WT/DS296/R 
Page F-1 
 
 
 
ANNEX F 
 
 
LIST OF FIGURES AND EXHIBITS 
 
 
Contents Page 
Annex F-1 List of Figures and Exhibits of Korea F-2 
Annex F-2 List of Figures and Exhibits of the United States F-9 
 
 
  WT/DS296/R 
Page F-2  
 
 
ANNEX F-1 
 
 
LIST OF FIGURES AND EXHIBITS OF KOREA 
 
  
Figure 
Korea-   
Title of Figure  
 
1  
The Extreme Business Cycles of the DRAM Industry 
 
2  
Fewer DRAM Companies Dominate the Market 
 
3  
DRAM Prices Have Become Much More Volatile 
 
4  
Prices Decline Over Time, But Are Consistent On Global Basis 
 
5  
Largest US Customers of DRAMs Insist On A Global Price  
6  
Major DRAM Customers Increasingly Manufacture in Non-US Locations  
7  
DRAM Consumption Grows Dramatically  
8  
America's Market Share by Supplier Brand  
9  
US Market Shares  
10  
Micron's Consistent Capital Spending  
11  
Relative DRAM Capital Spending  
12  
Micron and Infineon Have Global and Expanding Scale  
13  
Micron Had Improving Cashfrom Operations During Downturns  
14  
Micron Was Better Off Than Previous Troughs  
15  
Domestic Industry Has Been Increasing Market Share  
16  
Hynix Market Share and Micron/Infineon Profitability Do Not Correlate  
17  
Overview of ITC Approach to Pricing  
18  
ITC Approach to Pricing Masks Key Information  
19  
Historical Changes in DRAM Wafer-Start Capacity July 2000-April 2003  
20  
Historical Changes in DRAM Functional Capacity July 200-April 2003 
 
  
Exhibit 
Korea-   
Title of Exhibit  
 
1  
DRAMs and DRAM Modules from Korea  [Inv. No. 701-TA-431 (Preliminary)], 
Institution of Countervailing Duty Investig ation and Scheduling of Preliminary Phase 
Investigation, 67 Fed. Reg. 68176, 8 November 2002  
2  
DRAMs and DRAM Modules from Korea  [C-580-851], Notice of Initiation of 
Countervailing Duty Investigation, 67 Fed. Reg. 70927, 27 November 2002 WT/DS296/R 
Page F-3 
 
  
Exhibit 
Korea-   
Title of Exhibit  
 
3  
DRAMs and DRAM Modules from Korea  [Inv. No. 701-TA-431 (Preliminary)], 
Preliminary Injury Determination, 67 Fed. Reg. 79148, 27 December 2002   
4  
DRAMs and DRAM Modules from Korea  [C-580-851], Preliminary Affirmative 
Countervailing Duty Determination,  68 Fed. Reg. 16766, 7 April 2003  
5  
DRAMs and DRAM Modules from Korea  [C-580-851], Final Affirmative 
Countervailing Duty Determination, 68 Fe d. Reg. 37122, 23 June 2003, and Issues 
and Decision Memorandum for the Final Determination  
6  
DRAMs and DRAM Modules from Korea  [C-580-851], Notice of Amended Final 
Affirmative Countervailing Duty Determination: , 68 Fed. Reg. 44290, 28 July 2003  
7  
DRAMs and DRAM Modules from Korea  [Inv. No. 701-TA-431 (Final)], Final Injury 
Determination, 68 Fed. Re g. 47607, 11 August 2003  
8  
DRAMs and DRAM Modules from Korea  [C-580-851], Notice of Countervailing 
Duty Order, 68 Fed. Reg. 47546, 11 August 2003  
9  
DRAMs and DRAM Modules from Korea  [Inv. No. 701-TA-431 (Preliminary)], 
Determinations and Views of the Intl. Trade Commission , USITC Pub. No. 3569, 
December 2002  
10  
DRAMs and DRAM Modules from Korea  [Inv. No. 701-TA-431 (Final)], 
Determination and Views of the Intl. Trade Commission , USITC Pub. No. 3616, 
August 2003  
11  
RESERVED  
12  
In the Matter of DRAMs and DRAM Modules from Korea  [Inv. No. 701-TA-431 
(Preliminary)], Transcript of the Intl. Trade Commission Staff Conference, 22 November 2002 
 
