8            IN THE UNITED STATES DISTRICT COURT FOR
  9   THE NORTHERN DISTRICT OF CALIFORNIA IN THE MATTER
10   OF C-00-20905, CONSOLIDATED RAMBUS LITIGATION.
11             AS TO THE ALLEGED VIOLATION OF THE
12   SHERMAN ACT:  MONOPOLIZATION.
13             DO YOU FIND THAT IT IS MORE LIKELY THAN
14   NOT THAT ANY OF THE FOLLOWING TECHNOLOGY MARKETS
15   EXIST?
16             LATENCY TECHNOLOGY MARKET:  YES.
17             BURST LENGTH TECHNOLOGY MARKET:  YES.
18             DATA ACCELERATION TECHNOLOGY
19             MARKET:  YES.
20             CLOCK SYNCHRONIZATION TECHNOLOGY
21             MARKET:  YES.
22             PRECHARGE TECHNOLOGY MARKET:  YES.
23             WRITE LATENCY TECHNOLOGY MARKET:  YES.
24             WITH RESPECT TO ANY OF THE MARKETS FOR
25   WHICH YOU ANSWERED "YES" TO QUESTION 1, DO YOU FIND

                                                                  6112

 1   IT MORE LIKELY THAN NOT THAT A GEOGRAPHIC MARKET
 2   COMPRISING THE UNITED STATES OF AMERICA EXISTS?
 3             LATENCY TECHNOLOGY MARKET:  YES.
 4             BURST LENGTH TECHNOLOGY MARKET:  YES.
 5             DATA ACCELERATION TECHNOLOGY
 6             MARKET:  YES.
 7             CLOCK SYNCHRONIZATION TECHNOLOGY
 8             MARKET:  YES.
 9             PRECHARGE TECHNOLOGY MARKET:  YES.
10             WRITE LATENCY TECHNOLOGY MARKET:  YES.
11             FOR EACH MARKET YOU HAVE FOUND TO EXIST
12   IN YOUR RESPONSE TO QUESTIONS 1 AND 2, DO YOU FIND
13   IT MORE LIKELY THAN NOT THAT RAMBUS HAS MONOPOLY
14   POWER IN THAT MARKET?
15             LATENCY TECHNOLOGY MARKET:  YES.
16             BURST LENGTH TECHNOLOGY MARKET:  YES.
17             DATA ACCELERATION TECHNOLOGY
18             MARKET:  YES.
19             CLOCK SYNCHRONIZATION TECHNOLOGY
20             MARKET:  YES.
21             PRECHARGE TECHNOLOGY MARKET:  YES.
22             WRITE LATENCY TECHNOLOGY MARKET:  YES.
23             FOR EACH MARKET YOU HAVE FOUND TO EXIST,
24   DO YOU FIND IT MORE LIKELY THAN NOT THAT RAMBUS
25   ACQUIRED OR MAINTAINED ITS MONOPOLY POWER THROUGH

                                                                  6113

 1   ANTICOMPETITIVE CONDUCT?
 2             LATENCY TECHNOLOGY MARKET:  NO.
 3             BURST LENGTH TECHNOLOGY MARKET:  NO.
 4             DATA ACCELERATION TECHNOLOGY MARKET:  NO.
 5             CLOCK SYNCHRONIZATION TECHNOLOGY
 6             MARKET:  NO.  THAT WAS NO.
 7             PRECHARGE TECHNOLOGY MARKET:  NO.
 8             WRITE LATENCY TECHNOLOGY MARKET:  NO.
 9             FOR THE MARKETS THAT YOU FOUND TO EXIST
10   IN RESPONSES 1 AND 2 IN SECTION I ABOVE, DO YOU
11   FIND THAT IT IS MORE LIKELY THAN NOT THAT RAMBUS
12   HAD A SPECIFIC INTENT TO ACHIEVE MONOPOLY POWER IN
13   ONE OR MORE OF THOSE MARKETS?
14             LATENCY TECHNOLOGY MARKET:  YES.
15             BURST LENGTH TECHNOLOGY MARKET:  YES.
16             DATA ACCELERATION TECHNOLOGY
17             MARKET:  YES.
18             CLOCK SYNCHRONIZATION TECHNOLOGY MARKET:
19             YES.
20             PRECHARGE TECHNOLOGY MARKET:  YES.
21             WRITE LATENCY TECHNOLOGY MARKET:  YES.
22             FOR EACH MARKET YOU HAVE FOUND TO EXIST,
23   DO YOU FIND IT MORE LIKELY THAN NOT THAT RAMBUS
24   ENGAGED IN ANTICOMPETITIVE CONDUCT?
25             LATENCY TECHNOLOGY MARKET:  NO.

