Crucial 2012 Annual Report Download - page 22

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ITEM 2. PROPERTIES
Our corporate headquarters are located in Boise, Idaho. The following is a summary of our principal facilities as of August
30, 2012:
Location Principal Operations
Boise, Idaho R&D, including wafer fabrication; reticle manufacturing; test and module assembly
Lehi, Utah Wafer fabrication
Manassas, Virginia Wafer fabrication
Singapore Three wafer fabrication facilities and a test, assembly and module assembly facility
Avezzano, Italy Wafer fabrication
Aguadilla, Puerto Rico Module assembly and test
Xi’an, China Module assembly and test
Kiryat Gat, Israel Wafer fabrication
Muar, Malaysia Assembly and test
Agrate, Italy R&D, including wafer fabrication
We also own and lease a number of other facilities in locations throughout the world that are used for design, research and
development, and sales and marketing activities.
Our facility in Lehi is owned and operated by our IMFT joint venture with Intel. (See "Item 8. Financial Statements and
Supplementary Data – Notes to Consolidated Financial Statements – Consolidated Variable Interest Entities – IM Flash" note.)
We believe that our existing facilities are suitable and adequate for our present purposes. We do not identify or allocate
assets by operating segment. (See "Item 8. Financial Statements and Supplementary Data – Notes to Consolidated Financial
Statements – Geographic Information" note.)
ITEM 3. LEGAL PROCEEDINGS
Patent Matters
On August 28, 2000, we filed a complaint against Rambus in the U.S. District Court for the District of Delaware seeking
declaratory and injunctive relief. Among other things, our complaint (as amended) alleges violation of federal antitrust laws,
breach of contract, fraud, deceptive trade practices, and negligent misrepresentation. The complaint also seeks a declaratory
judgment (1) that we did not infringe on certain of Rambus' patents or that such patents are invalid and/or are unenforceable,
(2) that we have an implied license to those patents, and (3) that Rambus is estopped from enforcing those patents against us.
On February 15, 2001, Rambus filed an answer and counterclaim in Delaware denying that we are entitled to relief, alleging
infringement of the eight Rambus patents (later amended to add four additional patents) named in our declaratory judgment
claim, and seeking monetary damages and injunctive relief. In the Delaware action, we subsequently added claims and
defenses based on Rambus' alleged spoliation of evidence and litigation misconduct. The spoliation and litigation misconduct
claims and defenses were heard in a bench trial before Judge Robinson in October 2007. On January 9, 2009, Judge Robinson
entered an opinion in our favor holding that Rambus had engaged in spoliation and that the twelve Rambus patents in the suit
were unenforceable against us. Rambus subsequently appealed the decision to the U.S. Court of Appeals for the Federal
Circuit. On May 13, 2011, the Federal Circuit affirmed Judge Robinson's finding of spoliation, but vacated the dismissal
sanction and remanded the case to the Delaware District Court for further analysis of the appropriate remedy. On January 13,
2006, Rambus filed a lawsuit against us in the U.S. District Court for the Northern District of California. Rambus alleges that
certain of our DDR2, DDR3, RLDRAM, and RLDRAM II products infringe as many as fourteen Rambus patents and seeks
monetary damages, treble damages and injunctive relief. The accused products account for a significant portion of our net sales.
On June 2, 2006, we filed an answer and counterclaim against Rambus alleging, among other things, antitrust and fraud claims.
The Northern District of California Court stayed the trial of the patent phase of the Northern District of California case upon
appeal of the Delaware spoliation issue to the Federal Circuit.