13  
In the Matter of DRAMs and DRAM Modules from Korea  [Inv. No. 731-TA-431 
(Final)], Transcript of the Intl. Trade Commission Hearing, 24 June 2003  
14  
Hynix Presentation Material at the Intl. Trade Commission Hearing, 24 June 2003  
15  
19 U.S.C. 1677  
16  
Dynamic Random Access Memory Semiconduc tors of One Megabit and Above from 
Taiwan [Inv. No. 731-TA-811 (Final)], Determination and Views of the Intl. Trade 
Commission, USITC Pub. No. 3256, December 1999  
17  
Respondents’ Joint Post-Conference Brief, 2 December 2002 
 (a)  Hynix Answers to Commission Staff Questions  (b)  Micron London Roadshow 
 
18  
Hynix Semiconductor’s Pre-Hearing Brief; DRAMs and DRAM Modules from Korea  
[Inv. No. 731-TA-431 (Final)], 19 June 2003 
 (a)  Hynix Pre-Hearing Brief Selected Articles  
 
(b)  Berenberg Bank Sector Analysis--Semiconductors, 9 July 2002  
 WT/DS296/R 
Page F-4  
  
Exhibit 
Korea-   
Title of Exhibit  
(c)  Micron Computing and Consumer Gr oup Update Presentation, January 2003 
(Excerpts)  
 
(d)  DRAM Market Forecast: Déjà vu (Cahners In-Stat Data)  
(e)  ICIS-LOR Competitive Analysis 
 
(f)  Micron Year in Review 2001 and 2002  
 
(g)  Morningstar.com Financial Summary  
 
(h)  IDC Competitive Analysis 
 
(i)  Gartner/Dataquest Data for Market Share  
 
(j)  Micron 4Q 2002 Conference Call Excerpts  
 
(k)  Strategic Marketing Associates/International Fabs on Disks 
 
19  
Hynix Semiconductor’s Post-Hearing Br ief and Answers to Questions by 
Commissioners and Staff:  DRAMs and DRAM Modules from Korea  [Inv. No. 701-
TA-431 (Final)], 2 July 2003  
(a)  Commission and Staff Questions and Answers  
 (b)  Customer Inventories Documentation   (c)  Rambus Shipment Data  
 
(d)  Market Share Data  
 
20  
Final Comments of Hynix Semiconductor: DRAMs from Korea  [Inv. 701-TA-
431(Final)], 21 July 2003  
21  
Hynix’s Questionnaire Response to the De partment of Commerce, 27 January 2003 
 (a)  Citibank/SSB Engagement Letter    
(b)  KRW 800 Billion Loan Agreement  
 (c)  GDR Offering Memorandum   (d)  Audited Financial Reports 1998-June 2002  
 
(e)  KRW 994.1 Billion Bond Table   (f)  April 17 SSB Private Capitalization Proposals  
(g)  Outside Expert Analysis on Hynix Market Position 
 (h)  Creditor Financial Institution’s Council Meeting Agenda -- October 
Restructuring WT/DS296/R 
Page F-5 
 
  
Exhibit 
Korea-   
Title of Exhibit  
(i)  Table Listing Shares Issued in Debt-to-Equity Swap 
 (j)  October 2001 Restructuring Fresh Loan Agreement   (k)  KEIC Insurance Table  
 
(l)  SSB Discussion Documents  (m)  Hynix Stock Volume and Value Change Data 
 
22  
Questionnaire Response of the Government of the Republic of Korea to the 
Department of Commerce, 3 February 2003 
 
(a)  BOK Paper on Korean Financial Reform   (b)  Article 20.3 of the Enforcement Decree of the Banking Act   (c)  Corporate Restructuring Promotion Act  
 
23  
Hynix’s Supplemental Questionnaire Res ponse to the Departme nt of Commerce, 
4 March 2003 
 (a)  SSB/Hynix Discussion Documents from 30 July, 1 August and 9 August, 
5 September, and 27 September 2001  
 
(b)  Agreement Forming Hynix’ s First Creditor’s Council  
 (c)  KDB Debenture Programme Table  (d)  Bond Ratings issued by National Information & Credit Evaluation Inc. and 
Korea Management Consulting & Cred it Rating Corp. in Relation to KRW 
994.1 Billion CB  
 (e)  October Restructuring Package   (f)  Hynix/Citibank Letter of Intent Esta blishing Citibank’s Role and Terms of 
KRW 800 billion syndicated loan  
 (g)  KEB Bid Letter and Andersen Consulting (Korea) Report   (h)  FSC Corporate Restructuring Document 
 
24  
Hynix’s Initial Arguments on the Directed Credit Issue, 10 March 2003  
25  
Hynix’s Initial Arguments on the Indepe ndence of Korean Banks, 10 March 2003  
26  
Citibank Affidavit of 20 March 2003  
27  
Communication Between the US Depart ment of Commerce and the Korean 
Government for Verification Schedule, April 2003 
 (a)  Department of Commerce’s Letter to the Korean Embassy Informing the 
Verification Schedule in Korea, 10 April 2003 WT/DS296/R 
Page F-6  
  
