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EXHIBIT A

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Mike McKool, Jr. (pro hac vice) Douglas Cawley (pro hac vice) McKOOL SMITH P.C. 300 Crescent Court Suite 1500 Dallas, Texas 75201 Telephone: (214) 978-4000 Facsimile: (214) 978-4044 Email:mmckool@mckoolsmith.com; dcawley@mckoolsmith.com Scott L. Cole (pro hac vice) Pierre J. Hubert (pro hac vice) Craig N. Tolliver (pro hac vice) McKOOL SMITH P.C. 300 W. 6th Street Suite 1700 Austin, Texas 78701 Telephone: (512) 692-8700 Facsimile: (512) 692-8744 Email: scole@mckoolsmith.com; phubert@mckoolsmith.com; ctolliver@mckoolsmith.com Attorneys for Plaintiff RAMBUS INC.

J. Daniel Sharp (CSB No. 131042) CROWELL & MORING LLP 275 Battery Street, 23rd Floor San Francisco, California 94111 Telephone: (415) 986-2800 Facsimile: (415) 986-2827 Email: dsharp@crowell.com

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION RAMBUS INC., Plaintiff, v. NVIDIA CORPORATION, Defendant. RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA CORPORATION Case No. C-08-03343 SI

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Rambus Inc. hereby requests that Defendant NVIDIA Corporation respond to the following Interrogatories separately and fully in writing under oath, and serve these responses to the undersigned counsel at McKool Smith P.C., 300 W. 6th St., Suite 1700, Austin, Texas 78701 within thirty (30) days of service hereof.

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DEFINITIONS AND INSTRUCTIONS 1. Rambus means Plaintiff Rambus Inc., including without limitation all of its

subsidiaries, affiliates, divisions, related entities, predecessors, successors, and any present or former officers, directors, trustees, employees, agents, or representatives. 2. Defendant, NVIDIA, You or Your means Defendant NVIDIA

Corporation including without limitation all subsidiaries, affiliates, divisions, related entities, controlled entities, predecessors, and successors of NVIDIA Corporation and any present or former officers, directors, trustees, employees, agents, representatives, or individuals acting on behalf of NVIDIA Corporation. The term NVIDIA, as used in any Request below, shall be interpreted to refer to each and all of the entities or Persons listed in the preceding sentence so as not to exclude any otherwise responsive documents from the scope of the Request. 3. Document or documents is defined broadly, and includes all documents,

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electronically stored information and tangible things within the meaning of the Federal Rules of Civil Procedure, either originals or identical copies thereof, all non-identical copies, all drafts of final documents, all other written, printed, or recorded matter of any kind, and all other data compilations from which information can be obtained and translated if necessary, that are or have been in NVIDIAs actual or constructive possession or control, regardless of the medium on which they are produced, reproduced, or stored (including without limitation computer programs and files, electronic mail, recordings, writings, and any other electronically stored information containing any requested information). Any document bearing marks, including without limitation, initials, stamped initials, comments, or notations not a part of the original text or photographic reproduction thereof, is a separate document. 4. Person or persons includes natural persons and entities such as any individual

or firm, association, organization, joint venture, trust, partnership, corporation, or other collective organization or entity. 5. Communication or communications means any transfer or exchange between

or among two or more Persons of any information whether by written, oral, electronic or other means, including but not limited to personal conversations, correspondence, electronic mail,
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telephone calls, voice mail, facsimile communications, or telegrams. 6. 7. The terms any and all shall include each and every. Patents-in-Suit means Rambuss U.S. Patent No. 7,209,997 (the 997 Patent),

U.S. Patent No. 6,751,696 (the 696 Patent), U.S. Patent No. 6,564,281 (the 281 Patent), U.S. Patent No. 6,470,405 (the 405 Patent), U.S. Patent No. 7,287,109 (the 109 Patent), U.S. Patent No. 7,330,952 (the 952 Patent), U.S. Patent No. 7,330,953 (the 953 Patent), U.S. Patent No. 7,360,050 (the 050 Patent), U.S. Patent No. 7,287,119 (the 119 Patent), U.S. Patent No. 7,210,016 (the 016 Patent), U.S. Patent No. 7,177,998 (the 998 Patent), U.S. Patent No. 6,591,353 (the 353 Patent), U.S. Patent No. 6,260,097 (the 097 Patent), U.S. Patent No. 6,304,937 (the 937 Patent) and/or U.S. Patent No. 6,715,020 (the 020 Patent). Certain of the Patents-in-Suit are currently subject to a stay pursuant to 35 U.S.C. 1659. To the extent that there exists responsive information in Your possession, custody, or control that You contend is responsive solely with respect to stayed Patents-in-Suit and not with respect to any other Patent-in-Suit, state Your contention/objection with particularity. Further, to the extent that information responsive to any interrogatory herein is responsive solely with respect to stayed Patents-in-Suit, Your response to the interrogatory should be supplemented with respect to such information promptly following the lifting of the aforementioned stay. 8. Accused Products means all versions of all products made, used, sold,

