Docket No. 9302
In the Matter of Rambus Incorporated.

November 21, 2007

• Brief of Respondent Federal Trade Commission, Filed in the United States Court of Appeals for the District of Columbia Circuit in Rambus Inc., Petitioner, v. Federal Trade Commission, Respondent, Docket Nos. 07-1086, 07-1124, On Petitions for Review of Final Orders of the Federal Trade Commission

September 7, 2007

• Commission Letter Approving Respondent's Appointment of Compliance Officer
• News Release

July 11, 2007

• Application for Approval of Compliance Officer - Public

June 14, 2007

• Commission Letter Approving Wells Fargo & Company As An Escrow Agent, and Approving The Escrow Agreement
  Attached to the May 22, 2007 Supplemental Submission Filed By Respondent
  

May 22, 2007

• Supplemental Submission by Rambus Inc. Regarding Escrow Issues

April 27, 2007

• Opinion of the Commission On Respondent's and Complaint Counsel's Petitions For Reconsideration of the Final Order, by Chairman Deborah Platt Majoras [Public Record Version]
• Order Granting in Part and Denying in Part Respondent's Petition for Reconsideration of the Final Order and Granting Complaint Counsel's Petition for Reconsideration of Paragraph III.C. of the Final Order

April 11, 2007

• Respondent's Proposal Regarding Escrow Agent and Manner of Collection Pursuant to March 16, 2007 Order

March 16, 2007

• Order and Opinion of the Commission Granting In Part and Denying In Part Respondent's Motion For Stay of Final Order Pending Appeal

March 9, 2007

• Motion of Respondent Rambus Inc. for Leave to File Response to Brief of Amici Curiae Micron Technology, Inc., Samsung Electronics Corporation, Ltd., and Hynix Semiconductor, Inc. - Public
• Respondent Rambus Inc. Opposition to Motion of Micron Technology, Inc., Samsung Electronics Corporation, Ltd., and Hynix Semiconductor, Inc. for Leave to File Brief as Amici Curiae - Public

March 7, 2007

• Answer of Respondent Rambus Inc. To Complaint Counsel's Petition for Reconsideration of Paragraph III.C
• Motion of Respondent Rambus Inc. For Leave To File Reply In Support Of Its Petition For Reconsideration of the Commission's Final Order
• Reply of Respondent Rambus Inc. In Support of Its Petition For Reconsideration of the Commission's Final Order

March 1, 2007

• Brief of Amici Curiae Micron Technology, Inc., Samsung Electronics Corporation Ltd., and Hynix Semiconductor, Inc. in Opposition to Rambus's Motion to Reconsider the Commission's Remedy Order in the Matter of Rambus Inc.
• Motion of Micron Technology, Inc., Samsung Electronics Corporation, Ltd., and Hynix Semiconductor, Inc. for Leave to File Brief as Amici Curiae
• Notice of Appearance Filed by Alan J. Weinschel of Weil, Gotshal & Manges LLP on Behalf of Samsung Electronics Corporation, Ltd.
• Reply of Respondent Rambus Inc. in Support of Motion for Stay of Order Pending Appeal - Public

February 26, 2007

• Complaint Counsel's Response to Rambus's Petition for Reconsideration of the Commission's Final Order, and Complaint Counsel's Petition for Reconsideration of Paragraph III.C. [Public Record Version]
• Complaint Counsel's Opposition, In Part, To Motion of Respondent Rambus Inc. For Stay of Order Pending Appeal

February 21, 2007

• Motion of Respondent Rambus Inc. for Leave to Correct Prior Filing

February 16, 2007

• Motion of Respondent Rambus Inc. For Stay of Order Pending Appeal [Public Record Version]
• Petition of Respondent Rambus Inc. For Reconsideration of the Commission's Final Order [Public Record Version]

February 5, 2007

• Opinion of the Commission On Remedy, by Chairman Deborah Platt Majoras [Public Record Version]
• Final Order
• Remedy Statement of Commissioner Pamela Jones Harbour, Concurring in Part and Dissenting in Part
• Statement of Commissioner J. Thomas Rosch, Concurring in Part and Dissenting in Part
• News Release
  • Date News Release Issued: February 5, 2007
  • Date of Decision: February 2, 2007
  • Date of Oral Argument: November 15, 2006

November 15, 2006

• Oral Argument Relating to Remedy: Transcript of the Proceedings

October 30, 2006

• Complaint Counsel's Reply to Responding Brief of Amicus Curiae American Antitrust Institute on Issues of Remedy
• Supplemental Brief of Respondent Rambus, Inc. in Response to Amicus Curiae Brief for American Antitrust Institute, Inc.

October 19, 2006

• Order Granting Motions for Leave to File Briefs Amici Curiae

October 11, 2006

• Reply to the Opposition by Rambus, Inc. to Motion of the American Antitrust Institute, Inc. for Leave to File Brief as Amicus Curiae

October 5, 2006

• Opposition by Rambus Inc. to Motion of American Antitrust Institute, Inc. for Leave to File Brief as Amicus Curiae

October 4, 2006

• Notice Scheduling Oral Argument
  

September 29, 2006

• Reply Brief of Respondent Rambus Inc., Addressing Issues Relating to Remedy
• Complaint Counsel's Reply Brief on Remedy
• Brief of Counsel Supporting the Complaint On the Issue of Remedy (Revised Public Version)
• Responding Brief of Amicus Curiae American Antitrust Institute, Inc. On Issues of Remedy In Support of Neither Party
• Motion of the American Antitrust Institute, Inc. For Leave to File Responding Amicus Curiae Brief On Issues of Remedy In Support of Neither Party

September 25, 2006

• Opposition by Rambus Inc. to Motion of Nvidia Corporation, Micron Technology, Inc., Samsung Electronics Corporation, Ltd., and Hynix Semiconductor, Inc. for Leave to File Brief as Amici Curiae

September 18, 2006

• Brief of Counsel Supporting the Complaint on the Issue of Remedy [Public Record Version]
• Brief of Amici Curiae, Gesmer Updegrove LLP and Andrew Updegrove, on the Issue of the Appropriate Remedy for Rambus's Violations of the FTC Act - Public
• Motion of Gesmer Updegrove LLP and Andrew Updegrove for Leave to File Amici Curiae Brief on the Issue of the Appropriate Remedy for Rambus's Violations of the FTC Act - Public
• Notice of Appearance Filed by Andrew Updegrove, Esq. of Gesmer Updegrove LLP
  

September 15, 2006

• Brief of Respondent Rambus Inc. Addressing Issues Relating to Remedy
• Amicus Curiae Brief of Jedec Solid State Technology Association In Support of Complaint Counsel
• Motion of Jedec Solid State Technology Association for Leave to File Amicus Curiae Brief
• Brief of Amici Curiae Nvidia Corporation, Micron Technology, Inc., Samsung Electronics Corporation, Ltd., and Hynix Semiconductor, Inc. on the Issue of the Appropriate Remedy for Rambus's Violations of the FTC Act
• Motion of Nvidia Corporation, Micron Technology, Inc., Samsung Electronic Corp, Ltd., Hynix Semiconductor, Inc. for Leave to File Brief as Amici Curiae - Public
• Brief of Amicus Curiae Broadcom Corporation and Freescale Semiconductor, Inc. on the Issue of the Appropriate Remedy for Rambus's Violation of the Federal Trade Commission Act - Public
• Joint Motion of Broadcom Corporation and Freescale Semiconductor, Inc. for Leave to File Amicus Curiae Brief under 16 CFR 3.52(j) - Public
• Notice of Appearance Filed by David Healey of Weil Gotshal & Manges
• Notice of Appearance Filed by Kenneth L. Nissly of Thelen Reid & Priest LLP
• Notice of Appearance Filed by David M. Shannon of Nvidia Corporation
• Notice of Appearance Filed by Theodore G. Brown, III, of Townsend and Townsend & Crew LLP

August 2, 2006

• Opinion of the Commission, by Commissioner Pamela Jones Harbour For A Unanimous Commission [Public Record Version]
• Order Reversing and Vacating Initial Decision and Accompanying Order, Scheduling Supplemental Briefing on Issues
  of Remedy, and Denying Complaint Counsel's Motion for Sanctions
• Concurring Opinion of Commissioner Jon Leibowitz
• News Release

August 1, 2006

• Order Denying Complaint Counsel's Motion to Reopen the Record To Include Evidence That Corrects Misrepresentation in Answering Brief

July 21, 2006

• Notice of Intent to Release In Camera Information [Public Record Version]

June 16, 2006

• Notice of Filing of Ruling in Related Case Regarding JEDEC Duty Issues Raised in Complaint Counsel's Appeal

March 1, 2006

• Order Denying Rambus's Motion for Additional Oral Argument

February 17, 2006

• Complaint Counsel's Response to Rambus' Motion for Additional Oral Argument

February 13, 2006

• Motion of Respondent Rambus, Inc. for Additional Oral Argument

February 2, 2006

• Order Granting In Part Complaint Counsel's Motion To Reopen the Record To Admit Documents From Rambus's Newly-Found Back-Up Tapes Pertaining To Rambus's Spoliation of Evidence; and Denying Without Prejudice Rambus's Motion To Reopen the Record To Admit Newly Obtained Evidence Rebutting Complaint Counsel's Proposed Findings and Undermining Complaint Counsel's Proposed Remedy

