Name: Jeung, Bok Dong
Occupation: assistant manager of Sam Hong Sa Co., Ltd.
About 2/3 of the 1.44 M diskette had data saved in it, but I do not know the contents of the data.
I handed it over on my way home from work, in a coffee shop on the second floor of a store near the subway station in Kayang-dong. That was around nine in the evening. I handed it over to Manager Ahn (Ahn, Sun Gap) without thinking twice.
I did not know Ahn was designing for other companies. I desperately wanted to outsource Sam Hong Sa drawings, and ended up making this mistake.
I found out that Ahn was doing other drawings near the end of October. I now know that I should have consulted my boss beforehand.
This data (LOT-56) is two-cylinder type – the first type that I worked on.
February 21, 2000
Jeung, Bok Dong
Q: How much education did the suspect receive?
A: I graduated Shingu College majoring in Computerization in 1993.
Q: Does the suspect have any job experience?
A: After graduation in 1993, I worked for my uncle at Jinyang Electrical Locomotiveering and was in charge of designing metal molds for audio case. In 1994, I went to work for another uncle at Shinil Metal, which makes metal cast molds, and was put in charge of mold designing. In July 1996, I joined Sam Hong Sa export industrial complex 3 in Kasan-dong, Kumchun-ku, Seoul, and designed miniature locomotives in the Modeling Division. I made assistant manager in March 1999 and work there still.
Q: Does the suspect know Lee, Se Yong, Lee, Chun Sik, Choi, Dae Yul, and Kim, Sun Chul? If so, what is the nature of the relationship?
A: I became acquainted with them upon joining Sam Hong Sa’s Modeling Division in 1996. Lee, Se Yong is president of the company, Lee, Chun Sik is senior executive of Production Team 2, Choi, Dae Yul is senior executive of Planning and Coordination Office, and Kim, Sun Chul is head of the Designing Team. No other relatives.
Q: Does the suspect know suspects Cho, Sung Won and Ahn, Sun Gap?
A: I have no idea who Cho, Sung Won is. Regarding Ahn, Sun Gap, he was a my direct manager when I was working for Sam Hong Sa’s Modeling Division until he resigned in October 1998.
Q: What was the suspect’s job at Sam Hong Sa?
A: Sam Hong Sa is divided into 4 divisions: Modeling, Bidets, Motor, and GS. I worked in the Modeling Division. I worked in the Modeling Division and my job was to design miniature locomotives.
Q: Is it true that the suspect transferred miniature locomotive drawings to Ahn, Sun Gap?
A: Yes, it is.
Q: When and where?
A: On September 14, 1999 at 21:00 in a coffee shop on the second floor of near the unidentified subway station in Kayang-dong, Kangsuh-ku, Seoul.
Q: Which of the drawings were transferred?
A: In the afternoon of September 14, 1999, inside the designing office of Sam Hong Sa Modeling Division, I copied STEAM LOCOMOTIVE OGUAGE TRAIN-56, the drawings of miniature locomotives designed on a computer, to a diskette received from our outsourcing molder. That evening, I handed a CAD DATA diskette with those drawings to Ahn, Sun Gap.
Q: Is this the drawing that the suspect transferred to Ahn, Sun Gap?
(At this point, the Prosecutor shows the drawings attached to pages 84 and 93 of the deposition.)
A: Thank you. Yes, those are the drawings handed over to Ahn, Sun Gap, except that the ones that you have just shown me are fully-completed drawings and the ones that I gave to Ahn, Sun Gap were only half-completed.
(At this point, the Prosecutor shows the drawing filed as page 9 of the deposition.)
Q: Is this the drawing that the suspect transferred to Ahn, Sun Gap?
A: Yes, it is the drawing that was handed over to Ahn, Sun Gap, but this one has been worked on by about 30% more compared to the one I gave to Ahn, Sun Gap.
Q: Give us the full account of how you came to transfer the drawings.
A: There are two types of miniature locomotives: two-cylinder and one-cylinder. Ahn, Sun Gap asked for the harder design, which is of two-cylinder, and I gave him a diskette with the half-completed drawing of STEAM LOCOMOTIVE OGUAGE toy. In return, Ahn, Sun Gap was to outsource its miniature locomotives to Sam Hong Sa.
Q: Did you seek approval from Sam Hong Sa President Lee, Se Yong when sending the miniature locomotive drawing to Ahn, Sun Gap?
