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Case 5:05-cv-00334-RMW
1 2 3 4 5 6 7 8 9 10 11
Document 2324
Filed 09/30/2008
Page 1 of 6
GREGORY P. STONE (#78329) KEITH HAMILTON (#252115) MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071-1560 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 E-mail: [email protected]; [email protected] BURTON A. GROSS (#166285) CAROLYN HOECKER LUEDTKE (#207976) MIRIAM KIM (#238230) MUNGER, TOLLES & OLSON LLP 560 Mission Street, 27th Floor San Francisco, CA 94105-2907 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 E-mail: [email protected]; [email protected]; [email protected]
12 Attorneys for Plaintiff RAMBUS INC. 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 15 16
RAMBUS INC.,
17
Plaintiff,
18 19
CASE NO.: C 05-00334 RMW
vs. HYNIX SEMICONDUCTOR INC., et al.,
20
Defendants.
21 22
RAMBUS INC.,
23
26
Trial Date: September 22, 2008 Courtroom: 6 Judge: Hon. Ronald M. Whyte CASE NO.: C 05-02298 RMW
Plaintiff,
24 25
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JUNG-BAE LEE
vs. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants.
27 28 6029681.1
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JUNG-BAE LEE; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
1 2
Document 2324
Filed 09/30/2008
Page 2 of 6
Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the video clip of the testimony of Jung-Bae Lee played in Court on September 30, 2008.
3
The video clip was taken from the following deposition transcript:
4
Deposition of Jung-Bae Lee, taken on August 29, 2007, attached hereto as Exhibit A.
5
This Notice is being filed with the Court and will be appended to the official trial
6
transcripts and, pursuant to the parties’ agreement, will become part of the official trial transcript.
7 8
DATED: September 30, 2008
MUNGER, TOLLES & OLSON LLP
9 10 11
By:
/s/ Carolyn Hoecker Luedtke Carolyn Hoecker Luedtke
12
Attorneys for Plaintiff RAMBUS INC.
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6029681.1
-1-
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JUNG-BAE LEE; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
Document 2324
Filed 09/30/2008
Exhibit A
Page 3 of 6
Case 5:05-cv-00334-RMW
Document 2324
Filed 09/30/2008
Page 4 of 6
Video Testimony of Jung-Bae Lee (8/29/2007 Deposition) Played 9/30/2008
12: 9 Q. Are you here, Dr. Lee, as you understand 12:10 it testifying on behalf of all the Samsung entities 12:11 that I mentioned? 12:12 A. Yes. 14: 4 When you began doing DRAM design for 14: 5 Samsung in 1995, what product did you work on? 14: 6 A. From 1995 I joined as a DRAM design 14: 7 engineer for 256 MB synchronous DRAM design, and 14: 8 then from 1996 I was involved in the development of 14: 9 DDR synchronous DRAM design, and in 1997 I designed 14:10 DDR SGRAM. 14:11 And from 1999 -- 1999, yeah -- I studied 14:12 packing DDR2 synchronous DRAM. 14:13 Q. You started speccing DDR2? 14:14 A. Speccing DDR2. And I designed the 14:15 prototype of DDR2 in year 2000. 14:16 And between 2000 and 2002 I designed 14:17 network DRAM for network application, and from year 14:18 2003 I started speccing DDR3, and I designed DDR3 14:19 prototype in 2004 and 5. 14:20 And I am now with the advanced technology 14:21 development team. 117:18 MR. DETRE: Q. And when did Samsung begin 117:19 developing that first DDR SDRAM part? 117:20 A. Prototype was developed in 1997 timeframe, 117:21 and the first mass production part development 117:22 started from 1998 or 9. Okay. 144:10 Q. Okay. When did Samsung first start 144:11 designing a DDR2 SDRAM? 144:12 A. Started designing, your question is? 144:13 Q. Yes. 144:14 A. DDR2 design started inside Samsung in 144:15 1999, according to my memory. 144:16 Q. And did that original design start result 144:17 in a mass produced part? 144:20 144:21 144:22
THE WITNESS: No. MR. DETRE: Q. Why not? A. The JEDEC standard specification finalized
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Document 2324
