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Gregory P. Stone (SBN 078329) Steven M. Perry (SBN 106154) Fred A. Rowley, Jr. (SBN 192298) Jeffrey Y. Wu (SBN 248784) 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; fred.rowley@mto.com; jeffrey.wu@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

SK HYNIX INC., et al., Plaintiffs, v. RAMBUS INC., Defendant.

CASE NO. CV 00-20905 RMW DECLARATION OF JEFFREY Y. WU SUPPORTING IN PART SK HYNIX’S ADMINISTRATIVE MOTION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL PURSUANT TO L.R. 7-11 AND 79-5(D) AND GENERAL ORDER NO. 62

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WU DECL. SUPPORTING IN PART SK HYNIX’S MOTION TO FILE UNDER SEAL CASE NO. CV 00-20905 RMW

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I, JEFFREY Y. WU, hereby declare: 1. I am an attorney with the law firm of Munger, Tolles & Olson LLP, counsel of

record for Rambus Inc. (“Rambus”) in the above-entitled action. I am licensed in the State of California and admitted to practice before this Court. I make this declaration based on my personal knowledge and, if called upon as a witness, I could and would testify competently as to the matters set forth below. 2. The Court entered protective orders in the above-captioned case on June 20, 2001

(Dkt. 119) and October 22, 2012 (Dkt. 4172) (“Protective Orders”). 3. On May 20, 2013, Rambus counsel received from counsel for the SK hynix

entities (collectively, “SK hynix”) SK hynix’s Brief in Support of Its Proposed Form of Final Judgment, dated May 20, 2013 (“SK hynix Brief”), in three versions: the Confidential Version, the Annotated Version, and the Redacted Public Version. 4. On May 20, 2013, SK hynix filed its Administrative Motion for Leave to File

Documents Under Seal Pursuant to L.R. 7-11 and 79-5(d) and General Order No. 62 (Dkt. 4248) (“Sealing Motion”), along with a supporting declaration (Dkt. 4248-1) and a proposed order (Dkt. 4248-2). 5. I understand that SK hynix’s Sealing Motion seeks, among other relief, permission

to file under seal the portions of the SK hynix Brief that have been highlighted in the Annotated Version and redacted in the Redacted Public Version. 6. The portions highlighted in the Annotated Version of the SK hynix Brief, and

redacted in the Redacted Public Version of the SK hynix brief, contain and/or describe business and financial information regarding royalty rates and/or rate volumes that have been designated by various parties, including Rambus, Samsung, and Elpida as “Confidential,” “Special Confidential,” “Outside Counsel Only,” and/or “SKh Outside Counsel + Listed Experts Only” information under the terms of the Protective Orders. I believe that the disclosure of this information could cause a substantial risk of business harm that could not be avoided by less restrictive means.

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WU DECL. SUPPORTING IN PART SK HYNIX’S MOTION TO FILE UNDER SEAL CASE NO. CV 00-20905 RMW

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7.

Rambus has previously submitted declarations from Samsung, Elpida, and

Rambus supporting the sealing of information regarding royalty rates and/or rate volumes. See Exhibits B – F to Declaration of Steven M.Perry in Support of Rambus’s Brief Regarding Redactions to the Sealed Portion of the Transcript of the December 19, 2012 Hearing, dated Jan. 11, 2013 (Dkt. 4233 & 4233-1). 8. The Court has previously sealed briefing that contains information regarding

royalty rates and/or rate volumes. See Order Granting Hynix’s Mot. to File Documents Under Seal Pursuant to Local Rules 79-5 and 7-11 and General Order No. 61, dated December 5, 2012 (Dkt. 4204). 9. Because SK hynix already submitted a proposed order that would seal the relevant

portions of the SK hynix Brief, this declaration is not accompanied by a separate proposed order. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. Executed on May 28, 2012, at Los Angeles, California. DATED: May 28, 2012 MUNGER, TOLLES & OLSON LLP By: /s/ Jeffrey Y. Wu Jeffrey Y.Wu Attorneys for RAMBUS, INC.

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WU DECL. SUPPORTING IN PART SK HYNIX’S MOTION TO FILE UNDER SEAL CASE NO. CV 00-20905 RMW

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