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Case 5:05-cv-00334-RMW
1 2 3 4 5 6 7 8 9 10 11
Document 2326
Filed 09/30/2008
Page 1 of 5
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 JIN SEUNG PARK
vs. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants.
27 28 6029750.1
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JIN SEUNG PARK; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
1 2
Document 2326
Filed 09/30/2008
Page 2 of 5
Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the video clips of the testimony of Jin Seung Park played in Court on September 30, 2008.
3
The video clips were taken from the following deposition transcripts:
4
Deposition of Jin Seung Park, taken on July 28 & 30, 2008, 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 6029750.1
-1-
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JIN SEUNG PARK; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
Document 2326
Filed 09/30/2008
Exhibit A
Page 3 of 5
Case 5:05-cv-00334-RMW
Document 2326
Filed 09/30/2008
Page 4 of 5
Video Testimony of Jin Seung Park (7/28/2008 Deposition) Played 9/30/2008
21:24 21:25 22: 1 22: 2 22: 3 22: 4 22: 5 22: 6 22: 7 22: 8 22: 9 22:10 22:11 22:12 22:13 22:14 22:15 22:16 22:17 22:18 22:19
Q. Topic 3, "Communication to Samsung employees regarding the retention, preservation, or destruction of documents, electronically stored information, or any other materials related to actual or potential litigation with Rambus from 1996 to the present." Mr. Park, what did you do to determine if any communications referred to in Topic 3 occurred? A. For starters, with respect to the pre-2005 time frame, that is before the suit from Rambus, the company had actually no expectation that we'd be sued by Rambus, and, therefore, there isn't any material pertaining to that period of time. But after 2005, specifically after June of 2005, once we were served with the suit by Rambus, the folks within IP legal have a procedure whereby which once there is litigation, they send out an official communique to relevant people that everything be maintained and preserved on hand. And with respect to that kind of communication, that is what I looked into.
25:22 Did the four Samsung entities take any 25:23 actions in the year 2000 to retain or preserve 25:24 documents, electronically stored information, or any 25:25 other materials related to actual or potential 26: 1 litigation with Rambus? 26: 6 THE WITNESS: When you say in 2000, you 26: 7 mean, the year 2000? 26:10
A. Then, no.
27: 6 Q. When did the Samsung entities issue their 27: 7 first litigation hold notice related to Rambus? 27:10 THE WITNESS: Based upon my investigation, 27:11 that would be immediately after the suit. But if 27:12 you have any relevant documents, I can look at them 27:13 and answer you better.
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Case 5:05-cv-00334-RMW
Document 2326
Filed 09/30/2008
Page 5 of 5
Video Testimony of Jin Seung Park (7/30/2008 Deposition) Played 9/30/2008 164:19 164:20 164:21 164:22 164:23 164:24 164:25 165: 1 165: 2
Q. Is Exhibit 9339 a complete list of all of the recipients that received any preservation notice from Samsung relating to actual or potential Rambus litigation? A. Well, efforts were made not to leave anybody out. So I would believe that everybody has been included. Q. Who prepared Exhibit 9339? A. It was done by the legal team.
Total Length - 00:03:45
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1 2 3 4 5 6 7 8 9 10 11
Document 2326
Filed 09/30/2008
Page 1 of 5
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 JIN SEUNG PARK
vs. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants.
27 28 6029750.1
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JIN SEUNG PARK; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
1 2
Document 2326
Filed 09/30/2008
Page 2 of 5
Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the video clips of the testimony of Jin Seung Park played in Court on September 30, 2008.
3
The video clips were taken from the following deposition transcripts:
4
Deposition of Jin Seung Park, taken on July 28 & 30, 2008, 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 6029750.1
-1-
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT OF VIDEO TESTIMONY OF JIN SEUNG PARK; CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW
Document 2326
Filed 09/30/2008
Exhibit A
Page 3 of 5
Case 5:05-cv-00334-RMW
Document 2326
Filed 09/30/2008
Page 4 of 5
Video Testimony of Jin Seung Park (7/28/2008 Deposition) Played 9/30/2008
21:24 21:25 22: 1 22: 2 22: 3 22: 4 22: 5 22: 6 22: 7 22: 8 22: 9 22:10 22:11 22:12 22:13 22:14 22:15 22:16 22:17 22:18 22:19
Q. Topic 3, "Communication to Samsung employees regarding the retention, preservation, or destruction of documents, electronically stored information, or any other materials related to actual or potential litigation with Rambus from 1996 to the present." Mr. Park, what did you do to determine if any communications referred to in Topic 3 occurred? A. For starters, with respect to the pre-2005 time frame, that is before the suit from Rambus, the company had actually no expectation that we'd be sued by Rambus, and, therefore, there isn't any material pertaining to that period of time. But after 2005, specifically after June of 2005, once we were served with the suit by Rambus, the folks within IP legal have a procedure whereby which once there is litigation, they send out an official communique to relevant people that everything be maintained and preserved on hand. And with respect to that kind of communication, that is what I looked into.
25:22 Did the four Samsung entities take any 25:23 actions in the year 2000 to retain or preserve 25:24 documents, electronically stored information, or any 25:25 other materials related to actual or potential 26: 1 litigation with Rambus? 26: 6 THE WITNESS: When you say in 2000, you 26: 7 mean, the year 2000? 26:10
A. Then, no.
27: 6 Q. When did the Samsung entities issue their 27: 7 first litigation hold notice related to Rambus? 27:10 THE WITNESS: Based upon my investigation, 27:11 that would be immediately after the suit. But if 27:12 you have any relevant documents, I can look at them 27:13 and answer you better.
V108
1
Case 5:05-cv-00334-RMW
Document 2326
Filed 09/30/2008
Page 5 of 5
Video Testimony of Jin Seung Park (7/30/2008 Deposition) Played 9/30/2008 164:19 164:20 164:21 164:22 164:23 164:24 164:25 165: 1 165: 2
Q. Is Exhibit 9339 a complete list of all of the recipients that received any preservation notice from Samsung relating to actual or potential Rambus litigation? A. Well, efforts were made not to leave anybody out. So I would believe that everybody has been included. Q. Who prepared Exhibit 9339? A. It was done by the legal team.
Total Length - 00:03:45
V108
2
