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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC, Plaintiffs, v. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, L.L.C., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR L.L.C., Defendants. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, L.L.C., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR L.L.C., Plaintiffs, v. ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 07-449 (JJF) REDACTED PUBLIC VERSION

C.A. No. 06-720 (JJF)

DECLARATION OF RICHARD J. BAUER IN SUPPORT OF ON SEMICONDUCTOR'S MOTION TO COMPEL DISCOVERY CONERNING INFRINGEMENT MORRIS, NICHOLS, ARSHT & TUNNELL LLP Karen Jacobs Louden (#2881) Richard J. Bauer (#4828) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 Attorneys for ON Semiconductor Corp and Semiconductor Components Industries, L.L.C

August 15, 2008
Redacted Filing Date: August 22, 2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC, Plaintiffs, v. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, L.L.C., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR L.L.C., Defendants. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, L.L.C., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR L.L.C., Plaintiffs, v. ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 07-449 (JJF)

REDACTED PUBLIC VERSION

C.A. No. 06-720 (JJF)

DECLARATION OF RICHARD J. BAUER IN SUPPORT OF ON SEMICONDUCTOR'S MOTION TO COMPEL DISCOVERY CONERNING INFRINGEMENT I, Richard J. Bauer, am an associate with the law firm of MORRIS, NICHOLS & TUNNELL LLP. I am one of the attorneys representing ON Semiconductor Corp. and

Semiconductor Components Industries, L.L.C. (collectively, "ON Semiconductor") in this litigation. I hereby declare as follows:

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1.

Attached as Exhibit A are true and correct copies of

2.

Attached as Exhibit B is a true and correct copy of ON Semiconductor's

First Supplemental Responses to Samsung's First Set of Interrogatories (Nos. 1, 11 & 12), dated April 11, 2008. 3. Attached as Exhibit C is a true and correct copy of ON Semiconductor's

Second Supplemental Responses to Samsung's First Set of Interrogatories (Nos. 1, 3 & 12), dated July 18, 2008. 4. Attached as Exhibit D is a true and correct copy of ON Semiconductor's

First Set of Requests for Production of Documents and Things, dated March 26, 2007. 5. Attached as Exhibit E is a true and correct copy of ON Semiconductor's

Second Set of Requests for Production of Documents and Things, dated May 8, 2007. 6. Attached as Exhibit F is a true and correct copy of ON Semiconductor's

Fourth Set of Requests for Production of Documents and Things, dated June 6, 2008 7. Attached as Exhibit G are true and correct copies of excerpts of the

deposition transcript of 8. correspondence: · · · · Attached as Exhibit H are true and correct copies of the following

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· · · · 9. . Attached as Exhibit I are true and correct copies of documents

10. correspondence: · · · 11.

Attached as Exhibit J are true and correct copies of the following

Attached as Exhibit K is a true and correct copy of ON Semiconductor's

Third Set of Interrogatories to Samsung (Nos. 28-35), dated June 11, 2008. 12. Attached as Exhibit L are true and correct copies of documents

13.

Attached as Exhibit M are true and correct copies documents

14.

Attached as Exhibit N are true and correct copy of documents

15.

Attached as Exhibit O are true and correct copy of documents

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I declare under penalty of perjury that the foregoing is true and correct. August 15, 2008

/s/ Richard J. Bauer
Richard J. Bauer (#4828)
2450204

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EXHIBIT A

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CONFIDENTIAL EXHIBIT

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EXHIBIT B

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CONFIDENTIAL EXHIBIT

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EXHIBIT C

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CONFIDENTIAL EXHIBIT

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EXHIBIT D

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SAMSUNG ELECTRONICS CO. LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, LLC, SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR LLC, Plaintiffs, v. ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 06-720 (***)

DEFENDANTS ON SEMICONDUCTOR CORPORATION'S AND SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS TO PLAINTIFFS SAMSUNG ELECTRONICS CO., LTD.; SAMSUNG ELECTRONICS AMERICA, INC.; SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, LLC; SAMSUNG SEMICONDUCTOR, INC.; and SAMSUNG AUSTIN SEMICONDUCTOR, LLC Pursuant to Rule 34 of the Federal Rules of Civil Procedure, Defendants ON Semiconductor Corporation and Semiconductor Components Industries, LLC (collectively, "ON Semiconductor") request that Plaintiffs Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung Telecommunications America General, LLC; Samsung Semiconductor, Inc.; and Samsung Austin Semiconductor, LLC (collectively, "Samsung") produce to ON Semiconductor the documents and things identified below for inspection and copying at the offices of ON Semiconductor's counsel, Jones Day, 1755 Embarcadero Road, Palo Alto, CA 94303, within thirty (30) days of service.

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DEFINITIONS These requests incorporate, without limiting the scope of the Federal Rules of Civil Procedure, the following definitions: 1. 2. "ALL" refers to all and each, and "EACH" refers to all and each. "AND" and "OR" refers to either disjunctive or conjunctive use as necessary to

bring within the scope of the interrogatories all responses that might otherwise be construed to be outside of its scope. 3. "COMMUNICATION" refers to any transmittal of information in the form of

facts, ideas, inquiries, or otherwise. 4. constituting. 5. The term "DOCUMENT" refers to the usage of this term in Federal Rule of Civil "CONCERNING" refers to relating to, referring to, describing, evidencing, or

Procedure 34(a), and is synonymous in meaning and equal in scope to this usage, including, without limitation, electronically stored documents, photographs, tape recordings, or other sound or visual materials, computer databases, computer tapes, and any other materials that are in your actual or constructive possession, custody, or control, as well as all prior drafts of the foregoing, and copies of the foregoing on which any mark, alteration, writing or other change from the original has been made. A draft of non-identical copy is a separate document within the meaning of the term. 6. The "ON SEMICONDUCTOR PATENTS" refers to the United States Patent

Nos. 6,362,644; 5,563,594; 5,361,001; and 5,000,827, including any reexaminations.

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7.

The "ON SEMICONDUCTOR PRODUCTS" refers to any accused apparatus,

product, device, process, method, act and/or other instrumentality that Plaintiffs asserts infringe United States Patent No. 5,252,177. 8. referenced "RELATED APPLICATIONS" refers to any and all applications related to the patent(s), including any continuations, continuations-in-part, divisionals,

interferences, reexaminations, reissues, parents, foreign counter-part applications, and any other applications disclosing, describing, or claiming any invention disclosed, described, or claimed in the referenced patent(s), or claiming the benefit of the filing date of any application whose benefit is claimed in the referenced patent, whether or not abandoned and whether or not issued. 9. "RELATED PATENTS" refers to any or all patents based upon any RELATED

APPLICATION, including any patents that may have been opposed, contacted, or subjected to any nullity proceedings. 10. 11. The "SAMSUNG PATENT" refers to the United States Patent No. 5,252,177. The "SAMSUNG PRODUCTS" refer to Double Data Rate (DDR) Synchronous

Dynamic Random Access Memory (SDRAM) that includes but is not limited to DDR SDRAM, Mobile DDR SDRAM, DDR2 SDRAM, GDDR SDRAM, GDDR2 SDRAM, and GDDR3 SDRAM, as well as any integrated circuits manufactured using cup plating systems. The

