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February 15, 2008
VIA CM/ECI? FILING & HAND DELIVERY
The Honorable Gregory M. Sleet
Chief Judge
U.S. District Court for the District of Delaware
844 N. King Street
Wilmington, DE 19801
RE: ExxonMobil Oil Corporation v. Hyundai Mobis Co., Ltd., et al.,
C.A. No. 07—177 {GMS]
Dear Chief Judge Sleet,
We are counsel to plaintiff ExxonMobil Oil Corporation ("Mobil") in the above—
referenced matter. Pursuant to Your l*Ionor’s January 4, 2008 Order, we provide this updated
status letter to apprise the Court of ongoing developments in the parties’ efforts to reach a
settlement in this case. Counsel for defendants Hyundai Mobis C0., Ltd., Mobis America, Inc.,
Mobis Parts America, LLC, Mobis Parts Detroit, LLC and Mobis Alabama, LLC (collectively,
“Mobisâ€) have reviewed this Eetter and approved its filing-
Since our status letter of January 2, counsel for the parties have continued to discuss
settlement, and have exchanged several written proposals. On January 29, counsel held a
meeting at ExxonMobil’s headquarters and jointly prepared an outline of possible settlement
scenarios for presentation to their respective management. As a result of those discussions, a
proposal containing a potentially promising new approach to settlement was advanced just this
week, and the parties are currently discussing the details of that proposal.
The parties believe that substantial progress has been made toward settlement, and
remain hopeful that they will reach an amicable settlement of the claims in this case. However,
there are several issues remaining to be resolved, which must be discussed with and approved by
management for both sides (including l\/lobis’ principals in Korea), and the parties anticipate that
these discussions will necessarily continue for several more weeks.
Rl..Fl-3254318-1
Case 1:07-cv-00177-Gl\/IS Document 16 Filed 02/15/2008 Page 2 of 2
The Honorable Gregory M. Sleet
February I5, 2008
Page 2
Therefore, if it is satisfactory to the Court, the parties propose to provide the Court with a
further update regarding the status of negotiations on or before March 17, 2008. if the parties
have not made additional substantial progress towards resolving the dispute by that time, they
expect to proceed with the litigation and will request that the Court reset the scheduling
conference.
As always, if Your Honor has any questions or concerns regarding the foregoing, counsel
are available at the Court’s convenience.
Respectfully,
Cifltxlttl mwl xgéii
Anne Shea Gaza (#4093)
cc: John Shaw, Esq. (via email)
Louis T. Pirkey, Esq. (via email)
Stephen P. Meleen, Esq. (via email)
William J. Wade, Esq. (via email)
RLFl~32S43l8··§
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