Free Answering Brief in Opposition - District Court of Delaware - Delaware


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Date: December 31, 1969
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State: Delaware
Category: District Court of Delaware
Author: unknown
Word Count: 1,218 Words, 8,183 Characters
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Case 1:05-cv—00441-JJF Document 243-8 Filed 11/13/2006 Page1 014

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"This is the first agreement under which a premier
foundry company joins forces in a broadly unified
partnership with a leading integrated device
rnanufacturerf said Robert Tsao, chairman and chief
executive officer of L1iVlC;.. "i expect our collaboration will
set the example for success between pure—play ‘
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foundries and leading semiconductor manufacturers. In
the emerging arena of 300-mm manufacturing, the
traditional boundaries between these two types of
companies wiil blur as we move toward closer
coliaboration. Our respective customers around the
world wiil benefit as we join forces to develop leading-
edge technology and drive down manufacturing costs
through rapid, cost~effecl:ive implementation ofthe
most advanced process technologies and manufacturing
practices.”
"It is time to revisit the basic business model in the
serniconductor industry,” said Hector de J. Ruiz,
president and chief operating officer of AMD. “Flexibility
and timing are still the keys to success — but the way to
optimize these has fundamentally changed.
"In the era of 300-rnm manufacturing, flexibility wiil be
an increasingly important success metric. A 300~mm
megafab can achieve cost savings of substantially more
than 30 percent compared to today's 200-mrn
manufacturing facilities. The key to reaiizing these
savings, however, is creating the kind of operational
flexibility necessary to maximize utilization rai:es," said
Ruiz. "l3y joining forces with UMC, we expect to achieve
utilization rates that could become a benchmark for the
industiy."
Ruiz also said that the joint venture with UMC will
enable AMD to make the transition to 300-mrn
manufacturing at precisely the right time. "Orie of the
important benefits of working with UMC. on technology
deveiopment is that we will gain immediate access to
an existing 300-mm wafer fab for R&D activities/’ said
Ruiz. "In the next few years, we expect to require
substantial aciditionai production capacity. We heiieve
the optimum time for us to make the transition to nigh-
volume prociuction on 300-rnrn wafers is in the mid—
2005 time frame when we expect to be starting
production on the 65-nanometer node.
By working together with UMC on technology
deveiopment for 300—mm manufacturing, we expect to
achieve a very smooth transitlon," said Ruiz.
Ruiz also cited a process technology development
collaboration between AMD and Motorola as a model for
future joint efforts with industry-ieading partners.
"Our activities with UMC will closely paraliel th way we
have worked with Motoroia," said Ruiz. "With Motoroia,
we have shown we can maintain a leadership position in
critical process technology while controlling technology
development costs. The truly extraordinary results of
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our Fab 30 in Dresden show that geographicaily
distributed development teams can deliver results that
exceed our expectations, as weil as those of our
custorners," Ruiz concluded.
About AMD
AMD is a global suppiier of integrated circuits for the
personal and networked computer and communications
markets with manufacturing facilities in the United
States, Europe, Japan, and Asia. AMD, a Fortune 500
and Standard & Poor's 500 company, produces
microprocessors, flash memory devices, and support
circuitry for communications and networking
applications. Founded in 1969 and based in Sunnyvale,
California, AMD had revenues of $3.9 biilion in 2001.
(NYSE: AMD). AMD can be found on the web at
http://www.amd.com.
About UMC
UMC (NYSE: UMC, TSE: 2303) is a worid~ieading
semiconductor foundry that manufactures advanced
process ICs for applications spanning every major
sector of the semiconductor industry. UMC delivers the
c:utting—edge foundry technoiogies that enable
sophisticated systern—on-chip (SOC) designs, including
0i13—rnicron copper/low k, embedded DRAM, and mixed
signal/RFCMOS. in addition, UMC is a iader in 300mm
manufacturing with three 300mm fabs strategicaliy
iocated worldwide to serve our giooal customer base:
Trecenti Technologies in Japan, Fab 12A in Taiwan, and
UMCE in Singapore (completion in 2002). UMC empioys
over 8,500 peopie woridwide and has offices in Taiwan,
Japan, Singapore, Europe, andthe united Statesr UMC
can be found on the web at http://www.umc.com,
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