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Rambus Inc. v. Nvidia Corp.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


January 26, 2010

RAMBUS INC., PLAINTIFF,
v.
NVIDIA CORPORATION, DEFENDANT.
NVIDIA CORPORATION PLAINTIFF,
v.
RAMBUS, INC., DEFENDANT.

The opinion of the court was delivered by: Honorable Susan Illston United States District Judge

STIPULATION AND [PROPOSED] ORDER

following joint stipulation and proposed order:

WHEREAS, the Parties are involved in a related proceeding pending in the International Trade Commission (the "ITC Action"); Orders") governing discovery in this case, which among other things implemented an initial phase of discovery limited to document production from other proceedings, including but not limited to the ITC Action; that the initial phase of discovery should continue until the February 12, 2010 case management conference in part because an initial determination in the ITC Action is due to be issued on

WHEREAS, the Parties are meeting and conferring regarding NVIDIA's proposals to amend the Court's April 21, 2009 Protective Order, including without limitation paragraph 7.3(b) regarding in-house counsel access to information that is designated "HIGHLY CONFIDENTIAL

WHEREAS, NVIDIA and Rambus each represent that none of their in-house counsel has accessed the other party's materials designated "HIGHLY CONFIDENTIAL -- ATTORNEYS'

WHEREAS, the Parties intend to further minimize burden and inefficiency by reaching a stipulation without the need to engage in motion practice at this time to resolve any dispute regarding the Protective Order;

February 12, 2010, at 3:00 pm should be rescheduled to March 12, 2010, at 3:00 pm, and that the case management statement should be filed no later than March 5, 2010;

March 12, 2010 case management conference;

Rambus Inc. and NVIDIA Corporation (collectively, the "Parties") hereby submit the

WHEREAS, the Court entered a Protective Order on April 21, 2009 (Docket No. 124):

WHEREAS, the Court entered Orders on April 13, 2009 and June 18, 2009 ("Discovery

WHEREAS, on August 5, 2009, the Court ordered, pursuant to the Parties' stipulation,

January 22, 2010;

-- ATTORNEYS' EYES ONLY" pursuant to the Protective Order;

EYES ONLY" in this action; and

WHEREAS, the parties agree that the case management conference scheduled for

WHEREAS, the parties agree that the initial phase of discovery should continue until the Rambus and NVIDIA hereby stipulate as follows:

1. The case management conference scheduled for February 12, 2010, at 3:00 pm should be rescheduled for March 12, 2010, at 3:00 pm, and the case management statement should be filed no later than March 5, 2010;

2. The initial phase of discovery should continue until the March 12, 2010 case management conference;

3. Notwithstanding the Protective Order's provision to the contrary, materials that are designated "HIGHLY CONFIDENTIAL -- ATTORNEYS' EYES ONLY" shall not be made available to in-house counsel for any party before March 16, 2010, unless the parties otherwise agree or the Court so orders. If the March 16, 2010 date is not extended by stipulation or a Court order and a party files no later than March 15, 2010, a motion to amend the Protective Order with respect to in-house counsel access, this paragraph 3 shall remain in effect until final resolution of the motion, including any and all appeals to the district court of the Special Master's ruling on that motion.

4. In view of the Stipulation addressing discovery matters in the interim, neither party may file a motion in this matter until March 1, 2010.

5. Nothing in this Stipulation affects a party's right, pursuant to the terms of the Protective Order, to challenge the designation of a document as "HIGHLY CONFIDENTIAL -- ATTORNEYS' EYES ONLY."

Dated: January 21, 2010

ORRICK, HERRINGTON & SUTCLIFFE LLP

David M. Goldstein Attorneys for NVIDIA Corporation 405 Howard Street San Francisco, CA 94105 Telephone: (415) 773-4255 Facsimile: (415) 773-5759 Email: dgoldstein@orrick.com

Dated: January 21, 2010

MCKOOL SMITH

Pierre Hubert Attorneys for Rambus Inc. 300 West 6th Street, Suite 1700 Austin, TX 78701 Telephone: (512) 692-8700 Facsimile: (512) 692-8744 Email: phubert@mckoolsmith.com

SO ORDERED:

20100126

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