January 5, 2006

• Notice of Filing of Ruling in Related Case Regarding Issues Raised in Complaint Counsel's Motion for Sanctions

December 20, 2005

• Complaint Counsel’s Response to Rambus’s Supplemental Brief in Support of Motion to Reopen Record
• Motion for Leave to File Complaint Counsel’s Response to Rambus’s Supplemental Brief in Support of Motion to Reopen Record

December 12, 2005

• Supplemental Brief In Support Of Motion By Respondent Rambus Inc. To Reopen Record To Admit Newly Obtained Evidence Rebutting Complaint Counsel's Proposed Findings and Undermining Complaint Counsel's Proposed Remedy

October 19, 2005

• Notice of Withdrawal of Counsel of Record
• Complaint Counsel's Motion to Reopen the Record To Admit Documents from Rambus' Newly-found Back-up Tapes Pertaining to Rambus's Spoliation of Evidence (Revised Public Version)
  • Appendix: Timeline (Public Record Version)

October 11, 2005

• Memorandum by Respondent Rambus Inc. In Opposition to Complaint Counsel's Motion to Reopen the Record to Admit Documents from Rambus's Back-up Tapes

October 6, 2005

• Complaint Counsel's Motion to Reopen the Record To Admit Documents from Rambus' Newly-found Back-up Tapes Pertaining to Rambus's Spoliation of Evidence

September 29, 2005

• Complaint Counsel's Opposition to Rambus's Motion to Reopen the Record

September 21, 2005

• Notice of Filing by Respondent Rambus, Inc. of Corrected Certificates of Service

September 20, 2005

• Declaration of Steven M. Perry in Support of Rambus' Motion to Reopen the Record
• Motion by Respondent Rambus Inc. to Reopen Record to Admit Newly Obtained Evidence Rebutting Complaint Counsel's Proposed Findings and Undermining Complaint Counsel's Proposed Remedy

August 19, 2005

• Response By Rambus Inc. To Complaint Counsel's Motion For Sanctions
• Notice of Filing of Corrected Version of Response by Rambus Inc. to Complaint Counsel's Motion for Sanctions

August 18, 2005

• Corrected Page 15 in Complaint Counsels' Supplemental Proposed Findings of Fact and Conclusions of Law
• Correction to Complaint Counsels’ Supplemental Proposed Findings of Fact and Conclusions of Law

August 17, 2005

• Responses By Respondent Rambus Inc. to Complaint Counsel's Supplemental Proposed Findings Of Fact and Conclusions of Law
• Response by Rambus Inc. to Complaint Counsel's Motion for Sanctions
• Complaint Counsels’ Replies to Rambus’s Amended Proposed Findings of Fact and Conclusions of Law in Response to the Commission’s July 20, 2005 Order

August 10, 2005

• Rambus's Amended Proposed Findings Of Fact And Conclusions Of Law In Response To The Commission's July 20, 2005 Order
• Complaint Counsel’s Supplemental Proposed Findings of Fact And Conclusions of Law
• Complaint Counsel’s Motion For Sanctions Due to Rambus’s Spoliation of Documents
  • Attachment

August 5, 2005

• Response By Respondent Rambus Inc. To Complaint Counsel's Petition To Modify The Schedule In The Commission's July 20, 2005 Order

August 4, 2005

• Order Denying Complaint Counsel's Petition to Modify the Schedule in the Commission' s July 20, 2005 Order

July 20, 2005

• Order Reopening the Record to Admit Into Evidence the Supplemental Evidence Filed By the Parties In Accordance With the Provisions of the Commission's Order of May 13, 2005, As Amended, and Directing Briefing of Issues Related to Such Supplemental Evidence

July 15, 2005

• Complaint Counsel’s Schedule of Proposed Exhibits from the Unclean Hands Hearing
• Infineon' s Proposed Findings of Fact Regarding Rambus' Unclean Hands and Spoliation of Evidence
• Petition to Supplement the Record In Response to Request by the Commission

July 8, 2005

• Response by Rambus Inc. to Complaint Counsel's Proposed Exhibits from the Infineon Hearing [PDF 232K]
• Complaint Counsel’s Response to Rambus’s Proposed Exhibits from the Unclean Hands Hearing [PDF 14K]

June 17, 2005

• Rambus Inc.'s Schedule of Proposed Exhibits Pursuant to May 13, 2005 Order [PDF 39K]
• Complaint Counsel’s Response to the Commission’s May 13, 2005 Order [PDF 11K]
• Complaint Counsel’s Schedule of Proposed Exhibits from the Unclean Hands Hearing [PDF 104K]

June 7, 2005

• Joint Petition To Modify The Schedule In The Commission's May 13, 2005 Order [PDF 14K]

May 27, 2005

• Complaint Counsel’s Motion to Compel Production of Additional Unproduced Responsive Documents [PDF 33K]
  

May 13, 2005

• Order Granting in Part Complaint Counsel’s Motion to Compel Production of, and to Reopen the Record to Admit, Documents Relating to Rambus Inc.’s Spoliation of Evidence; and Granting Rambus’s Unopposed Motion for Release of Testimony [PDF 18K]

March 30, 2005

• Supplemental Memorandum of Complaint Counsel in Support of Motion to Compel Production Of, and to Reopen the Record to Admit, Documents Relating to Respondent Rambus Inc.'s Spoliation of Evidence [PDF 59K]

March 21, 2005

• Unopposed Motion by Respondent Rambus Inc. for Release of Certain Testimony Cited in Initial Decision into the Public Record [PDF 16K]

February 4, 2005

• Objections By Respondent Rambus Inc. to Complaint Counsel’s Response to The Commission’s Order Regarding Designation of Record Pertaining to Spoliation of Evidence By Rambus; Request to Submit Additional Exhibit [PDF 17K]

December 22, 2004

• Response of Complaint Counsel to the Commission’s Order Regarding Designation of the Record Pertaining to Spoliation of Evidence by Rambus [PDF 52K]
• Designation of Record By Respondent Rambus Inc. Regarding Alleged Spoliation of Evidence {PDF 30K]

December 16, 2004

• Declaration of Robert G. Kramer in Compliance with the Commission’s December 6, 2004 Order Granting the Motion of Non-Party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 30K]
• Statement of Rambus Inc. in Compliance with the Commission’s December 6, 2004 Order Granting the Motion of Non-Party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 24K]

December 6, 2004

• Order Directing Designation of the Record Regarding Complaint Counsel’s Motion to Compel Production Of, And to Reopen the Record to Admit, Documents Relating to Rambus Inc.’s Spoliation of Evidence [PDF 13K]
• Order Granting the Motion of Non-party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 11K]

November 8, 2004

• Motion of Non-party Mitsubishi Electric Corporation for Leave to File a Response to Rambus Inc.'s Response to Complaint Counsel’s Brief Regarding Motion of Non-party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 381K]

October 26, 2004

• Response of Rambus Inc. to Complaint Counsel’s Brief Regarding Motion of Non-party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 45K]
• Motion of Respondent Rambus Inc. for Leave to File a Response to Complaint Counsel’s Brief Regarding Motion of Non-party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 10K]

October 18, 2004

• Opposition of Rambus Inc. to Complaint Counsel’s Motion to Compel Production of, and to Reopen the Record to Admit, Documents Relating to Respondent Rambus Inc.’s Spoliation of Evidence [PDF 109K]
• Appendix to Brief of Appellee and Cross-Appellant Rambus Inc. [PDF 35K]
• Complaint Counsel’s Brief Regarding Motion of Non-party Mitsubishi Electric Corp. to Enforce Protective Order [PDF 665K]

October 6, 2004

• Supplemental Memorandum in Support of Motion to Compel Production Of, and to Reopen the Record to Include, Documents Relating to Respondent Rambus Inc.'s Spoliation of Evidence [PDF 17K]
  • Attachment A [PDF 300K]
  • Attachment B [PDF 56K]
  • Attachment C [PDF 39K]
  • Attachment D [PDF 184K]

October 4, 2004

• Order Granting Complaint Counsel's Motion for Leave to File Appendices to Their Appeal Brief, Denying Rambus's Motion
  to Strike Attachment 1 and Appendix A to Complaint Counsel's Brief, and Granting Rambus Leave to File An Appendix [PDF 10K]
• Order Denying Joint Application to Postpone Briefing and Stay Commission Action On Complaint Counsel's Motion to Compel,
  and Establishing Briefing Schedule For That Motion [PDF 10K]
• Order Inviting Complaint Counsel to File A Brief Expressing Their Views On the Motion of Non-Party Mitsubishi Electric Corp.
  to Enforce the Protective Order [PDF 9K]
• Order Removing Privileged Third Party Document From Trial Record [PDF 8K]
• Order Granting Motions for Leave to File Electronic Versions of Briefs [PDF 8K]

October 1, 2004

• Order Granting District Court Request to Make Depositions Available for Use inRambus Inc. v. Infineon Technologies AG, et al [PDF 13K]

September 14, 2004

• List of Exhibits That May Be Displayed or Otherwise Referred to During Complaint Counsel's Technology Presentation [PDF 7.2M]
• List of Exhibits That Will Be Visually Displayed or Otherwise Referred to by Counsel for Rambus Inc. During the September 21, 2004 Presentation [PDF 93K]

September 3, 2004

• Revised Stipulation Postponing Briefing and Staying Commission Action on Complaint Counsel’s
  Motion to Compel Production Of, and to Reopen The Record to Admit, Documents Relating to
  Respondent Rambus Inc.’s Spoliation of Evidence [PDF 83K]