Exhibit 
Korea-   
Title of Exhibit  
(b)  Korean Government’s Response to  the Department of Commerce (through 
Willkie Farr & Gallagher) Concerning the Proposed Verification Schedule, 
14 April 2003  
 (c)  Department of Commerce’s Lette r to the Korean Government (through 
Willkie Farr & Gallagher) Confirming the Original Verification Schedule, 16 
April 2003 
 
28  
DRAMs from Korea  -- CVD Investigation:  Documenting Supporting Papers on the 
Directed Credit Issue and Independence of Korean Banks and Other Relevant Documents, 14 April 2003  
(a)  An Affidavit from Kookmin Bank Attorneys to the Department of Commerce 
 (b)  Dr. Bennett A. Zelner, Explaining Investment Practices: The Shifting View 
of How Investors Actually Make Decisions 
 
29  
Citibank Affidavit of 22 May 2003  
30  
Commerce Department’s Private Financial Experts Verification Report, 15 May 2003  
31  
Commerce Department’s Verification Re port on Information submitted by Hynix 
Semiconductor, Inc., 15 May 2003  
(a)  Creditors’ Discussion Materials in Preparation for October 2001 
Restructuring 
 
32  
Commerce Department’s Verification Re port on Information submitted by Republic 
of Korea, 15 May 2003  (a)  FSC Press Release, 13 March 2001  
 
(b)  CRA/CRPA Participating Companies  (c)  FSC Granting of Exception of Single Borrower Credit Limit    
(d)  KDB Hynix Fast Track CBO and Guarantee Information  
 (e)  CRA Documents 
 
33  
Hynix’s Case Brief -- DRAMs from Korea, 22 May 2003 
 (a)  October Summary Table 
 
34  
Calculations for the Final Determin ation for Hynix Semiconductor, Inc., 
16 June 2003 
35  
RESERVED  
36  
US Government Printing Office, Code of Federal Regulation , 19 CFR 351.505 and 
351.508  
37  
The Concise Oxford Dictionary, Ninth Edition, 1995  
38  
The New Shorter Oxford English Dictionary , Fourth Edition, Clarendon Press, 
Oxford (1993) WT/DS296/R 
Page F-7 
 
  
Exhibit 
Korea-   
Title of Exhibit  
 
39  
Countervailing Duty Petition: Dynamic Random Access Memory from Korea, 
1 November 2002 (Excerpts)  
40  
Examples of Bailouts by the US Government for Key US Industries     
41  
Hynix Semiconductor America’s Importer Questionnaire  
42  
Robert F. Emery, Korean Economic Reform , Ashgate 2001  
43  
Semiconductor Forecast: First Quarter 2004  
44  
ITC Questionnaires Issued in the Underlying Investigation 
 (a)  Producers’ Questionnaire  
(b)  Importers’ Questionnaire 
 (c)  Purchasers’ Questionnaire 
 
45  
Prime Minister’s Decree No. 408 (13 Nov. 2000)  
46  
The New Shorter Oxford English Dictiona ry, Thumb Index Edition Clarendon Press, 
Oxford (1993)  
47  
Oxford Hachette French Dictionary, Thir d Edition, Oxford University Press (2001)  
48  
Oxford Spanish Dictionary, Third Edition, Oxford University Press (2003)  
49  
Evidence Submitted to the USDOC To Pr ove Absence Of GOK Influence Over 
KorAm Bank  
50  
FSC/FSS Document Requesting Banks To Conduct Reliable and Stringent Credit 
Risk Assessment For Potentially Non-Viable Corporations (21 Oct. 2000)  
51  
List of Korean Companies That Were Liquidated After The 1997 Financial Crisis 
Based on Market Principles  
52  
Documentation Showing GOK Safeguards To  Prevent Outside Intervention With 
Banks’ Day-to-Day Operation By Imposing Legal Obligation on Bank Officials To 
Make Commercially Reasonable Decisions  
53  
Sample MOU  
54  
Press Report Regarding KFB’s Own Decision Not To Participate In the KDB Fast 
Track Programme  
55  
Communication With Respect To Kyungnam Bank’s Exercise of Appraisal Rights In 
The October Restructuring  
56  
List of Credit Limit Waivers Granted By the GOK  
57  
Evidence Submitted to the USDOC To Prove  Absence Of GOK Influence Over KFB  
58  
FSS Press Release Correcting Mistaken Press Reports About FSS’s Exercise of 
Influence Over Credit Rating Agencies  
59  
Comparison of Korean Credit Rating System and S&P/Moody’s  
60  
Bank of Korea Annual Report Showing Yields on Three-Year Corporate Bonds in 
Korea WT/DS296/R 
Page F-8  
  
