Free Affidavit - District Court of Delaware - Delaware

Case 1 :07-cv-00357-JJF Document 53 Filed 06/OQ/2007 Page 1 of 3
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IN TI-IE UNITED STATES DISTRICT COURT mm gp R 2 Q ppl g; { 8
POR THE WESTERN DISTRICT OF WISCONSIN ` " " l Y H `
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AU OPTRONICS CORPORATION, 5
Plaintiff, E
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V` { Civil Action No. 07-C-0137-S
LGPHILIPS LCD CO., LTD. and E
LG.PI—l]L[PS LCD AIVIERICA, .
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Defendants. E
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DECLARATION OF DONG HOON HAN .
I, Dong Hoon Han, hereby declare and state:
I. I am over the age of 18 and have personal knowledge about the facts described
below.
2. I am the Accounting Manager for LG.Philips LCD America, Inc. ("LPLA").
LPLA is a corporation organized under the laws of the State of California, with its principal
place of business located in San Jose, California. I have examined the records of LPLA from
January 1, 2004 to the present. The declarations herein are made based upon my personal
knowledge and review of these records.
3. LPLA has six offices in the United States. Two of LPLA’s offices are located in
California, two are in Texas, one is in North Carolina and one is in Illinois. LPLA does not have
any offices or employees in Wisconsin.
4. LPLA sells Liquid Crystal Display (“LCD") modules, which are a type of flat
panel display incorporated into products such as portable computers, computer monitors and
televisions- LPLA sells its LCD modules to customers located in states other than Wisconsin.
Except for the one shipment detailed below, LPLA does not ship products into Wisconsin.

L Case 1 :07-cv-00363-JJF Document 53 Filed 06/0/6€OO7 Page 2 of 3
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5. LPLA has not sold products in Wisconsin.
6. LPLA has not entered into any contracts in Wisconsin.
7. LPLA has not done or transacted business in Wisconsin.
S. LPLA has not advertised in Wisconsin.
9. LPLA is not registered to do business in Wisconsin.
10. LPLA does not maintain an office or other business facility in Wisconsin.
11. LPLA does not have a mailing address or telephone number in Wisconsin.
I2. LPLA does not have personnel or agents in Wisconsin.
13. LPLA does not have subsidiaries or affiliates in Wisconsin.
14. LPLA does not maintain a bank account in Wisconsin.
15. LPLA does not own, use or possess any real property situated in Wisconsin nor
has LPLA acquired possession of or control over any asset or thing of value in Wisconsin.
16. LPLA has not engaged in any persistent course of` conduct in Wisconsin.
17. LPLA has not committed any torts in Wisconsin. l l
18. Since January 1, 2004, LPLA has made product shipments to various locations in
the United States. In 2004, 2005 and 2007, LPLA did not make any shipments to Wisconsin. In
2006, LPLA made only one shipment to Wisconsin. The value of this single shipment was
$2,100 which equates to 0.0004% of LPLA’s total U.S. shipments since January l, 2004.
19. The one shipment in 2006 to Wisconsin was a drop shipment of 15 LCD modules
sold for $2,100 total to LPLA’s customer, All American Semiconductor, Inc. ("All American"), g
in Fremont California. At the request of All American, LPLA had the modules shipped to a third
party in Hartford, Wisconsin. The shipment was made F.O.B. Shipping Point in San Jose h
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l C Case 1 :07-cv-0035;]: Document 53 Filed 06/06/2007 Page 3 of 3
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California. Consequently, All American took title to the products in California before they were
shipped to Wisconsin; and the sales transaction took place and was completed between LPLA
and All American in California. The invoice for $2,100 was sent to All American
Semiconductor at its Miami corporate oftice. This drop shipment was LPLA’s only shipment to
Wisconsin since January 1, 2004. Attached as Exhibit 1 is a true and correct copy of LPLA’s
invoice, dated October 31, 2006, to All American Semiconductor, Inc. for this shipment.
I declare under penalty of perjury that th foregoing is true and correct.
Executed on March j—_€=»_, 2007. p
Dong n Han ·

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