August 20, 2004

• Commission Order Dividing Oral Argument into Two Sessions And Scheduling the Second Session [PDF 43K]

August 11, 2004

• Complaint Counsel's Motion for Leave to File Public Electronic Versions of Appeal Brief and Reply Brief [PDF 14K]

July 26, 2004

• Errata Sheet [PDF 85K]
• Motion for Leave to File Supplemental Electronic Version of Reply Brief and Errata Sheet [PDF 18K]

July 16, 2004

• Rebuttal Brief of Appellee and Cross-Appellant Rambus Inc. [PDF 45K]

July 12, 2004

• Rambus’s Opposition to Complaint Counsel’s Motion to Reopen the Record to Include “Evidence That Corrects Misrepresentation in Answering Brief” [PDF 50K]

July 7, 2004

• Reply Brief of Counsel Supporting the Complaint [PDF 247K]
  • Attachment A [PDF 1.3M]
  • Attachment B [PDF 869K]

July 2, 2004

• Motion to Compel Production Of, and to Reopen the Record to Admit, Documents Relating to Respondent Rambus Inc.'s Spoliation of Evidence [PDF 36K]
• Motion to Reopen the Record to Include Evidence That Corrects Misrepresentation in Answering Brief [PDF 21K]

June 21, 2004

• Third-Party Infineon Technologies’ Reply in Support of its Motion for Clarification of the August 2, 2002 Protective Order [PDF 32K]
• Third-Party Infineon Technologies’ Motion For Leave to File a Reply Brief in Support of its Motion for Clarification
  of the August 2, 2002 Protective Order [PDF 12K]
• Order Granting Motions for Leave to File Briefs Amici Curiae [PDF 38K]

June 18, 2004

• Motion for Leave to File Supplemental Electronic Version of Brief of Appellee and Cross-Appellant Rambus Inc. and Errata Sheet [PDF 19K]

June 14, 2004

• Rambus’s Objections to Attachment 1 and Appendix A Submitted by Complaint Counsel [PDF 34K]

June 4, 2004

• Amended Proof of Service to Response of Rambus Inc. to Motion of Third-Party Infineon Technology for Clarification of the August 2, 2002 Protective Order, and the Supporting Declaration of Gregory P. Stone [PDF 10K]
• Declaration of Gregory P. Stone in Response to Motion of Third-Party Infineon Technology for Clarification of the August 2, 2002 Protective Order [PDF 20K]
• Response of Rambus Inc. to Motion of Third-Party Infineon Technology for Clarification of the August 2, 2002 Protective Order [PDF 27K}]

June 2, 2004

• Brief of Appellee and Cross-Appellant Rambus Inc. [PDF 440K]
• Brief Amicus Curiae of Citizens for Voluntary Trade [PDF 81K]
• Motion of Citizens for Voluntary Trade for Leave to File Amicus Curiae Brief
  In Support of Rambus, Inc. [PDF 12K]
• Notice of Appearance for Citizens for Voluntary Trade [PDF 10K]

May 25, 2004

• Third-Party Infineon Technology's Motion For Clarification Of The August 2, 2002 Protective Order [PDF 43K]

May 12, 2004

• Motion of The American Antitrust Institute for Leave to Filed Amicus Curiae Brief in Support of Neither Party
• Amicus Curiae Brief of The American Antitrust Institute in Support of Neither Party
• Notice of Appearance of the Undersigned

April 30, 2004

• Order Granting Motions For Leave to File Briefs Amicus Curiae and Scheduling Oral Argument

April 23, 2004

• Reply Of Non-Party Mitsubishi Electric CorporationIn Support Of Its Motion To Enforce Protective Order [PDF 13K]
• Certificate Of Service [PDF 8K]
• Declaration [PDF 10K]
• [Proposed] Order Granting Motion Of Non-Party Mitsubishi Electric Corporation For Leave File A Reply In Support Of Its Motion To Enforce Protective Order [PDF 8K]
• Motion Of Non-Party Mitsubishi Electric Corporation For Leave To File A Reply In Support Of Its Motion To Enforce Protective Order [PDF 9K]

April 22, 2004

• Appeal Brief of Counsel Supporting the Complaint [PDF 368K]
• Certificate of Service [PDF 8K]

April 19, 2004

• Declaration of Steven Perry in Opposition to Motion of Non-Party Mitsubishi Electric Corporation to Enforce Protective Order [PDF 15K]
  
• Opposition of Rambus Inc. to Motion of Non-Party Mitsubishi Electric Corporation to Enforce Protective Order [PDF 33K]

April 16, 2004

• Appendices [PDF 161K]
  
• Complaint Counsel’s Motion for Leave to File Appendices to Aid Commission Review [PDF 9K]
  
• Amicus Curiae Brief of JEDEC Solid State Technology Association in Support of Complaint Counsel’s Appeal of Initial Decision [PDF 156K]
  
• Motion of JEDEC Solid State Technology Association for Leave to File Amicus Curiae Brief [PDF 67K]
  
• Brief of Amici Curiae Micron Technology, Inc., Hynix Semiconductor, Inc., and Infineon Technologies AG [PDF 157K]
  • Exhibit A [PDF 1.1M]
  • Exhibit B [PDF 182K]
  • Exhibit C [PDF 88K]
  • Exhibit D [PDF 252K]
    
• Motion of Micron Technology, Inc., Hynix Semiconductor, Inc., and Infineon Technologies AG for Leave to File Brief as Amici Curiae [PDF 15K]
  
• Notice of Appearance (Jared Bobrow) [PDF 8K]
  
• Notice of Appearance (William Baer & Wilson Mudge) [PDF 8K]
  
• Notice of Appearance (David Beddow & Patrick Lynch) [PDF 8K]
  
• Notice of Appearance (John Desmarais & Mark Kovner) [PDF 8K]

April 15, 2004

• Brief Amicus Curiae of Economics Professors and Scholars [PDF 67K]
  
• Motion of Economics Professors and Scholars - Joseph Farrell, University of California, Berkeley; Jay Pil Choi, Michigan State University; Aaron S. Edlin, University of California, Berkeley; Shane Greenstein, Northwestern University; Bronwyn H. Hall, University of California, Berkeley; and Garth Saloner, Stanford University - For Leave to File Brief as Amicus Curiae [PDF 20K]

March 18, 2004

• Order Granting Extensions of Time to File Appellate Briefs and Increases in Word Count Limits [PDF 11K]

March 3, 2004

• Joint Motion for Extensions of Time and Word Count Limits Throughout the Appellate Briefing Schedule
  [Expedited Consideration Requested] [PDF 22K]

March 1, 2004

• Complaint Counsel's Notice of Appeal [PDF 7K]

February 24, 2004

• Text of Initial Decision of Chief Administrative Law Judge Stephen J. McGuire [Public Version] [PDF 19MB]
• News Release
• Trial Transcripts - Public

February 17, 2004

• Order of the Administrative Law Judge Dismissing the Complaint [PDF 759K]

February 3, 2004

• Notice of Change of Firm Name [PDF 10K]

December 23, 2003

• Order Granting Request for Extension of Time to File Initial Decision Beyond 90 Days from the Close of the Record [PDF 8K]

December 17, 2003

• Order Extending the One Year Deadline for Filing the Initial Decision [PDF 45K]
• Request to the Commission for Extension of Time to File Initial Decision Beyond 90 Days from the Close of the Record [PDF 91KB]

October 29, 2003

• Complaint Counsel’s Request for Leave to File the Attached Submission Regarding Company Attendance At Synclink and Jedec 42.3 Meetings [PDF 19K]

October 28, 2003

• Respondent Rambus Inc.’s Submission Regarding Company Attendance at Synclink and Jedec 42.3 Meetings [PDF 18K]
  • Exhibit A - Chart of 1996-97 synclink Mtgs Attended by Corporation [PDF 11K]
  • Exhibit B - Chart of 1996-97 Jedec Mtgs Att by Corps Who Attended Synclink Mtgs [PDF 13K]

October 20, 2003

• Administrative Law Judge's Order Extending the Deadline for Filing the Initial Decision [PDF 52K]

October 10, 2003

• Complaint Counsel's Revised Reply Findings Numbered 192 and 969 [PDF 13K]
  
• Complaint Counsel's Reply to Respondent's Proposed Findings of Fact [PDF 1.5M]

October 9, 2003

• Administrative Law Judge's Order Closing the Record [PDF 21K]

October 1, 2003

• Complaint Counsel’s Revised Reply Findings Numbered 109, 413, 676, 677, & 700 [PDF 11K]
• Rambus Inc.'s Response to Complaint Counsel's Proposed Findings of Fact
  • Volume I [PDF 1M]
  • Volume II [PDF 1.46M]
  • Volume III [PDF 1.29M]
• Complaint Counsel's Response To Respondent's Post-Trial Brief [PDF 197K]

September 29, 2003

• Post-Trial Reply Brief of Respondent Rambus Inc. [PDF 361K]
• Stipulation and Order Regarding Admission and In Camera Treatment of Certain Exhibits [PDF 14K]
• Joint Exhibit Index Pursuant to 16 C.F.R. 3.46 [PDF 10K]
  • Attachment A - Exhibit Index [PDF 295KB]

