Case 5:05-cv-00334-RMW Document 2086-2 Filed 08/27/2008 Page 1 of 2

Samsung’s Witness List

Pretrial Statement, Section F
August 27, 2008
Case No. 05-00334-RMW; 05-02298-RMW

Pursuant to the Court’s Standing Order Re: Pretrial Preparation, Samsung hereby
submits the list of the fact witnesses it presently intends to call, or may call, to testify in
its case.

As per the Court’s Standing Order, Samsung designates for each witness the
likely subject matter of his or her testimony and whether Samsung presently “intends” to
call the witness, or “may” call the witness if the need arises.

Finally, many of the adverse witnesses that Samsung “may call” are there to
provide brief testimony establishing the admissibility of documents. Samsung, however,
anticipates their depositions can be avoided if there are stipulations pretrial on the
exhibits for which they are the sponsoring witness.

1. Jay Shim: Samsung will call Mr. Shim to testify regarding the license
negotiations between Samsung and Rambus, the license negotiations of the 2000
SDR/DDR License, the 2001 Amendment Number 1 to that License, and renewal
negotiations of the 2000 SDR/DDR License, Rambus’s June 6, 2005 termination of the
2000 SDR/DDR License, as well as industry customs and practices in licensing and
Rambus’s audit of Samsung's royalties as well as the business relationship between
Rambus and Samsung.

2. Keith Ugone: Samsung will call Dr. Ugone, an economics and damages expert,
to testify regarding the comparability of differing licensing payment terms and the relief
sought by Samsung under the SDR/DDR License Agreement.

3. Carl Sechen: Samsung will call Dr. Sechen, as an expert witness to testify
regarding the application of the 2000 SDR/DDR License to improvements to DDR,
which include DDR2, and other products asserted by Rambus to be beyond the scope of
the license .

4. Jon Kang: Samsung may call Mr. Kang to testify regarding negotiations of the
2000 SDR/DDR License, the 2001 Amendment Number 1 to that License, industry
customs and practices in licensing as well as the business relationship between Rambus
and Samsung. .

5. Gil Young Heo: Samsung may call Mr. Heo to testify regarding Rambus’s audit
of Samsung’s royalties.

6. Joel Karp: Samsung may call Mr. Karp to testify as an adverse witness
regarding the documents he produced per the Court's May 7, 2008 Order.
Case 5:05-cv-00334-RMW Document 2086-2 Filed 08/27/2008 Page 2 of 2

7. David Mooring: Samsung may call Mr. Mooring to testify as an adverse witness
regarding Rambus’s licenses and licensing practices, license negotiations between
Samsung and Rambus.

8. Geoff Tate: Samsung may call Mr. Tate to testify as an adverse witness
regarding Rambus’s licenses and licensing practices, license negotiations between
Samsung and Rambus, and the license negotiations of the 2000 SDR/DDR License.

9. William Deley: Samsung may call Mr. Deley to testify as an adverse witness
regarding Rambus’s audit of Samsung's royalties.

10. Nigel Shepherd: Samsung may call Mr. Shepherd to testify as an adverse
witness regarding Rambus’s audit of Samsung's royalties.

11. Jared Smith: Samsung may call Mr. Smith to testify as an adverse witness
regarding Rambus’s licenses and licensing practices, and license negotiations between
Samsung and Rambus in 2004-2005.

12. John Danforth: Samsung may call Mr. Danforth to testify as an adverse witness
regarding Rambus’s licenses and licensing practices, and license negotiations between
Samsung and Rambus in 2004-2005

13. Ira Blumberg: Samsung may call Mr. Blumberg to testify as an adverse
witness regarding Rambus’s licenses and licensing practices, and license negotiations
between Samsung and Rambus in 2004-2005.

14. Harold Hughes: Samsung may call Mr. Hughes regarding Rambus’s licenses
and licensing practices.

15. Sean Cunningham: Samsung may call Mr. Cunningham to testify as an adverse
witness regarding Rambus’s anticipation of litigation against DRAM manufacturers.