Class Actions are pending against certain manufacturers of DRAM. In the Class Actions, plaintiffs allege that defendants unlawfully agreed to fix, raise, maintain and stabilize the prices of DRAM and/or to allocate among themselves major customers and accounts in violation of the federal antitrust laws during the period of April 1, 1999 through June 30, 2002. Plaintiffs allege that, as a result of defendants' unlawful conduct, they and members of the Class paid more for DRAM than they would have in the absence of defendants' wrongful conduct. Defendants deny plaintiffs' allegations and have asserted numerous affirmative defenses. On June 5, 2006, the Court certified the Class described above.

This notice is given pursuant to the Federal Rules of Procedure and an Order of the United States District Court for the Northern District of California to inform Class Members that, in exchange for the release of claims by Settlement Class members against the defendants who have settled, four separate proposed settlements have been reached with defendants: (i) Elpida Memory, Inc. and Elpida Memory (USA) Inc.; (ii) NEC Electronics America, Inc.; (iii) Winbond Electronics Corporation and Winbond Electronics Corporation America; and (iv) Micron Technology, Inc. and Micron Semiconductor Products, Inc. through its Crucial Technology division for a total of 143,247,000. For a list of other defendants in this Action, please see the Notice.

A hearing will be held on April 18, 2007 in San Francisco, California, to determine whether each of the proposed settlements is fair, adequate and reasonable to the Class, and whether, therefore, this litigation should be dismissed with prejudice against each of the Settling Defendants.

These are the second group of settlements reached in this litigation, which will continue against the remaining defendants. The Court has granted final approval of the first group of settlements with (i) Infineon Technologies AG and Infineon Technologies North America Corp.; (ii) Samsung Semiconductor, Inc.; and (iii) Hynix Semiconductor Inc. and Hynix Semiconductor America, Inc.

The settlement funds will be distributed at a later date, and therefore no claim forms are to be submitted at this time.

You do not need to do anything at this time to remain in the Class. If you change your address, or if the Notice was not mailed to your correct address, you should immediately provide your correct address in writing to the Class Administrator at the address listed below.

Members of the Class will be entitled to receive money from the settlement fund when it is ultimately distributed. At final approval, Class Counsel and Plaintiffs will ask the Court to approve a plan of allocation and distribution of the Net Settlement Fund on a pro rata basis among Class members based on the dollar amount each Class member paid to Defendants for direct purchases of DRAM from the Defendants during the period of April 1, 1999 through June 30, 2002. If you did not exclude yourself from the Class or have otherwise settled or released Defendants, there is not another opportunity to request exclusion from the Class. If you want to object to any or all of the settlements, you must file a written objection not later than March 26, 2007.

A more detailed description of this litigation, the proposed settlements and your rights as a Class Member is contained in the Notice of Pendency of Class Action and Partial Class Action Settlements (the "Notice").

Questions concerning the matters contained herein should be directed to the following Class Counsel: