EXHIBIT C

CONDITIONALLY LODGED UNDER SEAL

1 SUSMAN GODFREY LLP Marc M. Seltzer (54534) 2 mseltzer@susmangodfrey.com David H. Orozco (220732) 3 dorozco@susmangodfrey.com Kathryn P. Hoek (219247) 4 khoek@susmangodfrey.com Kalpana Srinivasan (237460) 5 ksrinivasan@susmangodfrey.com 1901 Avenue of the Stars, Suite 950 6 Los Angeles, California 90067-6029 Telephone: (310) 789-3100 7 Facsimile: (310) 789-3150 8 IRELL & MANELLA LLP Morgan Chu (70446) 9 mchu@irell.com Charles E. Elder (186524) 10 celder@irell.com 1800 Avenue of the Stars, Suite 900 11 Los Angeles, California 90067-4276 Telephone: (310) 277-1010 12 Facsimile: (310) 203-7199 13 Attorneys for Plaintiff Tessera Technologies, Inc. 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 FOR THE COUNTY OF SANTA CLARA 16 17 TESSERA TECHNOLOGIES, INC., 18 a Delaware corporation, 19 20 21 22 23 24 25 26 27 ) ) ) Plaintiff, ) ) ) vs. ) ) ) HYNIX SEMICONDUCTOR, INC., a Korean ) corporation; and HYNIX SEMICONDUCTOR ) AMERICA, INC., a California corporation, ) ) Defendants. ) ) ) ) Case No. 1-06-CV-076688 DECLARATION OF RON MALTIEL IN SUPPORT OF TESSERAS OPPOSITIONS TO HYNIXS MOTIONS FOR SUMMARY ADJUDICATION Date: August 28, 2009 Time: 9:00 am Judge: Honorable Jack Komar Dept.: 17C Complaint Filed: Trial Date: December 18, 2006 Not Set

DECLARATION OF RON MALTIEL IN SUPPORT OF TESSERAS OPPOSITIONS TO HYNIXS MOTIONS FOR SUMMARY ADJUDICATION 963731v1/010187

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I, Ron Maltiel, declare: 1. I am a semiconductor expert with more than 20 years experience in all phases of

3 design, process implementation, and consulting in semiconductor processes, devices, and circuits. 4 I have worked in the semiconductor field in the development and production of various product 5 types such as Dynamic Ram Memory (DRAM), Flash Memory, and Static Ram Memory (SRAM) 6 used for microprocessor and logic, digital, and analog devices. 7 2. I hold more than half a dozen patents that have been cited more than 100 times.

8 These patents cover varied areas of semiconductor device, circuit, process, and measurements. I 9 have studied semiconductors at Stanford University. I also have developed new semiconductor 10 processes and devices at Intel, AMI, Advanced Micro Devices (AMD), and Maxim Integrated 11 Products. I have served as an expert consultant and witness in close to twenty U.S. and

12 international patent cases. 13 3. Computers have at least two types of memory that are used to store system setup

14 information and user data: 15 (a) DRAM memory which is fast and volatile memory. DRAM memory will

16 retain the information as long as the computer is connected to electrical power. 17 (b) Hard Drive memory which is slow and a more permanent memory. Hard

18 Drive memory does not lose information when the computers power is turned off. 19 4. The DRAM industry tends to propagate a single mainstream memory solution at

20 any point in time i.e. the largest volume memory product being sold. This is driven by the eco21 system of new technology products. For example, computer vendors design the next generation of 22 computers around the future generation memory products that will become mainstream. 23 5. A single mainstream memory supported by most semiconductor companies enables

24 faster computer development. 25 6. When the semiconductor industry develops the next generation of DRAM chips,

26 they look for the product most likely to be in high demand. The development effort of the 27 1
DECLARATION OF RON MALTIEL IN SUPPORT OF TESSERAS OPPOSITIONS TO HYNIXS MOTIONS FOR SUMMARY ADJUDICATION
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1 semiconductor companies is shortened and simplified by having to develop just one product that 2 will be widely used. 3 7. The broadly accepted memory chip increases production volume of the DRAM.

4 The large production volume, in turn, accelerates advances in manufacturing and sharply reduces 5 the cost of chip production. 6 8. The experience gained in increased production leads to expedited development of

7 higher performance DRAMs with superior manufacturing yields. Greater production improves 8 understanding of the technology sensitivities and the factors affecting the yield of that memory 9 product. Both substantially drive down costs. 10 9. Once a memory solution is established, the industry stays with that solution until

11 something significantly better comes along because of the development costs and the time it 12 would take to develop and implement the new technology. 13 10. Intel, as a large seller of chipsets and microprocessors, plays a critical role in the

14 choice of the next mainstream memory solution for microprocessors. 15 11. Original Equipment Manufacturers (OEMs), including the nations major PC

16 makers, incorporate Intels microprocessors in their computer products that require memory. 17 12. Because of the wide acceptance of Intel microprocessors, OEM manufacturers

18 demand memory chips that are compatible with Intel microprocessors. Consequently, memory 19 manufacturers, seeking to make sales to these OEM manufacturers have a compelling incentive to 20 build chips based on the memory technology that Intel chooses. 21 22 13. 14. In the 1990s, Rambus introduced its RDRAM memory technology. RDRAM had the benefits of superior bandwidth, which improves overall computer

23 performance, and higher granularity, which increases flexibility in the cost of the computer 24 system. In addition, RDRAM chips were already used in production by Nintendo 64, which 25 meant the memory had already started to prove itself among electronic product manufacturers. 26 27 28 2
DECLARATION OF RON MALTIEL IN SUPPORT OF TESSERAS OPPOSITIONS TO HYNIXS MOTIONS FOR SUMMARY ADJUDICATION

