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Bobbie Wilson (SBN 148317) E-mail: BWilson@perkinscoie.com Heather R. Bobkova (SBN 257014) E-mail: HBobkova@perkinscoie.com Perkins Coie LLP 3150 Porter Drive Palo Alto, CA 94304 Telephone: (650) 838-4300 Facsimile: (650) 838-4350 Attorneys for Defendant Broadcom Corporation UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

RAMBUS, INC, Plaintiff, v. BROADCOM CORPORATION, Defendant.

Case No. 10-cv-05437 RS BROADCOM CORPORATION'S MOTION FOR ADMINISTRATIVE RELIEF FROM THE CASE MANAGEMENT ORDER

Pursuant to Local Rules 16-2(d) and 7-11 and Federal Rules of Civil Procedure 4(m) and 6(b), Broadcom Corporation makes this Administrative Request for an Order relieving it from the from the Courts Order Setting Initial Case Management Conference and ADR Deadlines and from subsequent Clerk's Notices setting the date for the Case Management Conference (collectively the Case Management Order). Broadcom respectfully requests that the initial Case Management Conference be held on or after August 25, 2011 as the Courts calendar permits, and that the deadline for submitting the Joint Case Management Statement be moved accordingly.1

A review of the Court's calendar indicates that the Court is unavailable on August 18, 2011.

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This Motion for Administrative Relief is based upon the Memorandum of Points and Authorities, the Declaration of Bobbie Wilson ("Wilson Decl."), and the complete files and records in this action. MEMORANDUM OF POINTS AND AUTHORITIES On December 1, 2010, Rambus, Inc. filed suit against Defendant Broadcom Corporation, alleging infringement of certain patents assigned to Rambus. D.E. 1. The Court originally set the Case Management Conference for March 10, 2011. D.E. 3. On February 18, 2011, the Court extended the Case Management Conference to March 31, 2011, based on a stipulation from the parties. D.E. 27. That extension allowed the Court time to consider whether additional matters filed by Rambus were related to the above-captioned matter. Id. On February 23, 2011, the Court issued a determination that the above-captioned matter is related to the following matters: Rambus v. Freescale, C 10-5445; Rambus v. LSI Corp., C 10-5446; Rambus v. Mediatek, C 105447; Rambus v. Nvidia, C 10-5448; and Rambus v. STMicroelectronics, C 10-5449. D.E. 28. On June 13, 2011, the Court granted in part and denied in part a motion to stay the related Rambus actions. D.E. 40. The Court subsequently continued the Case Management Conference to August 4, 2011. D.E. 36; D.E. 41. On July 26, 2011, attorneys from Perkins Coie LLP filed a Notice of Appearance in the above captioned action on behalf of Broadcom Corporation. Broadcom Corporation now seeks to continue the Case Management Conference and the corresponding deadline for the Joint Case Management Statement. First, Local Rule 16-10 requires lead trial counsel to attend the Case Management Conference; however, the lead trial counsel from the Perkins Coie LLP team will not be available on August 4, 2011. Second, Broadcom Corporation's newly retained counsel would appreciate additional time to investigate the complex issues involved in the case and confer with the multiple related defendants before presenting a Joint Case Management Statement to the Court. Broadcom Corporation is seeking this extension, which will not result in significant delay, for good cause and so that justice may be served. Additionally, as discussed below, the extension will not prejudice any party. Plaintiff would not have objected to an August 25, 2011 Case Management Conference, but conditioned a stipulation on additional scheduling limitations to which Defendants could not agree. -2-

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Pursuant to Local Rule 16-2(d) and 6-3, counsel for Broadcom Corporation contacted Plaintiff's counsel and asked whether they would stipulate to a continuance of the Case Management Conference. Wilson Decl. at 6-7. Through their counsel, Plaintiff responded that they would agree to move the Case Management Conference to August 25, 2011 if all Defendants whose cases are currently proceeding in the related matters would agree to Plaintiff's proposed schedule for other discovery deadlines. Id. at 8. The Defendants cannot agree to Plaintiff's proposal as the parties are continuing to meet and confer regarding the case schedule as required by Local Rule 16-3 and Fed. R. Civ. P. 26(f). All Defendants in the related matters that are currently proceeding in front of the Court have agreed to extend the Case Management Conference until August 25, 2011. Id. at 9. Broadcom Corporation requests that the Court revise the Case Management Order as follows: (1) The initial Case Management Conference is to be held on or after August 25, 2011, as the Courts calendar permits. (2) The parties shall file the Federal Rule 26(f) Report, complete Initial Disclosures or state objections in the Rule 26(f) Report and file the parties Joint Case Management Statement no later than August 18, 2011.

CONCLUSION For the foregoing reasons, Broadcom Corporation respectfully requests that the Court grant this Motion for Administrative Relief from the Case Management Order.

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1 DATED: July 26, 2011 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4By: /s/ Bobbie Wilson Bobbie Wilson, Bar No. 148317 BWilson@perkinscoie.com Heather R. Bobkova Bar. No. 257014 HBobkova@perkinscoie.com Attorneys for Defendant Broadcom Corporation PERKINS COIE LLP

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CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's ECF System. /s/ Heather R. Bobkova

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