"SAMSUNG PRODUCTS" include, but are not limited to, the following product designations: K4D261638K, K4D263238K, K4D263238K, K4H1G0438A, K4H1G0638C, K4H1G0738C, K4H1G0838A, K4H2G0638A, K4H510438C, K4H510638E, K4H510638H, K4H510738E, K4H510738H, K4H510838C, K4H510838D, K4H511638C, K4H511638D, K4H560438E, K4H560438H, K4H560838E, K4H560838H, K4H561638H, K4J52324QE, K4J52324QE, K4J55323QG, K4J55323QG, K4N51163QC, K4N51163QE, K4N51163QE, K4N56163QG,

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K4N56163QG, K4U52324QE, M312L2820EG(Z)0, M312L2820HZ0, M312L2828ET(U)0, M312L2828HU0, M312L2920CUS, M312L2920CZ0, M312L2923CUS, M312L2923CZ0, M312L3223EG(Z)0, M312L3223ET(U)S, M312L3223HUS, M312L3223HZ0,

M312L5128AU0, M312L5128AU1, M312L5620AUS, M312L5623AUS, M312L5628CU0, M312L5720CZ0, M312L6420EG(Z)0, M312L6420ET(U)S, M312L6420HUS, M312L6420HZ0, M312L6423EG(Z)0, M312L6423ET(U)S, M312L6423HUS, M312L6423HZ0,

M312L6523CUS, M312L6523CZ0, M368L2923CUN, M368L2923DUN, M368L3223ET(U)M, M368L3223ET(U)N, M368L6423ET(U)M, M368L6523DUS, M381L3223HUM, M368L3223HUS, M368L6423ET(U)N, M381L2923CUM, M381L6423ET(U)M, M368L3324CUS, M368L6423HUN, M381L2923DUM, M381L6423HUM, M368L3324DUS, M368L6523CUS, M381L3223ET(U)M, M381L6523CUM,

M381L6523DUM, M470L1624HU0, M470L2923DV0, M470L3224HU0, M470L3324CU0, M470L3324DU0, M470L6524CU0, M470L6524DU0. The "SAMSUNG PRODUCTS" also include, but are not limited to, product made using the following systems: Applied Materials, Inc.'s SlimCell system, Novellus Systems Inc.'s Sabre System, and Semitool Inc.'s Raider ECD, Raider ECD 310, and Equinox systems. 12. 34(a). 13. "SAMSUNG," "YOU," and "YOUR" refers to Plaintiffs Samsung Electronics "THING" refers to the broadest meaning recognized under Fed. R. Civ. P. Rule

Co., Ltd.; Samsung Electronics America, Inc.; Samsung Telecommunications America General, LLC; Samsung Semiconductor, Inc.; and Samsung Austin Semiconductor, LLC, their present and former directors, officers, employees, attorneys, accountants, consultants, representatives,

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agents, subsidiaries, divisions, successors in interest, any partnerships or joint ventures to which any of the Plaintiffs is party, and/or other persons acting on any of the Plaintiffs' behalf. 14. The use of the singular form of any word includes the plural and vice versa. INSTRUCTIONS These requests incorporate, without limiting the scope of the Federal Rules of Civil Procedure, the following instructions: 1. When producing documents to satisfy this Request, identify the paragraph number

to which the produced document responds. 2. The identical text of the individual request for production being answered from

this Request must immediately precede each answer given. 3. You are to produce the documents as they are kept in the ordinary course of

business or with appropriate markings or designations so that it may be determined to what request they are responsive, including, without limitation, labels that identify documents, binder covers or file folders with tabs or dividers. 4. Any electronic information must be produced in a coherent and understandable

format or together with a description of the system from which it was derived so that it may be converted to a coherent and understandable format. 5. If a time period is not specified in the request, all responsive documents for each

request must be produced, regardless of the date of the documents were created or received. 6. PRIVILEGE: If you withhold from production any document on the grounds of

privilege, please further provide the following information: (a) Date(s) of the creation, transmission, and modification of the document (or an estimate of these dates if not known);

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(b) (c) (d) (e) (f) (g) (h)

Author(s); Addressee(s); Person(s) who received copies; Subject of the document; The present location and custodian of the document; Nature and grounds for the privilege claimed; and The paragraph number of the individual request(s) to which each document is responsive.

7.

If any of the documents demanded herein have been destroyed, please furnish a

list identifying each such document, its author and addressee, each person to whom copies of the document were furnished or to whom the contents of the document were communicated, a summary of the substance of the document, the date upon which it was destroyed, the reason it was destroyed, and the name of the person who ordered or authorized such destruction. 8. This Request is deemed to be continuing in nature, and in the event you become

aware of or acquire in your possession, custody, or control new responsive documents, you are requested promptly to produce such additional documents for inspection and copying. REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS Request No. 1: DOCUMENTS AND THINGS sufficient to show SAMSUNG'S

DOCUMENT retention AND destruction policies AND practices from 1991 to present, including retention OR destruction of DOCUMENTS OR files, including, but not limited to electronic data AND/OR media.

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Request No. 2:

DOCUMENTS AND THINGS sufficient to describe the corporate

structure, both inter- AND intra-entity AND including ownership AND control, of SAMSUNG, AND any corporate parents, subsidiaries, affiliates, predecessors OR successors thereof. Request No. 3: From 2000 to the present, organizational charts sufficient to

identify SAMSUNG'S personnel involved with research AND development, testing, design, patent activities, management, finance, engineering, production, manufacturing, licensing, sales AND marketing, technical services, AND distribution. Request No. 4: ALL DOCUMENTS CONCERNING SAMSUNG'S pre-filing

investigation for ALL claims brought by SAMSUNG against ON Semiconductor in this action. Request No. 5: ALL DOCUMENTS OR THINGS CONCERNING any of the

allegations in SAMSUNG'S complaint. Request No. 6: initial disclosures. Request No. 7: ALL DOCUMENTS identified OR relied upon in response to ALL DOCUMENTS AND THINGS identified in SAMSUNG'S

Defendants First Set of Interrogatories served herewith. Request No. 8: ALL DOCUMENTS constituting OR CONCERNING internal

SAMSUNG COMMUNICATIONS AND/or COMMUNICATIONS between SAMSUNG AND any other party regarding this lawsuit. Request No. 9: ALL DOCUMENTS CONCERNING internal SAMSUNG

COMMUNICATIONS OR COMMUNICATIONS between SAMSUNG AND any party other than SAMSUNG in which ON Semiconductor OR any of the ON SEMICONDUCTOR PATENTS are referenced OR discussed.

