Free Letter - District Court of Delaware - Delaware

__ Case 1 :06-cv-00753-GIVIS-IVIPT Document 6 Filed 06/18/2007 Page 1 of 4
l ` l ` {M \ H¤||¤¤d Shielding Systems BV

/ PO. Box 730
NL-3300 AS Dordrecht
the Netherlands
Jacobus Lipsweg 124
NL—3316 BP Dordrecht
Phone +31 (0)7B — 613 13 66
Fax +31 (0)78 - 614 95 85
ABN/AMRO la k 49.55.%.625
an Petal T' .Dal1c0 lBAN NL 34AEl;’»nNAO4955BE625
United States district court K_V_K_ H, 23057218
for the district of Delawere BTW/VAT nr NL so4.474.oee.eo1
844 NOI‘hl Kl11gSU‘€€t info@hollandshieldingcom
Lockbopx 18 www.hollandshieIding.com
Wilmington 1 WWW.lE·1TH(ZlB.yC£il:]€S.COfTl
l USA
the Netherlands, Dordrecht, 31st of Mai 2007
re: CA no 06-753
Dear Sir,
Pls find enclosed the email we have send dated 24 Mai 2007 and 31 Mir 2007 for attention of
mr Francis DiGiovanni, ( #3189) of Connoly Bove Lodge & Hutz, representing Plainttiff,
Parker-Hannifin Corp. _
We got the complaint, unsigned, only on the ll th of Mai from the Dutch Court in
Rotterdam, without any description of them. However is was dated ll dec 2006. So we have
reacted just in time. I have spoken to the ombudsman of the court mr John E. James and he
told me that we still react just in time.
We try to reach an amicable settlement with Parker and we made an appointment with their
European Manager, for the 15 th of Junein our offices. However I send emails and tried to
phone mr DiGiovanni but he did not confirm until now.
ln this complaint we were not told product ( and we make over 20.000 different parts) is
involved and to which customer we should have delivered this, so that we can defend
ourselves. Only that reason makes that we can not answer nor defend. i
We hope we are allowed to tell our own story on this complain for the jury, and l hope that
we get the invitation to do so just in time. ls there any need to get a Delawere lawyer with us,
or are we allowedti} do this ourselves?
Best Regards?
Jan van Tierllroxierf" Managing Director,
\*··.-···"’/
Enclosed: copy email dd 24-5-07 and 31-5-07 to mr DiGiovani / copy of complaint 06-753

6 J Cawsrepj :06-cv-00753-GIVIS-IVIPT Document 6 Iiiled 06/18/2007 Page 2 of 4
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//0' IN THE UNITED STATES DISTRICT COURT Zgggpys _,., ,__, »
. FOR THE DISTRICT or DELAWARE ***8 R VR '+= ii Li
PARKER-HANNIFIN CORPORATION, )
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Plaintiff ) __
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v. ) . C.A.Ne. —T 5 3 *1.
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HOLLAND SHIELDING SYSTEMS B.V., ) JURY TRIAL DEMANDED
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Defendant. )
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COMPLAINT
Plaintiff, PARKER-HANNIFIN CORPORATION, as and for its complaint against
defendant, HOLLAND SHIELDING SYSTEMS B.V., alleges as follows:
PARTIES 8
1. Plaintiff, PARKER-HANNIFHNT CORPORATION (hereinafter "PARKER"), is a
corporation organized and existing under the laws ofthe State of Ohio, having its principal place of
business at 6035 Parkland Blvd., Cleveland, Ohio.
2. Defendant, HOLLAND S1-HELDING SYSTEMS B.V. (hereinafter "I-ISS"), is, on
infomation and belief, a corporation organized and existing under the laws ofthe Kingdom of the
Netherlands, with its principal place of business at J acobus Lipsweg 124, 3316 BP Dordrecht, The
Netherlands. n -
JU RISDICTION AND VENUE
3. The jurisdiction of this Court arises under 28 U.S.C. §§ 1331 and 133 8(a).
- 4. _Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b) and (c), and 1400(b),
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ComplaintParkcQCae,e0]$:Q§—cv-00753-GI\/IS-I\/IPT Document 6 Filed 06/18/2007 Page 3 of 4
Onderwerpz complaint Parker ca nr 06 753
Van: "Holland Shielding Systems B.V."
Datum: Thu, 24 May 2007 12:46:40 +0200
Aan: [email protected]
dear Giovanni,
We have received your complaint, last week , on flame retardent gaskets.
As you can see in the attachment , this was also publiced in the item, (at that time an important
paper for electro—magnetic shielding0 , in april 1997 , however we send that ad already in januari
1997 or even before.
We produce flame retardant gaskets since 1989.
At that time we worked mostly with coatings on the textile but the main business we do now is to
make gasket with flame retarded foam core, as you can read in our catalog and website. By the
way in that case we are sure that your patent on coatings do not stand up.
We even have not any UL 94 Vo approval at this time, for we use mostly flame retardant foams,
so we do not see that Parker could have any problem with us.
Vlfhen i looked in my files, mr Martin Lapp the CEO of Parker( if I m well informed) tried to sell
us in febr 1996 as employee of Monsanto material to produce gaskets.
We are a small company with 8 employees and sell to USA at this moment less as $ 20,000.-- of
all kind of shielding products
Of coarse we do not like to disturb anyones business, we believe in our own force and hope to can I
cooperate with Parker as friend, for we buy for some application even their products!
We hope that mr Lapp will buy our company in stead of fighting with us at the Court of Delaware,
and we hope you will bring this proposal under his attention.
Pls let me know if you want anything more from us. Is it important and usual in USA that we send
this letter also to the court?
Best Regards,
Jan van Tienhoven
Holland Shielding Systems BV
P.O. Box 730
NL 3300 AS Dordrecht
the Netherlands
phone+ 3178 61313 66
fax+3l 786 1495 85
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{ ,t _ Case 1 :06-cv-00753-GIVIS-IVIPT Document 6 Filed 06/18/2007 Page 4 of 4
parker patent claim/Delaware 06-753
l Onderwerp: parker patent claim/Delaware 06-753
Van: "Holland Shielding Systems B.V."
Datum: Thu, 31 May 2007 14:25:51 +0200
Aan: fdigiovam1i@,cblh.com
dear rm DiGionvanni,
Thank you for passing my request to you , dated 24 Mai 2007, through to the management of
Parker.
The European manager will visit me on the 15 th of June for a discussion in our company.
Pls be so kind to contirm that we have a stop in legal actions, during these negotiations, else we
have to make even more cost for defending ourselves.
You can be sure that we have always have and always will respect the patents mentioned in your
complaint.
Best Regards,
Jan van Tienhoven
Holland Shielding Systems BV
P.O. Box 730
NL 3300 AS Dordrecht
the Netherlands
ph0ne+3l 78 61313 66
fax+ 3178 614 95 S5
e-mail: [email protected]
internet: www.hollandshielding.com
new website: www.faradaycages.com