Case 5:05-cv-00334-RMW Document 2324 Filed 09/30/2008 Page 1 of 6

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 JUNG-BAE LEE
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
6029681.1 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 Page 2 of 6

1 Rambus hereby gives notice that it is lodging, concurrently herewith, a transcript of the
2 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

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11 By: /s/ Carolyn Hoecker Luedtke

Carolyn Hoecker Luedtke
12
Attorneys for Plaintiff RAMBUS INC.
13

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RAMBUS’S NOTICE OF LODGING OF TRANSCRIPT
6029681.1 -1- 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 Page 3 of 6

Exhibit A
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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 THE WITNESS: No.

144:21 MR. DETRE: Q. Why not?
144:22 A. The JEDEC standard specification finalized

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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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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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