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Request No. 10:

ALL DOCUMENTS CONCERNING correspondence of the

named inventors who are employed OR no longer employed by SAMSUNG regarding the SAMSUNG PATENT, the subject matter therein, OR this lawsuit. Request No. 11: ALL DOCUMENTS that YOU have shown OR otherwise made

available to any expert YOU expect to call as a witness in connection with this lawsuit AND EACH DOCUMENT that such expert has shown OR transmitted to SAMSUNG. Request No. 12: ALL DOCUMENTS reviewed in connection with this lawsuit by

any expert YOU expect to call as a witness in connection with this lawsuit. Request No. 13: ALL other DOCUMENTS not previously produced OR identified

that YOU intend to rely upon in support of YOUR claims at the trial. Request No. 14: ALL DOCUMENTS AND THINGS CONCERNING the ON

SEMICONDUCTOR PATENTS. Request No. 15: ALL DOCUMENTS AND THINGS CONCERNING any

searches, investigations OR evaluations as to the novelty, patentability, validity, enforceability, scope AND/or infringement of the ON SEMICONDUCTOR PATENTS including but not limited to, ALL DOCUMENTS that CONCERN any written OR oral opinion, evaluation OR analysis as to the novelty, patentability, validity, enforceability, scope AND/or infringement of the ON SEMICONDUCTOR PATENTS. Request No. 16: ALL opinions, reports AND evaluations, AND ALL

DOCUMENTS CONCERNING OR embodying opinions (whether written OR oral), including those by attorneys, CONCERNING the alleged infringement, validity, AND/or unenforceability of the ON SEMICONDUCTOR PATENTS OR any RELATED PATENT OR RELATED APPLICATION.

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Request No. 17:

ALL DOCUMENTS CONCERNING any formal OR informal

opinions, analyses, tests, OR studies CONCERNING whether SAMSUNG PRODUCTS infringe any of the ON SEMICONDUCTOR PATENTS. Request No. 18: ALL DOCUMENTS that have ever been considered OR evaluated

by OR for YOU CONCERNING patentability, validity, OR enforceability of the ON SEMICONDUCTOR PATENTS, including any evaluation OR analysis of the patentability of the ON SEMICONDUCTOR PATENTS. Request No. 19: ALL DOCUMENTS AND THINGS that SAMSUNG contends are

relevant to the construction OR interpretation of the asserted claims of the ON SEMICONDUCTOR PATENTS, including ALL DOCUMENTS AND THINGS that support OR refute ON Semiconductor's AND SAMSUNG'S proposed constructions of the asserted claims. Request No. 20: ALL DOCUMENTS AND THINGS that demonstrate the level of

ordinary skill in the art for EACH claim of the ON SEMICONDUCTOR PATENTS. Request No. 21: ALL DOCUMENTS AND THINGS that support OR contradict

YOUR contention that the claims in the ON SEMICONDUCTOR PATENTS are invalid because they fail to satisfy the conditions for patentability specified in 35 U.S.C. § 102. Request No. 22: ALL DOCUMENTS AND THINGS that support OR contradict

YOUR contention that the claims in the ON SEMICONDUCTOR PATENTS are invalid because they fail to satisfy the conditions for patentability specified in 35 U.S.C. § 103. Request No. 23: ALL DOCUMENTS AND THINGS that support OR contradict

YOUR contention that the claims in the ON SEMICONDUCTOR PATENTS are invalid because they fail to satisfy the conditions for patentability specified in 35 U.S.C. § 112.

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Request No. 24:

ALL DOCUMENTS AND THINGS that support OR contradict

YOUR contention that the ON SEMICONDUCTOR PATENTS are unenforceable against YOU pursuant to the doctrine of laches, estoppel, waiver AND/or acquiescence. Request No. 25: ALL DOCUMENTS AND THINGS that support OR contradict

YOUR contention that YOU have not INFRINGED, AND are not INFRINGING the ON SEMICONDUCTOR PATENTS. Request No. 26: ALL DOCUMENTS CONCERNING OR evidencing YOUR first

knowledge OR awareness of the ON SEMICONDUCTOR PATENTS, including ALL DOCUMENTS describing the circumstances in which YOU first learned of the ON SEMICONDUCTOR PATENTS. Request No. 27: ALL DOCUMENTS AND THINGS CONCERNING any patents

OR patent applications RELATED to the SAMSUNG PRODUCTS, including but not limited to: a. ALL patents; b. ALL patent applications; c. The complete prosecution files of ALL patent applications; d. ALL DOCUMENTS that were reviewed in connection with, OR that provide any part of the basis for, the preparation of the patent application; e. ALL DOCUMENTS that constitute OR CONCERN

COMMUNICATIONS OR other DOCUMENTS exchanged between SAMSUNG AND any patent attorney OR agent CONCERNING the application OR prosecution of the applications; f. ALL drafts of the applications OR papers filed during prosecution of the patent applications; AND

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g. ALL publications, patents, THINGS, public uses, AND offers for sale located OR identified in connection with any investigation regarding the patentability, validity, OR enforceability of the patent OR the subject matter claimed in the patent OR patent applications. Request No. 28: ALL DOCUMENTS sufficient to identify ALL persons involved

in the prosecution of any patents OR patent applications CONCERNING the SAMSUNG PRODUCTS. Request No. 29: ALL DOCUMENTS CONCERNING the scope, validity,

infringement, non-infringement, enforceability, OR unenforceability of any patents OR patent applications CONCERNING the SAMSUNG PRODUCTS, including, but not limited to, any opinion of counsel. Request No. 30: ALL DOCUMENTS AND THINGS that form the basis for, in

whole OR in part, OR that were considered in connection with, any opinion of counsel CONCERNING the scope, validity, infringement, non-infringement, enforceability, OR unenforceability of ALL patents OR patent applications CONCERNING the SAMSUNG PRODUCTS. Request No. 31: ALL DOCUMENTS CONCERNING any patentability OR prior

art investigation, search, study, evaluation, OR opinion of any patent OR patent applications CONCERNING the SAMSUNG PRODUCTS. Request No. 32: ALL DOCUMENTS AND THINGS CONCERNING the

conception, development, testing, OR reduction to practice of the SAMSUNG PRODUCTS, including, but not limited to, laboratory notebooks, prototypes, AND invention disclosures.

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Request No. 33:

ALL DOCUMENTS sufficient to identify ALL persons who

participated in the development OR testing of the SAMSUNG PRODUCTS. Request No. 34: PRODUCTS. Request No. 35: Request No. 36: ALL publications CONCERNING the SAMSUNG PRODUCTS. ALL DOCUMENTS CONCERNING the first sale OR offer for ALL prototypes created in connection with the SAMSUNG

sale of ALL SAMSUNG PRODUCTS. Request No. 37: ALL marketing, promotional, AND sales DOCUMENTS

CONCERNING the SAMSUNG PRODUCTS. Request No. 38: ALL DOCUMENTS CONCERNING presentations,

demonstrations, proposals, AND other COMMUNICATIONS to any third party regarding the SAMSUNG PRODUCTS, including, but not limited to, sales AND marketing presentations AND product demonstrations. Request No. 39: ALL DOCUMENTS constituting OR CONCERNING any

agreements CONCERNING the SAMSUNG PRODUCTS OR any patents OR patent applications CONCERNING the SAMSUNG PRODUCTS, including, but not limited to, sales agreements. Request No. 40: ALL DOCUMENTS sent to OR received from any licensee OR

potential licensee CONCERNING the SAMSUNG PRODUCTS. Request No. 41: ALL DOCUMENTS CONCERNING any monetary evaluation of

the SAMSUNG PRODUCTS, any patents OR patent applications related thereto, including, but not limited to, any determination of an appropriate royalty rate for the invention OR products.

