Free Declaration - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF

Document 270-8

Filed 06/12/2006

Page 1 of 6

Exhibit G

Case 1:04-cv-01371-JJF

Document 270-8

Filed 06/12/2006

Page 2 of 6

EXHIBIT G
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Brian, Please let me know when we can expect to receive the Fairchild-Intersil license. When we spoke yesterday, you said you were preparing it for production last night or this morning, but I have yet to receive the license or anything further from your end with respect to the license (or any other Intersil-related documents). Thanks. Michael R. Headley Fish & Richardson P.C. 500 Arguello St., Suite 500 Redwood City, CA 94063-1526 (650) 839-5139 (direct) (650) 743-3335 (cell) (650) 839-5071 (fax) This e-mail may contain confidential and privileged information. If you received it in error, please contact the sender and delete all copies.

Case 1:04-cv-01371-JJF

Document 270-8

Filed 06/12/2006

Page 3 of 6

Exhibit H

Case 1:04-cv-01371-JJF

Document 270-8

Filed 06/12/2006

Page 4 of 6

Exhibit H
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Hop, Power Integrations has been trying to obtain the Fairchild-Intersil license providing Fairchild exclusive rights to assert the `719 patent against Power Integrations since Fairchild sued Power Integrations and publicly announced the license over two weeks ago, but our repeated requests have been rebuffed and/or ignored to date. The license is clearly relevant to issues in the Texas case (in addition to several of Power Integrations' discovery requests in the Delaware case), and although we do not know when the license was executed, it was clearly executed more than two weeks ago. As such, there is no excuse for Fairchild's continued delay in producing the license. Moreover, despite an explicit agreement from your associate Brian VanderZanden that Fairchild would produce the license earlier this week, we have yet to receive the license. Fairchild's delay in producing the Intersil license to date has impeded Power Integrations' ability to draft an Answer to Fairchild's complaint in the Texas case; among other issues, the license bears on the issue of Fairchild's standing to bring suit in the first place. In light of Fairchild's delay, Power Integrations requests a 30-day extension for the time to file an Answer in the Texas case, which would move the date for the Answer from May 2 to June 1. Let me know as soon as possible if you are amenable to such an extension, and we will draft a stipulation to get on file with the Court. Sincerely, Michael R. Headley Fish & Richardson P.C. 500 Arguello St., Suite 500 Redwood City, CA 94063-1526 (650) 839-5139 (direct) (650) 839-5071 (fax) This e-mail may contain confidential and privileged information. If you received it in error, please contact the sender and delete all copies.

Case 1:04-cv-01371-JJF

Document 270-8

Filed 06/12/2006

Page 5 of 6

Exhibit I

Case 1:04-cv-01371-JJF

Document 270-8

Filed 06/12/2006

Page 6 of 6

Exhibit I
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Brian, Power Integrations has sought to obtain relevant production regarding the Intersil '719 patent from Fairchild for some time now, including Fairchild's license to sue Power Integrations on the '719 patent and any communications with Intersil regarding the '719 patent. You agreed to produce relevant documents over two weeks ago in your letter of April 20, and you further agreed to produce the Intersil license during our phone call on Monday, April 24, stating that you were preparing the license for production that night or the following morning. To date, though, we have not received a copy of the license or anything beyond your initial production of fewer than a dozen pages of documents. Fairchild's delay in producing the Intersil license is inexplicable; I cannot imagine what has held up the seemingly trivial exercise of faxing me a copy of what I expect to be a short document. The Fairchild-Intersil license is highly relevant to the parties' efforts in the Delaware case, and Power Integrations needs this license to Answer Fairchild's complaint in Texas, so again I reiterate Power Integrations' request for the immediate production of the license (in addition to other documents regarding the '719 patent). If Fairchild is withholding any such documents (including any communications with Intersil) on the basis of privilege or some other protection, please immediately provide a log for those documents so that Power Integrations can evaluate the claim of privilege in time to raise the issue with the Court at or before the pretrial if necessary. I look forward to your response. Sincerely, Michael R. Headley Fish & Richardson P.C. 500 Arguello St., Suite 500 Redwood City, CA 94063-1526 (650) 839-5139 (direct) (650) 839-5071 (fax) This e-mail may contain confidential and privileged information. If you received it in error, please contact the sender and delete all copies.