A: No, I transferred it without the knowledge of the President or senior executives.
Q: Why did you hand over the drawings without seeking approval from President Lee, Se Yong or other executives?
A: I know I should have reported it to the President, but I made the transfer without his approval nevertheless.
Q: When the suspect handed over the CAD DATA with these drawings to Ahn, Sun Gap, who at that time was working for Korea Brass, the suspect had disclosed company drawings to Sam Hong Sa’s competition which he should not have done, what do you have to say?
A: I thought Korea Brass was a Sam Hong Sa’s subcontractor, not its competition.
Q: It seems that the suspect was to receive other pecuniary compensation for handing over the CAD diskette to Ahn, Sun Gap. Is this true?
A: No, I gave Ahn, Sun Gap the diskette in return for securing subcontracts.
(At this point, the Prosecutor shows the suspect a copy of his wife Lee, Jae Ok’s bankbook at Choheung Bank and files it in the back of the deposition.)
Q: On October 5, which is a month after the suspect handed over the diskette to Ahn, Sun Gap, Ahn, Sun Gap remitted 2 million won to this bankbook of the suspect’s wife. Is this compensation received by the suspect for handing over the diskette with the drawings to Ahn, Sun Gap?
A: That was a repayment of the money I lent to Ahn, Sun Gap when we were working together at Sam Hong Sa.
Q: When was the loan made?
A: Around July or August of 1998.
Q: Was an IOU received for it?
A: No, there is no IOU.
Q: Can you explain why the loan, which was made when the suspect and Ahn, Sun Gap were working together, was paid back after Ahn, Sun Gap resigned and a month after the suspect transferred the drawing diskette to Ahn, Sun Gap?
A: Ahn, Sun Gap had not received his severance pay and so could not pay me back until a month later.
Q: In return for handing over the drawing diskette and other business secrets to Ahn, Sun Gap, the suspect was to receive a huge compensation and a certain percentage of profit accrued in the future. Is this true?
A: I did not receive or expect to receive any money.
Q: Did the suspect seek approval from President Lee, Se Yong after handing over the CAD DATA to Ahn, Sun Gap?
A: No. Executive Director Seong, Ki Ho, Team Manager Kim, Sun Chul, and Manager Kim, In Suk were focusing development on STEAM LOCOMOTIVE OGUAGE toy and so was Korea Brass. Upon learning this fact, Sam Hong Sa executed an internal investigation and found out that I had transferred CAD DATA of that drawing to Ahn, Sun Gap at Korea Brass. I was pressed to tell the truth and so wrote a confession explaining what had taken place.
Q: Is this the confession written by the suspect in the presence of Executive Director Seong, Ki Ho?
(At this point, the Prosecutor shows a copy of the confession written by the suspect and files it in the back of the deposition.)
A: Yes, it is.
Q: The suspect just stated that the CAD diskette was transferred in return for securing subcontracts with Ahn, Sun Gap. However, the suspect’s confession states that the transfer was made because Ahn, Sun Gap needed to study the drawings on the CAD diskette. Why are the reasons different?
A: The reason was for Ahn, Sun Gap to study the drawings on the CAD diskette so that I could outsource designs.
Q: It does not make sense to hand over company drawings to Ahn, Sun Gap without being compensated. What do you think?
A: Yes, I agree, but I did make the transfer without compensation.
Q: Aside from this case, the suspect took home other confidential files. Is this true?
A: Yes. On February 14, 2000 around 19:00, I did take the above mentioned miniature locomotive LOT-19 and –20 CAD DATA to my home in # 203-1902 Dongmun 2-cha Apt., Ilsan-dong, Ilsan-ku, Kyunggi Province.
Q: What was the reason for copying LOT-19 and –20 to a diskette and taking it home?
A: I took the work home to finish it.
Q: Did you seek approval from the company president when taking the CAD DATA home?
A: No, I did so at my own discretion. The diskette was confiscated at home.
Q: The suspect wrongfully handed over the miniature locomotive design data, Sam Hong Sa’s core technology, to its competition and also took it home. What do you have to say?
A: I am sorry.
Q: Have any other material been disclosed besides the drawing transferred to Ahn, Sun Gap on September 14, 1999?
Q: Do you have anything else to say?
A: I sincerely did not know that the LOT-56 drawing that I
gave to Ahn, Sun Gap would be used by our competition Korea Brass.