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Rambus Inc. v. Nvidia Corp.

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 ...


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