,034,918; 6,038,195;
6,260,097; 6,304,937; 6,426,916; 6,564,281; 6,584,037; 6,715,020; 6,751,696; and
7,209,997 6,470,405; 6,591,353; 7,602,857; 7,602,858; and 7,715,494, against
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STMicro on the ground of collateral estoppel due the existence of prior decisions or
judgments entered in, inter alia, Rambus Inc. v. Infineon Technologies A. G., et al., U.S.
District Court for the Eastern District of Virginia, Civil Action No. 3:00-cv-00524;
Samsung Electronics Co., Ltd. v. Rambus Inc., U.S. District Court for the Eastern
District of Virginia, Civil Action No. 3:05-cv-00406; and Micron Technology, Inc. v.
Rambus Inc., U.S. District Court for the District of Delaware, Civil Action No.
1:00-cv-00792.
'02(*++-*1#&''!()&*!$+#,+'+-.+ *1!(*++-*1#&''!()&*!$+#,+'+-.+##
(Laches)
44. 33. The relief sought by Rambus is barred in whole or in part by the doctrine of laches,
speciIically Rambus`s unreasonable and unexplained delay in bringing an action
against STMicro alleging infringement of U.S. Patent Nos. 6,470,405, 6,591,353, and
7,287,109. Because of a license agreement between Rambus and STMicro`s
predecessor to the memory controller technology called out in the Asserted Patents,
Rambus was aware at least as early as December 1996, the effective date of the license,
that STMicro had the right to make and sell products utilizing memory controller
technology. Despite this knowledge, Rambus delayed for 14 years to claim patent
infringement. STMicro has been prejudiced as a result of this delay.
'!'*++-*1#&''!()&*!$+#,+'+-.+ '02(*++-*1#&''!()&*!$+#,+'+-.+##
(Limitation on Damages and Costs)
45. 34. Rambus`s claim Ior relieI and prayer Ior damages are limited by 35 U.S.C. §§ 286
and 287. Rambus`s recovery oI costs is limited under 35 U.S.C. § 288.
////
COUNT ERCL AI MS
STMicro alleges and counterclaims against Rambus as follows:
T HE PART I ES
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139. 1. STMicroelectronics N.V. is a Netherlands corporation with a principal place of
business at 39, Chemin de Champ des Filles, 1228 Plan-Les-Ouates, Geneva,
Switzerland.
140. 2. STMicroelectronics, Inc. is a Delaware corporation and an indirect, wholly-owned
subsidiary of STMicroelectronics N.V., having a place of business at 1310 Electronics
Dr., Carrollton, Texas 75006.
141. 3. Upon information and belief, Rambus is a Delaware corporation with its principal
place of business at 1050 Enterprise Way, Sunnyvale, California 94089.
JURISDI CTI ON AND V E NUE
142. 4. STMicro`s counterclaims arise under 35 U.S.C. § 1, et seq., and seek relief for
which this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338,
2201, and 2202.
143. 5. Rambus is a resident of the State of California and is, therefore, subject to personal
jurisdiction in this District. Rambus has furthermore consented to personal jurisdiction
by commencing its action against STMicro for patent infringement in this judicial
district,
144. 6. Venue is proper in this judicial district under 28 U.S.C. § 1400.
NA T URE OF T HE C OUNT E RC L AI MS
145. 7. STMicro counterclaims against Rambus for declaratory judgment pursuant to 28
U.S.C. §§ 2201 and 2202, and in compliance with Federal Rule of Civil Procedure 13.
F I RST C OUNT E RC L AI M
(Decl aratory Judgment of Non-I nf ri ngement of the Asserted Patents)
146. 8. STMicro realleges and incorporates by reference the allegations of Paragraphs 1
through 7 of these Counterclaims as if fully set forth herein.
147. 9. An actual and justiciable controversy exists between STMicro and Rambus with
respect to the Asserted Patents because Rambus has brought this action against
STMicro alleging that STMicro infringes these patents, which allegations STMicro
denies. Absent a declaration of non-infringement, Rambus will continue to
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wrongfully assert the Asserted Patents against STMicro and thereby cause STMicro
irreparable injury and damage.
148. 10. STMicro has not infringed any of the Asserted Patents directly, indirectly,
contributorily, by inducement, literally or under the doctrine of equivalents, willfully
or otherwise, and is entitled to a declaration to that effect.
149. 11. This is an exceptional case entitling STMicro to an award oI costs and attorney`s
fees incurred in connection with this action pursuant to 35 U.S.C. § 285.
SE C OND COUNT E RC L AI M
(Decl aratory Judgment of I nval idity of the Asserted Patents)
150. 12. STMicro realleges and incorporates by reference the allegations of Paragraphs 1
through 11 of these Counterclaims as if fully set forth herein.
151. 13. An actual and justiciable controversy exists between STMicro and Rambus with
respect to the Asserted Patents because Rambus has brought this action against
STMicro alleging that STMicro infringes these patents, which allegations STMicro
denies. Absent a declaration of invalidity, Rambus will continue to wrongfully assert
the Asserted Patents against STMicro and thereby cause STMicro irreparable injury