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144:23 in year, around year 2002 or so, we made our part, 144:24 we designed our part and made prototype two already 144:25 compared to JEDEC 10 dot finalization. 145: 1 Q. So that original prototype that you made 145: 2 based on the 1999 design start didn't comply with 145: 3 the final JEDEC specification? 145: 4 A. Some part were implemented. But not fully 145: 5 compatible with JEDEC standard, final spec. 145: 6 Q. Do you recall in what way or ways that 145: 7 original prototype was not fully compatible with the 145: 8 JEDEC standard? 145:11 THE WITNESS: The only part which is not 145:12 compatible to the final JEDEC standard comes from on 145:13 die termination. 145:14 MR. DETRE: Q. Could you explain what on 145:15 die termination means? 145:16 A. On die termination is for the better 145:17 signal integrity on a data bus for DDR SDRAM. So 145:18 here what I mean with data burst is for separated 145:19 designated data bus for the data input and output, 145:20 including command and address. 145:21 So you know that for the better signal 145:22 integrity sometimes you need impedence matching 145:23 device on a bus. That was the convention up to DDR 145:24 synchronous DRAM era. 145:25 But for the higher operating frequency of 146: 1 the data bus, we need to take that terminator, 146: 2 terminate, termination device into our DRAM device, 146: 3 we put it on die termination. 163: 6 Q. Okay. When do you think you would have 163: 7 had the first prototype with the on die termination 163: 8 feature? 163: 9 A. So after finishing the system level 163:10 evaluation with IBM, the situation was changing in 163:11 the JEDEC committee. So reflecting that request, we 163:12 started with design of five Mb DDR2 SDRAM. 163:25 Q. So this is around the time that you 164: 1 started the design -164: 2 A. Not exactly, but around that timeframe. 164: 3 Q. Okay. And then about how long after this 164: 4 do you think you had the first prototypes? 164: 5 A. First prototype of 512 Mb -164: 6 Q. Yes.
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Document 2324
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164: 7 A. -- SDRAM? I don't know exact date. But 164: 8 maybe in the middle of year 2003 we had silicon from 164: 9 the 512 Mb DDR2 SDRAM.
Total Length - 00:06:44
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1 2 3 4 5 6 7 8 9 10 11
Document 2324
Filed 09/30/2008
Page 1 of 6
GREGORY P. STONE (#78329) KEITH HAMILTON (#252115) MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071-1560 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 E-mail: [email protected]; [email protected] BURTON A. GROSS (#166285) CAROLYN HOECKER LUEDTKE (#207976) MIRIAM KIM (#238230) MUNGER, TOLLES & OLSON LLP 560 Mission Street, 27th Floor San Francisco, CA 94105-2907 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 E-mail: [email protected]; [email protected]; [email protected]
12 Attorneys for Plaintiff RAMBUS INC. 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 15 16
RAMBUS INC.,
17
Plaintiff,
18 19
CASE NO.: C 05-00334 RMW
vs. HYNIX SEMICONDUCTOR INC., et al.,
20
Defendants.
21 22
RAMBUS INC.,
23
26
Trial Date: September 22, 2008 Courtroom: 6 Judge: Hon. Ronald M. Whyte CASE NO.: C 05-02298 RMW
Plaintiff,
24 25
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JUNG-BAE LEE
vs. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants.
27 28 6029681.1
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JUNG-BAE LEE; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
1 2
Document 2324
Filed 09/30/2008
Page 2 of 6
Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the video clip of the testimony of Jung-Bae Lee played in Court on September 30, 2008.
3
The video clip was taken from the following deposition transcript:
4
Deposition of Jung-Bae Lee, taken on August 29, 2007, attached hereto as Exhibit A.
5
This Notice is being filed with the Court and will be appended to the official trial
6
transcripts and, pursuant to the parties’ agreement, will become part of the official trial transcript.
7 8
DATED: September 30, 2008
MUNGER, TOLLES & OLSON LLP
9 10 11
By:
/s/ Carolyn Hoecker Luedtke Carolyn Hoecker Luedtke
12
Attorneys for Plaintiff RAMBUS INC.