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imported, or offered for sale by or for NVIDIA that consist of or include: SDR (Single Data Rate) memory controllers, DDR (Double Data Rate) memory controllers, DDRx memory controllers (where DDRx includes at least DDR2, DDR3, LPDDR2, LPDDR3, and gDDRx), GDDR (Graphics Double Data Rate) memory controllers, and/or GDDRy memory controllers (where GDDRy includes at least GDDR2, GDDR3, GDDR4 and GDDR5), including the accused products and instrumentalities set forth in Rambuss P.R. 3-1 and 3-2 Disclosure of Asserted Claims and Infringement Contentions, including any amendments thereto or subsequent versions thereof. The Accused Products include, but are not limited to, the following: chipsets, graphics processors, media communication processors, multimedia applications processors and/or products that are part of NVIDIAs GeForce, Quadro, nForce, Tesla, Tegra -3RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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and/or GoForce product lines. 9. Relate to, related to or relating to means embodying, pertaining,

concerning, involving, constituting, commenting upon, comprising, reflecting, discussing, evidencing, mentioning, referring to, consisting of, responding to, or having any logical or factual connection whatsoever with the subject matter in question. 10. Concern or concerning means embodying, pertaining, relating to, involving,

constituting, commenting upon, comprising, reflecting, discussing, evidencing, mentioning, referring to, consisting of, responding to, or having any logical or factual connection whatsoever with the subject matter in question. 11. Identify or Identity or Identification should be interpreted in accordance

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with the full scope of the Federal Rules of Civil Procedure, and when used in reference to: (a) a natural person, means: (1) the persons full name or title, last known address, and telephone number; (2) the persons present employer(s) and place(s) of employment; and (3) the persons job title or position held. (b) a document, means: (1) its date, author, and addressee(s); (2) the type of

document (e.g., letter, memorandum, etc.); (3) providing a Bates number, where applicable, and (4) its present location and identity of its custodian. (c) a statement, either written or spoken, means: (1) the substance of each

such statement; (2) the exact words used by each person participating in the statement; (3) to identify each person engaging in the statement; (4) the identity of each person present at the making or reception of such statement; (5) the time and place of the statement; (6) the means of such statement (e.g., written, telephone, face-to-face, etc.). 12. The past tense of a verb used herein includes the present tense and the present

tense includes the past tense. 13. 14. The term "including" shall mean "including, without limitations." The term "each" shall be construed to include "every," and vice versa. -4RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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15.

If any information is withheld on the basis of a claim of privilege, work product,

or any other reason, then the answer shall state the privilege or reason for withholding asserted; generally identify the information withheld by subject matter, author or originator, addressees or recipients, and carbon copy recipient(s) or parties to the communication; state the basis for withholding the information; and identify the person(s) knowledgeable about the subject matter of the withheld information. 16. The singular form of a word should be interpreted in the plural as well. Any

pronoun shall be construed to refer to the masculine, feminine, or neuter gender as in each case is most appropriate. The connectives and and or should be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope and to render Your responses fully responsive, comprehensible and not misleading.

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INTERROGATORIES INTERROGATORY NO. 1: Describe in detail each NVIDIA Accused Product manufactured, used, sold, offered for sale, or imported by NVIDIA since January 1, 2000, including by Identifying each such Accused Products NVIDIA product name, part number, model number, version number, all internal names and designations (including marketing designations), what type of memory is supported by the product, and the Date of Sale (where Date of Sale shall include the date each such product was first offered for sale, released for sale and, if no longer sold, removed from sale). RESPONSE:

INTERROGATORY NO. 2: Separately for each Accused Product, describe, in a detailed claim chart that sets forth on a limitation-by-limitation basis each claim limitation that NVIDIA contends is not met by each Accused Product, all factual and legal bases for NVIDIAs assertion of non-infringement, direct or indirect (through contributory and/or induced infringement), literal or under the doctrine of -5RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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equivalents, if any, with respect to each such claim limitation that allegedly is not met, including an Identification of all documents that support or refute NVIDIAs contention. RESPONSE:

INTERROGATORY NO. 3: Identify all documents and categories of documents prepared by or on behalf of NVIDIA or its suppliers that disclose the structure, function, and/or operation of the Accused Products, such as (a) user guides, (b) block diagrams, (c) product samples, (d) brochures, (e) data sheets, (f) specification sheets, (g) application notes, (h) schematics, (i) white papers, and (j) programming documentation. RESPONSE:

