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UNITED STATES INTERNATIONAL TRADE COMMISSION WASHINGTON, D.C. Administrative Law Judge Hon. Theodore R.

Essex

In the Matter of: CERTAIN SEMICONDUCTOR CHIPS AND PRODUCTS CONTAINING THE SAME Investigation No. 337-TA-753

JOINT MOTION TO PARTIALLY TERMINATE INVESTIGATION ON THE BASIS OF SETTLEMENT AGREEMENT Complainant Rambus Inc. and Customer Respondent Motorola Mobility, Inc. respectfully request termination of the above-captioned Investigation of the United States International Trade Commission as to Motorola Mobility, Inc. pursuant to Commission Rule 210.21 (19 C.F.R. 210.21) in view of the Settlement Agreements and the Patent License Agreements (collectively, the Agreements) between Rambus and Broadcom and between Rambus and NVIDIA.1 Good cause exists to terminate as to Motorola Mobility, Inc. because as a result of the Agreements between Rambus and Broadcom and between Rambus and NVIDIA, none of the products of Motorola Mobility, Inc. that incorporate either Broadcom or NVIDIA products remain unlicensed. As a result, Rambus and Motorola Mobility, Inc. request termination of the Investigation as to Motorola Mobility, Inc.

Respondent Broadcom was terminated from this Investigation by Order. No. 60 (January 17, 2012) (granting Motion Docket No. 661-102), which was not reviewed by the Commission. (Commission Notice dated February 7, 2012). Rambus and Respondent NVIDIA filed a motion to terminate the Investigation as to NVIDIA on February 10, 2012 (Motion Docket No. 661-105). Copies of the Agreements, which are confidential to Rambus and Broadcom, and to Rambus and NVIDIA, respectively, are included with those motions.

There are no other agreements, written or oral, express or implied, between Rambus and Motorola Mobility, Inc. concerning the subject matter of this Investigation. The Agreements resolve the infringement claims raised in Rambuss Complaint against Motorola Mobility, Inc.s products to the extent those claims were based on the incorporation of products from either Broadcom or NVIDIA into such products of Motorola Mobility, Inc. This motion thus seeks to terminate Motorola Mobility, Inc. from this Investigation. Pursuant to Ground Rule 3.2, Rambus and Motorola Mobility, Inc. certify that they have made reasonable, good-faith efforts to contact and resolve the matter presented in this motion with counsel for the remaining Respondents and the OUII Staff, and requested that the parties provide their positions on a request to shorten the two-day period required by Ground Rule 3.2. LSI, Seagate, Cisco, MediaTek, Oppo, Audio Partnership, Hewlett-Packard, the Asus Respondents, and Hitachi do not oppose the motion or the request to waive the two-day period. ST does not oppose waiver of the two-day period, but will wait to see the papers before taking a position on the motion to terminate. Garmin does not oppose waiver of the two-day period, but did not state a position on the motion for partial termination. NVIDIA takes no position on either request. The Staff does not oppose waiver of the two-day period, and stated that they will take a position after reviewing the as-filed motion papers. Because the public interest favors the termination of investigations through settlement in the interest of the public and administrative economy, Rambus and Motorola Mobility, Inc. respectfully request that the Administrative Law Judge issue an initial determination terminating the above-captioned Investigation with respect to Motorola Mobility, Inc. in accordance with the provisions of 19 U.S.C. 1337(c) and 19 C.F.R. 210.21.

Dated: February 29, 2012

/s/ Christine E. Lehman J. Michael Jakes Doris Johnson Hines Christine E. Lehman Kathleen A. Daley Naveen Modi Luke J. McCammon FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, NW Washington, DC 20001-4413 Michael J. McCabe Jason E. Stach Brannon C. McKay FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 303 Peachtree Street, N.E. Sun Trust Plaza, Suite 3500 Atlanta, Georgia 30308-3263 Attorneys for Complainant Rambus Inc.

/s/ Evette D. Pennypacker Evette D. Pennypacker QUINN EMANUEL URQUHART & SULLIVAN LLP 555 Twin Dolphin Drive, 5th Floor Redwood Shores, California 94065 Telephone: (650) 801-5000 Sean Pak QUINN EMANUEL URQUHART & SULLIVAN LLP 50 California St., 22nd Floor San Francisco, California 94111 Telephone: (415) 875-6600 Thomas D. Pease QUINN EMANUEL URQUHART & SULLIVAN LLP 51 Madison Ave., 22nd Floor New York, New York 10010 Telephone: (212) 849-7000 Counsel for Respondent Motorola Mobility, Inc.

