Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1382

Unredacted Exhibits to Arnold Declaration ISO Samsung's MSJ ( by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company) re 1256 Order on Administrative Motion to File Under Seal, (Dkt. Nos. 930, 944, 945) (Attachments: # 1 Exhibit 20 to Arnold, # 2 Exhibit 23 to Arnold, # 3 Exhibit 31 to Arnold, # 4 Exhibit 36 to Arnold, # 5 Exhibit 38 to Arnold, # 6 Exhibit 39 to Arnold, # 7 Exhibit 40 to Arnold, # 8 Exhibit 41 to Arnold, # 9 Exhibit 42 to Arnold, # 10 Exhibit 43 to Arnold, # 11 Exhibit 44 to Arnold)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

EXHIBIT 20

In The Matter Of:
APPLE,ȱINC.,
v.
SAMSUNGȱELECTRONICSȱCO.,ȱLTD.,ȱetȱal.,
ȱȱȱ___________________________________________________

SUNGYUBȱLEEȱȬȱVol.ȱ1
Marchȱ8,ȱ2012
ȱȱȱ___________________________________________________
ȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱȱ

CONFIDENTIAL ATTORNEYS' EYES ONLY

CONFIDENTIAL ATTORNEYS' EYES ONLY
SUNGYUB LEE - 3/8/2012
Page 7
1

Raise your right hand for me, please.

2

Do you each of you solemnly swear or affirm

3

that the testimony you're about to interpret today,

4

English to Korean, Korean to English, you will do so to

5

the best of your ability today?

6

MR. KIM:

Yes.

7

MS. KIM:

Yes.

8

COURT REPORTER:

Thank you.

9
10
11

PHYLLIS KIM,

12

HAVING BEEN FIRST DULY SWORN BY THE COURT REPORTER

13

TO INTERPRET ENGLISH TO KOREAN,

14

KOREAN TO ENGLISH TO THE BEST OF HER ABILITY,

15

INTERPRETED THE FOLLOWING PROCEEDINGS:

16
17
18

ALBERT KIM,
HAVING BEEN FIRST DULY SWORN BY THE COURT REPORTER

19

TO INTERPRET ENGLISH TO KOREAN,

20

KOREAN TO ENGLISH TO THE BEST OF HIS ABILITY,

21

CHECK INTERPRETED THE FOLLOWING PROCEEDINGS:

22
23
24
16:53:20

25

617-542-0039

COURT REPORTER:

Raise your right hand for me,

please.
Do you solemnly swear or affirm that the

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testimony you're about to give today will be the truth,

2

the whole truth, and nothing but the truth?

3
4
16:53:36

THE WITNESS:

COURT REPORTER:

5

MS. NEILL:

6

Yes.
Please begin.

First, I just wanted to read for

the record the following statement:

7

We understand the court reporter is not

8
9

nevertheless, we request she administer the oath, and we

10

stipulate that we waive any objection to the validity of

11

16:53:45

authorized to administer oath in this venue;

the deposition based on the oaths.

12

Does counsel for Apple agree?

13

MR. AHN:

So agreed.

14
15
16

SUNGYUB LEE,

17

30(B)(6) WITNESS OF BLUEBIRD SOFT, INC.,

18

HAVING BEEN FIRST DULY SWORN BY THE COURT REPORTER,

19

WAS EXAMINED AND TESTIFIED AS FOLLOWS:

20
21

DIRECT EXAMINATION

22
23

BY MS. NEILL:

24
16:54:15

Q

Good afternoon, Mr. Lee.

25

A

Good afternoon.

617-542-0039

Nice to meet you.

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Q

Nice to meet you.

I just wanted to explain a

2

I'm going to -- I'm

3

going to ask you some questions.

Mr. Ahn may object to

4
16:54:38

little bit about the deposition.

my questions.

5

answer my question.

If he does object, you should still

6

A

I understand.

7

Q

Okay.

8

And when I'm done, Mr. Ahn may have some

questions for you.

9
16:54:55

A

Yes.

10

Q

And I may object, and you would still answer

11
12

the question.
A

13
14
16:55:21

MR. AHN:

17
18

Just for the record, I note that I'm

not here representing the witness.

15
16

Yes, I understand.

MS. NEILL:

Neither am I.

BY MS. NEILL:
Q

Also if you need a break at any point, please

let us know.

19
16:55:28

A

Yes.