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INTERROGATORY NO. 4: Identify each memory device employed in the Accused Products or used in conjunction with the Accused Products, including an Identification of all suppliers/manufacturers of each memory device. RESPONSE:

INTERROGATORY NO. 5: Describe in detail all factual, legal and statutory bases that support or relate to any contention by NVIDIA that its infringement of the Patents-in-Suit was not or is not willful and deliberate, including an Identification, by Bates number, of all documents that refer to, relate to or support any such contention. RESPONSE:

INTERROGATORY NO. 6: Separately for each claim of the Patents-in-Suit, describe all attempts or plans to design -6RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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around or otherwise avoid infringement of any of the claims of the Patents-in-Suit. RESPONSE:

INTERROGATORY NO. 7: Separately for each of the Patents-in-Suit, Identify and describe in detail all actions (including analyses, investigations, evaluations, inquiries, modifications, and communications) undertaken by You or on Your behalf (including, but not limited to, any advice or opinions of attorneys, agents, solicitors, legal representatives, or any other person that have been provided to You or rendered by You on Your behalf) concerning the Patents-in-Suit, including (i) infringement/non-infringement; (ii) validity/invalidity (including but not limited to any searches for prior art); (iii) enforceability/unenforceability; (iv) patentability; or (v) the scope or interpretation of any claims of any of the Patents-in-Suit. Such Identification should include at least the following information: the person requesting the opinion; the person rendering the opinion and whether that person was an attorney; all persons to whom the opinion was shown, copied or otherwise distributed; the date of the opinion; whether the opinion was provided in a written and/or oral format; all materials on which the opinion was based; the substance of the opinion; and all other documents concerning the opinion. RESPONSE:

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INTERROGATORY NO. 8: Describe in detail, including by Identifying all relevant documents by Bates number, the facts and circumstances surrounding NVIDIAs pre-litigation knowledge of Rambus and/or its products (e.g. XDR and XDR2 products, and RDRAM (including direct RDRAM) products), or patents and response thereto, including any meetings between Rambus and NVIDIA, any testing or analysis of Rambuss products by NVIDIA, when and how NVIDIA first became aware of each of the Patents-in-Suit, each instance when NVIDIA was informed of any of the Patents-inSuit, and all steps NVIDIA took in response to having become aware or informed of each Patentin-Suit. With respect to any testing or analysis performed by NVIDIA of Rambuss product(s), -7RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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NVIDIAs Identification shall include each product and version tested, the date each product was tested and Identify all NVIDIA personnel or third parties involved in the testing or analysis. RESPONSE:

INTERROGATORY NO. 9: Identify and describe each patent license to which NVIDIA is a party, including the Bates number assigned in this lawsuit to each such license. RESPONSE:

INTERROGATORY NO. 10: From January 1, 2000 to the present, on a monthly and yearly basis (if any information cannot be segregated by month, then the smallest time frame possible), state separately for each Accused Product, the unit volume sales, average selling price, total cost of products sold, average costs of products sold, amount of gross revenue, net revenue, gross profit, and net profit derived by NVIDIA from the sales of the Accused Products. State in Your response the method by which the revenue, sales, and profit figures were computed and include a description of each cost used to determine the net revenue and net profit. Include in Your response the Identity, by Bates number, of each document that supports Your answer or to which You referred in preparing Your answer and the names of any individuals who assisted in preparing Your answer. RESPONSE:

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INTERROGATORY NO. 11: From January 1, 2000 to the present, on a monthly and yearly basis (if any information cannot be segregated by month, then the smallest time frame possible), state separately for each Accused Product (including components of Accused Products), the number of Accused Products made, assembled, sold or offered for sale (including by total unit volume and sales), including specific indication separately for each Accused Product as to the number of Accused Products (including by total unit volume and sales) made, assembled, or tested in the United States and -8RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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sold or offered for sale abroad, and the number of Accused Products made or assembled abroad and imported into, sold, or offered for sale in the United States. For each Accused Product that is not made, assembled, imported into, sold, or offered for sale within the United States, state (by name and model/part number, including marketing designations), where the product was manufactured, the entity that manufactures the product, entities to which the product was sold and where the sales took place, the method by which You determined where the sale took place, and for products that contain components other than Accused Products, where and to what entity the Accused Product was manufactured and sold, respectively. RESPONSE:

