Free Declaration in Opposition - District Court of California - California

Case 5:07-cv-02504-RMW

Document 24-5

Filed 06/22/2007

Page 1 of 3

[Translator's note: In the translated transcript below, green indicates text that was in the on-screen transcript but not in the audio, while the pink text indicates what was in the audio but not the on-screen transcript.] [News Anchor] A gang that was attempting to carry out the diversion overseas of the technology for WiBro, a wireless Internet technology in which Korea possesses advanced technical capability, has been exposed. Fortunately, it has been possible to block the technology leak, but a technology with huge market potential nearly slipped away. Reporter Kim Suk Soon reports. [Report] Here is a domestic business enterprise that possesses the cutting edge wireless Internet technology WiBro. WiBro, which delivers the capability for super high speed Internet even during movement at high speed, is the next generation of Internet technology whose introduction is being promoted in various countries beginning with Korea and including the United States and Japan. Starting from the end of last year, four researchers from this company began to divert documentation that they themselves had developed. The plan was to take the diverted technology, set up a company in the United States, and then to reap massive profits by selling the company to a US communications enterprise. Since Korea possesses the source technology, their calculation was that overseas companies would not be able to keep their eyes off the company as a way of bridging the technological gap. [Tape excerpt: Lee Jae Yeong, Head of the High Technology Crime Investigation Department of Seoul Central District Prosecutors' Office] "It has been confirmed that they had established a plan to realize a huge windfall by selling the technology concerned [through a merger and acquisition transaction] to a communications company in the United States for the equivalent of 180 Billion Won." The researchers who diverted the technology set up a company in the United States in November of last year, but before the technology passed over, they were caught in a dragnet of the Prosecutors' Office and the National Intelligence Service and apprehended, and we also succeeded in preventing the leaking of the technology.

Case 5:07-cv-02504-RMW

Document 24-5

Filed 06/22/2007

Page 2 of 3

The company that has been victimized revealed: 'If the technology had been hijacked, it would have involved enormous losses.' [Interview: Shin Jun Il, Executive Director of Posdata] "[Given that Korea is some one to two years ahead of foreign companies in WiBro technology] With the technology now being developed, since it a technology that is more than a year in advance of our competitors, if the technology had leaked out, our competitors would have been right at our heels and [there was a concern that] the losses for [the] Korea's industry [would] could have been [on the order of] around 15 Trillion Won. " The Prosecutors' Office revealed that it has detained four former or currently employed researchers, and that it plans to call the remaining researchers in the United States back to Korea for investigation. [Reporter] Noting that the number of cases in which cutting edge technology is being leaked by industrial spies has been increasing every year as the competition of various countries for cutting edge technology intensifies, investigative authorities have called for thoroughgoing security control for key technology. This is Kim Suk Soon of YTN.

Case 5:07-cv-02504-RMW

Document 24-5

Filed 06/22/2007

Page 3 of 3