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Exhibit O
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REDACTED IN ITS ENTIRETY
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Exhibit P
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REDACTED IN ITS ENTIRETY
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Exhibit Q
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Exhibit R
Samsung Enterprise Portal mySingle Document 624-4 Case 1:04-cv-01371-JJF
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Jennifer Pierce
From: Sent: To: Cc: Subject: Kristina Kim [[email protected]] Friday, December 16, 2005 11:32 AM Michael Headley [email protected]; ??? Fwd: Power Integrations v. Fairchild
Attachments: LG Electronics order.pdf; LG Electronics opinion.pdf; Memorandum Order.pdf
Mike -I am doing a quick e-mail informing you that, pusuant to explanation I received from counsel for Fairchild (forwarded below), Samsung International, Inc. (SII) has not purchased from Fairchild the part items you list in your Subpoena, as further amended in your discovery responses produced to Fairchild in this lawsuit. Also, I confirm that SII has at no time purchased components from System General. Our formal repsonse to the Subpoena will be sent to you during January 2006. Regards,
Kristina Sojung Kim, Esq. General Counsel Samsung International, Inc. Office (619) 671-6011 Fax (619) 671-6010/6013 Cell (619) 384-5685 E-mail: [email protected] THIS EMAIL AND ATTACHMENTS ARE CONFIDENTIAL AND ARE INTENDED SOLELY FOR THE USE OF THE ADDRESSEE(S). IF YOU ARE NOT THE INTENDED RECIPIENT, BE ADVISED THAT YOU HAVE RECEIVED THIS EMAIL IN ERROR, AND WE ASK THAT YOU IMMEDIATELY NOTIFY KRISTINA S. KIM, GENERAL COUNSEL, SAMSUNG INTERNATIONAL, INC., BY TELEPHONE AT (619)384-5685 OR (619) 671-6011.
------- Original Message ------Sender : de Blank, Bas
Kristina,
It was good to speak with you. As we discussed, while Power Integrations originally accused Fairchild's FSCQ0765 device, in its latest (September 30, 2005) interrogatory response on the subject, Power Integrations has dropped those accusations and no longer accuses the FSCQ0765 device of infringing any of its patents. Thus, whether or not Fairchild sold any of its FSCQ0765 devices to Samsung is not of any relevance to this case. Further, I have attached a copy of the Court's Order precluding Power Integrations from seeking damages related discovery prior to the filing of the complaint. The relevant passage of that Order is on page 6, which states "Accordingly, the Court concludes that Power Integrations has not established that documents related to Fairchild's sales prior to the date of the Complaint are relevant to the question of damages, and therefore, the Court concludes that Power Integrations is not entitled to the discovery of these documents." As the Order notes, the Complaint was filed on October 20, 2004. Thus, Samsung need not produce any sales or other information prior to October 20, 2004. I also attach a copy of the Court's Order quashing an essentially identical subpoena Power Integrations served on LG. I will also send you copies of these orders via facsimile. I hope that this answers all of your questions. I understand that Samsung intends to respond that Samsung has not purchased any accused Fairchild device. If that is not correct or if there is anything else I can do to be of assistance, please do not hesitate to call. Bas de Blank ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 650-614-7343 (phone) 650-614-7401 (fax)
From Orrick, Herrington & Sutcliffe LLP
12/3/2007
Samsung Enterprise Portal mySingle Document 624-4 Case 1:04-cv-01371-JJF
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or (ii) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein. ====================================================================================================================== NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS E-MAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. For more information about Orrick, please visit http://www.orrick.com/
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Exhibit S
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Exhibit T
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