20

Q

Do you understand that Apple and Samsung are

21
22
23
24
16:55:54

25

617-542-0039

involved in litigation in California?
A

My extent of -- my extent to the knowledge is

that I have seen it on the newspaper.
Q

And do you understand that you are here today

to give testimony on behalf of Bluebird Soft that might

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be used in that litigation?

2

A

Yes.

3

Q

Is there any reason you cannot provide your

4
16:56:18

best testimony here today?

5

A

No.

6

Q

If you could please describe for me your

7
8
9
16:57:00

education since high school?
A

Uhm, I completed -- actually, I received a

master's degree for clothing and textile at Seoul

10

National University, and I have completed the course

11

work for the Ph.D. in the same university, but I did not

12

get the Ph. degree.

13
14
16:57:23

Q

And do you hold any other degrees besides the

master's degree?

15

A

No.

16

Q

When did you get your master's degree?

17

INTERPRETER:

Interpreter's correction, Mr. Lee

18
19
16:57:49

said that he also has a bachelor's degree from the same
university.

20
21
22
23
24

16:58:18

25

617-542-0039

THE WITNESS:

It was in 1997.

BY MS. NEILL:
Q

And after you finished your master's degree,

did you start a job?
A

No.

I was going to complete my course work for

the Ph.D. for two years.

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Is that until 1999?

2

A

(Indicating).

3

Q

And in 1999, did you start working?

4

A

Yes.

5

Q

And what company did you work for?

6

16:58:36

Q

A

I started teaching at Kijeon Women's College in

7

Jonju.

8
9
16:59:08

INTERPRETER:

Interpreter spelling is

K-I-J-E-O-N, Women's University, in the City of

10

J-O-N-J-U.

11

BY MS. NEILL:

12

Q

And what did you teach?

13

A

I taught mostly marketing or the fashion

14
16:59:25

15
16

marketing.
Q

And how long did you teach at Kijeon Women's

College?

17

Two years.

18

Q

And so that was until 2001?

19

A

Yes.

20

Q

And what did you do then?

21

16:59:41

A

A

I worked for a consulting company called PFIN

22

for about two years.

23

Does PFIN stand for anything?

24
17:00:14

Q
A

Yes.

25

617-542-0039

I don't have a clear recollection about

it, but it was a company related to a fashion business.

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1
2
3

Q

And you said that you did consulting for that

company?
A

No.

I worked as a consultant for that company,

4

year.
Q

And how long did you work at PFIN?

7

A

I don't think it was quite two years.

8

Q

And where did you go after PFIN?

9

A

Here, Bluebird Software.

10

Q

And when did you start at Bluebird Software?

11

A

I believe it was the fall of 2002.

12

17:01:22

5
6

17:00:49

but then afterwards, I served as the CEO for about a

Q

And when you joined Bluebird Software, what was

13
14
17:01:49

15
16
17
18
19

17:02:26

your title?
A

I started working as the planning department

team leader.
Q

And at any point in the past 10 years, has your

title changed?
A

Yes.

After working for about six month, I was

promoted to become executive vice president.

20

Q

And how long were you executive vice president?

21

A

Until now.

22

Q

So, your title is is still executive vice

23

So about 9 years now.

president?

24
17:02:39

A

Yes.

25

Q

Are you familiar with the Bluebird device

617-542-0039

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called the Pidion BM-200?

2

A

Yes.

3

Q

I am going to hand you a device that's a BM-200

4
17:03:05

for you to confirm that that is a BM-200.

5

A

Yes, it is correct.

6

Q

Can you, please, hold it up so that the camera

7

can see it?

8

(Witness complies).

9
17:03:16

A
Q

And maybe turn it around so you can see the

10

back as well?

11

A

(Witness complies).

12

Q

Thank you.

13

MS. NEILL:

I would like to mark as the first

14
15

this case.

16

17:03:32

exhibit, uhm... a copy of the subpoena to testify in

Exhibit 2200.

And we should start our exhibit numbers with

17
18

(Exhibit 2200 marked for identification.)

19
17:04:04

20

BY MS. NEILL:

21

Mr. Lee, have you ever seen this document?

22

A

Yes.

23

Q

And did you read this document before today?

24
17:04:27

Q

A

I only read a couple of first pages, including

25

617-542-0039

the cover.

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Q

If you could, please, turn to the page --

2
3

from the back.