September 22, 2003

• Joint Request for Short Continuance of Filing Deadline for Reply Papers; Proposed Order Regarding Same [PDF 12K]

September 15, 2003

• ALJ’s Order Rescheduling Closing Argument [PDF 24K]

September 9, 2003

• Respondent Rambus Inc.'s Proposed Findings of Fact and Conclusions of Law [PDF 1.18M]
• Initial Post-Trial Brief of Respondent Rambus Inc. [PDF 347K]
• Complaint Counsel's Proposed Findings of Fact, Conclusions of Law and Order [PDF 916KB]
• Complaint Counsel's Post-Hearing Brief [PDF 254KB]

September 5, 2003

• Joint Witness Index [PDF 20KB]

August 27, 2003

• ALJ Order Denying Hynix's Motion to Amend Protective Order> [PDF 81KB]
• ALJ Order on Respondent's Request for Official Notice [PDF 158KB]

August 26, 2003

• ALJ Order Revising Post-Trial Brief Schedule [PDF 24KB]
• ALJ Order On Non-Party Micron Technology Inc.'s Motion For In Camera Treatment  [PDF 26KB]

August 25, 2003

• The Parties' Designated Deposition Testimony - Second Corrected Version [PDF 13KB]

August 22, 2003

• Joint Request for Revision of Schedule; and [Proposed] Order [PDF 11KB]

August 20, 2003

• Third Party Hynix's Motion for Leave to File Reply in Support of Its Motion to Amend Protective Order [PDF 9KB]
• Third Party Hynix's Reply in Support of Motion to Amend Protective Order [PDF 11KB]
  • Exhibit A [PDF 11KB]
  • Exhibit B [PDF 370KB]

August 19, 2003

• The Parties' Designated Deposition Testimony Corrected Version [PDF 12KB]

August 18, 2003

• ALJ Order Extending the Deadline for Filing the Initial Decision [PDF 64K]

August 13, 2003

• Respondent Rambus Inc.'s Opposition to Non-party Hynix's Motion to Amend the Protective Order[PDF 17KB]

August 8, 2003

• Rambus Inc.'s Reply in Support of Request for Official Notice of Various United States Patents and Proposed Order [PDF 39KB]
  
  
• The Parties' Designated Deposition Testimony [PDF 12KB]

August 6, 2003

• Non-Party Micron Technology Inc.'s Reply in Support of its Motion for In Camera Treatment [PDF 8KB]
  
  
• Non-Party Micron Technology Inc.'s Motion For Leave to File a Reply in Support of its Motion for In Camera Treatment [PDF 8KB]

August 5, 2003

• Administrative Law Judge's Order on Micron's Motion for In Camera Treatment [PDF 114KB]
  
  
• Complaint Counsel's Opposition in Part to Respondent's Request for Official Notice of United States Patents and Proposed Order [PDF 23KB]

August 1, 2003

• Third Party Hynix's Motion to Amend Protective Order and Proposed Order [PDF 17KB]
  • Exhibit A [PDF 118KB]
  • Exhibit B [PDF 11KB]
    
    
• Complaint Counsel's Memorandum in Support of its Offer of Proof Regarding the Designated Testimony from Rambus' Chief Executive Officer, Geoffrey Tate, and the Chairman of its Board of Directors, William Davidow [PDF 10KB]

July 29, 2003

• Declaration of Steven M. Perry in Support of Rambus’s Motion for an Order Limiting the Scope of Rebuttal Evidence and Excluding the Testimony of Kevin Ryan, Terry Lee and Bruce Jacob [PDF 13KB]
  • Exhibit A  [PDF 32KB]
  • Exhibit B  [PDF 73KB]
  • Exhibit C  [PDF 49KB]
  • Exhibit D  [PDF 9KB]
    
    
• Non-party Micron Technology Inc.'s Motion for In Camera Treatment [PDF 24KB]
  • Exhibit A [PDF 5KB]
  • Exhibit B [PDF 211KB]
  • Exhibit C [PDF 108KB

July 28, 2003

• Respondent's Request for Official Notice of Various United States Patents [PDF 37MB]
  
  
• Rambus's Motion for an Order Limiting the Scope of Rebuttal Evidence and Excluding the Testimony of Kevin Ryan, Terry Lee and Bruce Jacob [PDF 30KB]

July 25, 2003

• The Parties' Second Set of Stipulations [PDF 12KB]

July 24, 2003

• Notice of Complaint Counsel's Anticipated Rebuttal Case[PDF 15KB]
  
  
• Respondent's Memorandum in Support of Professor Teece's Testimony Regarding Royalty Rates [PDF 13KB]

July 10, 2003

• Response by Rambus Inc. to Complaint Counsel's Request for Clarification of the Grounds for Excluding Certain Deposition Testimony of J. Reese Brown [PDF 10KB]
  
  
• Order on Post Trial Brief [PDF 192KB]

July 9, 2003

• Order on Respondent's Motion for in Camera Treatment of Certain Trial Exhibits and Demonstratives [PDF 52KB]
  
  
• Complaint Counsel’s Request for Clarification of the Grounds for Excluding Certain Deposition Testimony of J. Reese Brown [PDF 10KB]

July 2, 2003

• Respondent Rambus inc.'s Motion for in Camera Treatment of Certain Trial Exhibits and Demonstratives [PDF 30KB]

June 26, 2003

• Administrative Law Judge's Order on Non-party Micron Technology, Inc.'s Request to Limit Questioning of Witnesses [PDF 62KB]

June 25, 2003

• Brief in Support of Respondent Rambus Inc.'s Anticipated Objections to the Testimony of Preston Mcafee  [PDF 20KB]
  • Exhibit A  [PDF 587KB]

June 19, 2003

• Response by Rambus Inc. to Micron Technology Inc.'s Request that the Court Reconsider its April 21, 2003 Order Regarding Collusion Among Dram Manufacturers [PDF 22KB]
  • Attachment A [PDF 228KB]

June 18, 2003

• Administrative Law Judge's Order Extending the Deadline for Filing the Initial Decision [PDF 14KB]
• Administrative Law Judge's Order on Micron's Motion for In Camera Treatment [PDF 16KB]

June 11, 2003

• ALJ's Order Granting in Part, Non-party Micron Technology Inc.'s Motion for Protective Order [PDF17KB]

June 9, 2003

• Rambus's Reply Memorandum in Support of Certain Objections to the Designated Deposition Testimony of Joel Karp [PDF 13KB]

June 5, 2003

• Complaint Counsel's Response to Rambus's Memorandum in Support to Certain Objections to the Designated Testimony of Joel Karp [PDF 32KB]

June 3, 2003

• Non-party Micron Technology Inc.'s Motion in Camera Treatment [PDF 5KB]
  • Exhibit A (Public) [PDF 5KB]
  • Exhibit B [PDF 6KB]
• Order on Respondent’s Objections to the Deposition Testimony of Dr. K.h. Oh. [PDF 15KB]
• Respondent Rambus's Objections to Certain "Demonstrative" Exhibits That Complaint Counsel Propose to Use with Brian Shirley on June 4, 2003 and an Accompanying Certification. [PDF 12KB]

June 2, 2003

• Rambus's Memorandum in Support of Certain Objections to the Designated Deposition Testimony of Joel Karp [PDF 16KB]
• Complaint Counsel’s Response to Rambus Inc.’s Supplemental Memorandum in Support of its Objections to the Deposition Testimony of Dr. K.H. Oh, and the corresponding Certificate of Service. [PDF 57KB]

May 30, 2003

• Complaint Counsel's Response to Certain Objections by Rambus to Deposition Testimony by J. Reese Brown [PDF 524KB]

May 29, 2003

• Administrative Law Judge Order Granting Request for Reconsideration [PDF 286KB]
• Non-Party Micron Technology Inc.'s Motion for Protective Order and [Proposed] Order [PDF 20KB]
  • Exhibit A - Declaration of Robert Donnelly [PDF 217KB]
  • Exhibit B - Protective Order Governing Discovery Material [PDF 267KB]

May 28, 2003

• Opposition to Rambus Inc.'s Request for Reconsideration and/or Clarification of May 13, 2003, Order Regarding Documents for which Rambus Asserts Privilege [PDF 70 KB]
• Rambus Inc.'s Notice of Non-Opposition By Non-Party Micron Technology, Inc. To Certain Confidentiality Challenges; and Declaration Of Adam R. Wichman In Support Of Notice Of Non-Opposition By Non-Party Micron Technology, Inc. To Certain Confidentiality Challenges [PDF 32KB]
  • Exhibit 2 [PDF 10KB]
• Declaration of Gregory P. Stone [PDF 10KB]

May 21, 2003

• Supplemental Memorandum In Support of Complaint Counsel's Motion to Compel Discovery Relating to Subject Matters as to Which Rambus's Privilege Claims Were Invalidated on Crime-Fraud Grounds and Subsequently Waived; and [Proposed] Order [PDF 53KB]

May 20, 2003

• Stipulation and Order Regarding Admission of Certain Exhibits [PDF 14KB]
  • Exhibit A (Complaint Counsel's Shortened Trial Exhibit List) [PDF 10KB]
  • Exhibit B (Respondent's Shortened Trial Exhibit List) [PDF 93KB]
  • Exhibit C (Joint Exhibit List) [PDF 19KB]

May 19, 2003

• Request for Reconsideration and/or Clarification of the May 13, 2003 Order Regarding Rambus's Privileged Documents [PDF 69KB]