Exhibit 
Korea-   
Title of Exhibit  
 
61  
USDOC Verification Report Proving Hynix Creditors’ Meeting in December 2000 
for KDB Fast Track Programme Application  
62  
US Market Shares and Source Documentation  
63  
Documentation Regarding Samsung Rambus Shipments  
64  
Kookmin's Corporate Loan Process Documents 
 
 WT/DS296/R 
Page F-9 
 
 
 
ANNEX F-2 
 
 
LIST OF FIGURES AND EXHIBI TS OF THE UNITED STATES 
 
  
Figure US-   
Title of Figure  
 
1  
Business Proprietary Information on DRAM  Consumption, Shipments and Imports 
 
2  
The Numerous Time Periods in the Data Sources Used by Korea 
 
3  
The Constituent Parts of Hynix’s Debt Restructuring 
 
4  
GOK Ownership in Hynix’s Creditors and their Participation in Hynix’s 
Restructuring   
 
5  
Summary of Data Pertinent to ITC's Determination of Material Injury by Reason of 
Subject DRAM Products from Korea 
 
  
Exhibit US-   
Title of Exhibit  
 
1  
Letter dated 10 July 2003, from United St ates to Korea accepting first consultation 
request 
 
2  
Letter dated 28 August 2003, from United States to Korea accepting second 
consultation request 
 
3  
Letter dated 8 September 2003, from Korea to United States  
 
4  
Letter dated 10 September 2003, from United States to Korea 
 
5  
Minutes of the Meeting of the Dispute Settlement Body Held on 1 December 2003 , 
WT/DSB/M/159, pages 1 and 7-8 
 
6  
The Political Economy of the Financial Libera lization and Crisis in Korea, Working 
Paper No. 99-06, Yoon Je Cho (October 1999) 
 
7  
Creating Advantage; Semiconductors and G overnment Industrial Policy in the 1990s, 
T. Howell, et al., Semiconductor Industry Association (1992) 
 
8  
Direction of Credit Memo, dated 31 March 2003. 
 
9  
C. Soh, The State, Technology, and Industrial Competitiveness: Steel and 
Semiconductor Industries in Korea, Fletcher  School of Law and Diplomacy (Graduate 
Thesis) (1991) 
 
10  
Sung Gul Hong, The Politics of Industrial Leapfrogging: The Semiconductor Industry 
in Taiwan and South Korea, Northwestern University Ph.D Dissertation 
(December 1992). 
 
11  
Sung Gul Hong, The State and Sectoral Development: The Semiconductor Industries 
of Taiwan and South Korea, Northwestern University Department of Political Science WT/DS296/R 
Page F-10  
  
Exhibit US-   
Title of Exhibit  
(1992). 
 
12  
GOK Verification Report 
 
13  
Bank for International Settlements, “The Banking Industry in the Emerging Market 
Economies: Competition, Consolidation and Sy stemic Stability,” BIS Papers No. 4 at 
95 (August 2001) 
 
14  
American Boss Dispenses With Protocol at South Korean Bank, Wall Street Journal 
(29 January 2001) 
 
15  
With Growth in Site, Korea Plans Privati zation for Banks, New York Times, Don Kirk 
(7 March 2002) 
 
16  
No Pause for Woori: Seoul’s Major Bank Pr ivatization Vehicle has Gotten Off to a 
Promising Start, Euromoney Institutional Investor (1 July 2002) 
17  
The State Activism toward the Big Busi ness in Korea, 1998-2000: Path Dependence 
and Institutional Embeddedness, Jiho Jang,  University of Missouri-Columbia 
(April 2001) 
 
18  
With Bank Merger, S. Korea Takes Steps to Revamp Economic System, Los Angeles 
Times (2 January 1999) 
 
19  
Banks Halt Loans to LG Semicon, CN ET news.com (28 December 1998) 
 
20  
So Much for Reform, Business Week International (26 July 26 1999) 
 
21  
The Great Universe is Torn Asunder, Euromoney (September 1999) 
 
22  
Kim’s Big Deals with the Chaebol Sound Be tter than they Really Are, Asiaweek 
(26 February 1999) 
 
23  
Hynix Creditworthiness Memorandum  
 
24  
Hynix Back from Jaws of Defeat, The Asset (5 September 2001) 
 
25  
Hynix Practically in Default, . . . What’s the Problem?  Chosun Daily 
(29 August 2001)(English Translation) 
 
26  
Creditors Deny Hynix Receivership Rumors, Korea Times (4 May 2001) 
 
27  
Chong Wa Dae Defends Hyundai Rescue, Korea Times (7 February 2001) 
 
28  
Results of Discussions at the Economic Ministers’ Meeting, letter from Ministry of 
Finance and Economy (28 November 2000) w ith enclosure (translated version) 
 