4
17:05:04

there's no numbers, I apologize.

at the top.

It's about four, five

And it has the title "Deposition Topics"

5

A

Yes.

6

Q

Have you seen this page before?

7

A

No.

8

Q

If you would read number 1, please, and let me

9
17:05:35

10
11
12

I have never read it before.

know if you have information today that's responsive to
that topic?
A

Uhm, I don't think I can answer to the exact

date, but I think I can testify to the level of month.

13

Okay.

14
17:06:32

Q
A

I don't understand exactly what the phrase

15
16
17

And the same for the second topic?

"scope of use" means here.
Q

Are you aware of the markets in which the

BM-200 was sold during the first two years?

18

That, I think I can answer.

19
17:06:47

A
Q

Okay.

20
21
22
23
24

17:07:20

25

617-542-0039

MR. AHN:

Objection.

Assumes facts.

BY MS. NEILL:
Q

Do you have any information about the third

topic?
A

Since my recollection isn't entirely clear, I

think I can't give you an exact answer to the topic 3.

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1

Q

2
3

And the topic 4?
MR. AHN:

One second.

Looks like we've lost

the Live Note feed.

4
17:09:59

5

(Pause in proceedings.)

6
7
8
9
17:10:24

10

THE WITNESS:

I can answer, yes.

BY MS. NEILL:
Q

And as to topic 5, do you have any knowledge or

recollection about what the graphical use or interface?

11

MR. AHN:

12

THE WITNESS:

13

MS. NEILL:

Objection.

Vague and ambiguous.

Yes.
I would like to mark as the next

14
17:10:58

exhibit a document with Bates label BBS 000004 that was

15

produced by Bluebird Soft in this case.

16
17

(Exhibit 2201 marked for identification.)

18
19
17:11:39

20

BY MS. NEILL:
Q

Mr. Lee, do you recognize this document to show

21

a view -- a front -- a view of the front face of the

22

BM-200?

23
24
17:12:03

25

617-542-0039

MR. AHN:

Objection.

Compound.

Vague and

ambiguous.
THE WITNESS:

Yes.

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1
2

BY MS. NEILL:
Q

And can you tell if this device has a bezel?

3
4
17:12:29

MR. AHN:

THE WITNESS:

5

Vague and ambiguous.

I don't know exactly what you

mean by "bezel."

6

Objection.

BY MS. NEILL:

7
8

Q

So, do you see the silver area that runs around

the perimeter of the device?

9
17:12:47

A

Yes.

10

Q

And if I refer to that as a bezel, will you

11

understand what I am referring to?

12

A

Yes.

13

Q

So, referring to the actual device that I

14
17:13:15

15
16

handed you earlier, does the BM-200 have a silver bezel?
MR. AHN:
Assumes facts.

Objection.

Foundation.

17

THE WITNESS:

18

MS. NEILL:

19
17:13:29

Vague and ambiguous.

Yes.
I would like to mark as the next

exhibit a printout of a website.

20
21

(Exhibit 2202 marked for identification.)

22
23

MR. AHN:

I object to the use of this document.

24
17:13:59

It does not have any production numbers on it.

25

not appear to have been produced to Apple.

617-542-0039

It does

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1
2

COURT REPORTER:

It does not.... something to

Apple?

3

MR. AHN:

It has not been produced to Apple.

4
5

as well as any testimony pertaining to it.

6

17:14:12

Accordingly, Apple will move to strike both the exhibit

BY MS. NEILL:

7

Q

Mr. Lee, do you recognize this document?

8

A

Yes.

9
17:14:27

10

MR. AHN:

Same objections.

BY MS. NEILL:

11

Q

And what do you recognize it to be?

12

A

This is an article, which was reported on the

13
14
17:14:56

Korean IT News back when we released a BM-200.
Q

15
16
17
18

INTERPRETER:

20

Q

-- do you see on this document, the date

April 28, 2005?
MR. AHN:
facts.

Objection.

THE WITNESS:

22

MR. AHN:

24
17:15:26

25

617-542-0039

Foundation.

Assumes

Vague and ambiguous.

21

23

IT News.

BY MS. NEILL:

19
17:15:12

And --

Yes.

Misstates the document.

BY MS. NEILL:
Q

And is it your recollection that the BM-200 was

made publically known by April 8th of -- April 28th,

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excuse me --

2
3
4
17:15:34

MR. AHN:
BY MS. NEILL:
Q

5
6

Objection.

