Free Redacted Document - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF Document 45-2 Filed 08/04/2005 Page1 of 3

Case 1 :04-cv-01371-JJF Document 45-2 Filed 08/04/2005 Page 2 of 3
ORRICK, HERRINGTON It SUTCLIFFE LLP
1000 MARSH Rom
O Memo PARK. ca 914025 .
rel 650-6147400
fax 650-614-7401
O R R l C K WWVlI.ORRICK.COM
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VIA FACSIMILE AND MAIL (650) 839-5070
Howard G. Pollack
Fish & Richardson P.C.
500 Arguello Street, Suite 500
Redwood City, CA 94063
Re: Power Integgations y, Fairchild Semiconductor et al. {QA 04—1371 HE)
Dear Howard:
Thank you for responding to my letter of january 26, 2005 and identifying the Fairchild
devices presently accused by Power Integrations of infringing the patents—in-suit. In order to meet
the parties’ ambitious schedule and complete document production no later than june 30, 2005, we
intend to begin to gather documents concerning the accused FSDH0165, FSDL0365, FSDM0565,
FSD200, and FSD210 families of products shortly.
As we discussed, we anticipate that the majority of documents related to the accused families
of Fairchild devices are located entirely in Korea and written in Korean. This makes any effort to
gather such documents both complicated and expensive. To avoid the undue expense of having to
return to Korea to search for additional documents, we wish to confirm that Power Integrations
does not intend to accuse any additional Fairchild devices outside of the five accused families.
Should Power Integrations later seek to broaden the scope of accused products, however, we reserve
the right to shift the cost of the collection, review, and production of additional documents to
Power Integrations.
It appears likely that Fairchild will produce electronic documents concerning the five
accused families of products. Should this happen, Fairchild intends to produce such documents in
TIFF format. This is consistent with guidelines for electronic discovery in the Delaware courts and
will facilitate inclusion of Bates numbers and the appropriate confidentiality designation on each
page. _
Finally, your letter of january 31, 2005 did not respond to our request that Power
Integrations identify which claims it asserts from the patents-in-suit and, specifically, which Fairchild
product or products are accused of infringing each such claim. We repeat our request for this
information as it will facilitate our investigation of Power Integrations’ allegations and our collection
of responsive documents.
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Case 1:04-cv-01371-JJF Document 45-2 Filed 08/04/2005 Page 3 of 3
O R R I C K
Howard G. Pollack
February 3, 2005
Page 2
Thank you for your assistance in these matters. Please do not hesitate to call should you
have any questions.
Sincerely,
/ B ¢'·o. deé
Bas de Blank
cc: William Marsden, jr.
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