29  
Direct Intervention by the Government in Supporting Hynix, The Korea Economic 
Daily (28 August 2001) 
 
30  
Regarding the Provision of Export Insurance for the Hyundai Electronics’ D/A 
transaction, letter from Ministry of Commerce, Industry and Energy 
(30 November 2000) (t ranslated version) 
 
31  
Results of Discussions at the Economic Ministers’ Meeting, letter from Ministry of 
Finance and Economy (10 January 2001) w ith enclosure (translated version) WT/DS296/R 
Page F-11 
 
  
Exhibit US-   
Title of Exhibit  
 
32  
Results of Discussions at the Economic Ministers’ Meeting, letter from Ministry of 
Commerce, Industry and Energy (12 Ja nuary 2001) (translated version) 
 
33  
Advising the Results of Discussions at the Economic Ministers’ Meeting, letter from 
Ministry of Finance and Economy (10 April 2001) (translated version) 
 
34  
No End in Sight, Asiaweek.com (24 November 2000) 
 
35  
Hynix Says Deal Close to Stave Off Debt Woes, Electronic Engineering Times 
(17 September 2001) 
 
36  
GOK Supplemental Questionnaire Response (11 March 2003) 
 
37  
Chart of Hynix Creditors (16 June 2003) 
 
38  
Chart of Outstanding Long-Term Balance at End of 2001 
 
39  
KDB to Acquire Hyundai Electronics Bonds , KDB Press Release (3 January 2001) 
 
40  
Hynix Supplemental Questionnaire Response  (5 March 2003), at 19-20 
 
41  
Hyundai’s Brinkmanship vs. Timid Government, Korea Times (10 January 2001) 
 
42  
Rescue of Three Hyundai Companies Deepen s Doubts Over Reform Drive, Korea 
Herald (12 March 2001). 
 
43  
Hynix Verification Report 
 
44  
Republic of Korea: Financial System Stab ility Assessment, International Monetary 
Fund, IMF country Report No. 03/81 (March 2003) 
 
45  
Kookmin Bank Prospectus (10 September 2001) 
 
46  
Kookmin Bank Prospectus (18 June 2002) 
 
47  
Four Commercial Banks Get W775 bil. in Public Funds, The Korea Herald 
(1 January 2001) 
 
48  
Six Banks to Receive W3 tril. in A dditional Public Funds, Korea Times 
(27 September 2001) 
 
49  
KEB to Receive 336 Bil. Won in Public  Funds, Korea Times (28 January 1999) 
 
50  
KFB Gets W18 Tril. In Public Fund (20 January 2003) 
 
51  
Corporate Restructuring Promotion Act, Articles 2, 27 (1) 
 
52  
Foreign Banks Required to Attend Creditor Meetings for Ailing Firms, Korea Times 
(22 July 2001) 
 
53  
Banking Act, Article 35  
 
54  
Hyundai Electronics May Seek Loans Beyond Borrowing Limit, AFX News Limited, 
AFX-Asia (1 December 2000) (translated version) 
 
55  
Panel to Approve Excess Credit Provision to Hyundai Electronics, Korea Herald WT/DS296/R 
Page F-12  
  
Exhibit US-   
Title of Exhibit  
(2 December 2000) (translated version) 
 