-- of 2005?
MR. AHN:

conclusion.

Objection.

Vague and ambiguous.

7

THE WITNESS:

8

MS. NEILL:

9
17:16:57

Calls for legal
Also foundation.

Yes, that is my recollection.
I would like to mark as the next

exhibit a document bearing dates number BBS 000003.

10
11

(Exhibit 2203 marked for identification.)

12
13

BY MS. NEILL:

14

Mr. Lee, do you recognize this document?

15

A

Yes.

16

Q

And what is this?

17

17:17:14

Q

A

This is a certificate for excellent industrial

18
19

Korea Institute of Design Promotion, which is a Korean

20

government agency, where they select excellent design.

21

17:17:59

design, which was selected by the Korean agency called

So, this is the certificate awarded to us.

22

Q

And what is the date on the certificate?

23

A

It is as of May 27th of -- 2005.

24
17:18:32

25

617-542-0039

MS. NEILL:

I would like to mark as the next

exhibit a document bearing Bates numbers BBS 000005

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1

through BBS 000006.

2
3

(Exhibit 2204 marked for identification.)

4
17:19:09

5
6
7

BY MS. NEILL:
Q

Mr. Lee, if you could just take a look at this

exhibit for me, please.

8

Do you recognize this exhibit?

9

Yes.

10

Q

And what is this?

11

17:19:15

A

A

This is a catalog that we made for the purposes

12
13

of marketing at the time we released the product.
Q

And do you know when this document was created?

14
17:19:41

MR. AHN:

15

THE WITNESS:

Objection.

Foundation.

I don't remember exactly.

We

16

usually prepared the document when the product gets

17

released.

18

BY MS. NEILL:

19
17:19:58

Q

And is this document given to anyone?

20

A

Yes.

Usually, we print out many copies, like

21

thousand copies or 10,000 copies, and distribute and use

22

as marketing material.

23

MS. NEILL:

I would like to mark as the next

24
17:20:30

exhibit a document bearing Bates numbers BBS 000007

25

through 000008.

617-542-0039

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1
2

(Exhibit 2205 marked for identification.)

3
4
17:20:54

BY MS. NEILL:

5

Q

Mr. Lee, do you recognize this document?

6

A

Yes.

7

Q

And what is this document?

8

A

After we released the product in Korea, this is

9
17:21:21

the document we prepared in order to prepare the

10

launching of the product overseas.

11

marketing material.

12
13

Q

And was this document prepared after the

previous one we were just looking at, Exhibit 2204?

14
17:21:51

So, this is overseas

MR. AHN:

15

THE WITNESS:

Objection.

Foundation.

Usually what happens is that we

16

usually create the Korean version and English version of

17

the catalog at the same time.

18

BY MS. NEILL:

19
17:22:05

Q

And do you have any recollection of when this

20

document would have been distributed for overseas

21

markets?

22
23
24
17:22:40

25

617-542-0039

MR. AHN:
Foundation.

Objection.

Foundation.

Vague and ambiguous.

THE WITNESS:

Form.

Objection.
Assumes facts.

I believe this document would

have been distributed in 2005 because, according to our

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1

sales record, it says that our product was, uhm, product

2

started being sold since 2005.

3

MS. NEILL:

I would like to mark as the next

4
5

through 000036.

6

17:23:07

exhibit a document bearing Bates numbers BBS000009

color copy of it, so that's the one I want to mark.

Yeah, unfortunately, I only have one

7
8

(Exhibit 2206 marked for identification.)

9
17:23:35

10

BY MS. NEILL:

11

Mr. Lee, do you recognize this document?

12

A

Yes.

13

Q

And what is this document?

14
17:23:58

Q

A

This is a manual usually included when a

15
16
17
18
19

17:24:21

product is sold.
Q

Do you know if this is the manual that was

included with the Pidion BM-200?
A

Yes.
MS. NEILL:

I would like to mark as the next

20

exhibit a document bearing Bates number BBS 0000001

21

through 0000002.

22
23

(Exhibit 2207 marked for identification.)

24
17:24:56

25

617-542-0039

BY MS. NEILL:

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1

Mr. Lee, have you seen this document before?

2

A

I haven't, but it looks like our ERP material.

3

Q

And what does ERP stand for?

