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I. NEEL CHATTERJEE (SBN 173985) nchatterjee@orrick.com VICKIE L. FEEMAN (SBN 177487) vfeeman@orrick.com 1000 Marsh Road Menlo Park, CA 94025 Telephone: (650) 614-7400 Facsimile: (650) 614-7401 JESSICA S. PERS (SBN 77740) jpers@orrick.com CATHERINE KROW (SBN 208412 ) ckrow@orrick.com JUSTIN M. LICHTERMAN (SBN 225734) jlichterman@orrick.com ORRICK, HERRINGTON & SUTCLIFFE LLP The Orrick Building 405 Howard Street San Francisco, CA 94105-2669 Telephone: (415) 773-5700 Facsimile: (415) 773-5759 Attorneys for Defendant and Cross-Complainant NVIDIA CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION RAMBUS INC., Plaintiff, v. NVIDIA CORPORATION, Defendant. NVIDIA CORPORATION, Cross-Complainant, v. RAMBUS INC., Cross-Defendant. Case No. 3:08-cv-03343-SI DECLARATION OF VICKIE FEEMAN IN SUPPORT OF NVIDIA CORPORATIONS OBJECTION TO ORDER OF THE SPECIAL MASTER

VICKIE FEEMAN DECLARATION ISO NVIDIAS OBJECTION TO ORDER OF THE SPECIAL MASTER CASE NO. C-08-03343 SI

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I, Vickie Feeman, declare: 1. I am an attorney licensed to practice law in the State of California and am a

Partner at Orrick, Herrington & Sutcliffe LLP, and counsel for NVIDIA Corporation (NVIDIA) in this action. I make this declaration based on my own personal knowledge and if called to testify to the truth of the matters herein, I could and would do so competently. 2. On July 29, 2011, NVIDIA filed a motion to compel disclosures pursuant to Patent

Local Rule 3-1 and 3-2, for protective order, and to stay NVIDIAs Patent L.R. 3-3 and 3-4 invalidity contentions. A true and correct copy of NVIDIAs motion is attached hereto as Exhibit 1. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 3. A true and correct copy of Rambus, Inc.s (Rambus) Opposition to NVIDIAs

motion to compel, for protective order, and to stay, filed on August 4, 2011, is attached hereto as Exhibit 2. 4. A true and correct copy of NVIDIAs Reply to Rambuss Opposition, filed on

August 8, 2011, is attached hereto as Exhibit 3. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER]. 5. A true and correct copy of Special Master Infantes Order Granting NVIDIAs

Motion to Compel Disclosures Pursuant to Patent L.R. 3-1 and 3-2 and for Stay, and Denying Rambuss Motion to Compel Further Responses to Interrogatories, dated August 24, 2011, is attached hereto as Exhibit 4. 6. On October 5, 2011, NVIDIA sent a letter brief to Special Master Infante

requesting that Rambus be compelled to provide further amended disclosures pursuant to Patent L.R. 3-1(c) and to stay infringement-related discovery and disclosure under the Patent Local Rules. A true and correct copy of this letter brief and its accompanying exhibits is attached hereto as Exhibit 5. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 7. A true and correct copy of Rambuss Opposition to NVIDIAs request regarding

Rambuss Amended Disclosure and its accompanying exhibits, sent to Special Master Infante on
VICKIE FEEMAN DECLARATION ISO NVIDIAS OBJECTION TO ORDER OF THE SPECIAL MASTER CASE NO. C-08-03343 SI

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October 14, 2011, is attached hereto as Exhibit 6. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 8. A true and correct copy of NVIDIAs Reply Letter Brief and its accompanying

exhibits, sent to Special Master Infante on October 20, 2011, is attached hereto as Exhibit 7. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 9. A true and correct copy of Rambuss Sur-Reply Letter Brief, sent to Special

Master Infante on October 25, 2011, is attached hereto as Exhibit 8. [LODGED UNDER SEAL PURSUANT TO COURTS STANDING ORDER] 10. A true and correct copy of Special Master Infantes October 31, 2011 Order

Denying NVIDIAs Motion to Compel Further Amended Disclosures in Compliance with Patent L.R. 3-1(c) and for Stay is attached hereto as Exhibit 9. 11. A true and correct copy of NVIDIAs November 3, 2011 letter to Special Master

Infante requesting clarification of the Courts October 31, 2011 Order is attached hereto as Exhibit 10. 12. A true and correct copy of Rambuss November 7, 2011 letter to Special Master

Infante in response to NVIDIAs letter requesting clarification of the Courts October 31, 2011 Order is attached hereto as Exhibit 11. 13. A true and correct copy of NVIDIAs November 7, 2011 letter to Special Master

Infante regarding Rambuss response letter is attached hereto as Exhibit 12. 14. A true and correct copy of Special Master Infantes November 10, 2011 Order

Denying NVIDIAs Request for Clarification of the October 31, 2011 Order is attached hereto as Exhibit 13. I declare under penalty of perjury that the foregoing is true and correct. Executed this 5th day of December, 2011, at Menlo Park, California.

/s/ Vickie Feeman /s/ Vickie Feeman

VICKIE FEEMAN DECLARATION ISO NVIDIAS OBJECTION TO ORDER OF THE SPECIAL MASTER CASE NO. C-08-03343 SI