May 14, 2003

• Rambus's Supplemental Memorandum in Support of its Objections to the Deposition Testimony of Dr. K.H. Oh  [PDF 20KB]

May 13, 2003

• Declaration of Steven Capella [PDF 56KB]
• Declaration of Michael D. Erickson [PDF 54KB]
• Declaration of Candice Jones [PDF 79KB]
• Declaration of Leslie Y. Kimball [PDF 1695KB]
• Declaration of Mark Kellogg [PDF 62KB]
• Memorandum by Non-Party IBM in Support of Motion to Compel the Return of Inadvertently Produced Documents [PDF 643KB]
• Motion by Non-Party IBM to Compel the Return of Inadvertently Produced Documents [PDF 64KB]
• ALJ's Order on Reconsideration of Complaint Counsel’s Motion to Compel Discovery Relating to Subject Matters for Which Respondent Asserts Privilege     [PDF 31KB]
• [Proposed] Order [PDF 5KB]
• Complaint Counsel’s Motion In Limine to Exclude Certain Testimony of Michael Geilhufe [PDF 8 KB]
• Memorandum in Support of Complaint Counsel’s Motion In Limine to Exclude Certain Testimony of Michael Geilhufe [PDF 59KB]
• Respondent Rambus Inc.’s Memorandum in Support of Certain Objections to Deposition Testimony by J. Reese Brown [PDF 15KB]

May 12, 2003

• Complaint Counsel’s Opposition to Rambus Inc.’s Request to Exclude the Deposition Testimony of Dr. K.H. Oh [PDF 28KB]

May 9, 2003

• Rambus’s Memorandum in Support of its Objections to the Deposition Testimony of Dr. K.H. Oh [PDF 22KB]

May 7, 2003

• Complaint Counsel’s Unopposed Motion for Extension of Time to File Opposition to Respondent's Motion For In Camera Treatment of Documents That Complaint Counsel Identified on April 17, 2003 as Additional Trial Exhibits, and [Proposed] Order [PDF 10KB]

May 6, 2003

• Stipulation and Order Regarding Admission of Certain Exhibits [PDF 19KB]
  • Exhibit A [PDF 10KB]
  • Exhibit B (Respondent's Shortened Trial Exhibit List) [PDF 94KB]

April 29, 2003

• Respondent's Memorandum Regarding Admissibility Of Expert Witness Reports [PDF 10KB]

April 28, 2003  

• Respondent's Proposed Agenda For Final Prehearing Conference On April 28, 2003, And Statement Of Position Regarding Certain Proposed Agenda Items [PDF 30KB]
• Complaint Counsel's Unopposed Motion for Extension of Time to File Opposition to Respondent's Motion For In Camera Treatment of Documents That Complaint Counsel Identify as Potential Trial Exhibits [PDF 10KB]

April 25, 2003 

• Complaint Counsel's Pretrial Brief [PDF 633KB]
• Complaint Counsel's Statement of Non-Opposition to Motions for In Camera Treatment Filed by Samsung Electronics Co., Micron Technology Inc., Mosaid Technology Inc., IBM and Dr. Betty Prince [PDF 10KB]
• Micron Technology, Inc's Reply To Respondent's Opposition To Motion By Micron Technology, Inc. For In Camera Treatment Of Certain Documents [PDF 8KB]
• Micron Technology, Inc.'s Motion For Leave To File A Reply To Respondent's Opposition To Micron Technology, Inc.'s Motion Requesting In Camera Treatment Of Certain Documents And [Proposed] Order [PDF 9KB]
• Respondent's Amended Supplemental Motion for the Issuance of a Subpoena Ad Testificandum [PDF 10KB]

April 24, 2003

• Complaint Counsel's Unopposed Motion for Extension of Time to File Opposition to Respondent's Motion For in Camera Treatment of Documents That Complaint Counsel Identify as Potential Trial Exhibits [PDF 10KB]

April 23, 2003

• ALJ's Order on Non-parties' Motions for In Camera Treatment of Documents Listed on Parties' Exhibit Lists [PDF 19KB]
• Statement of Non-Opposition of Respondent Rambus Inc. to Motions for In Camera Treatment Filed by Samsung Electronics Co., Mosaid Technology Inc. and IBM [PDF 13KB]
• The Parties' First Set Of Stipulations [PDF 19KB]

April 22, 2003

• Respondent's Supplemental Motion for the Issuance of a Subpoena Ad Testificandum [PDF 13KB]
• Trial Brief of Respondent Rambus Inc. [PDF 185KB]

April 21, 2003

• Administrative Law Judge's Order on Motions In Limine [PDF 1773 KB]
• Non-Party Mosaid Technologies Incorporated's Motion for In Camera Protection of Documents [PDF 584KB]

April 18, 2003

• Order Granting Respondent Rambus Inc.'s Motion for Leave to File a Corrected Motion for In Camera Treatment of Documents That Complaint Counsel Identify as Potential Trial Exhibits [PDF 8KB]
• ALJ's Order Granting Non-Party Samsung Electronics Co., Ltd.'s Unopposed Motion For Extension Of Time To File Motion For In Camera Treatment [PDF 75KB]
• Non-Party Samsung Electronics Co., Ltd.'s Unopposed Motion For Extension Of Time To File Motion For In Camera Treatment Pursuant To 16 C.F.R. Sec. 3.45 [PDF 75KB]
• Non-Party Dr. Betty Prince's Motion For In Camera Protection Of Documents [PDF 887KB]

April 17, 2003

• Rambus Inc.'s Motion for Leave to File a Corrected Motion for In Camera Treatment of Documents That Complaint Counsel Identify as Potential Trial Exhibits (and the related Proposed Order) [PDF 17KB]
• Opposition By Respondent Rambus Inc. To Complaint Counsel's Motion In Limine Regarding Rambus's Patent Prosecution Efforts After June 1996 And Neil Steinberg's Opinions Regarding The Scope Of Rambus's Prior Patent Applications [PDF 3974KB]
• ALJ's Order Granting Respondent Rambus Inc.'s Unopposed Motion For A Brief Extension Of Time To File Motion For In Camera Treatment Of Documents Pursuant To Commission Rule Of Practice 3.45(B) [PDF 79KB]
• Response Of Rambus Inc. To Complaint Counsel's Supplemental Memorandum In Support Of Their Motion To Compel Discovery On Crime-Fraud And Waiver Grounds [PDF 8296KB]
• ALJ's Order Granting Motion Of Non-Parties Dr. Betty Prince And Mosaid Technologies Inc. For An Extension Of Time To Seek In Camera Production Of Documents [PDF 69KB]

April 15, 2003

• ALJ's Order Granting Complaint Counsel's Motion For Acceptance Of Corrected Version Of "Attachment A" To Complaint Counsel's Motion For Additional Adverse Inferences And Other Appropriate Relief Necessary To Remedy Rambus Inc.'s Intentional Spoliation Of Evidence [PDF 5KB]
• ALJ's Order Granting Complaint Counsel's Motion For Acceptance Of Corrected Version Of "Tab 9" To Complaint Counsel's Motion For Additional Adverse Inferences And Other Appropriate Relief Necessary To Remedy Rambus Inc.'S Intentional Spoliation Of Evidence [PDF 78KB]
• ALJ's Order Granting Micron Technology, Inc.'s Motion for Extension of Time [PDF 7KB]
• ALJ's Order Denying Complaint Counsel's Motion for Additional Adverse Inferences and Other Appropriate Relief [PDF 590KB]
• Order Denying Respondent's Motion for Summary Decision [PDF 26KB]
• Respondent's Unopposed Motion for the Issuance of Subpoenas Ad Testificandum [PDF 27KB]
• Complaint Counsel's Unopposed Motion for the Issuance of Subpoenas Ad Testificandum [PDF 5164KB]
• Reply in Support of Complaint Counsel's Motion for Additional Adverse Inferences and Other Appropriate Relief Necessary to Remedy Rambus Inc.'s Intentional Spoliation of Evidence [PDF 2068KB]