UNITED STATES INTERNATIONAL TRADE COMMISSION WASHINGTON, D.C. Administrative Law Judge Hon. Theodore R. Essex

In the Matter of: CERTAIN SEMICONDUCTOR CHIPS AND PRODUCTS CONTAINING THE SAME Investigation No. 337-TA-753

MEMORANDUM IN SUPPORT OF JOINT MOTION TO PARTIALLY TERMINATE INVESTIGATION ON THE BASIS OF SETTLEMENT AGREEMENT Complainant Rambus Inc. and Respondent Motorola Mobility, Inc. have jointly moved to terminate the above-captioned Investigation of the United States International Trade Commission pursuant to the provisions of 19 U.S.C. 1337(c) and 19 C.F.R. 210.21 in view of the Settlement Agreements and the Patent License Agreements (collectively, the Agreements) between Rambus and Broadcom and between Rambus and NVIDIA. There are no other

agreements written or oral, expressed or implied, regarding the subject matter of this Investigation between Rambus and Motorola Mobility, Inc. Commission policy and the public interest generally favor settlements, which preserve resources for both the Commission and the private parties, and termination based on a settlement agreement is routinely granted. See, e.g., Certain Equipment for Telecommunications or Data Communications Networks, Including Routers, Switches, and Hubs, and Components Thereof, Inv. No. 337-TA-574, Order No. 27 at 4 (May 24, 2007) and Order No. 52 (September 8, 2008); Certain Safety Eyewear and Components Thereof, Inv. No. 337-TA-433, Order No. 37 at 2 (November 3, 2000); Certain Synchronous Dynamic Random Access Memory Devices,

Microprocessors, and Products Containing Same, Inv. No. 337-TA-431, Order No. 11 at 2 (July 13, 2000); Certain Integrated Circuit Chipsets, Components Thereof and Products Containing Same, Inv. No. 337-T A-428, Order No. 16 at 5 (August 22, 2000). Termination of this Investigation with respect to Motorola Mobility, Inc. will not have any adverse effect on the public health and welfare and/or competitive conditions in the United States. Accordingly, the Administrative Law Judge is authorized to issue an initial determination terminating this Investigation pursuant to 19 C.F.R. 210.21. This motion seeks to terminate the Investigation as to Motorola Mobility, Inc. which, following execution of the Agreements between Rambus and Broadcom and between Rambus and NVIDIA, no longer has unlicensed products accused of infringement in this Investigation. Thus, good cause exists to terminate Motorola Mobility, Inc. The Investigation will proceed against the non-settling Respondents. For the reasons set forth above, Rambus and Motorola Mobility, Inc. respectfully request that the Administrative Law Judge issue an initial determination terminating the above-captioned Investigation with respect to Motorola Mobility, Inc. in accordance with 19 C.F.R. 210.21.

Dated: February 29, 2012 /s/ Christine E. Lehman J. Michael Jakes Doris Johnson Hines Christine E. Lehman Kathleen A. Daley Naveen Modi Luke J. McCammon FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, NW Washington, DC 20001-4413 2 /s/ Evette D. Pennypacker Evette D. Pennypacker QUINN EMANUEL URQUHART & SULLIVAN LLP 555 Twin Dolphin Drive, 5th Floor Redwood Shores, California 94065 Telephone: (650) 801-5000 Sean Pak QUINN EMANUEL URQUHART & SULLIVAN LLP 50 California St., 22nd Floor

Michael J. McCabe Jason E. Stach Brannon C. McKay FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 303 Peachtree Street, N.E. Sun Trust Plaza, Suite 3500 Atlanta, Georgia 30308-3263 Attorneys for Complainant Rambus Inc.

San Francisco, California 94111 Telephone: (415) 875-6600 Thomas D. Pease QUINN EMANUEL URQUHART & SULLIVAN LLP 51 Madison Ave., 22nd Floor New York, New York 10010 Telephone: (212) 849-7000 Counsel for Respondent Motorola Mobility, Inc.