Free Declaration in Support - District Court of California - California

ase 5:07—cv—02504—FlIVIW Document 26 Filed 06/26/2007 Page 1 of 2
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1 BRENDAN DOLAN, State Bar No. I26732
L. TULIUS M. TURMAN, State Bar No. 226126
2 STEVEN J. GARRETT, State Bar No. 221021
MORGAN, LEWIS & BOCKIUS LLP
3 One Market, Spear Street Tower
San Francisco, CA 94105-1126
4 Tel: 4l5.442.I000
Fax: 415.442.100l
5 E-mail: [email protected]
6 Attorneys for Plaintiff
POSDATA CO., LTD.
7
E
8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA
10 SAN JOSE DIVISION
ll POSDATA CO., LTD., a South Korean Case No. C 07 2504 RMW
g corporation,
12 DECLARATION OF JOON IL SHIN IN
Plaintiff, SUPPORT OF POSDATA'S EX PART E
I3 APPLICATION FOR
1 vs.
14 (1) Tsmotunv Rnsrmmrnc
SEYOUNG KIM, an individual and ORDER;
15 l INQUADRON, INC., a California
corporation, (2) ORDER TO SHOW CAUSE ‘WHY A
16 PRELIMINARY INJUNCTION SHOULD
17 Defendants. NOT ISSUE; AND
(3) ORDER PERMITTING EXPEDITED
18 nrscoviznv.
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20 I, Joon Il Shin, declare:
2I 1. I have personal knowledge of the facts set forth in this declaration, and if called as
22 a witness, I could and would competently testify to them.
23 2. I am currently the Senior Vice President for Posdata Co., Ltd. ("Posdata" or
24 "PlaintifI"’), a corporation with its principal place of business in the Republic of Korea. In my
25 position as Senior Vice President, I am responsible for managing all aspects of Posdata’s mobile
26 WiMAX (Worldwide Interoperability for Microwave Access) technology business.
27 3. I have reviewed the tile of the news broadcast from Korean station YTN attached
28
Moucim, LEWIS & E
BOCKIUS LLP C
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sx PARTE Arrticnrrow

26/0Q%§$I qiiiigsci/1Ii)%§1O$1.ii:{|iQh/il DOCUP[di§piA26 Filed 06/26/2007 Page 2 @51:1
1 as Exhibit C to the declaration of David S. Elkins in Opposition to Posdata’s ex parte applications.
2 The Ele contains only an excerpt of my interview with the news station and does not contain ail
3 ofniy comments regarding the situation. At the time [ made this statement, I could not have
4 conceivably known the full extent ofthe activities of Dr. Seyoung Kim, [nQuad1·on, inc. and their
5 associates, or what they had taken from Posdata.
6 4. My statement was not a statement that Posdata had not been harmed by the
7 activities of Dr. Kim, InQuad1·on, Inc. or their associates. To the connary, Posdata iiied a lawsuit
8 in the United States District Court Northern Division of California on May I0, 2007 because
9 Posdata was harmed by the activities of Dr. Kim and InQt.mdi·on.
10 I declare under penalty of perjury ofthe laws ofthe United States and the State of
1 l California that the foregoing is true and correct.
12 Executed on June 26, 2007.
13 ,5 gg? g
JOON H. SHIN
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*E;'?’j§g§j§' 2 stun DECLARATION [S200}-i‘(§5S(124A1$fL,|ii\S
EXPARTE APPLICATION

Case 5:07-cv-02504-RMW

Document 26

Filed 06/26/2007

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Case 5:07-cv-02504-RMW

Document 26

Filed 06/26/2007

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