4
17:25:26

Q

A

Entire Resource Program or -- I don't know.

5

Q

And what kind of information is reflected in an

6

ERP document?

7

MR. AHN:

8

THE WITNESS:

9
17:26:02

Objection.

Form.

Foundation.

The company's entire resources,

including company's asset, materials, sales, and

10

production process and marketing process is managed by

11

ERP.

12

MR. AHN:

13

THE VIDEOGRAPHER:

14
17:26:36

MS. NEILL:

Should we take a break?

We should

take a break.

17
18

I believe the Blackberry is

giving interference.

15
16

We have lost the Live Note again.

THE VIDEOGRAPHER:

Going off the record.

The

time is 5:26 p.m.

19
17:26:42

20

(Off the record.)

21
22

THE VIDEOGRAPHER:

23

17:35:33

The

time is 5:35 p.m.

24

Back on the record.

BY MS. NEILL:

25

617-542-0039

Q

Mr. Lee, I would like to direct your attention

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back to Exhibit 2207 we were looking at before the

2

break?

3

Yes.

4
17:35:46

A
Q

Does this document indicate that sales of the

5

BM 2 -- of the BM-200 were made between the years 2005

6

and 2008?

7
8

MR. AHN:

THE WITNESS:

10

Yes.

That's correct.

This is

BY MS. NEILL:

12
13

Q

15

MR. AHN:

18

Objection.

THE WITNESS:
BY MS. NEILL:
Q

Do you know when that was?
MR. AHN:

20

THE WITNESS:

22

Vague and

We have sold one sample.

19

21

Foundation.

ambiguous.

16
17

And do you know if the BM-200 was ever sold in

the United States?

14

17:36:51

Form.

the sales data.

11

17:36:34

Foundation.

Compound.

9
17:36:17

Objection.

Objection.

Foundation.

Based on our record, it is

November of 2007.
MS. NEILL:

I'd like to mark as the next

23
24
17:37:25

exhibit a document bearing Bates number SAMNDCA00198065
through 00198067.

25

617-542-0039

Merrill Corporation - Boston
www.merrillcorp.com/law

0c8da1b2-0026-4b26-97f3-2047dc5f9fdb

CONFIDENTIAL ATTORNEYS' EYES ONLY
SUNGYUB LEE - 3/8/2012
Page 24
1

(Exhibit 2208 marked for identification.)

2
3

BY MS. NEILL:

4
17:37:55

Q

Mr. Lee, have you ever seen this document?

5

A

I have not seen this in the formal document,

6
7

but I have on the website.
Q

And under the "Bluebird Pidion BM-200 Specs,"

8
9
17:38:28

the third line down, it indicates release date of
November 2005?

10

A

Yes.

11

Q

Do you know if that release date is accurate?

12

MR. AHN:

13

THE WITNESS:

Objection.

Foundation.

I cannot tell you whether or not

14
15

that we usually released a product in Korea first and

16

then overseas.

17

17:39:00

it is true based on my recollection only, but it is true

BY MS. NEILL:

18

Q

Is there a usual timeframe between the time

19
17:39:24

that you release a document -- I mean, a product in

20

Korea and the time it's released overseas?

21
22

MR. AHN:

17:39:51

25

617-542-0039

Vague and ambiguous.

Foundation.

23
24

Objection.

THE WITNESS:

It varies depending on the

product.
MS. NEILL:

I'd like to mark as the next

Merrill Corporation - Boston
www.merrillcorp.com/law

0c8da1b2-0026-4b26-97f3-2047dc5f9fdb

CONFIDENTIAL ATTORNEYS' EYES ONLY
SUNGYUB LEE - 3/8/2012
Page 25
1

exhibit a document bearing Bates stamp SAMNDCA00326344

2

through 00326346.

3
4
17:40:32

(Exhibit 2209 marked for identification.)

5
6

BY MS. NEILL:

7

Mr. Lee, have you ever seen this before?

8

A

Yes.

9
17:40:42

Q

Q

And what is this?

10

A

It's an article on another IT news about our

11
12

BM-200 release.
Q

13

And if you look at the photographs...
INTERPRETER:

It's another IT news article,

14
17:41:33

which was about our BM-200 release.

15

BY MS. NEILL:

16
17

Q

If you look at the photographs in this

document --

18

Yes.

