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EXHIBIT A
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Video Testimony of William Deley (6/27/2008 30(b)(6) Deposition)

Played 9/25/2008

69:18 Q. Okay. So if you could look at what's been

69:19 marked as Deley, I think, Exhibit 13 --
69:20 THE REPORTER: 15.
69:21 BY MR. BEREZIN:
69:22 Q. 15, excuse me. That's a document that bears
69:23 Bates numbers EY-RAM-EF-NSHE-000212.
69:24 Do you recognize what's been marked as Deley
69:25 Exhibit 15 as an e-mail from Nigel Shepherd to you
70:1 dated on or about 10 -- October 4th, 2004?
70:2 A. I do.

71:16 RECORD READ AS FOLLOWS:

71:17 "Q. Did there come a time when you told
71:18 Mr. Shepherd of E&Y not to contact Samsung
71:19 affirmatively?"
71:20 THE WITNESS: I believe there was a time
71:21 period around this time period where I said don't
71:22 follow up on the audit temporarily.

71:23 BY MR. BEREZIN:

71:24 Q. Do you recall whether -- when that was, when
71:25 you gave that instruction?
72:1 A. It was around this time frame in October,
72:2 September, late September time frame.
72:3 Q. Why did you give Mr. Shepherd that
72:4 instruction?
72:5 A. The reason why is because we were internally
72:6 trying to understand, you know, how can we help
72:7 progress the audit with Samsung better, and we were
72:8 also trying to work with the legal team to make sure
72: 9 that we were working in a coordinated fashion with
72:10 them. And up to that point in time Ernst & Young had
72:11 had really no progress in progressing the audit due to
72:12 the fact that Samsung hadn't produced the documents
72:13 that they said they would produce in order for E&Y to
72:14 complete their processes.

72:15 Q. Did you instruct Ernst & Young to

72:16 affirmatively contact Samsung at any time during the
72:17 month of October?
72:18 A. I don't recall whether I affirmatively told
72:19 them to not contact Samsung.

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72:20 Q. I'm sorry. My question was whether you told

72:21 E&Y to contact Samsung any time after the date of
72:22 what's been marked as Deley Exhibit 15, which is, for
72:23 the record, October 4th, 2004?

72:24 MR. GROSS: I'm going to object as vague and

72:25 ambiguous as to time. In your previous question you
73:1 were referring to the month of October and in this one
73:2 you're referring to any time?
73:3 MR. BEREZIN: Any time after October 4th.
73:4 MR. GROSS: To the end of -- to when the
73:5 license was terminated?
73:6 MR. BEREZIN: That's correct.
73:7 MR. GROSS: Okay.

73:8 THE WITNESS: I believe there were discussions

73:9 where, you know, it was basically move the audit -- try
73:10 to move the audit forward with Samsung.
73:11 BY MR. BEREZIN:
73:12 Q. When were those discussions, sir?
73:13 A. I don't recall exactly, but they were sometime
73:14 in the fourth quarter of 2004.

Total Length: 00:02:34

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