Less than a week after a San Jose, Calif., federal judge slashed Rambus' $306 million award in its patent infringement case against Hynix Semiconductor Inc., another federal judge in Virginia piled on, criticizing the Los Altos, Calif., chip manufacturer's outside counsel. In a searing 116-page opinion issued July 18, U.S. District Judge Robert Payne attacked Rambus' legal tactics in past patent cases against Samsung Electrics Co. and German chip company Infineon Technologies AG. The judge also discounted explanations of Rambus' conduct provided by IP litigator Daniel Johnson Jr. Johnson -- now a partner at Morgan, Lewis & Bockius -- advised Rambus in the late 1990s as a lawyer at Cooley Godward. Payne also criticized -- respectfully -- his San Jose judicial colleague Ronald Whyte, who had come to a different conclusion about Rambus' shredding of documents than Payne.