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6029681.1
-1-
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JUNG-BAE LEE; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
Document 2324
Filed 09/30/2008
Exhibit A
Page 3 of 6
Case 5:05-cv-00334-RMW
Document 2324
Filed 09/30/2008
Page 4 of 6
Video Testimony of Jung-Bae Lee (8/29/2007 Deposition) Played 9/30/2008
12: 9 Q. Are you here, Dr. Lee, as you understand 12:10 it testifying on behalf of all the Samsung entities 12:11 that I mentioned? 12:12 A. Yes. 14: 4 When you began doing DRAM design for 14: 5 Samsung in 1995, what product did you work on? 14: 6 A. From 1995 I joined as a DRAM design 14: 7 engineer for 256 MB synchronous DRAM design, and 14: 8 then from 1996 I was involved in the development of 14: 9 DDR synchronous DRAM design, and in 1997 I designed 14:10 DDR SGRAM. 14:11 And from 1999 -- 1999, yeah -- I studied 14:12 packing DDR2 synchronous DRAM. 14:13 Q. You started speccing DDR2? 14:14 A. Speccing DDR2. And I designed the 14:15 prototype of DDR2 in year 2000. 14:16 And between 2000 and 2002 I designed 14:17 network DRAM for network application, and from year 14:18 2003 I started speccing DDR3, and I designed DDR3 14:19 prototype in 2004 and 5. 14:20 And I am now with the advanced technology 14:21 development team. 117:18 MR. DETRE: Q. And when did Samsung begin 117:19 developing that first DDR SDRAM part? 117:20 A. Prototype was developed in 1997 timeframe, 117:21 and the first mass production part development 117:22 started from 1998 or 9. Okay. 144:10 Q. Okay. When did Samsung first start 144:11 designing a DDR2 SDRAM? 144:12 A. Started designing, your question is? 144:13 Q. Yes. 144:14 A. DDR2 design started inside Samsung in 144:15 1999, according to my memory. 144:16 Q. And did that original design start result 144:17 in a mass produced part? 144:20 144:21 144:22
THE WITNESS: No. MR. DETRE: Q. Why not? A. The JEDEC standard specification finalized
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Document 2324
Filed 09/30/2008
Page 5 of 6
144:23 in year, around year 2002 or so, we made our part, 144:24 we designed our part and made prototype two already 144:25 compared to JEDEC 10 dot finalization. 145: 1 Q. So that original prototype that you made 145: 2 based on the 1999 design start didn't comply with 145: 3 the final JEDEC specification? 145: 4 A. Some part were implemented. But not fully 145: 5 compatible with JEDEC standard, final spec. 145: 6 Q. Do you recall in what way or ways that 145: 7 original prototype was not fully compatible with the 145: 8 JEDEC standard? 145:11 THE WITNESS: The only part which is not 145:12 compatible to the final JEDEC standard comes from on 145:13 die termination. 145:14 MR. DETRE: Q. Could you explain what on 145:15 die termination means? 145:16 A. On die termination is for the better 145:17 signal integrity on a data bus for DDR SDRAM. So 145:18 here what I mean with data burst is for separated 145:19 designated data bus for the data input and output, 145:20 including command and address. 145:21 So you know that for the better signal 145:22 integrity sometimes you need impedence matching 145:23 device on a bus. That was the convention up to DDR 145:24 synchronous DRAM era. 145:25 But for the higher operating frequency of 146: 1 the data bus, we need to take that terminator, 146: 2 terminate, termination device into our DRAM device, 146: 3 we put it on die termination. 163: 6 Q. Okay. When do you think you would have 163: 7 had the first prototype with the on die termination 163: 8 feature? 163: 9 A. So after finishing the system level 163:10 evaluation with IBM, the situation was changing in 163:11 the JEDEC committee. So reflecting that request, we 163:12 started with design of five Mb DDR2 SDRAM. 163:25 Q. So this is around the time that you 164: 1 started the design -164: 2 A. Not exactly, but around that timeframe. 164: 3 Q. Okay. And then about how long after this 164: 4 do you think you had the first prototypes? 164: 5 A. First prototype of 512 Mb -164: 6 Q. Yes.
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Case 5:05-cv-00334-RMW
Document 2324
Filed 09/30/2008
Page 6 of 6
164: 7 A. -- SDRAM? I don't know exact date. But 164: 8 maybe in the middle of year 2003 we had silicon from 164: 9 the 512 Mb DDR2 SDRAM.
Total Length - 00:06:44
V106
3