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Request No. 42:

ALL DOCUMENTS CONCERNING any legal OR administrative

proceedings involving the SAMSUNG PRODUCTS, including without limitation, pleadings, transcripts of hearings, depositions, trial transcripts, settlement agreements, AND any DOCUMENTS constituting exhibits offered OR admitted in any such pleading. Request No. 43: ALL DOCUMENTS CONCERNING OR comprising any license

agreements CONCERNING the SAMSUNG PRODUCTS OR any technology CONCERNING the SAMSUNG PRODUCTS, including licenses granted OR obtained as a result of the settlement of litigation. Request No. 44: ALL DOCUMENTS sufficient to show the total monthly gross

AND net sales (both in units AND in dollars) for EACH of the SAMSUNG PRODUCTS made, sold, AND/or offered for sale by SAMSUNG OR that SAMSUNG has licensed OR authorized a third party to sell. Request No. 45: ALL DOCUMENTS sufficient to show the monthly profits for

EACH of the SAMSUNG PRODUCTS made, sold, AND/or offered for sale by SAMSUNG OR that SAMSUNG has licensed OR authorized a third party to sell. Request No. 46: ALL DOCUMENTS sufficient to show any anticipated profits OR

sales for EACH of the SAMSUNG PRODUCTS made, sold, AND/or offered for sale by SAMSUNG OR that SAMSUNG has licensed OR authorized a third party to sell, including ALL forecasts AND projections. Request No. 47: ALL DOCUMENTS sufficient to show the market share for

EACH of the SAMSUNG PRODUCTS made, sold, AND/or offered for sale by SAMSUNG OR that SAMSUNG has licensed OR authorized a third party to sell.

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Request No. 48: PATENT. Request No. 49:

ALL DOCUMENTS CONCERNING the scope of the SAMSUNG

ALL DOCUMENTS AND THINGS that SAMSUNG contends are

relevant to the construction OR interpretation of the asserted claims of the SAMSUNG PATENT, including ALL DOCUMENTS AND THINGS that support OR refute ON Semiconductor's AND SAMSUNG'S proposed constructions of the asserted claims. Request No. 50: ALL DOCUMENTS AND THINGS that demonstrate the level of

ordinary skill in the art for EACH claim of the SAMSUNG PATENT. Request No. 51: ALL DOCUMENTS AND THINGS CONCERNING the

preparation AND prosecution of the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS, including the file histories of the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 52: PATENT. Request No. 53: ALL DOCUMENTS authored, written, OR published by OR under ALL invention disclosure forms CONCERNING the SAMSUNG

the name of the named inventors of the SAMSUNG PATENT with respect to the technological field of the SAMSUNG PATENT, including but not limited to correspondence, technical publications, journal articles, presentations, studies, theses, academic papers, research papers, technical analyses, AND inventor notebooks. Request No. 54: ALL DOCUMENTS AND THINGS CONCERNING the named

inventors of the SAMSUNG PATENT in the technological fields of the SAMSUNG PATENT. Request No. 55: ALL DOCUMENTS CONCERNING conception of EACH AND

every invention claimed in the SAMSUNG PATENT.

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Request No. 56:

ALL DOCUMENTS CONCERNING the alleged reduction to

practice, whether actual OR constructive, of EACH AND every invention claimed in the SAMSUNG PATENT. Request No. 57: ALL DOCUMENTS AND THINGS CONCERNING EACH AND

every instance in which any person has contended that any claim of the SAMSUNG PATENT AND/or RELATED PATENTS is invalid, unenforceable, void, OR not infringed. Request No. 58: ALL DOCUMENTS AND THINGS CONCERNING EACH AND

every instance in which any person has contended that any claim of the SAMSUNG PATENT AND/or RELATED PATENTS is actually, potentially, OR allegedly infringed. Request No. 59: ALL DOCUMENTS CONCERNING any lawsuit, ITC action,

interference, arbitration, mediation, OR any other dispute OR adversarial proceeding involving the SAMSUNG PATENT OR RELATED PATENTS, including without limitation: a. ALL deposition transcripts (with exhibits); b. ALL discovery, including, without limitation, interrogatories, requests for admissions, requests for production, expert witness discovery AND witness lists; c. ALL responses to discovery listed in (b) above, including, without limitation, ALL DOCUMENTS produced in response to the discovery requests; d. ALL expert reports; e. ALL infringement contentions AND invalidity contentions, as well as any technical DOCUMENTS AND prior art references referenced therein; f. ALL transcripts of hearings OR other court proceedings; g. ALL court orders; h. ALL claim charts; AND

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i. ALL DOCUMENTS produced in contemplation of settlement. Request No. 60: ALL DOCUMENTS AND THINGS CONCERNING ALL

litigation, prosecution, OR other administrative OR legal proceedings worldwide, completed OR ongoing, CONCERNING the SAMSUNG PATENT, RELATED PATENTS, OR RELATED APPLICATIONS. Request No. 61: For EACH device OR method that, to SAMSUNG'S knowledge,

actually OR allegedly practices OR practiced any of the claimed inventions from the SAMSUNG PATENT, ALL DOCUMENTS CONCERNING how EACH such device OR method actually OR allegedly practices EACH of the claimed inventions from the SAMSUNG PATENT. Request No. 62: ALL prior art of which SAMSUNG is aware to the SAMSUNG

PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 63: ALL DOCUMENTS AND THINGS that anyone ever contended

were prior art to the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 64: ALL DOCUMENTS AND THINGS CONCERNING any AND

ALL searches for Prior Art with respect to the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 65: DOCUMENTS sufficient to show the first sale of EACH device

that practices any of the claimed inventions from the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 66: DOCUMENTS sufficient to show the first offer for sale of EACH

device that practices any of the claimed inventions from the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS of which SAMSUNG is aware.

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Request No. 67:

DOCUMENTS sufficient to show the first public use of EACH

device OR method that practices any of the claimed inventions from the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS of which SAMSUNG is aware. Request No. 68: DOCUMENTS sufficient to show the first public disclosure of

EACH device that practices any of the claimed inventions from the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS of which SAMSUNG is aware. Request No. 69: DOCUMENTS sufficient to show the first use for a commercial

purpose of EACH device that practices any of the claimed inventions from the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS of which SAMSUNG is aware. Request No. 70: ALL DOCUMENTS that SAMSUNG may use to show non-

obviousness of the alleged inventions of the asserted claims of the SAMSUNG PATENT. Request No. 71: ALL DOCUMENTS CONCERNING the basis for any claim OR

defense of experimental use in response to an assertion by ON Semiconductor of invalidity of the SAMSUNG PATENT under 35 U.S.C. § 102(b). Request No. 72: ALL DOCUMENTS CONCERNING any "objective evidence" of

"secondary considerations" of the non-obviousness of any asserted claim of the SAMSUNG PATENT in accordance with, for example, Graham v. John Deere Co., 383 U.S. 1, 17 (1966), including, without limitation, commercial success, long-felt need, copying by others, attempts by others to solve the problems addressed by the SAMSUNG PATENT, AND acceptance in the industry AND/or by the public of the claimed alleged inventions. Request No. 73: ALL DOCUMENTS AND THINGS that SAMSUNG contends are

relevant to the construction OR interpretation of the asserted claims of the SAMSUNG

