Name: Sim, Heung Bo
Occupation: manager at Korea Brass
Q: How much education did the suspect receive?
A: I graduated Yoohan College majoring in Mechanical Design in February 1995.
Q: Does the suspect have any job experience?
A: I worked for Sam Hong Sa until July 1999, and in the following month in August, I joined Korea Brass (#B-201 Hagyae TechnoTown, Hagyae-dong, Nowon-ku, Seoul) as a manger and work there still.
Q: Does the suspect have a criminal record?
A: Not relevant.
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 Saís Modeling Division in 1990. 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, Ahn, Sun Gap, Sim, Heung Bo and Jeung, Bok Dong?
A: Cho, Sung Won is the president of Korea Brass, the company that I work for, and as for the others: Ahn, Sun Gap used to be my direct manager in Sam Hong Sa Modeling Division and someone who I am currently working with at Korea Brass; and Kwak, Byung Ki and Jeung, Bok Dong were my colleagues in Sam Hong Sa Modeling Division.
Q: What was the suspectís job at Sam Hong Sa?
A: I started to work for Sam Hong Sa in 1990. Sam Hong Sa is divided into 4 divisions: Modeling, Bidet, Motor, and GS. I worked in the Modeling Division; more specifically, my job was to draw plane figures (2D) of locomotive models.
Q: Is it true that the suspect received miniature locomotive drawings from Kwak, Byung Ki?
A: Yes, it is.
Q: Which drawings were transferred at what time, place and for how much?
A: 1) On February 16, 2000, around 14:30, at Ahn, Sun Gapís Jin Planning Office located in Jangan-dong, Kangbook-ku, Seoul, I received the completed miniature locomotive drawing of A AUX.TENDER (type 025), which was sent to my email address DJ971@chollian.net, via a computer provided by Korea Brass. On that morning, I met Kwak, Byung Ki at an unidentified coffee shop near Ewha University Hostpital in Dongdaemun-ku. I revised the drawing that Kwak, Byung Ki brought and handed him an envelope with 500 thousand won, and later received the final data via email. 2) On the 17th of the same month, at 20:46, in the same office, I received BIG BOY AUX. TENDER (type 026) data via the same email address. On the morning of the 17th at the same coffee shop, I met Kwak, Byung Ki again and went through the same procedure; only this time, the envelope contained 400 thousand won. 3) On the 22nd of the same month, at 23:42, I received SCALE PRR T-1 (4-4-4-4) via the same email address but did not make any payments this time.
Q: Give us the full account of how you came to transfer the drawings.
A: Ahn, Sun Gap ran Jin Planning, which provided miniature locomotive drawings for Korea Brass. Because we worked together at Sam Hong Sa, he asked me to find someone who could design miniature locomotive models and said that compensation would be made accordingly. I thought of Kwak, Byung Ki, a colleague at Sam Hong Sa, and called him up. He accepted and sent the aforementioned drawing. In case 1), I called Kwak, Byung Ki, asked if he could design A AUX.TENDER (type 025) which was outsourced by Lionel, a US company, and said compensation would be made accordingly. Kwak, Byung Ki accepted, so I emailed the general drawing of Sam Hong Saís A AUX.TENDER right side view and other data including 015 tender truck, truck ballstar, and windows. He made the drawings based on these materials and sent them to me. In case 2), I called Kwak, Byung Ki again, this time for Sam Hong Sa BIG BOY AUX.TENDER. I made the request at about the time he finished the previous drawing. He accepted, and I emailed the general drawing data of Sam Hong Sa BIG BOY AUX. TENDER. He made the drawing based on these materials and emailed me back. The same procedure took place for case 3). I called to ask for the general drawing of Sam Hong Sa T-1 design and Kwak, Byung Ki sent it via email.
Q: Do all of the three drawings mentioned above belong to Sam Hong Sa?
A: Regarding cases 1) and 2), I sent Kwak, Byung Ki a computer diskette with the basic drawings and he completed the drawings at home. Kwak, Byung Ki emailed drawing 1) via company computer and emailed drawing 2) from home. Drawing 3) was done by Jeung, Bok Dong, an employee at Sam Hong Sa, which Kwak, Byung Ki secretly emailed to me.
Q: Is this that drawing 3) of Sam Hong Saís miniature locomotive designed by Jeung, Bok Dong which the suspect received?
(At this point, the Prosecutor shows to the suspect the copy of the drawing by Jeung, Bok Dong, which was submitted by Choi, Jun Yul on January 18, 2000, and files it in the back of this deposition.)
A: Yes, that is correct.
Q: Is this drawing a slight revision of drawing 3) done at Korea Brass where the suspect works.
(At this point, the Prosecutor shows to the suspect the drawing confiscated from Korea Brass office, and files it in the back of this deposition.
A: Yes, that is the drawing that I did based on the data of Jeung, Bok Dongís general drawing but with the outline erased.
Q: Sam Hong Sa planned to sell the miniature locomotive drawing 3 to the US. Much damage was done to Sam Hong Sa as this drawing was transferred to the suspectís company. What do you have to say?
A: I am sorry. However, I only referred to the aforementioned T-1 drawing and production of miniature locomotive never took place.
Q: Drawing 3) is valued higher than drawings 1) and 2), and so a bigger compensation must have been made to Kwak, Byung Ki. What do you think?
A: Except for the 900 thousand won for drawings 1) and 2), further compensation was not made.
Q: How did the suspect know of drawing 3) by Jeung, Bok Dong at Sam Hong Sa and ask Kwak, Byung Ki for it?
A: Ahn, Sun Gap told me that Sam Hong Sa completed its T-1 design and asked to see it. I called Kwak, Byung Ki and asked for the T-1 design. Kwak, Byung Ki said he would and emailed me the data.
Q: Why did the suspect, who was a manager at Korea Brass, go to work at Ahn, Sun Gapís Jin Planning instead of at Korea Brass?
A: President Cho, Sung Won told me to help Ahn, Sun Gap with designing and dispatched me to Jin Planning.
Q: Tell us about Jin Planning: what kind of business it is in, number of employees, turnover, etc.?
A: Ahn, Sun Gap was the only person working and I was sent to assist him. There was no target or record of a turnover.
Q: Ahn, Sun Gap and the suspect received orders and salaries from President Cho, Sung Won. Is this true?
A: Yes, that is correct.
Q: What did you do with the aforementioned miniature locomotive data (cases 1, 2, and 3)?
A: I received them from Kwak, Byung Ki and gave them to Ahn, Sun Gap, and Ahn, Sun Gap then took them over to Cho, Sung Wonís Korea Brass.
Q: From whom did the suspect receive the money envelopes that were given to Kwak, Byung Ki?
A: I received the money envelopes from Ahn, Sun Gap and gave them to Kwak, Byung Ki. I believe Ahn, Sun Gap originally received them from Cho, Sung Won.
Q: Is there a miniature locomotive design and research team at Korea Brass similar to that at Sam Hong Sa?
Q: Tell us about Korea Brass: what are its operations, number of employees, turnover, etc.?
A: Korea Brass runs sales and manufacturing operations with about 60 employees. I am not sure about its monthly turnover.
Q: Are there any other materials disclosed by the suspect?
Q: The suspect should not have taken out business secrets of Sam Hong Sa, a competition of Korea Brass, and misused them. What do you have to say?
A: I am sorry.
Q: Did the suspect seek approval from Lee, Se Yong before or after receiving the aforementioned miniature locomotive design data of Sam Hong Sa?
Q: Do you have anything else to say?
A: I did not think my actions would lead to such grave consequences. I only did what I was told by Cho, Sung Won and Ahn, Sun Gap.