Case 1 :04-cv—OO875-GIVIS Document 154 Filed 05/O2/2006 Page 1 of 2
MORRIS, NICHOLS, ARSHT 8-L TUNNELL LLP
1201 NORTH MARKET STREET
P.O. Box 1347
WILMINGTON, DELAWARE 19899-1347
302 658 9200
302 658 3989 FAX
,lA¤1< B. BLUMENFELD
302 351 9291
302 425 3012 FAX
[email protected]
May 2, 2006
BY ELECTRONIC FILING
The Honorable Gregory M. Sleet
United States District Court
844 North King Street
Wilmington, DE 19801
Re: T elcordia Technologies, Inc. v. Alcatel S.A., et al., C.A. No. 04-874 (GMS)
T elcordia Technologies, Inc. v. Lucent T echologies, C.A. No. 04-875 (GMS)
T elcordia Technologies, Inc. v. Cisco Systems, Inc., C.A. No. O4-876 (GMS;
Dear Judge Sleet:
I am writing on behalf of the defendants in all three actions in response to
Telcordia’s letter of yesterday. The defendants have coordinated their claim construction
briefing to avoid repetitive arguments, and intend to do the same thing at the argument
tomorrow. We do not believe that it is necessary for the Court to set a strict allocation of time
for the hearing. The defendants do not request three-quarters of the time. Because the three
defendants have coordinated their efforts, however, there may be some points on which they may
need to have a few extra minutes. In any event, we do not believe that there is any real dispute
between the parties and no reason for the Court to address the matter.
In preparation for the hearing, defendants suggest, subject to the Court’s approval,
that the patents be presented in the following order: ‘306, ‘633 and ‘763, the same order as in
Telcordia’s opening brief.
Defendants’ counsel will, of course, be available should the Court wish to discuss
any issues in advance of the hearing.
Respectfully,
/s/ Jack B. Blumenfeld (#1014)
Jack B. Blumenfeld
Case 1 :04-cv—OO875-GIVIS Document 154 Filed 05/O2/2006 Page 2 of 2
The Honorable Gregory M. Sleet
May 2, 2006
Page 2
cc: Peter T. Dalleo, Clerk (By Hand)
Steven J. Balick, Esquire (By Hand)
Josy W. Ingersoll, Esquire (By Hand)
John W. Shaw, Esquire (By Hand)
Donald R. Dunner, Esquire (By Fax)
Stuart J. Sinder, Esquire (By Fax)
Steven C. Cherny, Esquire (By Fax)
Edward R. Reines, Esquire (By Fax)