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PATENT, including ALL DOCUMENTS AND THINGS that support OR refute ON Semiconductor's AND SAMSUNG'S proposed constructions of the asserted claims. Request No. 74: ALL DOCUMENTS CONCERNING when SAMSUNG became

aware that any ON SEMICONDUCTOR PRODUCT potentially OR actually allegedly infringed one OR more of the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 75: ALL DOCUMENTS CONCERNING whether the SAMSUNG

PATENT is allegedly infringed by any of the accused ON SEMICONDUCTOR PRODUCTS OR the use of the accused ON SEMICONDUCTOR PRODUCTS. Request No. 76: ALL DOCUMENTS AND THINGS CONCERNING the alleged

infringement by ON Semiconductor of the SAMSUNG PATENT. Request No. 77: ALL DOCUMENTS AND THINGS CONCERNING any actual

OR potential claim by SAMSUNG that ON Semiconductor's infringement of the SAMSUNG PATENT is willful OR that SAMSUNG is otherwise entitled to enhanced damages under 25 U.S.C. § 284. Request No. 78: ALL DOCUMENTS CONCERNING ON Semiconductor, its

business, its customers, OR its products. Request No. 79: ALL DOCUMENTS AND THINGS CONCERNING any of the

accused ON SEMICONDUCTOR PRODUCTS. Request No. 80: ALL DOCUMENTS CONCERNING any discussion of the ON

SEMICONDUCTOR PRODUCTS, including methods of manufacture, including but not limited to any competitive analysis of any products OR methods used by SAMSUNG.

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Request No. 81:

DOCUMENTS sufficient to show ALL assignments, licenses,

attempts to license, attempts to enforce, AND negotiations regarding the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 82: ALL DOCUMENTS CONCERNING any discussions

CONCERNING the possible licensing of any technology OR methods from SAMSUNG that are in the technical field of the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 83: ALL DOCUMENTS CONCERNING ON Semiconductor's

potential liability OR non-liability with respect to the SAMSUNG PATENT, RELATED PATENTS, AND RELATED APPLICATIONS. Request No. 84: ALL DOCUMENTS AND THINGS CONCERNING any damages

that SAMSUNG alleges it has suffered as a result of ON Semiconductor's alleged infringement of the SAMSUNG PATENT, including but not limited to any calculation OR estimates of damages, any information forming the basis for such damages calculations OR estimates, AND any methodology used to calculate OR estimate damages. Request No. 85: ALL DOCUMENTS AND THINGS sufficient to show any AND

ALL products marked with the SAMSUNG PATENT OR RELATED PATENTS. Request No. 86: ALL DOCUMENTS AND THINGS sufficient to show any

marking with the Patent Numbers of the SAMSUNG PATENT by any SAMSUNG licensee OR any efforts to require any licensee to mark any product. Request No. 87: ALL DOCUMENTS CONCERNING the value of the SAMSUNG

PATENT, damages for infringement of the SAMSUNG PATENT, AND royalties for licenses for the SAMSUNG PATENT.

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Request No. 88:

DOCUMENTS sufficient to show ALL rights ever granted under

the SAMSUNG PATENT, including assignments, security interests, exclusive AND nonexclusive licenses, transfers of ownership, AND the chain of title of the SAMSUNG PATENT. MORRIS, NICHOLS, ARSHT & TUNNELL LLP /s/ Richard J. Bauer (#4828) Karen Jacobs Louden (#2881) Richard J. Bauer (#4828) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 [email protected] Attorneys for defendants OF COUNSEL: Kenneth R. Adamo JONES DAY 2727 North Harwood Street Dallas, TX 75201-1515 (214) 220-3939 T. Gregory Lanier Behrooz Shariati JONES DAY 1755 Embarcadero Road Palo Alto, CA 94303 (650) 739-3939 March 26, 2007

777675.1

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CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on March 26, 2007, copies of the foregoing were caused to be served upon the following in the manner indicated: BY HAND AND EMAIL John W. Shaw Andrew A. Lundgren YOUNG, CONAWAY, STARGATT & TAYLOR LLP The Brandywine Building 1000 West Street, 17th Flr. Wilmington, DE 19899 BY EMAIL John M. Desmarais James E. Marina KIRKLAND & ELLIS 153 East 53rd Street New York, NY 10022

/s/ Richard J. Bauer (#4828) Richard J. Bauer (#4828)

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EXHIBIT E

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EXHIBIT F

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, L.L.C., Plaintiffs, v. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, L.L.C., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR L.L.C., Defendants. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA GENERAL, L.L.C., SAMSUNG SEMICONDUCTOR, INC., and SAMSUNG AUSTIN SEMICONDUCTOR L.L.C., Plaintiffs, v. ON SEMICONDUCTOR CORP. and SEMICONDUCTOR COMPONENTS INDUSTRIES, L.L.C., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 07-449 (JJF)

C.A. No. 06-720 (JJF)

ON SEMICONDUCTOR'S FOURTH SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS TO SAMSUNG Pursuant to Rule 34 of the Federal Rules of Civil Procedure, ON Semiconductor Corporation and Semiconductor Components Industries, L.L.C. (collectively, "ON

Semiconductor") request that Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.; Samsung Telecommunications America General, L.L.C.; Samsung Semiconductor, Inc.;

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and Samsung Austin Semiconductor, L.L.C. (collectively, "Samsung") produce to ON Semiconductor the documents and things identified below for inspection and copying at the offices of ON Semiconductor's counsel, Jones Day, 1755 Embarcadero Road, Palo Alto, CA 94303, within thirty (30) days of service. These requests are supplemental to the obligations Samsung already has to provide disclosure to ON Semiconductor pursuant to the Federal Rules of Civil Procedure and the local rules of the District of Delaware, and are not intended to delay Samsung's compliance with these rules. DEFINITIONS These requests incorporate, without limiting the scope of the Federal Rules of Civil Procedure, the following definitions: 1. 2. "ALL" refers to all and each, and "EACH" refers to all and each. "AND" and "OR" refers to either disjunctive or conjunctive use as necessary to

bring within the scope of the interrogatories all responses that might otherwise be construed to be outside of its scope. 3. "COMMUNICATION" refers to any transmittal of information in the form of

facts, ideas, inquiries, or otherwise. 4. constituting. 5. "DOCUMENT" refers to the usage of this term in Fed. R. Civ. P. 34(a), and is "CONCERNING" refers to relating to, referring to, describing, evidencing, or

synonymous in meaning and equal in scope to this usage, including, without limitation, electronically stored documents, photographs, tape recordings, or other sound or visual materials, computer databases, computer tapes, and any other materials that are in your actual or

2

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constructive possession, custody, or control, as well as all prior drafts of the foregoing, and copies of the foregoing on which any mark, alteration, writing, or other change from the original has been made. A draft or non-identical copy is a separate document within the meaning of the term. 6. The "ON SEMICONDUCTOR PATENTS" refers to the United States Patent