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RON MALTIEL
19743 Yuba Court, Saratoga, CA 95070 408.446.3040 E mail: ron@maltiel-consulting.com Web site: www.maltiel-consulting.com

PROFFESIONAL SUMMARY:
Mr. Maltiel has more than 20 years experience in all phases of design and implementation of semiconductor processes and devices. He has worked in the semiconductor field in the development and production of storage technology and storage devices such as Dynamic Ram (DRAM), Flash (NAND, NOR, EEPROM, SSD or HDD), and Static RAM (SRAM) memories used for microprocessors and logic, digital, and analog devices. Ron holds more than half a dozen patents that have been cited more than 100 times. His patents cover varied areas of semiconductor device, process, and measurements. Ron studied semiconductors at Stanford University graduate school and developed new semiconductor processes and devices at Intel, AMI, AMD, and Maxim. He is experienced in supporting patent and trade secret litigation. He is also fluent in Hebrew. He operates a website that is viewed as a major source of information pertaining to semiconductor technology and patents. The website addresses the information needs of technology companies, attorneys, and investors. .

EXPERTISE:
Circuit and Process Development: Analog processes DRAM processes SRAM processes Flash / EEPROM processes pMOS, nMOS, and CMOS process High voltage BICMOS process Process Steps Development: Process flow design Gate and polysilicon oxidation steps Cleaning steps Etching, deposition and planarization process steps Plasma and Trench etching steps Wafer gettering methods Transistors/ resistors/capacitors/JFET in pMOS, nMOS, CMOS, and BICMOS processes Polysilicon - polysilicon capacitors PNP and NPN transistors

Test Chip Development: Created a library of test chip structures for process, ESD circuits, design rules, and device evaluation using GDS tools. Measured test structures and evaluated their device properties.

Devices Development: DRAM memory cells SRAM memory cells Flash / EEPROM memory cells Precision resistors and capacitors

Litigation and Patent Support: Was deposed and testified in trial Wrote and received several patents for development work Developed a trade secret violation list Wrote expert reports and served as an expert witness for patent litigation Wrote several declarations regarding patent infringements Search and analyze patent infringement and validity

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RON MALTIEL
SEMICONDUCTOR CONSULTANT 1993 - present Consulting in various aspects of semiconductor technology and semiconductor manufacturing including Expert technical consultations in ITC and Civil litigation. Design and operate a popular semiconductor technology web site that is regularly viewed in more than 50 countries by major technology companies and universities. The site includes many articles discussing current developments in the DRAM, Flash (NAND, NOR, SSD or HDD), SRAM, and in other aspects of digital and analog fields. The site includes tutorials and educational information, industry news and resources, acronym and technical word definitions, and patent search or patent application information. MAXIM INTEGRATED PRODUCTS 1989 - 1993 Personally developed a high voltage BICMOS process, introduced it to production, and proved the feasibility of adding an EEPROM element to it. Established MAXIM processes in a newly purchased fab, developed the companys newest analog process, installed MAXIMs production process in a new foundry, and managed the relationship. ADVANCED MICRO DEVICES 1983 -1989 Managed consolidation of test chip development through the building of a company-wide standard test chip library. As a direct result of this project, the time needed to build test chips was reduced by 60%, structures were improved, and test program generation was accelerated. Contributed to development of 256k SRAM, including process flow, a backend planarization scheme, and overseeing the building of generic test chip library. Participated in defining 1M CMOS DRAM process and proved feasibility of integrating trenches in the process. Coordinated the development of post groove planarization process and double poly module. The project ended successfully with a working first silicon. Developed and proved feasibility of integrating EEPROM with DRAM CMOS process and devices. Reduced cell size by 40%, process steps by 15%, and improved EEPROM programming operation. AMERICAN MICROSYSTEMS, INC. 1982 - 1983 Introduced and established the EEPROM process. Directed the design of the test chip, process flow determination, manufacture of several working runs and measurement of the electrical parameters. Created a new process approach that improves poly dielectric strength and founded a new cell structure with multiple benefits over existing cells. INTEL 1980 - 1982 Participated in the development of EEPROM technology with particular emphasis on the process reliability aspects such as charge retention and cycling endurance. Work involved the study of failure mechanisms, making the necessary process changes, and evaluating the results. Regular interaction with fab and technology development was required. Improved operator utilization by 20%. STANFORD UNIVERSITY 1978 - 1980 E.E. research group on metallic impurities and their electrical behaviors. Independent research included manufacturing of Si devices and electrical measurements of their properties.

EDUCATION: Stanford University

Engineer Degree: Material Science Engineering - 1980 Master Degree: Material Science and Engineering - 1978

Ben-Gurion University
BS: Material Science and Engineering - 1977

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RON MALTIEL
PATENTS
(Cited more than 100 times )

Using the Ctrl key together with clicking on any of the patents will download the patent

Electrical measurements of profile of semiconductor devices during their manufacturing process - #4,978,923 Method and apparatus for non-destructive data in a shadow memory array - #4,716,552 Electrical measurements of properties of semiconductor devices during their manufacturing process - # 4,956,611

Memory cell providing simultaneous non-destructive access to volatile and non-volatile data - #4,672,580 Non-volatile dynamic ram cell - #4,611,309 Gold-doped IC resistor region - #4,432,008

PROFFESIONAL AFFILITIONS:
IEEE Senior Member IEEE Device Society IEEE Circuits Society IEEE Communications Society IEEE - CNSV: Consultants' Network of Silicon Valley IEEE-USA Consultants Database Jewish High Tech

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