In SK hynix Inc. v. Rambus Inc., No. 00-20905 (N.D. Cal. May 8, 2013), the court awarded sanctions against Rambus in this long-running patent litigation in which Rambus had previously won a judgment of $349 million against SK hynix. The trial court had found no spoliation in the proceedings leading up to that verdict but, on appeal, the Federal Circuit vacated that finding and remanded for proceedings on spoliation, but otherwise affirming the $349 million judgment. On remand, the trial court held that the proper sanction before trial would have been to exclude Rambus’s evidence in support of an increased royalty rate but given the posture of the case, “trying to fashion an after-the-fact evidentiary exclusion is not the most appropriate mechanism.” The court instead imposed a monetary sanction of $250 million as a credit against the judgment, calculated so as to reduce the judgment to the amount that would have applied if Rambus had been precluded from arguing for the increased royalty rates.