Nos. 6,362,644; 5,563,594; 5,361,001; and 5,000,827, including any reexaminations. 7. The "ON SEMICONDUCTOR PRODUCTS" refers to any accused apparatus,

product, device, process, method, act, and/or other instrumentality that Samsung contends infringe United States Patent No. 5,252,177. 8. referenced "RELATED APPLICATIONS" refers to any and all applications related to the patent(s), including any continuations, continuations-in-part, divisionals,

interferences, reexaminations, reissues, parents, foreign counter-part applications, and any other applications disclosing, describing, or claiming any invention disclosed, described, or claimed in the referenced patent(s), or claiming the benefit of the filing date of any application whose benefit is claimed in the referenced patent, whether or not abandoned and whether or not issued. 9. "RELATED PATENTS" refers to any or all patents based upon any RELATED

APPLICATION, including any patents that may have been opposed, contacted, or subjected to any nullity proceedings. 10. "SAMSUNG," "YOU," and "YOUR" refers to Samsung Electronics Co., Ltd.;

Samsung Electronics America, Inc.; Samsung Telecommunications America General, LLC; Samsung Semiconductor, Inc.; and Samsung Austin Semiconductor, LLC, their present and former directors, officers, employees, attorneys, accountants, consultants, representatives, agents,

3

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subsidiaries, divisions, successors in interest, any partnerships or joint ventures to which any of the foregoing are a party, and/or other persons acting on behalf of any of the foregoing. 11. 12. The "SAMSUNG PATENT" refers to the United States Patent No. 5,252,177. "SAMSUNG PRODUCTS" refers to Double Data Rate (DDR) Synchronous

Dynamic Random Access Memory (SDRAM) that includes but is not limited to DDR SDRAM, Mobile DDR SDRAM, DDR2 SDRAM, GDDR SDRAM, GDDR2 SDRAM, and GDDR3 SDRAM, as well as any integrated circuits manufactured using cup plating systems. The "SAMSUNG PRODUCTS" include, but are not limited to, the following product designations: K4B1G0446C-ZC(F7/F8/H9), K4D261638, K4D263238, K4B1G0846C-ZC(F7/F8/H9), K4D551638, K4H1G0438A, K4B1G1646C-ZC(F7/F8/H9), K4H1G0638C, K4H1G0738C,

K4H1G0838A, K4H2G0638A, K4H510438C, K4H510438D-ZC(L)B3/CCC, K4H510638E, K4H510638H, K4H510738E, K4H510738H, K4H510838C, K4H510838D, K4H510838DUC(L)B3/CCC, K4H510838D-ZC(L)B3/CCC, K4H511638C, K4H511638D, K4H511638DUC(L)B3/CCC, K4H511638D-ZC(L)B3/CCC, K4H560438E, K4H560438H, K4H560438HUC(L)B0, K4H560438H-ZC(L)CC/B3, K4H560838E, K4H560838H, K4H560838H-

UC(L)B3/CCC, K4H560838H-ZC(L)B3/CCC, K4H561638H, K4H561638H-UC(L)/B3/CCC, K4H561638H-ZC(L)B3/CCC, K4N51163Q, K4N56163Q, K4T1G044QA, K4T1G044QC, K4T1G044QC-ZC(D5/E6), K4T1G084QA, K4T1G084QC, K4T1G084QD-ZC(D5/E6),

K4T1G164QA, K4T1G164QC, K4T1G164QD-ZC(D5/E6), K4T2G044QM, K4T2G084QM, K4T51043QC, K4T51043QE, K4T51043QE-ZC(CC/D5/E6), K4T51083QC, K4T51083QE, K4T51083QE-ZC(CC/D5/E6/E7), K4T51163QC, K4T51163QE-ZC(CC/D5/E6), K4T56043QF, K4T56043QG, K4T56083QF, K4T56083QG, K4U52324Q, K4X28163PH, K4X51163PC, K4X51163PE-(1)(2)(3)(4), K4X51323PC, K4X51323PE, K4X51323PE-(1)(2)(3)(4),

4

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K4X56163PG,

K4X56163PG-(1)(2)(3)(4),

K4X56323PG,

K4X56323PG-(1)(2)(3)(4), K7D163674B,

K5E1G131CA-D075000,

K5W1G12ACD-DK75000,

K7D161874B,

K7D321874A, K7D321874C, K7D323674A, K7D323674C, K7D801871B, K7D803671B, K7I161882B, K7I323682C, K7J161882B, K7K1618T2C, K7I161884B, K7I323684C, K7J163682B, K7K1636T2C, K7I163682B, K7I641882M, K7J321882C, K7I163684B, K7I641884M, K7J323682C, K7I321882C, K7I643682M, K7J641882M, K7I321884C, K7I643684M, K7J643682M,

K7K3218T2C,

K7K3236T2C,

KAG001002A-DJJY000, M312L2828ET(U)0, -CB3/CCC,

KAL00X001M-AJYY000, M312L2828HU0, M312L2923CUS,

M312L2820EG(Z)0,

M312L2820HZ0,

M312L2920CUS, M312L2923CZ0,

M312L2920CZ0,

M312L2920DZ3

M312L3223EG(Z)0,

M312L3223ET(U)S,

M312L3223HUS, M312L3223HZ0, M312L5128AU0, M312L5128AU1, M312L5620AUS, M312L5623AUS, M312L6420EG(Z)0, M312L6423EG(Z)0, M312L6523CUS, M368L2923DUN, M368L3324CUS, M368L6423HUN, M312L5628CU0, M312L5720CZ0, M312L5720DZ3-CB3/CCC, M312L6420HZ0, M312L6423HZ0, M368L2923CUN, M368L3223HUS, M368L6423ET(U)N,

M312L6420ET(U)S, M312L6423ET(U)S, M312L6523CZ0,

M312L6420HUS, M312L6423HUS, CB3/CCC,

M312L6523DZ3

M368L2923DUN-CB3/CCC, M368L3324DUS, M368L6523CUS,

M368L3223ET,

M368L6423ET(U)M, M368L6523DUS,

M368L6523DUS-CB3/CCC,

M378B2873CZ0-C(F7/F8/H9), M378B5673CZ0-C(F7/F8/H9), M378B6474CZ0-C(F7/F8/H9), M378T2863AZ3, M378T2953EZ3, M378T5663AZ3, M378T6453FZ3, M378T2863CZ3, M378T2863DZS-C(D5/E6/E7/F7), M378T3354CZ3, M378T2953CZ3, M378T3354EZ3, M378T5763MZ3,

M378T2953EZ3-C(D5/E6/E7/F7), M378T5663CZ3, M378T6553CZ3,

M378T5663DZ3-C(D5/E6), M378T6553EZ3,

M378T6553EZS-C(D5/E6/E7/F7),

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M381L2923CUM, M381L3223HUM, M381L6523DUM,