                                                                  6114

 1             BURST LENGTH TECHNOLOGY MARKET:  NO.
 2             DATA ACCELERATION TECHNOLOGY MARKET:  NO.
 3             CLOCK SYNCHRONIZATION TECHNOLOGY
 4             MARKET:  NO.
 5             PRECHARGE TECHNOLOGY MARKET:  NO.
 6             WRITE LATENCY TECHNOLOGY MARKET:  NO.
 7             AS TO SECTION III:  FRAUD.
 8             AS TO HYNIX.  DID RAMBUS MAKE IMPORTANT
 9   REPRESENTATIONS THAT IT DID NOT HAVE ANY
10   INTELLECTUAL PROPERTY PERTAINING TO THE WORK OF
11   JEDEC AND INTEND OR REASONABLY EXPECT THAT THE
12   REPRESENTATIONS WOULD BE HEARD BY OR REPEATED TO
13   OTHERS INCLUDING HYNIX?
14             NO.
15             AS TO MICRON.  DID RAMBUS MAKE IMPORTANT
16   REPRESENTATIONS THAT IT DID NOT HAVE ANY
17   INTELLECTUAL PROPERTY PERTAINING TO THE WORK OF
18   JEDEC AND INTEND OR REASONABLY EXPECT THAT THE
19   REPRESENTATIONS WOULD BE HEARD BY OR REPEATED TO
20   OTHERS INCLUDING MICRON?
21             NO.
22             AS TO NANYA.  DID RAMBUS MAKE IMPORTANT
23   REPRESENTATIONS THAT IT DID NOT HAVE ANY
24   INTELLECTUAL PROPERTY PERTAINING TO THE WORK OF
25   JEDEC AND INTEND OR REASONABLY EXPECT THAT THE

                                                                  6115

 1   REPRESENTATIONS WOULD BE HEARD BY OR REPEATED TO
 2   OTHERS INCLUDING NANYA?
 3             NO.
 4             AS TO THE HALF-TRUTHS.
 5             DID RAMBUS UTTER HALF-TRUTHS ABOUT ITS
 6   INTELLECTUAL PROPERTY COVERAGE OR POTENTIAL
 7   COVERAGE OF PRODUCTS COMPLAINT WITH SYNCH --
 8             THE COURT:  COMPLIANT.
 9             THE CLERK:  COMPLIANT WITH SYNCHRO --
10   HELP ME OUT HERE.
11             THE COURT:  SYNCHRONOUS.
12             THE CLERK:  -- SYNCHRONOUS DRAM STANDARDS
13   THEN BEING CONSIDERED BY JEDEC BY DISCLOSING SOME
14   FACTS BUT FAILING TO DISCLOSE OTHER IMPORTANT FACTS
15   MAKING THE DISCLOSURE DECEPTIVE?
16             NO.
17             OMISSIONS.
18             DID JEDEC MEMBERS SHARE A CLEARLY DEFINED
19   EXPECTATION THAT MEMBERS WOULD DISCLOSE RELEVANT
20   KNOWLEDGE THAT THEY HAD ABOUT PATENT APPLICATIONS
21   OR THE INTENT TO FILE PATENT APPLICATIONS ON
22   TECHNOLOGY BEING CONSIDERED FOR ADOPTION AS A JEDEC
23   STANDARD?
24             NO.
25             AS TO NOMINAL DAMAGES.

                                                                  6116

 1             AS TO HYNIX:  N/A.
 2             AS TO MICRON:  N/A.
 3             DATED BY FOREPERSON ANN HENNON ON
 4   MARCH 26TH, 2008.
 5             THE COURT:  THE N/A REFERS TO NOT
 6   APPLICABLE.
 7             MS. HENNON, DID THE CLERK PROPERLY READ
 8   THE VERDICT?
 9             JUROR:  SHE DID, YOUR HONOR.