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RAMBUS INC.
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A PROFESSIONAL CORPORATION • ATTORNEYS
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MCKOOL SMITH
DALLAS, TEXAS
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28 DECLARATION OF PIERRE J. HUBERT IN SUPPORT OF
RAMBUS INC’S OPPOSITION TO HYNIX’S MOTION TO STRIKE PORTIONS OF RAMBUS’S FINAL INFRINGEMENT
CONTENTIONS
Case No. CV 05-00334
Austin 45797v2
Case 5:05-cv-00334-RMW Document 2115 Filed 08/29/2008 Page 3 of 3
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1. I am an attorney with the law firm of McKool Smith P.C., counsel of record for
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Plaintiff Rambus Inc. in the above-entitled action. I am duly licensed in the State of Texas and
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admitted to practice before this Court pro hac vice. I make this declaration based on my personal
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knowledge, the record in this action, and matters of public record, and if called upon as a
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witness, I could and would testify competently as to the matters set forth below.
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2. Attached hereto as Exhibit A is a true and correct copy of the Qimonda IDGV1G-
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05A1F1C-40X/45X/50X 1Gbit x32/x15 GDDR5 SGRAM Advance Internet Data Sheet, Rev.
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0.60, dated June 2008. This was the first publicly available datasheet, of which Rambus became
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aware, relating to production-ready GDDR5 products.
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I declare under penalty of perjury under the laws of the State of Texas that the foregoing
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is true and correct, and that this declaration was executed on August 29, 2008, at Austin, Texas.
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DECLARATION OF PIERRE J. HUBERT IN SUPPORT OF
RAMBUS INC’S OPPOSITION TO HYNIX’S MOTION TO STRIKE PORTIONS OF RAMBUS’S FINAL INFRINGEMENT
CONTENTIONS
Austin 45797v2