April 11, 2003

• Non-Party Micron Technology Inc.'s Motion For Extension Of Time To Request In Camera Treatment [PDF 252KB]
• Notice Of Appearance Filed By Mark L. Kovner And Clifford E. Wilkins, Jr., Esqs. Of Kirkland & Ellis, Counsel For Third Party Infineon Technologies N.A. Corp. [PDF 294KB]
• Declaration of Sean P. Gates in Support of Opposition to Complaint Counsel's Motion In Limine to Bar Presentation of Testimony and Arguments Regarding Purported Collusion Among DRAM Manufacturers [PDF 7KB]
• Hynix's Motion For In Camera Treatment Of Proposed Evidence [PDF 19KB]
• Declaration Of D.S. Chung In Support Of Hynix's Motion For In Camera Treatment Of Proposed Evidence [PDF 17KB]
• Declaration Of Susan Van Keulen In Support Of Hynix's Motion For In Camera Treatment Of Proposed Evidence [PDF 76KB]
  • Exhibit A [PDF 2883KB]
  • Exhibit B [PDF 114KB]
  • Exhibit C [PDF 132 KB]
  • Exhibit D [PDF 1119KB]
• Motion of Non-Parties Dr. Betty Prince and Mosaid Technologies Inc. for an Extension of Time to Seek In Camera Production of Documents [PDF 240KB]         
• Respondent Rambus Inc.'s Opposition to Complaint Counsel's Motion In Limine to Preclude Report and Testimony of William L. Keefauver [PDF 128KB]
• Respondent Rambus Inc.'s Opposition to Complaint Counsel's Motion In Limine to Preclude Opinions of Richard T. Rapp and David J. Teece Regarding "Efficient Breach" Theory [PDF 74KB]
• Respondent Rambus Inc.'s Combined Opposition to Complaint Counsel's Motion In Limine Regarding the Testimony of Michael Geilhuffe and Motion In Limine Regarding Testimony of Donald Soderman and Martin Fliesler [PDF 68KB]
• Rambus Inc.'s Unopposed Motion for a Brief Extension of Time to File Motion for In Camera Treatment of Documents Pursuant to Commission Rule of Practice 3.45(b) [PDF 16KB]
• Opposition of Respondent Rambus Inc. to Complaint Counsel's Motion for Leave to File a Reply in Support of Motion for Additional Adverse Inferences and Other Appropriate Relief Necessary to Remedy Rambus Inc.'s Intentional Spoliation of Evidence [PDF 17KB]
• Opposition to Complaint Counsel's Motion In Limine to Bar Presentation of Testimony and Arguments Regarding Purported Collusion Among DRAM Manufacturers [PDF 58KB]
• Opposition by Respondent Rambus Inc. to Complaint Counsel's Motion In Limine to Bar Presentation, on Collateral Estoppel Grounds, of Testimony and Arguments Regarding Issues that Rambus Has Previously Litigated and Lost [PDF 58KB]
• Proposed Order [PDF 6KB]

April 10, 2003

• Opposition of Respondent Rambus Inc. to Complaint Counsel's Motion for Additional Adverse Inferences and Other Appropriate Relief Necessary to Remedy Rambus Inc.'s Intentional Spoliation of Evidence [PDF 72KB]
  • Attachment A [PDF 96KB]
• Complaint Counsel's Motion for Leave to File Reply in Support of Motion for Additional Adverse Inferences and Other Appropriate Relief Necessary to Remedy Rambus Inc.'s Intentional Spoliation of Evidence [PDF 10KB]
• ALJ's Order Postponing Final Prehearing Conference [PDF 5KB]
• Order Granting Motion by Respondent Rambus, Inc. for Leave to File a Corrected Version of its Reply Memorandum in Support of Motion for Summary Decision [PDF 5KB]

April 9, 2003

• Reply Memorandum By Respondent Rambus Inc. In Support Of Motion For Summary Decision (Corrected Version) [PDF 46KB]
• Proposed Order [PDF 5KB]
• Motion By Respondent Rambus Inc. For Leave To File A Corrected Version Of Its Reply Memorandum In Support Of Motion For Summary Decision [PDF 12KB]
• Complaint Counsel's Rule 3.24(A)(2) Statement Of Material Facts As To Which There Is A Genuine Dispute [PDF 162KB]
• Complaint Counsel's Memorandum In Opposition To Respondent Rambus Inc.'s Motion for Summary Decision [PDF 288KB]

April 7, 2003

• Reply Memorandum of Rambus Inc. in Support of Motion for Summary Decision and Accompanying Certification [PDF 46KB]
• Unopposed Motion by Respondent Rambus Inc. for Leave to File Reply Memorandum in Support of Motion for Summary Decision (and the Related Proposed Order) and Accompanying Certification [PDF 15KB] 

April 4, 2003

• Complaint Counsel’s Motion For Acceptance Of Corrected Version Of "tab 9" To Complaint Counsel’s Motion For Additional Adverse Inferences And Other Appropriate Relief Necessary To Remedy Rambus Inc.’s Intentional Spoliation Of Evidence [PDF 9KB]

April 3, 2003

• Rambus Inc.'s Final Witness List [PDF 14KB]
• Complaint Counsel's Final Witness List [PDF 14KB]
• ALJ’s Order Denying Respondents' Motion For Pre-hearing Determination Of Order Of Issues To Be Tried [PDF 55KB]

March 27, 2003

• Complaint Counsel’s Motion For Acceptance Of Corrected Version Of "attachment A" To Complaint Counsel’s Motion For Additional Adverse Inferences And Other Appropriate Relief Necessary To Remedy Rambus Inc.’s Intentional Spoliation Of Evidence [PDF 151KB]
• Complaint Counsel’s Motion For Additional Adverse Inferences And Other Appropriate Relief Necessary To Remedy Rambus Inc.’s Intentional Spoliation Of Evidence [PDF 282KB]

March 26, 2003

• Administrative Law Judge’s Order Denying Respondent's Applications for Review of February 26, 2003, Order (granting Complaint Counsel’s Motion for Collateral Estoppel) and February 28, 2003, Order (granting Complaint Counsel’s Motion to Compel Discovery Relating to Subject Matters as to Which Rambus’s Privilege Claims Were Invalidated on Crime-fraud Grounds and Subsequently Waived); Denying Respondent’s Request for Reconsideration of the February 26 Order; and Granting Respondents Request for Reconsideration of the February 28 Order [PDF 460KB]
• Memorandum In Support of Motion In Limine to Bar Presentation, on Collateral-Estoppel Grounds, of Testimony and Arguments Regarding Issues That Rambus Has Previously Litigated and Lost [PDF 24KB]
• Complaint Counsel's Motion In Limine to Bar Presentation, on Collateral-Estoppel Grounds, of Testimony and Arguments Regarding Issues That Rambus Has Previously Litigated and Lost [PDF 10KB] 
• Memorandum in Support of Motion In Limine To Preclude Report and Testimony of William L. Keefauver; and [Proposed] Order [PDF 40KB]
• Memorandum In Support of Motion In Limine to Bar Presentation of Testimony and Argument Regarding Purported Collusion Among DRAM Manufacturers [PDF 20KB]
• Motion In Limine to Bar Presentation of Testimony and Argument Regarding Purported Collusion Among DRAM Manufacturers [PDF 10KB]
• [Proposed] Order Granting Rambus Inc.’s Motion In Limine To Exclude Certain Opinion Testimony Of R. Preston Mcafee [PDF 10KB]
• Rambus Inc.'s Motion In Limine to Exclude Certain Opinion Testimony of R. Preston McAfee [PDF 53KB]

March 25, 2003

• Joint Proposed Agenda for Status Conference [PDF 7KB]

March 24, 2003

• Administrative Law Judge’s Order Granting Rambus Inc.’s Application for Leave to File Supplemental Rule 3.24 Separate Statement in Support of Rambus Inc.’s Motion for Summary Decision [PDF 5KB]

March 21, 2003

• Declaration Of Steven M. Perry In Support Of Respondent Rambus Inc.’s Motion For Prehearing Determination Of Order Of Issues To Be Tried [PDF 8KB]
• [Proposed] Order Determining Order Of Issues To Be Tried [PDF 5KB]
• Motion By Respondent Rambus Inc. For Pre-Hearing Determination Of Order Of Issues To Be Tried And Memorandum In Support Thereof [PDF 28KB]

March 20, 2003

• Proposed Order Granting Respondent's Unopposed Motion for Leave to File Reply Memorandum in Support of Respondent's Application for Review of the 2/28/2003 Order Granting Complaint Counsel’s Motion to Compel Discovery Relating to Subject Matters as to Which Rambus’s Privilege Claims Were Invalidated on Crime-fraud Grounds and Subsequently Waived, Pursuant to Rule 3.23(b) or, in the Alternative, Request for Reconsideration of That Order [PDF 15KB]
• Reply Brief in Support of Respondent’s Application for Review of the February 28, 2003 Order Granting Complaint Counsel’s Motion to Compel Discovery Relating to Subject Matters as to Which Rambus’s Privilege Claims Were Invalidated on Crime-Fraud Grounds and Subsequently Waived, Pursuant to Rule 3.23(b) or, in the Alternative, Request for Reconsideration of That Order [PDF 52KB]
• Unopposed Motion by Respondent Rambus Inc. for Leave to File Reply Memorandum in Support of Respondent’s Application for Review of the February 28, 2003 Order Granting Complaint Counsel’s Motion to Compel Discovery Relating to Subject Matters as to Which Rambus’s Privilege Claims Were Invalidated on Crime-Fraud Grounds and Subsequently Waived, Pursuant to Rule 3.23(b) or, in the Alternative, Request for Reconsideration of That Order [PDF 12KB]
• Verification of Respondent Rambus Inc.’s Supplemental Responses to Complaint Counsel’s First Request for Admissions [PDF 6KB]

March 19, 2003

• Complaint Counsel’s Supplemental Response to Respondent Rambus Inc.’s Second Set of Requests for Admissions to the Federal Trade Commission[PDF 176KB]
• Complaint Counsel’s Response to Respondent Rambus Inc.’s Second Set of Requests for Admissions to the Federal Trade Commission[PDF 166KB]

March 18, 2003

• Supplemental Declaration of Steven M. Perry in Support of Rule 3.24 Separate Statement in Support of Rambus Inc.'s Motion for Summary Decision [PDF 11KB]
• Supplemental Rule 3.24 Separate Statement in Support of Rambus Inc.'s Motion for Summary Decision [PDF 13KB]
• Proposed Order [PDF 5KB]
• Respondent Rambus Inc.’s Application for Leave to File (1) Supplemental Rule 3.24 Separate Statement in Support of Rambus Inc.'s Motion for Summary Decision; and (2) Supplemental Declaration of Steven M. Perry in Support of Rule 3.24 Separate Statement in Support of Rambus Inc.'s Motion for Summary Decision [PDF 11KB]

