Case 5:05-cv-00334-RMW Document 2326 Filed 09/30/2008 Page 1 of 5

1 GREGORY P. STONE (#78329)

KEITH HAMILTON (#252115)
2 MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue, 35th Floor
3 Los Angeles, CA 90071-1560
Telephone: (213) 683-9100
4 Facsimile: (213) 687-3702
E-mail: gregory.stone@mto.com;
5 keith.hamilton@mto.com
6 BURTON A. GROSS (#166285)
CAROLYN HOECKER LUEDTKE (#207976)
7 MIRIAM KIM (#238230)
MUNGER, TOLLES & OLSON LLP
8 560 Mission Street, 27th Floor
San Francisco, CA 94105-2907
9 Telephone: (415) 512-4000
Facsimile: (415) 512-4077
10 E-mail: burton.gross@mto.com;
carolyn.luedtke@mto.com;
11 miriam.kim@mto.com
12
Attorneys for Plaintiff RAMBUS INC.
13
UNITED STATES DISTRICT COURT
14
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
15

16 RAMBUS INC., CASE NO.: C 05-00334 RMW

17 Plaintiff, RAMBUS’S NOTICE OF LODGING OF
TRANSCRIPT OF VIDEO TESTIMONY
18 vs. OF JIN SEUNG PARK
19 HYNIX SEMICONDUCTOR INC., et al.,
20 Defendants. Trial Date: September 22, 2008
Courtroom: 6
21 Judge: Hon. Ronald M. Whyte
22 RAMBUS INC., CASE NO.: C 05-02298 RMW
23 Plaintiff,
24 vs.
25 SAMSUNG ELECTRONICS CO., LTD.,
et al.,
26
Defendants.
27

28
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT
6029750.1 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 Page 2 of 5

1 Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the
2 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
RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT
6029750.1 -1- 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 Page 3 of 5

Exhibit A
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 Q. Topic 3, "Communication to Samsung

21:25 employees regarding the retention, preservation, or
22: 1 destruction of documents, electronically stored
22: 2 information, or any other materials related to
22: 3 actual or potential litigation with Rambus from 1996
22: 4 to the present."
22: 5 Mr. Park, what did you do to determine if any
22: 6 communications referred to in Topic 3 occurred?
22: 7 A. For starters, with respect to the pre-2005
22: 8 time frame, that is before the suit from Rambus, the
22: 9 company had actually no expectation that we'd be
22:10 sued by Rambus, and, therefore, there isn't any
22:11 material pertaining to that period of time.
22:12 But after 2005, specifically after June of
22:13 2005, once we were served with the suit by Rambus,
22:14 the folks within IP legal have a procedure whereby
22:15 which once there is litigation, they send out an
22:16 official communique to relevant people that
22:17 everything be maintained and preserved on hand. And
22:18 with respect to that kind of communication, that is
22:19 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 Q. Is Exhibit 9339 a complete list of all of

164:20 the recipients that received any preservation notice
164:21 from Samsung relating to actual or potential Rambus
164:22 litigation?
164:23 A. Well, efforts were made not to leave
164:24 anybody out. So I would believe that everybody has
164:25 been included.
165: 1 Q. Who prepared Exhibit 9339?
165: 2 A. It was done by the legal team.

Total Length - 00:03:45

V108 2