and damage.
152. 14. The Asserted Patents are each invalid Ior Iailure to meet the 'Conditions oI
Patentability¨ oI Title 35, United States Code, §§ 102 and 103 because the alleged
inventions thereof are taught by, suggested by, and/or are obvious in view of, the prior
art, and no claim of the patents in suit against STMicro can be validly construed to
cover any STMicro product, process, or method.
153. 15. The Asserted Patents each are invalid Ior Iailure to meet the 'SpeciIication¨
requirements of Title 35, United States Code, § 112 because the specifications thereof
do not contain written descriptions of the alleged inventions and of the manner and
process of making and using them in the form required by § 112 and do not conclude
with one or more claims particularly pointing out and distinctly claiming the subject
matter which the applicant regards as his invention, and no claim of the patents in suit
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against STMicro can be validly construed to cover any STMicro product, process, or
method.
154. 16. This is an exceptional case entitling STMicro to an award oI costs and attorney`s
fees incurred in connection with this action pursuant to 35 U.S.C. § 285.
T HI RD C OUNT E RCL AI M
(Decl aratory Judgment of Unenforceabi l ity of the Asserted Patents)
155. 17. STMicro realleges and incorporates by reference the allegations of Paragraphs 1
through 16 of these Counterclaims as if fully set forth herein.
156. 18. An actual and justiciable controversy exists between STMicro and Rambus with
respect to the Asserted Patents because Rambus has brought this action against
STMicro alleging that STMicro infringes these patents, which allegations STMicro
denies. Absent a declaration of unenforceability, Rambus will continue to
wrongfully assert the Asserted Patents against STMicro and thereby cause STMicro
irreparable injury and damage.
157. 19. The Asserted Patents are each unenforceable at least by reason of the acts and
omissions described above in STMicro`s AIIirmative DeIenses to Rambus`s
Complaint, and STMicro is entitled to a declaration to that effect.
158. 20. This is an exceptional case entitling STMicro to an award oI costs and attorneys`
fees incurred in connection with this action pursuant to 35 U.S.C. § 285.
PRA Y E R F OR RE L I E F
WHEREFORE, STMicro prays for judgment as follows:
A. That Rambus take nothing by way of its Complaint;
B. That judgment be entered in favor of STMicro and the Complaint be dismissed with
prejudice;
C. That judgment be entered declaring that STMicro has not directly, indirectly,
contributorily, by inducement, literally or under the doctrine of equivalents, willfully or otherwise,
infringed any claim of U.S. Patent Nos. 6,034,918; 6,038,195; 6,260,097; 6,304,937; 6,426,916;
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6,470,405; 6,542,555; 6,564,281; 6,584,037; 6,591,353; 6,715,020; 6,751,696; 7,099,404; 7,209,997;
7,287,109; 7,580,474; 7,602,857; 7,602,858; or 7,715,494;
D. That judgment be entered declaring the claims of U.S. Patent Nos. 6,034,918;
6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,470,405; 6,542,555; 6,564,281; 6,584,037; 6,591,353;
6,715,020; 6,751,696; 7,099,404; 7,209,997; 7,287,109; 7,580,474; 7,602,857; 7,602,858; and
7,715,494 invalid, void, and/or unenforceable;
E. That judgment be entered declaring that Rambus is not entitled to damages for any
alleged infringement, alleged contributory infringement, or alleged induced infringement any claim of
U.S. Patent Nos. 6,034,918; 6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,470,405; 6,542,555;
6,564,281; 6,584,037; 6,591,353; 6,715,020; 6,751,696; 7,099,404; 7,209,997; 7,287,109; 7,580,474;
7,602,857; 7,602,858; or 7,715,494;
F. That judgment be entered declaring that Rambus is not entitled to injunctive relief
against STMicro, its officers, employees, agents, privies, successors, assigns, and affiliates for any
alleged infringement, or alleged contributory or induced infringement of any claim of U.S. Patent
Nos. 6,034,918; 6,038,195; 6,260,097; 6,304,937; 6,426,916; 6,470,405; 6,542,555; 6,564,281;
6,584,037; 6,591,353; 6,715,020; 6,751,696; 7,099,404; 7,209,997; 7,287,109; 7,580,474;
7,602,857; 7,602,858; or 7,715,494;
G. That this be declared an exceptional case under 35 U.S.C. § 285;
H. That judgment be entered awarding STMicro its reasonable attorney`s Iees and costs;
and
I. That the Court award STMicro such other and further relief as the Court may deem
appropriate.
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DE MAND F OR JURY TRI AL
STMicro demands a trial by jury on all issues triable as of right by a jury in this action.
Dated: January 24, 2013 K&L GATES LLP



By /s/ Michael J. Bettinger
Michael J. Bettinger
Elaine Y. Chow
Curt Holbreich
Stephen M. Everett

Attorneys for Defendants &
Counterclaimants
STMICROELECTRONICS N.V. and
STMICROELECTRONICS, INC.

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