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Case 1 :04-cv—00875-GIVIS Document 67 Filed 12/13/2005 Page 1 of 2
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ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
222 DELAWARE AVENUE °°Z`°°`°"°°°
»=. ¤. Box use SQLCZZIZZS.,
WILMINGTON, DELAWARE 19899
December 13, 2005
The Honorable Gregory M. Sleet VIA ELECTRONIC FILING
United States District Court
844 North King Street
Wilmington, DE 19801
Re: T elcordio Technologies, Inc. v. Lucent Technologies, Inc.
Civil Action No. 04-875-GMS
Dear Judge Sleet:
Plaintiff Telcordia hereby respectfully submits its proposed agenda in the above case, in
anticipation of the combined teleconference scheduled at 11:30 a.m. on December 15, 2005 in
C.A. Nos. 04-874, 875, and 876-GMS. Telcordia notes that we have not received any proposed
text from Lucent, nor have we received any response to our proposed text, and in light of our 48-
hour filing deadline we therefore are filing our own proposed agenda letter rather than a joint
submission.
Plaintiffs Issues
A. Claim Construction Issue Common to All Cases
The defendants have not addressed Telcordia’s means-plus—function claims during
the claim construction process. Telcordia respectfully requests an Order compelling Lucent (and
the other defendants) to provide proposed claim constructions for all claims and claim terms
asserted by Telcordia prior to the November 17, 2005, deadline for exchanging disputed claim
terms.
B. The Timing and Content of Lucent’s Document Production
(1) Telcordia respectfiilly requests an Order compelling Lucent to produce, by
a date certain, documents relevant to Telcordia’s infringement analysis, including hardware
specifications for the circuit emulation modules in the CBX-500 and CBX-3500 products, and
hardware specifications for the DMX Access Multiplexer product.
(2) Telcordia respectfully requests an Order compelling Lucent to resolve the
problems conceming improperly processed and inadvertently produced documents in Lucent’s
document production.

Case 1:04-cv—00875-G1l\/IS Document 67 Filed 12/13/2005 Page 2 of 2
The Honorable Gregory M. Sleet
December 13, 2005
Page 2
Respectfully,
/s/ Steven J Balick
Steven J. Balick
SJB/dmf
164556.1
c: John W. Shaw, Esquire (via electronic mail)
Steven C. Cherny, Esquire (via electronic mail)
David A. Nelson, Esquire (via electronic mail)
John Williamson, Esquire (via electronic mail)