Case 3:08-cv-03343-SI Document 43 Filed 10/24/2008 Page 1 of 3

Mike McKool, Jr. (pro hac vice)

Douglas Cawley (pro hac vice)
McKOOL SMITH P.C.
300 Crescent Court
Suite 1500
Dallas, Texas 75201
Telephone: (2 14) 978-4000
Facsimile: (2 14) 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. 6thStreet
Suite 1700
Austin, Texas 7870 1
Telephone: (5 12) 692-8700
Facsimile: (5 12) 692-8744
Email: scole@mckoolsmith.com;
phubert@mckoolsmith.com;
ctolliver@mckoolsmith.com
Julie S. Turner (State Bar IVo. 191146)
THE TURNER LAW FIRM
344 Tennessee Lane
Palo Alto, California 94306
Telephone: (650) 494-1 530
Facsimile: (650) 472-8028
Email: jturner@julieturnerlaw.com
Attorneys for Plaintiff
RAMBUS INC.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

RAMBUS INC.,
Case No. C-08-03343 SI
Plaintiff,
DECLARATION OF TRENT E.
v. CAMPIONE IN SUPPORT OF
RAMBUS INC.'S OPPOSITION TO
NVIDIA CORPORATION, NVIDIA CORPORATION'S
MOTION TO DISMISS AND TO
Defendant. STRIKE, OR IN THE
ALTERNATIVE, FOR MORE
DEFINITE STATEMENT
Date: November 14,2008
Time: 9:00 a.m.
Judge: The Hon. Susan Illston
Declaration of Trent E. Campione in Support of Rambus's
Opposition to NVIDIA's Motion to Dismiss
Case No. C-08-03343 SI
Case 3:08-cv-03343-SI Document 43 Filed 10/24/2008 Page 2 of 3

I, Trent E. Campione, declare as follows:

1. I am an attorney with the law firm of McKool Smith, P.C., attorneys of
qecord for Rambus Inc. in the above-referenced matter. I am duly licensed in the State of Texas
md admitted to practice before this Court. I make this declaration based on my personal
cnowledge and matters of public record, and if called upon to testify, I could and would testify
:ompetently as to the matters set forth below.
2. Attached hereto as Exhibit A is a true and correct copy of a "Report and
iecommendation of the United States Magistrate Judge" in Fotomedia Technologies, Inc. v.
40L, LLC., et al., Civil Action No. 2:07CV255, in the United States District Court for the
3astern District of Texas, dated August 29, 2008.
3. Attached hereto as Exhibit B is a true and correct copy of "Plaintiffs
h e n d e d Complaint" in Fotomedia Technologies, Inc. v. AOL, LLC., et al., Civil Action No.
!:07CV255, in the United States District Court for the Eastern District of Texas, dated
qovember 6,2007.
4. Attached hereto as Exhibit C is a true and correct copy a "Complaint for
latent Infringement" in Nichia Corporation v. Seoul Semiconductor Ltd, et al., Civil Action No.
3-06-0162, in the United States District Court for the Northern District of California, dated
ranuary 10,2006.
5. Attached hereto as Exhibit D is a true and correct copy of excerpts of a
'First Amended Complaint" in NVIDIA Corporation v. Rambus Inc., Civil Action No.
:08CV473, in the United States District Court for the Middle District of North Carolina, dated
i l y 24,2008.
6. Attached hereto as Exhibit E is a true and correct copy of a "Complaint
or Patent Infringement" in Scanner Technologies Corp, v. Nvidia Corporation, Civil Action No.
):06CV205, in the United States District Court for the Eastern District of Texas, dated
September 15,2006.

Declaration of Trent E. Campione in Support of Rambus's

Opposition to NVIDIA's Motion to Dismiss
Case No. C-08-03343 SI
Case 3:08-cv-03343-SI Document 43 Filed 10/24/2008 Page 3 of 3

7. Attached hereto as Exhibit F is a true and correct copy of "Defendant

Nvidia Corporation's Answer and Counterclaims to Scanner Technologies Corp.'s Complaint for
Patent Infringement" in Scanner Technologies Corp, v. Nvidia Corporation, Civil Action No.
9:06CV205, in the United States District Court for the Eastern District of Texas, dated
November 6,2006.
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct. Executed on October 24,2008 in Austin, Texas.

Declaration of Trent E. Campione in Support of Rambus's

Opposition to NVIDIA's Motion to Dismiss
Case No. C-08-03343 SI
2