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Case 1 :04-cv—00875-GIVIS Document 52 Filed 10/07/2005 Page 1 of 2
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WILMINGTON, DELAWARE 19899
October 7, 2005
The Honorable Gregory M. Sleet VIA E—FILE
United States District Court
844 North King Street
Wilmington, DE 19801
Re: T elcordia Technologies, Inc. v. Lucent Technologies, Inc.
Civil Action No. 04-875-GMS
Dear Judge Sleet:
In preparation for the teleconference scheduled on October 11, 2005, at 10:00 a.m., the
parties jointly submit this letter agenda. The Plaintiffs issue is set forth in Item I and the
Defendant’s issues are set forth in Item II.
I. Telcordia Interrogatory N 0. 1 Seeking the Identification of Products Subject
to Discovery and Related Document Production
Defendant Lucent Teclmologies, Inc. ("Lucent") has thus far agreed only to provide
discovery (documents and information) relating to products Plaintiff has charged with
infringement. In an effort to discover other Lucent products that may infringe one or more
claims of the asserted patents, Plaintiff respectfully requests the Court to compel Lucent to
answer Plaintiff’ s April 7, 2005, Interrogatory No. 1 to identify:
(1) all Lucent products that map Packetized Data into SONET frames, which
is targeted at products likely to infringe the ‘306 patent;
(2) all Lucent products that practice and/or are capable of practicing the
"Synchronous Residual Time Stamp" technology disclosed in the ATM
Forum Standard (see, e. g., af—vtoa-0078.000 Section 3.4.1), the ITU-T
Standard 1.363.1 (see, e.g., Section 2.5.2.2.2), and/or the ANSI T1.630
standard (see, e. g., Section 5 referencing 1.363.1), which is targeted at
products likely to infringe the ‘633 patent; and

Case 1 :04-cv—00875-GIVIS Document 52 Filed 10/07/2005 Page 2 of 2
(3) all Lucent products that perform unidirectional path switched ring
automatic protection switching and/or that comply with GR-1400 (see,
e. g., GR-1400 Issue 1, Revision 1, Section 3), which is targeted at
products likely to inhinge the ‘763 patent.
Plaintiff also respectfully requests the Court to compel the Defendant to produce a
discrete set of "relevant functionality" documents for each product identified in response to
Telcordia Interrogatory No. 1, so that Plaintiff can identify the universe of infiinging Lucent
products in this case.
II. Issues Raised by Lucent
(1) Whether Telcordia must produce documents and 30(b)(6) deponents
relating to Lucent’s laches and equitable estoppel defenses, including
Telcordia’s certification and testing of Lucent’s accused products and
Telcordia’s sale of its products as compatible with Lucent’s accused
products?
(2) In responding to an interrogatory seeking when Telcordia first became
aware of Lucent’s alleged infringement, can Telcordia limit its response to
the date upon which its outside counsel completed its diligence?
(3) Whether Telcordia’s interrogatory response must provide its claim
constructions?
(4) Telcordia’s current interrogatory response states that the conception dates
for the asserted claims of the ’763 and ’633 patent are the filing dates of
those patents. May Telcordia later change its answer in response to prior
art cited by Lucent. For the patents Lucent is alleging were procured
through inequitable conduct, must Telcordia provide conception and
reduction to practice dates for each of the claims?
(5) Whether Telcordia’s interrogatory response must provide what Telcordia
contends to be a reasonable royalty for each asserted patent?
Respectfully,
/s/ John G. Day
John G. Day (I.D. #2403)
J GD: nrnl
162142.1
cc: John W. Shaw, Esquire (by hand)
Donald R. Dunner, Esquire (via electronic mail)
Steven C. Chemey, Esquire (via electronic mail)