19
17:41:41

A
Q

-- do you recognize the devices in those

20

photographs to be BM-200 models?

21
22

MR. AHN:

17:41:55

25

617-542-0039

Foundation.

Assumes

facts.

23
24

Objection.

THE WITNESS:

Yes.

BY MS. NEILL:
Q

Was the BM-200 also released in a black

Merrill Corporation - Boston
www.merrillcorp.com/law

0c8da1b2-0026-4b26-97f3-2047dc5f9fdb

CONFIDENTIAL ATTORNEYS' EYES ONLY
SUNGYUB LEE - 3/8/2012
Page 26
1

version?

2

A

Yes.

3

Q

And if you could, with the device that I gave

4
5

device, show the camera what part of the device would be

6

17:42:16

you earlier, could you please show, pointing on that

black?

7

MR. AHN:

8

THE WITNESS:

9
17:42:49

10
11

Objection.

Foundation.

At the time, we used black for

the front face bezel and key areas.
BY MS. NEILL:
Q

And turning your attention to the second page

12
13

the one that isn't cut off, appears to have a picture of

14
17:43:15

of this document, the last full picture at the bottom,

a white BM-200 next to a black BM-200.

15
16

MR. AHN:

19
17:43:27

20

THE WITNESS:

Yes.

BY MS. NEILL:
Q

And does this photo also show the graphical

user interface?

21

MR. AHN:

22

facts.

23

Objection.

Foundation.

Assumes

itself.

24
17:43:39

Assumes facts.

Foundation.

17
18

Objection.

25

617-542-0039

Vague and ambiguous.

THE WITNESS:

Document speaks for

Yes.

BY MS. NEILL:

Merrill Corporation - Boston
www.merrillcorp.com/law

0c8da1b2-0026-4b26-97f3-2047dc5f9fdb

CONFIDENTIAL ATTORNEYS' EYES ONLY
SUNGYUB LEE - 3/8/2012
Page 27
1
2

Q

Did the display of the BM-200 have icons that

appeared in rows and columns on the front?

3
4
17:44:05

MR. AHN:

Objection.

Foundation.

5

THE WITNESS:

6

MS. NEILL:

7

17:44:34

Yes.
I'd like to mark as the next

exhibit a printout of a website titled PAS News.

8
9

Vague and ambiguous.

MR. AHN:

I note for the record that this

exhibit does not have any Bates numbers, does not appear

10

to have been produced to Apple; accordingly, we move to

11

strike this exhibit as well as any testimony regarding

12

this exhibit.

13
14
17:44:53

(Exhibit 2210 marked for identification.)

15
16

BY MS. NEILL:

17

Mr. Lee, have you ever seen this before?

18

A

No.

19
17:45:12

Q

Q

Was the BM-200 ever released with a black front

20

face and a silver bezel?

21
22

I have not seen this before.

MR. AHN:

Objection.

Foundation.

Vague and

ambiguous.

23

THE WITNESS:

Based on the photo, uhm, I think

24
17:45:40

there would have, but I don't have clear recollection

25

about it.

617-542-0039

Merrill Corporation - Boston
www.merrillcorp.com/law

0c8da1b2-0026-4b26-97f3-2047dc5f9fdb

CONFIDENTIAL ATTORNEYS' EYES ONLY
SUNGYUB LEE - 3/8/2012
Page 28
1

MS. NEILL:

I have nothing further.

2
3
4
17:46:03

CROSS-EXAMINATION

5
6

BY MR. AHN:

7
8

Q

Mr. Lee, I have a few followup questions for

you.

9

Yes.

10

Q

Are you currently represented by an attorney?

11

A

No.

12

17:46:13

A

Q

Did you want to be represented by an attorney

13

at today's deposition?

14
17:46:38

A

I never thought about it.

15

Q

Are you at all concerned about the legal

16

ramifications of your testimony today?

17

MS. NEILL:

18

THE WITNESS:

Objection.

Vague.

Just because you just asked me

19
20

nothing particular that I'm concerned about.

21

17:47:06

that question, I started being concerned, but there's

BY MR. AHN:

22
23

Q

Sitting next to you is a member of your legal

department?

24
17:47:21

A

Yes.

25

Q

I just want to confirm whether or not Mr. Yun

617-542-0039

Merrill Corporation - Boston
www.merrillcorp.com/law

0c8da1b2-0026-4b26-97f3-2047dc5f9fdb