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To: Earlie who wrote (81123)	3/15/2001 7:05:41 PM
From: Ilaine	Read Replies (3) \| Respond to of 436258

Earlie, just for you I did a little extra. The people being deposed about matters which would ordinarily be within the attorney client privilege include Geoffrey Tate, the Rambus CEO; Neil Steinberg, VP for Intellectual Property, and a lawyer who specializes in intellectual property; Anthony Diepenbrock, an attorney who specializes in intellectual property who works for Townsend, Townsend and Crew; Richard Crisp, who is involved in chip design; and a Mr. Vincent, who is a lawyer and was working with Diepenbrock; and a Mr. Mitchell, whose role doesn't pop up on a google search. So that resolves the question of whether the lawyers are part of the litigation team, they aren't. So that means that Infineon is not just trying to disqualify the litigators, there's more to it. It has to do with disclosures Rambus made to JEDEC and IEEE, and to its shareholders at the 2000 shareholder's meeting, and attempts by Rambus to broaden its patents to cover matters within JEDEC standards, which is all stuff you probably understand better than I do.