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Case 1 :04-cv—00874-GIVIS Document 68 Filed 12/13/2005 Page 1 of 2
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ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
302-G54-IBB!
222 DELAWARE AVENUE
FACSIMILE
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: Telcordia Technologies, Inc. v. Alcatel USA., Inc.
C.A. No. 04-874-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 Alcatel was not ready to provide its
portion of this letter in time for our 48—hour filing deadline, and we therefore are filing our own
proposed agenda letter rather than a joint submission.
A. Claim Construction Issue Common to All Cases
The defendants have not addressed Telcordia’s means-plus-fimction claims during
the claim construction process. Telcordia respectfully requests an Order compelling Alcatel (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. Alcatel’s Claim Constructions
(1) Alcatel identified 71 disputed claim terms, and Telcordia offered proposed
constructions for all 71 terms. Alcatel only offered constructions for 24 terms, and offered the
construction of “ordinary meaning" for 5 terms. Telcordia respectfully requests an Order (1)
precluding Alcatel from offering constructions for the claim terms that it identified in its list of
disputed claim terms but for which it did not offer proposed constructions, (2) precluding Alcatel
from offering constructions for the five claim terms for which it offered "ordinary meaning" as a
construction, and (3) precluding Alcatel from relying on, or introducing into evidence,
Telcordia’s proposed constructions for (a) the claim terms for which Alcatel did not offer
proposed constructions, and (b) the claim terms for which Alcatel offered the construction of
"ordinary meaning."
C. Alcatel’s Interrogatory and Document Responses

Case 1 :04-cv—00874-GIVIS Document 68 Filed 12/13/2005 Page 2 of 2
The Honorable Gregory M. Sleet
December 13, 2005
Page 2
Telcordia respectfully requests an Order compelling Alcatel to supplement its answers to
Telcordia’s interrogatories on damages, invalidity contentions, and infringement contentions, and
to address Telco1·dia’s ’633 patent in its answers. Telcordia also respectfully requests an Order
compelling Alcatel to produce specific documents relevant to Te1cordia’s infringement analysis
and documents relevant to Telcordia’s damages analysis.
E. The Protective Order
The parties have been tmable to agree upon the terms of a Protective Order.
Respectfully,
/s/ Steven J Balick
Steven J. Balick (I.D. #21 14)
SJ B: mnl
164555.1
cc: Josy W. Ingersoll, Esquire (by hand)
Stuart J. Sinder, Esquire (via electronic mail)
John Williamson, Esquire (via electronic mail)