M381L2923DUM,

M381L2923DUM-CB3/CCC, M381L6423HUM, M391T2863AZ3,

M381L3223ET(U)M, M381L6523CUM, M391T2953CZ3,

M381L6423ET(U)M,

M381L6523DUM-CB3/CCC,

M391T2953EZ3, M391T5663AZ3, M391T5663CZ3, M391T5763MZ3, M391T6453FZ3, M391T6553CZ3, M391T6553EZ3, M392T2863CZA, M392T2950CZA, M392T2950EZA, M392T2953CZA, M392T2953EZA, M392T5160CJA, M392T5660CZA, M392T5663CZA, M392T6553CZA, M392T6553EZA, M393T1K66MZ3, M393T1K66MZA, M393T2863AZ3, M393T2863AZA, M393T2863CZ3, M393T2863CZA, M393T2950CZ3, M393T2950CZA, M393T2950EZ3, C(CC/D5/E6), C(CC/D5), M393T2950EZ3-C(CC/D5), M393T2953CZ3, M393T2953EZA, M393T5160CZ0, M393T2950EZA, M393T2953EZ3, M393T2950EZAM393T2953EZ3M393T3253FZ3, M393T5160CZ4, M393T5166AZA,

M393T2953CZA,

M393T2953EZA-C(CC/D5/E6), M393T5160CZ0-C(CC/D5), M393T5166AZ4,

M393T3253GZ3, M393T5160CZA,

M393T5160CZA-C(CC/D5/E6),

M393T5168AZ0, M393T5263MZ3, M393T5263MZA, M393T5660AZ3, M393T5660AZA, M393T5660CZ3, C(CC/D5/E6), M393T5660CZ3-C(CC/D5), M393T5660CZA, M393T5663CZ3, M393T5660CZAM393T5663CZ3-

M393T5663AZ3,

M393T5663AZA,

C(CC/D5), M393T5663CZA, M393T5663CZA-C(D5/E6), M393T5750CZ3, M393T5750CZ4, M393T5750CZA, C(CC/D5/E6), M393T5750EZ3, M393T5750EZ3-C(CC/D5), M393T6450FZ3, M393T5750EZ3M393T6450GZ3,

M393T5750EZ4,

M393T5750EZA,

M393T6453FZ3, M393T6453GZ3, M393T6553CZ3, M393T6553CZA, M393T6553EZ3, M393T6553EZA, M393T6553EZA-C(CC/D5/E6), M395T2953CZ4, M395T2953EZ4, M395T5160CZ4-

M395T2953EZ4-CD5(50/60/20), CD5(50/60/20),

M395T2953EZ4-CE6(50/60/20),

M395T5160CZ4-CE6(50/60/20),

M395T5750EZ4-CD5(50/60/20),

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M395T5750EZ4-CE6(50/60/20),

M395T6553CZ4,

M395T6553EZ4,

M395T6553EZ4-

CD5(50/60/20), M395T6553EZ4-CE6(50/60/20), M470L2923BN0 - C(L)B3, M470L2923DV0CB300, M470L3224HU0, M470L3324CU0, M470L3324DU0, M470L6524CU0,

M470L6524DU0-CB300, M470T2953CZ3, M470T3354EZ3,

M470T2864AZ3,

M470T2864CZ3,

M470T2864DZ3-C(D5/E6), M470T3354CZ3, M470T5669AZ0,

M470T2953EZ3, M470T5663CZ3,

M470T2953EZ3-C(D5/E6), M470T5663CZ3-C(D5/E6),

M470T6464AZ3, M470T6464CZ3, M470T6554CZ3, M470T6554EZ3, and M470T6554EZ3C(D5/E6). The "SAMSUNG PRODUCTS" also include, but are not limited to, products and chips made using any of the following systems: Applied Materials, Inc.'s SlimCell system; Novellus Systems Inc.'s Sabre System; Semitool Inc.'s Raider ECD, Raider ECD 310, Equinox systems; Electroplating Engineers of Japan Ltd.'s Posfer System; and Semicon Science Co. Ltd.'s or SSC's plating system (collectively, "CUP PLATING MACHINES"). 13. 14. "THING" refers to the broadest meaning recognized under Fed. R. Civ. P. 34(a). The use of the singular form of any word includes the plural and vice versa. INSTRUCTIONS These requests incorporate, without limiting the scope of the Federal Rules of Civil Procedure, the following instructions: 1. When producing documents to satisfy this Request, identify the paragraph number

to which the produced document responds. 2. The identical text of the individual request for production being answered from

this Request must immediately precede each answer given. 3. You are to produce the documents as they are kept in the ordinary course of

business or with appropriate markings or designations so that it may be determined to what

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request they are responsive, including, without limitation, labels that identify documents, binder covers, file folders, tabs, or dividers. 4. Any electronic information must be produced in a coherent and understandable

format or together with a description of the system from which it was derived so that it may be converted to a coherent and understandable format. 5. If a time period is not specified in the request, all responsive documents for each

request must be produced, regardless of the date of the documents were created or received. 6. PRIVILEGE: If you withhold from production any document on the grounds of

privilege, please further provide the following information: (a) Date(s) of the creation, transmission, and modification of the document (or an estimate of these dates if not known); (b) (c) (d) (e) (f) (g) (h) Author(s); Addressee(s); Person(s) who received copies; Subject of the document; The present location and custodian of the document; Nature and grounds for the privilege claimed; and The paragraph number of the individual request(s) to which each document is responsive. 7. If any of the documents demanded herein have been destroyed, please furnish a

list identifying each such document, its author and addressee, each person to whom copies of the document were furnished or to whom the contents of the document were communicated, a

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summary of the substance of the document, the date upon which it was destroyed, the reason it was destroyed, and the name of the person who ordered or authorized such destruction. 8. This Request is deemed to be continuing in nature, and in the event you become

aware of or acquire in your possession, custody, or control new responsive documents, you are requested promptly to produce such additional documents for inspection and copying. REQUESTS Request No. 168: DOCUMENTS sufficient to identify each SAMSUNG PRODUCT

and Samsung integrated circuit chip ("SAMSUNG CHIP") that has been manufactured by electroplating through the use of CUP PLATING MACHINES, and that has been imported, sold, made, used, and offered for sale in the U.S. Request No. 169: DOCUMENTS sufficient to identify model numbers of ALL CUP

PLATING MACHINES purchased and/or used by Samsung. Request No. 170: DOCUMENTS sufficient to identify ALL Samsung entities that

have purchased any of the CUP PLATING MACHINES, and ALL Samsung entities that operate or use any of the CUP PLATING MACHINES to manufacture the SAMSUNG PRODUCTS and SAMSUNG CHIPS. Request No. 171: DOCUMENTS sufficient to identify ALL Samsung entities in

possession, custody or control of any of the CUP PLATING MACHINES. Request No. 172: DOCUMENTS sufficient to identify ALL SAMSUNG

PRODUCTS into which the SAMSUNG CHIPS are incorporated for importation, sale, use, and/or offer for sale in the U.S.

