Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01338-JJF Document 966 Filed O1/O9/2008 Page 1 of 2
MORRIS, NICHOLS, ARSHT & TUNNELL LLP
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tg1·[email protected] January 9,
BY E-FILING
The Honorable Mary Pat Thynge
United States Magistrate Judge
United States District Court
for the District of Delaware
844 King Street
Wilmington, DE 19801
Re: Honeywell, et al. v. Apple Computer, etal.,
C.A. No. 04-1338-*** (Consolidated)
Dear Judge Thynge:
I write to follow-up on the teleconference held by the Court on Monday,
January 7, to discuss, among other things, Honeywell’s production of documents regarding the
licenses to the patent—in-suit taken by several former parties to this action.
First, during the conference, Your Honor asked when the Court addressed
previously the issue of discovery from the Customer Defendants. We have determined that it
was raised during the hearing on February 22, 2007 (Tab A). Also, for the benefit of the Court,
we are providing copies of the parties’ letter brief submissions on this issue (Tab B).
Second, during the conference, counsel for Fuji acknowledged that Honeywell
had produced all of the license agreements and certain other documents relating to the licenses
such as letters and emails scheduling meetings, but represented that Honeywell had not produced
any substantive documents conceming the negotiations of those licenses. That is incorrect.
The proof is in the 3,500 pages of documents that Honeywell has produced. To give Your Honor
a flavor for the type of substantive documents produced by Honeywell, I am enclosing three
examples: HW021509—514, HWO26388-395, and HW026670-676, which are confidential and
filed separately under seal (Tab C).

Case 1:O4—cv—O1338-JJF Document 966 Filed O1/O9/2008 Page 2 of 2
The Honorable Mary Pat Thynge
January 9, 2008
Page 2
We did not wish to burden the Court by providing to Your Honor all of the substantive
documents Honeywell produced to Fuji, but, of course, Honeywell would be happy to provide to
the Court more or all of the substantive documents for the Court’s review.
Respectfully,
Thomas C. Grimm (#1098)
TCG
cc: Dr. Peter T. Dalleo, Clerk (by hand, w/encls.)
CM/ECP list (by e-filing, w/encls.)
Non-Stayed Defendants (by e-tiling & e-mail, w/encls.)
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