56  
KFB Changing Fast Under Profit-First Ma nagement, Korea Times (29 January 2001) 
 
57  
Government’s Compulsory Allotment of Corporate Bond Causes a Stir, Korea 
Economic Daily (6 January 2001) 
 
58  
FSS-Korea First Bank Collide Head-on Over Corporate Debentures, The Korea Daily 
News (6 January 2001) 
 
59  
This Banker Breaks Rules: Wilfred Horie Riles the Establishment, BusinessWeek 
Online (9 April 2001) 
 
60  
Korea First Bank Shuts Government ‘Wa llet’ Under New Management, Bloomberg 
(30 January 2001) 
 
61  
Cooperate or be Damned, Euromoney (February 2001) 
 
62  
Foreign Bank in ROK Rebels Against Govt  Bond Purchase Order, The Daily Star 
(6 January 2001) 
 
63  
Korea First Bows to Gov’t pressure, The Digital Chosun, (27 March 2001) 
 
64  
KorAm Reluctantly Continues Financial Support for Hynix, Korea Times 
(21 June 2001) 
 
65  
Hynix Questionnaire Response (27 January 2003) at Exh. 19 
 
66  
Korean Banks Complete Purchase of KRWIT Hynix Conv. Bond, Dow Jones 
International News (20 June 2001) 
 
67  
Banks Under Fire for Reducing Export Credit Ceilings for HEI, Korea Herald 
(27 January 2001) 
 
68  
Creditor Group Conflicts With Government  Over Supporting Hyundai Group, Maeil 
Economic Daily (2 February 2001) 
 
69  
Financial Community’s Support for Hyundai Electronics – A US Subsidiary Facing 
Insolvency Risk, Maeil Economic Daily (7 Mar. 2001) (English translation) 
 
70  
Corporate Restructuring and Reform: Lessons from Korea, W. Mako, Korean Crisis 
and Recovery, David T. Coe & Se-jik Kim, eds. (2002) 
 
71  
Not an Outright Order of Do-this-Do-that, but a Subtle Pressure, Dong-A Ilbo 
(6 March 2001) (translated version) 
 
72  
FSS Asked for Reflection of Hyundai Aff iliates’ Improved Business Performance on 
Credit Rating, Korea Economic Daily (27 January 2001) (translated version) 
 
73  
Interest Rate on Hyundai Electronics Corporate Debentures Likely to Go Up by 1.8% 
Points ... Result of Downgraded Credit Rating, Korea Economic Daily 
(30 January 2001) (translated version) 
 
74  
Does the FSS Peddle Influence even on Credit Ratings?  Hankyoreh Shinmun 
(14 February 2001) (translated version) 
  WT/DS296/R 
Page F-13 
 
  
Exhibit US-   
Title of Exhibit  
75 Corporate Credit Rating ‘Wobbles’ Under the Sway of Government Influence, Dong-
A-Illbo (1 March 2001) (translated version) 
 
76  
FSC Chairman Lee, ... Will Demand Correc tions on Incorrect Credit Ratings, Seoul 
Economic Daily (8 February 2001) (translated version) 
 
77  
Does the Government Do Corporate Credit Rating?  Dong-A-Ilbo 
(2 March 2001)(translated version) 
 
78  
The Creditor Group Finalizes Financing Package for 3 Hyundai Affiliates, Naeoe 
Economic Daily (10 March 200 1) (translated version) 
 
79  
The Grace Period Decision for Three Affiliates of Hyundai Group – Stories of Inside 
and Outside, Korean Seoul Economic Daily  (11 March 2001) (translated version) 
 
80  
Never-ending Aid for Hyundai, Korea Times (12 March 2001) 
 
81  
Self-Rescue Before Asking for Help, The Korea Economic Daily (11 January 2001) 
(translated version) 
 
82  
Government and Creditor Group ‘Bewild ered’ by Hyundai Electronics ‘Dogged 
Clamoring’, Kookmin Daily (11 Janua ry 2001) (translated version) 
 
83  
Seoul, Commerzbank Expected to Inject W600 Billion Into KEB, Korea Herald 
(26 September 2000) 
 
84  
State-Run Bank Will Buy W20 Trillion Wort h of Corporate Bonds, Korea Herald 
(27 December 2000) 
 
85  
ShinHan Bank (ING Barings, 24 April 2001) 
 
86  
KorAm Bank (ING Barings, 26 September 2002) 
 
87  
Hana Bank (Morgan Stanley, Dean Witter, 30 October 2001) 
 
88  
Kookmin Bank (Morgan Stanley, Dean Witter, 24 October 2001) 
 
89  
The New Shorter Oxford English Dictionary (1993) 
 
90  
Moody’s Investors Service, Historical Default Rates of Corporate Bond Issuers, 1920-
1997 (February 1998) 
 
91  
Specificity Memorandum (16 June 2003)    
92  
Letter dated 23 April 2003, from Hale & Dorr to Secretary of Commerce 
 
93  
A More Detailed Description of the Commiss ion’s Investigation Process to Illustrate 
the Fairness and Transparency of the Process 
 
94  
In the Matter of DRAMs and DRAM Modules from Korea, Inv. No. 701-TA-431 
(Final), Transcript of the International Trade Commission Hearing (24 June 2003) 
(selected pages) 
 