March 17, 2003

• Complaint Counsel’s Opposition To Respondent’s Application For Review Of The February 28, 2003 Order Granting Counsel’s Motion To Compel Discovery Relating To Subject Matters As To Which Rambus’s Privilege Claims Were Invalidated On Crime-fraud Grounds And Subsequently Waived, Pursuant To Rule 3.23(b) Or, In The Alternative, Request For Reconsideration Of That Order [PDF 55KB]
• Administrative Law Judge's Order Granting Rambus Inc.'s Motion For Leave To File A Reply Brief In Support Of Respondent's Application For Review Of The February 26, 2003 Order Granting Complaint Counsel's Motion For Collateral Estoppel [PDF 69KB]
• Administrative Law Judge’s Order Setting Prehearing Conference [PDF 67KB]

March 13, 2003

• Joint Request for Status Conference [PDF 195KB]
• Administrative Law Judge’s Order Denying Complaint Counsel's Motion to Compel an Additional Day of Deposition Testimony of Richard Crisp[PDF 35KB]
• Respondent Rambus Inc.’s Supplemental Responses to Complaint Counsel’s First Request for Admissions [PDF 94KB]
• Reply Brief in Support of Respondent’s Application for Review of the February 26, 2003 Order Granting Complaint Counsel’s Motion for Collateral Estoppel Pursuant to Rule 3.23(b) or, in the Alternative, Request for Reconsideration of That Order [PDF 36KB]
• Proposed Order [PDF 5KB]
• Motion by Respondent Rambus Inc. for Leave to File a Reply Brief in Support of Respondent’s Application for Review of the February 26, 2003 Order Granting Complaint Counsel’s Motion for Collateral Estoppel Pursuant to Rule 3.23(b) or, in the Alternative, Request for Reconsideration of That Order [PDF 9KB]

March 11, 2003

• Response To Rambus’s Application For Review Of February 26, 2003, Order Granting Complaint Counsel’s Motion For Collateral Estoppel Or, In The Alternative, Request For Reconsideration [PDF 70KB]
• Proposed Order [PDF 5KB]
• Memorandum by Respondent Rambus Inc. and by Third-Party Witness Richard Crisp in Opposition to Motion to Complaint Counsel's Motion to Compel an Additional Day of Testimony of Richard Crisp [PDF 35KB]

March 10, 2003

• Appendix To Application For Review Of The February 28, 2003 Order Granting Complaint Counsel’s Motion To Compel Discovery Relating To Subject Matters As To Which Rambus’s Privilege Claims Were Invalidated On Crime-Fraud Grounds And Subsequently Waived, Pursuant To Rule 3.23(B) Or, In The Alternative, Request For Reconsideration Of That Order [PDF 10KB]

March 7, 2003

• Application For Review Of The February 28, 2003 Order Granting Complaint Counsel’s Motion To Compel Discovery Relating To Subject Matters As To Which Rambus’s Privilege Claims Were Invalidated On Crime-Fraud Grounds And Subsequently Waived, Pursuant To Rule 3.23(B) Or, In The Alternative, Request For Reconsideration Of That Order [PDF 56KB]
• Declaration of Steven M. Perry in Support of Opposition to Complaint Counsel’s Motion to Compel an Additional Day of Deposition Testimony of Richard Crisp [PDF 14KB]
• Proposed Order on Complaint Counsel’s Unopposed Motion for Extensions of Time to File Motions to Compel Regarding Requests for Admissions and Responses to Such Motions [PDF 5KB]

March 6, 2003

• Unopposed Motion For Extensions Of Time To File Motions To Compel Regarding Requests For Admissions And Responses To Such Motions [PDF 6KB]
• Proposed Order [PDF 5KB]

March 5, 2003

• Application for Review of the February 26, 2003 Order Granting Complaint Counsel’s Motion for Collateral Estoppel Pursuant to Rule 3.23(b) or, in the Alternative, Request for Reconsideration of That Order [PDF 54KB]

March 4, 2003

• ALJ Order Granting Respondent's Unopposed Motion for Extension of Time to Respond to Complaint Counsel's Motion to Compel an Additional Day of Deposition Testimony of Richard Crisp [PDF 10KB]
• Declaration of Steven M. Perry [PDF 20KB]
• Respondent Rambus Inc.’s Rule 3.24 Separate Statement of Material Facts as to Which There is No Genuine Issue [PDF 69KB]

February 28, 2003

• ALJ Order Reassigning Matter to Judge Stephen J. McGuire [PDF 29KB]
• ALJ Order Concerning Complaint Counsel's Motion to Compel Discovery Relating to Subject Matters as to Which Rambus's Privilege Claims Were Invalidated on Crime Fraud Grounds and Subsequently Waived [PDF 149KB]
• Memorandum in Opposition to Complaint Counsel’s Request for Immediate Clarification of February 26, 2003 Order on Complaint Counsel’s Motions for Default Judgment and for Oral Argument, and in Response to Order Denying Request for Clarification [PDF 14KB]
• Memorandum in Support of Respondent Rambus Inc.’s Motion for Summary Decision [PDF 147KB]

February 27, 2003

• ALJ Order Denying Request for Clarification [PDF 23KB]
• Unopposed Motion for Extension of Time to Respond to Complaint Counsel’s Motion to Compel an Additional Day of Deposition Testimony of Richard Crisp and Proposed Order [PDF 13KB]
• Rambus Inc.'s Motion for Summary Decision [PDF 8KB]
• Request for Immediate Clarification of February 26, 2003 Order on Complaint Counsel’s Motions for Default Judgment and for Oral Argument and Proposed Order [PDF 14KB]

February 26, 2003

• ALJ Order on Complaint Counsel's Motions for Default Judgment and for Oral Argument [PDF 392KB]
• ALJ Order Granting Complaint Counsel's Motion for Collateral Estoppel [PDF 196KB]
• ALJ Order Denying Complaint Counsel's Motion to Compel Discovery Relating to Rambus's Document Destruction[PDF 13KB]
• ALJ Order Denying Complaint Counsel's Amended Application to Place Documents on the Public Record [PDF 141KB]

February 24, 2003

• Proposed Orders [PDF 8KB]
• Rambus, Inc.’s Opposition to Complaint Counsel’s (1) Motion for Leave to File Supplemental Memorandum in Support of Motion for Default Judgment, and (2) Motion Seeking Recognition of the Collateral Estoppel Effect of Prior Factual Findings Underlying Portions of the Judgment in Infineon Now Vacated by the Federal Circuit [PDF 46KB]

February 21, 2003

• Objection by MOSAID Technologies Inc. to Rambus Inc.'s Subpoenas of Betty Prince [PDF 134KB]
• Complaint Counsel’s Motion to Compel an Additional Day of Deposition Testimony of Richard Crisp [PDF 6KB]
• Proposed Order [PDF 5KB]
• Memorandum in Support of Complaint Counsel’s Motion to Compel an Additional Day of Deposition Testimony of Richard Crisp [PDF 31KB]
• Administrative Law Judge's Fourth Revised Scheduling Order [PDF 71KB]
• Response of Complaint Counsel to Rambus Inc.'s Opposition to Complaint Counsel's Motion to Compel [PDF 1073KB]

February 19, 2003

• Joint Motion for Entry of Revised Scheduling Order and Request for Telephonic Scheduling Conference [PDF 190KB]

February 14, 2003

• Memorandum by Rambus Inc. in Opposition to Complaint Counsel’s Motion to Compel Discovery Relating to Rambus’s Document Destruction and Proposed Order [PDF 61KB]
• [Proposed] Order Granting Complaint Counsel's Motion [PDF 8KB]
• Complaint Counsel's Motion for Leave to File Reply in Support of Motion to Compel Discovery Relating to Rambus's Document Destruction [PDF 6KB]

February 12, 2003

• Supplemental Memorandum in Support of Complaint Counsel’s Pending Motion for Default Judgment, Relating to Collateral Estoppel Effect of Prior Factual Finding That Respondent Rambus Inc. Destroyed Material Evidence in Bad Faith [PDF 32KB]
• Motion for Leave to File Supplemental Memorandum in Support of Complaint Counsel’s Pending Motion for Default Judgment and Proposed Order [PDF 11KB]
• Motion Seeking Recognition of the Collateral Estoppel Effect of Prior Factual Findings That Respondent Rambus Inc. Destroyed Material Evidence in Anticipation of Future Litigation and Proposed Order [PDF 10KB]

February 11, 2003

• Complaint Counsel's Memorandum in Support of Motion to Compel Discovery Relating to Subject Matters as to Which Rambus's Privilege Claims Were Invalidated on Crime-fraud Grounds and Subsequently Waived [PDF 1511KB]

February 7, 2003

• Respondent Rambus Inc's Responses to Complaint Counsel's First Request for Admissions [PDF 935KB]

February 6, 2003

• Memorandum by Rambus Inc. in Opposition to Complaint Counsel's Motion to File a Reply Memorandum in Support of Their Motion to Compel Discovery Relating to Subject Matters as to Which Rambus's Privilege Claims Were Invalidated on Crime-Fraud Grounds and Subsequently Waived [PDF 28KB]
• Proposed Order [PDF 5KB]