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Request No. 173:

For the SAMSUNG PRODUCTS and SAMSUNG CHIPS,

DOCUMENTS sufficient to identify the period of manufacture, and the period of importation, sale, use, and/or offer for sale in the U.S. Request No. 174: For the SAMSUNG PRODUCTS and SAMSUNG CHIPS,

DOCUMENTS sufficient to identify the location of electroplating with each CUP PLATING MACHINE. Request No. 175: DOCUMENTS sufficient to identify the purchase date and the

period of use of each CUP PLATING MACHINE purchased or used by Samsung. Request No. 176: ALL DOCUMENTS concerning the factors considered in

Samsung's purchase of CUP PLATING MACHINES. Request No. 177: ALL DOCUMENTS concerning training received by Samsung,

including but not limited, training provided by the manufacturers of CUP PLATING MACHINES to Samsung for the operation, maintenance, troubleshooting, and use of the CUP PLATING MACHINE, and DOCUMENTS sufficient to identify ALL Samsung personnel who received such training, including but not limited to process flows, recipes, theory of operation, trouble shooting, and maintenance. Request No. 178: All DOCUMENTS received from the manufacturers of CUP

PLATING MACHINES, including but not limited to drawings, notes, process flows, schematics, manuals, memorandums, presentations, and reports related to CUP PLATING MACHINES. Request No. 179: ALL DOCUMENTS concerning the design, structure and

operation of each CUP PLATING MACHINE, including but not limited to any drawings, notes, specifications and specification databases, layouts and layout databases, process flows,

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schematics, manuals, memorandums, presentations, and reports related to CUP PLATING MACHINES. Request No. 180: ALL DOCUMENTS concerning the identity, content, and meaning

of drawings, notes, specifications and specification databases, layouts and layout databases, process flows, schematics, manuals, memorandums, presentations, and reports related to CUP PLATING MACHINES. Request No. 181: ALL DOCUMENTS concerning any proposed modifications and

any modifications actually implemented to CUP PLATING MACHINES, including modifications (proposed or implemented) from an earlier model to a later model of a particular CUP PLATING MACHINE. Request No. 182: ALL DOCUMENTS concerning the process used in

manufacturing each SAMSUNG PRODUCT and SAMSUNG CHIP, including all process steps and recipes. Request No. 183: ALL DOCUMENTS concerning the available processes and

recipes for the manufacture of each SAMSUNG PRODUCT and SAMSUNG CHIP with CUP PLATING MACHINES, including but not limited to recipes and processes described in any notes, process flows, manuals, memorandums, presentations, and reports related to CUP PLATING MACHINES. Request No. 184: ALL DOCUMENTS concerning the processes and recipes actually

used for the manufacture of each SAMSUNG PRODUCT and SAMSUNG CHIP with CUP PLATING MACHINES, including but not limited to recipes and processes described in any notes, process flows, manuals, memorandums, presentations, and reports related to CUP PLATING MACHINES.

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Request No. 185:

ALL DOCUMENTS concerning the development of the processes

and recipes actually used for the manufacture of each SAMSUNG PRODUCT and SAMSUNG CHIP with any of the CUP PLATING MACHINES, including but not limited to recipes and processes described in any notes, process flows, manuals, memorandums, presentations, and reports related to CUP PLATING MACHINES. Request No. 186: ALL DOCUMENTS concerning the design rules for all

interconnect layers (metals, vias, and contacts) and pad for each layer of each SAMSUNG PRODUCT and SAMSUNG CHIP electroplated with CUP PLATING MACHINES. Request No. 187: ALL DOCUMENTS concerning the electroplating uniformity

sought from the use of CUP PLATING MACHINES, and the actual uniformity achieved for each wafer used to manufacture the SAMSUNG PRODUCTS and SAMSUNG CHIPS from the use of CUP PLATING MACHINES. Request No. 188: ALL DOCUMENTS concerning the factors relevant to achieving

electroplating uniformity for each wafer used to manufacture the SAMSUNG PRODUCTS and SAMSUNG CHIPS from the use of CUP PLATING MACHINES. Request No. 189: ALL DOCUMENTS concerning the testing and measurement

performed to determine electroplating uniformity for each wafer used to manufacture the SAMSUNG PRODUCTS and SAMSUNG CHIPS from the use of CUP PLATING MACHINES, and the identity and content of any documents related to such testing and measurement. Request No. 190: ALL DOCUMENTS concerning the causes related to non-

uniformity in electroplating a wafer from the use of CUP PLATING MACHINES, and the available corrective measures, and the corrective measures taken, to correct the non-uniformity.

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Request No. 191:

ALL DOCUMENTS concerning the specific electroplating

applications (e.g., formation of metal, vias, contacts, or solder balls, etc.) for each CUP PLATING MACHINE used by Samsung in the manufacture of the SAMSUNG CHIPS. Request No. 192: ALL DOCUMENTS concerning the type of material that is

electroplated onto a wafer using CUP PLATING MACHINES. Request No. 193: ALL DOCUMENTS concerning the layout, arrangement and

topography of the interconnect layers (metals, vias, and contacts) and pad for each layer of each SAMSUNG PRODUCT and SAMSUNG CHIP manufactured using CUP PLATING MACHINES. Request No. 194: DOCUMENTS sufficient to identify the names, roles, current

whereabouts of the persons most knowledgeable about the operation, recipes, process flows, troubleshooting, maintenance, theory of operation, design, and structure of CUP PLATING MACHINES. MORRIS, NICHOLS, ARSHT & TUNNELL LLP

/s/ Richard J. Bauer
Karen Jacobs Louden (#2881) Richard J. Bauer (#4828) 1201 North Market Street P.O. Box 1347 Wilmington, DE 19899 (302) 658-9200 [email protected] [email protected] Attorneys for ON Semiconductor Corp. and Semiconductor Components Industries, L.L.C.

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OF COUNSEL: Kenneth R. Adamo JONES DAY 2727 North Harwood Street Dallas, TX 75201-1515 (214) 220-3939 Tharan Gregory Lanier Behrooz Shariati JONES DAY 1755 Embarcadero Road Palo Alto, CA 94303 (650) 739-3939

June 6, 2008
2356957

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CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on June 6, 2008, copies of the foregoing were caused to be served upon the following in the manner indicated: BY HAND AND EMAIL Josy W. Ingersoll John W. Shaw Andrew A. Lundgren YOUNG, CONAWAY, STARGATT & TAYLOR LLP The Brandywine Building 1000 West Street, 17th Flr. Wilmington, DE 19899 BY EMAIL John M. Desmarais James E. Marina KIRKLAND & ELLIS 153 East 53rd Street New York, NY 10022

/s/ Richard J. Bauer
___________________________ Richard J. Bauer (#4828)

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EXHIBIT G

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EXHIBIT I

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CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on August 22, 2008, I electronically filed the foregoing with the Clerk of the Court using CM/ECF, which will send notification of such filing(s) to the following: Josy W. Ingersoll John W. Shaw Andrew A. Lundgren I also certify that copies were caused to be served on August 22, 2008 upon the following in the manner indicated: BY HAND AND EMAIL Josy W. Ingersoll John W. Shaw Andrew A. Lundgren YOUNG, CONAWAY, STARGATT & TAYLOR LLP The Brandywine Building 1000 West Street, 17th Flr. Wilmington, DE 19899 BY EMAIL John M. Desmarais James E. Marina KIRKLAND & ELLIS 153 East 53rd Street New York, NY 10022

/s/ Richard J. Bauer
___________________________ Richard J. Bauer (#4828)