Free Declaration - District Court of Delaware - Delaware

Case 1:04-cv-01371-JJF Document 132-4 Filed 11/11/2005 Page 1 of 3
Exhibit C
Letter Received From Mr. Seaman On September 27, 2005

Case 1 :04-cv-01371-JJF Document 132-4 Filed 11/11/2005 Page 2 of 3
BOUCHARD MARGULES 5 FRIEDLANDER
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September 27, 2005
By Email
Lionel M. Lavenue, Esq.
Finnegan Henderson Farrabow Garrett & Dunner, LLP
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190-5675
Re: Power Integrations, Inc. v. Fairchild Semiconductor Int'], Inc.,
D. Del., C.A. No. 04-1371 (JJF)
Dear Lionel: "
I write regarding the subpoena that plaintiff served on LG Electronics, USA, Inc.
("LG") in the above matter. When we spoke last week, you indicated that you believed
that LG’s United States entities do not have the infomation plaintiff seeks, but that the
infomation is in the possession of LG’s parent in Korea. While we do not accept the
premise that responsive information in the possession of a corporate parent is outside the
possession, custody or control of the subsidiary,] we hope that we can help LG more
easily identify the information we seek.
Without limiting the scope of the subpoena, documents responsive to Requests 1
and 2 could be determined from LG’s (a) approved parts list, or (b) authorized and
approved suppliers and sub-contractors for integrated circuits for power conversion. LG
is also likely to acquire Fairchild PWM controllers directly from Fairchild, or through
subcontractors such as Powemet, for LG’s LCD monitors and DVD players. Documents
responsive to Request No. 3 should be readily ascertainable from LG’s US sales
information once LG has been able to identify the products that use or incorporate
Fairchild PWM controllers. ln any event, whether the information requested is located in
the United States or Korea, LG has an obligation to search for and produce documents
responsive to plaintiffs narrowly-tailored subpoena.
I See Ahos S.P.A. v. Krauss—Majfei Corp., 113 F.R.D. 127, 132 (D. Del. 1986) (granting
motion to compel discovery from foreign parent corporation).

Case 1:04-cv-01371-JJF Document 132-4 Filed 11/11/2005 Page 3 of 3
Lionel M. Lavenue, Esq.
September 27, 2005
Page 2
We look forward to receiving your response to the foregoing and are hopeful that
with further dialogue LG will be able to locate and produce the infomation plaintiff
seeks with minimal disruption.
Sincerely,
QM q(••u.•4»
John M. Seaman