95  
In the Matter of DRAMs and DRAM Modules from Korea, Inv. No. 701-TA-431 
(Prelim.), Transcript of the International Trade Commission Staff Conference 
(22 Nov. 2002) (selected pages) WT/DS296/R 
Page F-14  
  
Exhibit US-   
Title of Exhibit  
 
96  
Micron’s 2 July 2003, Posthearing Brief (selected pages) 
 
97  
Comments on Draft ITC Final Phase Questionnaires by Hynix Semiconductor Inc. and 
Hynix Semiconductor America (24 Mar. 2003) 
 
98  
Infineon’s 27 November 2002, Postconference Brief (selected pages) 
 
99  
Micron’s 27 November 2002, Postconference Brief (selected pages) 
 
100  
2 December 2002, Postconference Brief of Hynix and Samsung (selected pages) 
 
101  
Hynix’s 19 June 2003, Prehearing Brief (selected pages) 
 
102  
DRAMs and DRAM Modules from Korea , 68 FR 18671 (16 Apr. 2003) 
 
103  
Willkie Farr & Gallagher’s 4 November 2002, Letter to The Hon. Marilyn R. Abbott, 
Secretary, US International Trade Commission 
 
104  
4 November 2002 Administrative Protective Order 
 
105  
Letter to Chairman Okun, US Internationa l Trade Commission from the Governor of 
Chungcheongbuk-do and the Chairman of  Cheongju Chamber of Commerce and 
Industry (12 Jul. 2003) 
 
106  
Letter to Marilyn R. Abbott, Acting Secretary, US International Trade Commission 
from the Embassy of the Republic of Korea (2 June 2003) 
 
107  
Letter to Hon. Donald Evans, Secretary of Commerce, US Department of Commerce 
from the Deputy Prime Minister and Minister of Finance and Economy of the Republic of Korea, copied to Chairman Okun, US International Trade Commission 
(9 Apr. 2003) 
 
108  
Hynix’s 2 July 2003, Posthearing Brief (selected pages) 
 
109  
Section 751(a) of the Tariff Act of 1930, 19 U.S.C. 1675(a) 
 
110  
Letter from Commerce Department to W illkie Farr & Gallagher RE: Countervailing 
Duty Investigation: Dynamic Random Access Memory Semiconductors From the 
Republic of Korea (16 April 2003) 
 
111  
Letter from John Brinkman, Acting Office Direct or to Hae-yong Kim, Embassy of the 
Republic of Korea RE: Countervailing Duty  Investigation: Dynamic Random Access 
Memory Semiconductors from the Republic of Korea (10 April 2003) (“Verification 
Itinerary”) 
 
112  
Letter from Willkie Farr & Gallagher to DOC RE: GOK’s Comments on the Proposed 
Verification Schedule DRAMs from Korea (dated 14 April 2003) 
 
113  
Memorandum from Team through Susan H. Kuhbach, Director RE: Briefing and 
Hearing Schedules (16 May 2003) 
 
114  
Letter from Hale and Dorr to DOC RE: Dynamic Random Access Memory 
Semiconductors from the Republic of Ko rea – Factual Information Submission 
(22 May 2003) WT/DS296/R 
Page F-15 
 
  
Exhibit US-   
Title of Exhibit  
 
115  
Public fund Mismanagement Inves tigation Report, Special Committee on 
Parliamentary Inspection of Public Fund Administration (November 2002) (translated 
version from DOC record) (excerpts) 
 
116  
Semiconductor Industry Blue Book 2001, Worl d Semiconductor Trade Statistics, at 18 
 
117  
 “Jin Vows to Eliminate Uncertainties Thr ough Further Restructuring Efforts,” The 
Korea Economic Daily, 4 August 2001 
 
118  
Deputy Prime Minister Chin, “Government Will Take Actions to Turn Around Hynix , 
KOREA ECONOMIC DAILY  (4 August 2001) (t ranslated version) 
 
119  
Hynix Questionnaire Response  (28 January 2003), pages 14-15, 26, 38-42, 51, 54, 65 
 
120  
Kookmin 2001 Annual Report 
 
121  
Hynix Semiconductor’s Post-Hearing Brief and Answers to Questions by Commissioners 
and Staff  (2 July 2003) (Non-confidential version) 
 
122  
In the Matter of DRAMs and DRAM Modules from Korea, Inv. No. 701-TA-431 
(Final), Transcript of the International Trade Commission Hearing (24 June 2003), 
pages 205 and 250 
 
123  
Corporate Restructuring Promotion Act, Article 14 
 
124  
Korean Restructuring Law May Hurt Credit Growth and Credit Quality of Financial 
Firms , STANDARD & POOR’S RATINGS DIRECT  (26 September 2001) 
 