January 31, 2003

• Rambus Inc.’s Response to Complaint Counsel’s Amended Application to Place Exhibits to the Motion for Default Judgment on the Public Record [PDF 27KB]
• Declaration of Edward Larsen [PDF 21KB]
• Rambus Inc.’s Opposition to Complaint Counsel’s Motion to Strike Rambus Inc.’s Joinder in Complaint Counsel’s Request for Oral Argument on the Motion for Default Judgment [PDF 16KB]
  • Proposed Order [PDF 8KB]

January 30, 2003

• ALJ’s Order Granting Unopposed Motion for Extension of Time to Limit Subpoena Filed by Skjerven Morrill LLP [PDF 10KB]
• Notice of Rambus Inc’s Intention to File an Opposition to Complaint Counsel’s Motion for Leave to File Reply in Support of Motion to Compel [PDF 10KB]
• Complaint Counsel's Motion to Strike Rambus Inc.’s Joinder in Complaint Counsel’s Request for Oral Argument on the Motion for Default Judgment [PDF 14KB]

January 29, 2003

• Complaint Counsel’s Amended Application to Place on the Public Record Documents Attached as Exhibits to Complaint Counsel’s Motion for Default Judgment [PDF 31KB]
• Rambus Inc.’s Joinder in Complaint Counsel’s Request for Oral Argument on the Motion for Default Judgment [PDF 18KB]

January 28, 2003

• Non-party Skjerven Morrill Llp's Unopposed Motion for Extension of Time to Move to Quash or Limit Subpoena or Otherwise Respond [PDF 42KB]
• Complaint Counsel’s Corrected Reply to Rambus Inc.’s Memorandum in Opposition to Motion for Default Judgment [PDF 47K]
• Complaint Counsel’s Motion for Leave to File Reply in Support of Motion to Compel and Proposed Order [PDF 8KB]

January 23, 2003

• Complaint Counsel’s Application to Place on the Public Record Documents Attached as Exhibits to Complaint Counsel’s Motion for Default Judgment [PDF 1813KB]
• Administrative Law Judge's Third Revised Scheduling Order [PDF 23KB]
• Unopposed Motion for Entry of Revised Scheduling Order [PDF 15KB]

January 21, 2003

• Declaration of Joel A. Karp [PDF 10KB]
• Memorandum by Rambus Inc. in Opposition to Complaint Counsel’s Motion to Compel Discovery Relating to Subject Matters as to Which Rambus’s Privilege Claims Were Invalidated on Crime-Fraud Grounds and Subsequently Waived [PDF 64KB]

January 20, 2003

• Declaration of Gregory P. Stone [PDF 10KB]

January 16, 2003

• Complaint Counsel's Unopposed Motion for Leave to File Reply in Support of Motion for Default Judgment [PDF 96KB]
• Administrative Law Judge’s Order Dismissing Rambus's Motion, Without Prejudice, to Compel the Production of Documents in the Possession of NEC Electronics, Inc.'s Parent Company [PDF 12KB]
• Complaint Counsel's Motion for Default Judgment Relating to Respondent Rambus Inc.'s Willful, Bad-Faith Destruction of Material Evidence [PDF 5044KB]

January 15, 2003

• Administrative Law Judge's Second Revised Scheduling Order [PDF 72KB]
• Administrative Law Judge’s Order Granting Motion of the United States Department of Justice to Limit Discovery Relating to the Dram Grand Jury [PDF 34KB]
• Administrative Law Judge's Opinion Supporting Order Granting Motion of the United States Department of Justice to Limit Discovery Relating to the Dram Grand Jury [PDF 107KB]
• Respondent’s Unopposed Motion For Extension Of Time To Respond To Complaint Counsel’s Motion To Compel Discovery Relating To Subject Matters As To Which Rambus’s Privilege Claims Were Invalidated On Crime-Fraud Grounds And Subsequently Waived [PDF 13KB]
• Declaration of Jacqueline M. Haberer [PDF 10KB]
• Memorandum by Rambus Inc. in Opposition to Complaint Counsel's Motion for Default Judgment [PDF1614KB]

January 14, 2003

• Request By Respondent Rambus Inc. For Dismissal Without Prejudice Of Rambus’s Motion To Compel The Production Of Documents In The Possession Of NEC’s Parent Company [PDF 11KB]

January 13, 2003

• ALJ Order Granting Unopposed Motion for Extension of Time to File Public Version of Complaint Counsel's Motion to Compel Discovery Relating to Matters in Which Rambus's Privilege Claims Were Invalidated on Crime-fraud Grounds and Subsequently Waived [PDF 14KB]

January 10, 2003

• Unopposed Motion For Extension Of Time To File Public Record Version Of Complaint Counsel's Motion To Compel Discovery Relating To Subject Matters As To Which Rambus's Privilege Claims Were Invalidated On Crime-Fraud Grounds And Subsequently Waived [PDF 44KB]

January 9, 2003

• ALJ Order on Motion by Department of Justice for In Camera Treatment of Documents [PDF 67KB]

January 8, 2003

• Rambus Inc.'s Corrected Reply to Complaint Counsel's Response Regarding Motion by the Department of Justice to Limit Discovery [PDF 18KB]

January 7, 2003

• Memorandum by Rambus Inc. in Response to Motion by Department of Justice to Limit Discovery Relating to the Dram Grand Jury [PDF 899KB]
• ALJ Order Granting Skjerven Morrill LLP an Extension of Time to Move to Limit Subpoena [PDF 31KB]
• Declaration of Steven M. Perry in Response to Motion by Department of Justice to Limit Discovery Relating to the DRAM Grand Jury [PDF 15KB]

January 6, 2003

• Complaint Counsel’s Response to Memorandum by Rambus Inc. in Response to Motion by Department of Justice to Limit Discovery Relating to the Dram Grand Jury [PDF 725KB]
• Rambus Inc.'s Reply to Complaint Counsel's Response Regarding Motion by the Department of Justice to Limit Discovery[PDF 48KB]
• Rambus Inc.'s Second Set of Requests for Admissions to the Federal Trade Commission [PDF 68KB]

January 3, 2003

• ALJ Order Denying Motion to Quash Filed on Behalf of Third-Party De Dios & Associates [PDF 38KB]
• ALJ Order Granting NEC Electronics, Inc.'s Motion for Extension of Time to Repsond to Rambus' Motion to Compel [PDF 10KB]
• Complaint Counsel’s Statement in Support of Department of Justice’s Motion to Limit Discovery Relating to Dram Grand Jury [PDF 23KB]

January 2, 2003

• ALJ Order Denying Rambus' Motion to Compel [PDF 56KB]
• Non-party NEC Electronics, Inc.'s Unopposed Motion for an Extension of Time to Respond to Rambus' Motion to Compel [PDF 18KB]

December 31, 2002

• ALJ Order Re: Motion by Rambus to Compel Samsung Electronics America, Inc. To Produce Certain Documents Withheld on Privilege Grounds [PDF 39KB]
• Repondent's Notice of Filing of Revised Proposed Order [PDF 436KB]

December 30, 2002

• ALJ Order Granting Unopposed Motion for Extension of Time to File Public Record Version of Complaint Counsel's Motion for Default Judgment [PDF 34KB]
• Declaration of Steven M. Perry In Opposition to Motion by De Dios & Associates to Quash Subpoena Duces Tecum [PDF 273KB]
• Opposition by Respondent Rambus Inc. to Motion by De Dios & Associates to Quash Subpoena Duces Tecum [PDF 261KB]
• Non-Party Mitsubishi Electric & Electronics USA, Inc.'s Opposition To Respondent Rambus Inc.'s Motion To Compel; Declaration of Terrence H. Cross; Declaration of John W. Calkins and Proposed Order Denying Motion To Compel [PDF 1186KB]
• Unopposed Motion for Extension of Time to File Public Record Version of Complaint Counsel's Motion for Default Judgment [PDF 8KB]
• Proposed Order [PDF 5KB]

December 27, 2002

• U.S. Department of Justice Motion for In Camera Treatment of Documents, DOJ's Motion to Limit Discovery Relating to the Dram Grand Jury and Proposed Orders [PDF 315KB]

December 26, 2002

• Motion by Respondent Rambus Inc. for Leave to File a Reply Brief in Support of its Motion to Compel Samsung Electronics America, Inc. to Produce Certain Documents Withheld on Privilege Grounds [PDF 17KB]

December 24, 2002

• Rambus' Unopposed Motion for Extension of Time to Respond to Complaint Counsel's Motion for Default Judgment [PDF 281 KB]

December 23, 2002

• Samsung, Hynix, Infineon, Micron and Intel's Opposition to Rambus, Inc.'s Motion to Compel Samsung Electronics America, Inc. to Produce Certain Documents Withheld on Privilege Grounds [PDF 269 KB]

December 20, 2002

• Complaint Counsel's Motion for Default Judgment Relating to Respondent Rambus Inc.'s Willful, Bad-Faith Destruction of Material Evidence [PDF 5044KB]
• Motion By Respondent Rambus Inc. To Compel Mitsubishi Electric & Electronics USA, Inc. To Comply With This Court's Order To Produce Documents Responsive To The Subpoena Served By Rambus Inc. and Order [PDF 12KB]
• Rule 3.22(f) Declaration of Steven M. Perry In Support of Motion [PDF 542KB]
• Motion by Respondent Rambus Inc. to Compel NEC Electronics, Inc. to Produce Documents in its Parent Company’s P