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Rambus'S Notice of Lodging of Transcript of Video Testimony of Charles Donohoe
Rambus'S Notice of Lodging of Transcript of Video Testimony of Charles Donohoe
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RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT
6028117.1 OF VIDEO TESTIMONY OF CHARLES DONOHOE;
CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW Document 2317 Filed 09/30/2008 Page 2 of 11
1 Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the
2 video clips of the testimony of Charles Donohoe played in Court on September 29, 2008.
3 The video clips were taken from the following deposition transcripts:
4 Deposition of Charles Donohoe, taken on February 6, 2001, attached hereto as Exhibit A.
5 Deposition of Charles Donohoe, taken on May 14, 2008, attached hereto as Exhibit B.
6 This Notice is being filed with the Court and will be appended to the official trial
7 transcripts and, pursuant to the parties’ agreement, will become part of the official trial transcript.
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RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT
6028117.1 -1- OF VIDEO TESTIMONY OF CHARLES DONOHOE;
CASE NOS. 05-00334 RMW; 05-02298 RMW
Case 5:05-cv-00334-RMW Document 2317 Filed 09/30/2008 Page 3 of 11
Exhibit A
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V102 1
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87: 6 negotiation.
87: 7 Our direct interface in the negotiation
87: 8 was J. Shim, who is head of our patent department in
87: 9 Kiheung. I'm in the corporate office in Seoul,
87:10 Korea, that's where my office is, so sometimes I get
87:11 involved in patent license negotiations, and
87:12 sometimes I don't, but this one here the president of
87:13 the company asked me to be involved.
87:14 Q. And did Mr. Shim have the day-to-day
87:15 responsibility for conducting the negotiations with
87:16 Rambus?
87:17 A. Yeah. He had -- he communicated with
87:18 Mr. Steinberg on a day-to-day basis, that's correct.
87:19 Q. And were there meetings between Mr. Shim
87:20 and representatives of Rambus that you weren't
87:21 present at?
87:22 A. Yes. There was one in August, that I'm
88: 1 aware of. The meetings in September and October, I
88: 2 was at.
88: 3 Q. But there was at least one meeting then
88: 4 that you were not present at?
88: 5 A. That's right. Of course, I was not at
88: 6 the very beginning meeting, the introductory meeting.
88: 7 Q. The meeting with Mr. Tate that you
88: 8 described earlier?
88: 9 A. With president Lee. It was after that
88:10 that Mr. Lee asked me to become involved.
88:11 Q. Were there also telephone discussions as
88:12 part of these negotiations?
88:13 A. Probably, yes. Yes.
88:14 Q. Did you participate in those telephone
88:15 negotiations?
88:16 A. I think I only had one telephone
88:17 conversation with Neil Steinberg, yes.
88:18 Q. Were there other telephone negotiations
88:19 between Mr. Shim and representatives of Rambus that
88:20 you did not personally participate in?
88:21 A. That's correct, but they were at my
88:22 direction, basically, yes.
89: 1 Q. And in addition were there letters and
89: 2 drafts exchanged between the parties?
89: 3 A. Yes.
89: 4 Q. And did you receive copies of all the
89: 5 letters and drafts that were received between the
89: 6 parties?
89: 7 A. I was supposed to, yes.
V102 2
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V102 3
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Exhibit B
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V103 1
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V103 2
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V103 3
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V103 4