125  
Hynix Audit Report (2001) (selected pages) 
 
126  
Supplemental Questionnaire  to the GOK, Question 24, (19 February 2003) 
 
127  
See Seoul Pushes for a New “Big Bang” in Banking , ASIA TIMES ONLINE  
(18 March 2000); Government Control of Banks Diehard , HANGKOOK ILBO 
(13 March 2003); High-Handed Companies Sued for Unilateral Shareholders 
Meeting , KOREA TIMES  (5 April 2000) 
 
128  
GOK Questionnaire Respons e (4 February 2003) at A-17 to A-19 
 
129  
Hynix Questionnaire -Response (27 January 2003) at 60 
 
130  
DOC Supplemental Questionnaire to Hynix  (11 February 2003) at question 54 
(page 10) 
 
131  
Corporate Governance in Korea, Il Chong Na m et al., Korea Development Institute 
(from Organization for Economic Co-ope ration and Development conference on 
Corporate Governance in Asia: A Comparativ e Perspective) (Seoul, 3-5 March 1999) 
 
132  
Korea’s Economic Crisis and Corporate Governance, Sang-Woo Nam, School of 
Public Policy and Management, Kor ea Development Institute (undated) 
 
133  
‘Gangster-Style’ Solution for Hynix,  Dong-A Daily (1 November 2001)  
 
134  
GOK Questionnaire Response (4 February 2003) WT/DS296/R 
Page F-16  
  
Exhibit US-   
Title of Exhibit  
 
135  
Countervailing Duty Petition (1 November 2002) 
 
136  
Grace Period Discussion on Hyundai Electronics, Maeil Economic Daily 
(10 March 2001) (tra nslated version) 
 
137  
Kookmin Urges Seoul to Sell off its Stak e, Financial Times (10 November 2001) 
 
138  
Highhanded Companies Sued for Unilateral Shareholders Meeting, Korea Times 
(5 April 2000) 
 
139  
Seoul Pushes for a New ‘Big Bang’ in Banking, Asia Times (18 March 2000) 
 
140  
Soundness of Financial Sector Still Remains Remote, Korea Times 
(2 September 2002) 
 
141  
Hynix, Will it Really Survive?, Ne wsmaker, No. 439 (30 August 2001) 
 
142  
An Expensive Decision, Asiamoney (September 2001) 
 
143  
Deputy Prime Minister Chin, ‘Government w ill Take Actions to Turn Around Hynix’,  
Korea Economic Daily (4 August 2001) (translated version) 
 
144  
Jin Vows to Eliminate Uncertainties Thru Furthering Restructuring Efforts, Korea 
Times (4 August 2001) 
 
145  
Korean Official Defends Seoul’s Efforts on Economy, The New York Times, 
(23 February 2002) 
 
146  
Bank Should be Allowed to Make Decision on the Matter of Support for Specific 
Companies, Maeil Economic Daily (11 March 2001) 
 
147  
Banks Open Talks on Hynix Lifeline, BBC News (3 September 2001) 
 
148  
FSC Chairman Promises Sale of Daew oo Motor This Month, Korea Herald 
(10 September 2001) 
 
149  
The Office of National Tax Administration ’s Decree to Recognize the Creditors’  
Write-Off of the Hynix Loan as a Tax Deductible Expense … May Give Rise to an 
Issue of Preferential Treatment, Korea Econom ic Daily (6 November 2001) (translated 
version) 
 
150  
Standard and Poor’s Press Release (5 October 2001)  
 
151  
Hynix GDS Offering Memorandum 
 
152  
Micron’s 14 March 2003 Comments to the US Department of Commerce 
 
153  
Micron Case Brief (22 May 2003) 
 
154  
Stainless Steel Plate in Coils From the Republic of Korea, Final Negative 
Countervailing Duty Determination,  64 Fed. Reg. 15 530 (31 March 1999) 
155 Creditor Group ... Asks Investment Trust Co mpanies to Take Over 750 Billion Won of 
Hynix Corporate Debentures, The Korea Ec onomic Daily (3 May 2001) (translated 
version) WT/DS296/R 
Page F-17 
 
  
Exhibit US-   
Title of Exhibit  
 
156  
Finance/Conflict Between Banks and Investme nt Trust {Companies} Over Support for 
Hynix, Dong-A Daily (4 May 2001) (translated version) 
 
157  
Seoul’s Continuing Support Spawns Fresh De bate Over HEI’s Viability, Korea Herald 
(14 March 2001) 
 
158  
KEB Ownership Structure Chart  (2001) 
 
 
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