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INTERROGATORY NO. 12: To the extent that NVIDIA contends that it is not liable in whole or part for the making, using, selling, offering for sale and/or importing any Accused Product or subset of Accused Products because the act accused of infringement (whether performed by NVIDIA directly or indirectly through inducement and/or contributory infringement) takes place or may take place outside of the United States, please explain in detail all evidence supporting NVIDIAs contention, including the identity of the Accused Product, place of manufacture, supply chain (including both accused memory controllers and Accused Products including accused memory controllers), sales agreements, testing operations, sales channels, distribution, customers, customer operations, and location of retail sales and other sales to end-users of each Accused Product; and Identify any documents relating thereto. To the extent that NVIDIA asserts that it lacks any of the requested information, Identify with particularity such information separately for each Accused Product, including the last known transaction involving and/or location of sale, use, or transfer of said Accused Product. RESPONSE:

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INTERROGATORY NO. 13: If you contend that acceptable, non-infringing alternatives or substitutes to the methods, -9RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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systems, or apparatuses claimed in the Patents-in-Suit and/or accused of infringement by Rambus have existed or exist, specifically describe each such alternative, state when it became available, describe in detail the basis for your contention that it is an acceptable, non-infringing alternative (including the specific claims and limitation(s) of the Patents-in-Suit that the alleged alternatives would avoid infringing as a result of implementing the alternative(s)), the costs that would be associated with developing and implementing each alternative, the steps and the time required to develop and implement each alternative; and whether each Accused Product is capable of practicing any such non-infringing alternatives, and if so, which Accused Products and how. Your answer should also Identify all persons (including Your employees) who have knowledge and documents related to this contention. RESPONSE:

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INTERROGATORY NO. 14: Separately for each Accused Product, Identify the three persons most knowledgeable about, and the person(s) having direct responsibility for, each of the following: research and development; design; production, manufacturing, and testing; promotion and advertising; pricing; supply, importation; exportation, sales and distribution in the U.S.; and market and industry research, competitor intelligence, and customer relations. RESPONSE:

INTERROGATORY NO. 15: Identify all uses, deployments, or applications NVIDIA encourages, promotes, or communicates to third parties, including its customers, for each Accused Product; and, if You contend any such uses, deployments, or applications do not infringe the Patents-in-Suit and/or do -10RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA Austin 65731v4

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not involve acts accused of infringement; please describe in detail for each Accused Product all reasons for your contention upon which you may rely. RESPONSE:

INTERROGATORY NO. 16: Describe in detail all facts pertaining to NVIDIAs procedures, policies and facilities for generating, filing, storing, and destroying documents, including with respect to any litigation hold that may have been implemented as a result of this lawsuit or proceedings in the International Trade Commission involving Rambus and NVIDIA, and including an Identification, by Bates number, of all documents that refer to or relate to such procedures, policies and facilities, and an Identification of the persons most knowledgeable of such information. RESPONSE:

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DATED: June 6, 2011

MCKOOL SMITH P.C. CROWELL & MORING LLP

By:

/s/ Pierre J. Hubert

Pierre J. Hubert

Attorneys for Plaintiff RAMBUS INC.

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PROOF OF SERVICE STATE OF TEXAS, CITY OF AUSTIN AND COUNTY OF TRAVIS: I, the undersigned, declare that I am over the age of 18 and not a party to the within cause. I am employed by McKool Smith P.C. in the County of Travis, State of Texas. My business address is 300 West 6th Street, Austin, Texas 78701. On June 6, 2011, I served upon the interested party(ies) in this action the foregoing document(s) described as: RAMBUS INC.S FIRST SET OF INTERROGATORIES TO DEFENDANT NVIDIA CORPORATION placing the original(s) true and correct thereof, as By addressed, sealed envelope(s)aclearly labeled to copy(ies)the person(s)set out below, in an identify being served at the address(es) set forth on the attached service list. EXPRESS PRIORITY DELIVERY (AS BY FEDERAL SERVICE LIST BELOW) I OVERNIGHTsealed Federal Express INDICATED ON delivered the envelope(s) to an employee authorized by Federal Express to receive documents, with delivery fees paid or provided for. BY ELECTRONIC MAIL ON SERVICE LIST BELOW) I caused such documents to be (AS INDICATED mail for instantaneous transmittal via sent by electronic telephone line.

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I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Executed on June 6, 2011, at Austin, Texas. /s/ Laura S. Terrell Laura S. Terrell I. Neel Chatterjee Orrick Herrington & Sutcliffe LLP 1000 Marsh Road Menlo Park, California 94025-1015 Email: nchatterjee@orrick.com Theresa A. Sutton Orrick Herrington & Sutcliffe LLP 1000 Marsh Road Menlo Park, California 94025-1015 Email: tsutton@orrick.com David M. Goldstein Orrick Herrington & Sutcliffe LLP The Orrick Building 405 Howard Street San Francisco, California 94105-2669 Email: dgoldstein@orrick.com Andrew S. Ong Orrick Herrington & Sutcliffe LLP 1000 Marsh Road Menlo Park, California 94025-1015 Email: aong@orrick.com

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