Rambus Inc v. Broadcom Corporation

Filing 75

ORDER regarding the production of privileged documents previously ordered produced. Signed by Judge Richard Seeborg on 12/7/11. (cl, COURT STAFF) (Filed on 12/7/2011)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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RAMBUS INC.,

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Case No. 3:10-cv-05437 RS

Plaintiff,

[PROPOSED] ORDER REGARDING THE
PRODUCTION OF PRIVILEGED
DOCUMENTS PREVIOUSLY ORDERED
PRODUCED

v.
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BROADCOM CORP.,
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Defendant.

Judge:

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Hon. Richard Seeborg
Courtroom 3, 17th Floor

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RAMBUS INC.,

Case No. 3:10-cv-05446 RS

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Plaintiff,
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v.
LSI CORPORATION,

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Defendant.

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RAMBUS INC.,

Case No. 3:10-cv-05447 RS

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Plaintiff,
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v.
MEDIATEK INC.,

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Defendant.

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RAMBUS INC.,

Case No. 3:10-cv-05449 RS

Plaintiff,
v.
STMICROELECTRONICS N.V.;
STMICROELECTRONICS INC.,
Defendants.

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On December 6, 2011, Plaintiff Rambus Inc. and Defendants Broadcom Corporation,

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LSI Corporation, Mediatek Inc., and STMicroelectronics N.V. and STMicroelectronics Inc.

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submitted a Joint Proposed Form of Order Regarding the Production of Documents Previously

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Produced.

15876645.1

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[PROPOSED] ORDER RE PRODUCTION OF
PRIVILEGED DOCUMENTS PREVIOUSLY
ORDERED PRODUCED

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WHEREAS Defendants desire the production of privileged documents and/or

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attorney work product previously ordered produced in ITC Investigation No. 337-TA-661, Order

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No. 15, Order Granting in Part NVIDIA’s Motion to Compel Production of Materials Subject to

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Privilege Piercing Orders (“ITC Order No. 15”);

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WHEREAS Rambus has appealed ITC Order No. 15 and continues to object to the

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forced production of its privileged documents and/or attorney work product in ITC Investigation

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No. 337-TA-661 and all other litigation incorporating ITC Order No. 15;

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WHEREAS on February 11, 2011, a privilege piercing order incorporating ITC
Order No. 15 was entered in ITC Investigation No. 337-TA-753—the parallel ITC action in

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which all of the parties in the above-captioned cases are participating (see ITC Inv. No. 337-TA-

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753, Order No. 13, Order Regarding Piercing of Privilege);

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WHEREAS on May 24, 2011, the Special Master in Rambus Inc. v. NVIDIA

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Corporation, Case No. 08-cv-03343 SI, D.N. 210, ordered that ITC Order No. 15 shall govern

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Rambus’s production in that case of documents previously ordered produced in ITC Investigation

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No. 337-TA-661; and

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WHEREAS it would be an inefficient use of judicial and party resources to

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re-litigate Rambus’s claims of privilege and/or attorney work product protection related to

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documents ordered produced pursuant to ITC Order No. 15;

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NOW THEREFORE, IT IS HEREBY ORDERED that, without prejudice to

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Rambus’s continuing objections to the production of its privileged documents and/or attorney

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work product, ITC Order No. 15 shall govern Rambus’s production in these cases of documents

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previously ordered produced pursuant to that order in ITC Investigation No. 337-TA-661.

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DATED: December _____, 2011

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Honorable Richard Seeborg
UNITED STATES DISTRICT JUDGE

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15876645.1

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[PROPOSED] ORDER RE PRODUCTION OF
PRIVILEGED DOCUMENTS PREVIOUSLY
ORDERED PRODUCED