Free Letter - District Court of Delaware - Delaware

Case 1 :06-cv-00788-JJF Document 236 Filed 07/O9/2008 Page 1 of 1
Bl.Ai\ll<~ ROA/1EuP
COUNSELORS AT LAW
Phone: (302) 425-64l0
Fax: (302) 428-5132
Email: [email protected]
July 9, 2008
John G. Day, Esquire Mary B. Graham, Esquire
Ashby & Geddes Morris Nichols Arsht & Tumiell LLP
500 Delaware Avenue 1201 North Market Street
Wilmington, DE 19801 Wilmington, DE 19801
Re: ProMOS Technologies, Inc. v. Freescale Semiconductor, Inc.,
C.A. No. 06-788 (JJF) - Designation of Chan Patent Claims and
Representative Products (DM 6)
Dear Counsel,
I’m writing to follow up on your respective letters of June 11 and 12 regarding the
designation of (1) the number of cllaims ofthe Chan patents that will be asserted by ProMOS,
and (2) the representative products by Freescale.
In view of the apparent, albeit reluctant, agreement between the parties regarding the
number of claims that will be asserted by ProMOS, the parties shall prepare a form of order for
Judge Farnan’s signature memorializing that agreement. That is, the form of order should
designate claims 2, 8, 12, 14, 22 and 25 for the ‘709 patent and claims 1, 16, and 26 for the ‘241
patent for presentation at trial.
As of the June 11 and 12 letters, the parties could not agree as to the representative
products. The parties shall provide an update on where they stand, with respect to an agreement,
on Preescale’s proposed representative products (which products are agreed to and which
products are at issue) by July 11, 2008. Also with this submission, for those products which the
parties do not agree upon, the parties shall set forth, in one page or less, the reasons for any
disagreement.
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Specia :. e ! i 100614)
1.201 Market Street Suite 800 Wilmington, DE 19801
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