Case 5:05-cv-00334-RMW Document 2121 Filed 09/02/2008 Page 1 of 4

3 Attorney list on signature page

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5 IN THE UNITED STATES DISTRICT COURT

6 NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION

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RAMBUS, INC.,
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Plaintiff.
9 v.
10 HYNIX SEMICONDUCTOR INC., HYNIX
SEMICONDUCTOR AMERICA INC., HYNIX Case No. C 05-00334 RMW
11 SEMICONDUCTOR MANUFACTURING
AMERICA INC.,
12 SAMSUNG’S MOTION TO SHORTEN
SAMSUNG ELECTRONICS CO., LTD., TIME AND FOR EXPEDITED HEARING
13 SAMSUNG ELECTRONICS AMERICA, INC., PURSUANT TO CIVIL LOCAL RULE 6-
SAMSUNG SEMICONDUCTOR, INC., 3
14 SAMSUNG AUSTIN SEMICONDUCTOR,
L.P., Judge: Hon. Ronald M. Whyte
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NANYA TECHNOLOGY CORPORATION,
16 NANYA TECHNOLOGY CORPORATION
U.S.A.,
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18 Defendants.
19 RAMBUS, INC.,
20 Plaintiff.
v.
21
SAMSUNG ELECTRONICS CO., LTD., Case No. C 05-02298 RMW
22 SAMSUNG ELECTRONICS AMERICA, INC.,
SAMSUNG SEMICONDUCTOR, INC.,
23 SAMSUNG AUSTIN SEMICONDUCTOR,
L.P.,
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Defendants.
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Case No. C 05 00334 RMW

Case No. C 05 02298 RMW
SAMSUNG’S MOTION TO SHORTEN TIME
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I. ARGUMENT
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Pursuant to Civil Local Rules 6-3, Samsung Electronics Co., Ltd., Samsung Electronics
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America, Inc., Samsung Semiconductor, Inc., and Samsung Austin Semiconductor, L.P.
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(collectively, “Samsung”) hereby files this Motion to Shorten Time and moves this Court for an
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order expediting the briefing schedule and for an expedited hearing on Samsung’s Motion to
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Dismiss Certain Claims and Defenses Without Prejudice (hereinafter “Motion to Dismiss”), filed
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concurrently with this Motion to Shorten Time. Samsung requests that the Court hear
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Samsung’s Motion to Dismiss on an expedited basis on September 5, 2008. To that end,
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Samsung requests that the Court enter an order requiring Rambus to file its opposition to
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Samsung’s Motion to Dismiss no later than 10:00 a.m. on Thursday, September 4, 2008, so that
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the Court will have sufficient time to review on Samsung’s Motion to Dismiss and Rambus’s
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opposition prior to the September 5, 2008 hearing.
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Good cause for this Motion to Shorten Time exists given the fact that trial in this case is
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set to begin on September 22, 2008. The Court’s ruling on Samsung’s Motion to Dismiss will
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greatly change the scope of the case and will severely impact both parties’ ability to prepare for
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trial if a decision on Samsung’s Motion to Dismiss is delayed. As set forth in Samsung’s Motion
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to Dismiss, Samsung believes that the cases before this Court involving Samsung will be brought
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to conclusion faster and more effectively if the current Claims I-III and defenses based on the
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parties’ 2000 SDR/DDR Patent License, and the unclean hands issues, are tried the week of
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September 22, 2008; with other claims being cut out for resolution by the State Court. Samsung
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has met and conferred with Rambus in order to reach a resolution as to the Motion to Shorten
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Time but was unsuccessful in reaching a stipulation. Samsung has limited its Motion to Dismiss
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to three pages and will forgo a reply in order to facilitate this Motion to Shorten Time. Rambus
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will not be prejudiced by an expedited hearing schedule as a timely resolution of Samsung’s
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Motion to Dismiss will more quickly narrow the issues for trial.
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Pursuant to Local Rule 6-3(a)(3), Samsung asserts that it would be substantially harmed or
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prejudiced if the Court did not hear the Motion to Dismiss on shortened time. Since the Court’s
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ruling on Samsung’s Motion to Dismiss will greatly change the scope of the case, if a decision on
SAMSUNG’S MOTION TO SHORTEN TIME
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 Case 5:05-cv-00334-RMW Document 2121 Filed 09/02/2008 Page 3 of 4

1 Samsung’s Motion to Dismiss is delayed this will severely impact Samsung’s ability to deal with
2 these claims and defenses. Such a delay would harm and prejudice Samsung given that the trial
3 is set to begin in less than three weeks.
4 Pursuant to Local Rule 6-3(a)(5), Samsung states that it has not sought any other motions
5 to shorten time in connection with the upcoming September trial. Bennett Decl. __
6 Pursuant to Local Rule 6-3(a)(6), Samsung states that it does not believe the motion to
7 shorten time will have any impact on the schedule of the case. The issues in the Motion to
8 Dismiss will bring clarity to the upcoming September 22nd trial, and allow the parties to
9 appropriately focus their trial preparation efforts.
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11 II. CONCLUSION
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13 For the foregoing reasons, Samsung respectfully requests that this Court grants its Motion
14 to Shorten Time which requires Rambus to file its opposition to Samsung’s Motion to Dismiss no
15 later than 10:00 a.m. on Thursday, September 4, 2008 and for the Court to hear Samsung’s
16 Motion to Dismiss on September 5, 2008.
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18 Dated: September 2, 2008

19 WEIL, GOTSHAL & MANGES, LLP

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By: ___/s/_David J. Healey________________
21 David J. Healey

22 MATTHEW D. POWERS (Bar No. 104795)

Email: matthew.powers@weil.com
23 EDWARD R. REINES (Bar No. 135930)
Email: edward.reines@weil.com
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SAMSUNG’S MOTION TO SHORTEN TIME

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1 WEIL, GOTSHAL & MANGES LLP

201 Redwood Shores Parkway
2 Redwood Shores, CA 94065
Telephone: (650) 802-3000
3 Facsimile: (650) 802-3100
4 DAVID J. HEALEY (admitted pro hac vice)
Email: david.healey@weil.com
5 ANITA E. KADALA (admitted pro hac vice)
Email: anita.kadala@weil.com
6 WEIL, GOTSHAL & MANGES LLP
700 Louisiana, Suite 1600
7 Houston, TX 77002
Telephone: (713) 546-5000
8 Facsimile: (713) 224-9511
9 Attorneys for Defendants
SAMSUNG ELECTRONICS CO., LTD.,
10 SAMSUNG ELECTRONICS AMERICA, INC.,
SAMSUNG SEMICONDUCTOR, INC., and
11 SAMSUNG AUSTIN SEMICONDUCTOR, L.P
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SAMSUNG’S MOTION TO SHORTEN TIME

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