May 13, 2011-  The Federal District Court of Appeals affirmed a lower court’s ruling that Rambus improperly destroyed documents relevant to litigation against Micron and Hynix.  The court determined that Rambus had violated its duty to preserve evidence given that litigation was “reasonably forseeable” at the time the documents were detroyed.  The documents were destroyed at a Rambus “shred party” in 1999.  The court cited several Rambus-internal communications that demonstrated that the company was preparing for litigation at the time of the shred party.