Free Redacted Document - District Court of Delaware - Delaware

Case1:O4—cv-01371-JJF D0cument433—8 Fi|ec|11/21/2006 Page10f2
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Case 1 :04-cv-01371-JJF Document 433-8 Filed 11/21 /2006 Page 2 of 2
FISH st RICHARDSON 1>.c.
500 Argucllo Street
Suite 500
Redwood City, California
94063-1526
Frederick P. Fish
[855-1930 Telephone
VIA FACSIMILE & U.S. MAIL 6,0 839-5070
WK. Richardson · ·
I8§9-I9§I F3CSlH1ll€
October 26, 2006 650 839-5071
Web Site
Brian VanderZanden ‘”‘”W·fL·°°m
Orrick, Herrington & Sutcliffe LLP Howard G_ Poumk
l000 lVI31‘Sl'1 Road (650) 839-5007
Menlo Park, CA 94025
Email
Re: Power Integrations Inc. v. Fairchild Semiconductor Int’l P°Ha°k@fr'°°m
USDC-D. Del. — C.A. No. 04-1371-JJF
® Dear Brian:
AUSTIN I am writing with respect to Fairchild’s production of new documents and things this
”°sT°N week allegedly relating to work by James Beasom and Intersil/Harris. I have received
DALLAS new productions twice this week, but no word of explanation for why these materials
DELAWARE were not discovered and produced long ago.
The simple fact is that discovery has long since closed. We have no problem with
your providing better copies of documents produced in a timely manner during
SILICON VALLEY discovery, but with the first trial already behind us and our preparations for the
""N °"‘“ second trial nearly complete, the time for any new production has long since passed.
WA¤¤¤~¤T<>~» ¤¤ Moreover, there can be no excuse for Fairchild’s delay in producing Intersil or .
Beasom-related materials, as Fairchild’s joint defense agreement with Intersil
allegedly dates back to 2001, and Fairchild and Ir1tersil worked closely together
during the course of this case to produce documents and testimony from Mr. Beasom
and others regarding Mr. Beasom’s work.
Because these new materials are untimely, and because Power Integrations has not
had any opportunity to investigate these materials (through deposition or otherwise),
we will seek to preclude any attempt by Fairchild to introduce them at the upcoming
trial.
Howard G. P R