Free Objections - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 785-12 Filed O9/17/2007 Page1 0f 3

Case 1:04-cv-00343-JJF Document 785-12 Filed O9/17/2007 Page 2 of 3
McKenna Long ,,,90
Denver LLP San Francisco
'-°$ A"9°'°$ 1900 K Street, NW • Washington, DC 20006 Washington, DC
202.4%.7500 • Fax: 202.4%.7756
Philadelphia www.mckennalong.com Brussels
LORA A. BRZEZYNSKI EMA||_ ADDRESS
(202) 496-7239 [email protected]
July l7, 2007
VIA E-MA11. AND U.S. MAIL
Frank E. Merideth, Jr., Esq.
Greenberg Traurig LLP
2450 Colorado Avenue
Suite 400E
Santa Monica, CA 90404
Re: LG.Philips LCD C0., Ltd. v. WewSonic Corporation, et al.;
U.S. District Court Case N0. 04-343 JJF
Dear Frank:
Rel Ambrozy asked me to respond to your July 9, 2007 e-mail as he is out of the office
on vacation. I have reviewed the correspondence over the last several months between you and
Messrs. Ambrozy and Auito from this office. Based on your last communication to
Mr. Ambrozy dated July 9th, you apparently "believe that [you] need to proceed with
Ms. Rudich’s deposition."
After reading the communications on this issue since March and the draft declarations
submitted to you at your request by Messrs. Ambrozy and Auito, I do not understand your basis
for now seeking Ms. Rudich’s deposition. Please advise as to why you believe the latest draft
declaration sent to you by this firm on April 27, 2007 is not sufficient. As you know, that draft
declaration was specifically revised by us in response to your concerns raised in your April 25,
2007 letter.
Other than requesting better copies of photographs, which were attached as one of the
exhibits to Ms. Rudich’s draft declaration, you have never expressed any concerns about the
revised declaration sent to you more than eleven weeks ago. Further, you state in your July 9,
2007 e—mail to Mr. Ambrozy that the only subject for Ms. Rudich’s requested deposition will be
"the office action in connection [with] the ‘079 Application related to the IBM color display."
Please advise as to why you believe this office action is relevant to the case and as to what issue
it is relevant.
At this point, months after we sent you the second revised declaration, we believe that
Tatung should be prohibited from deposing Ms. Rudich regarding patent prosecution issues
DC:50489l99.l

Case 1:04-cv-00343-JJF Document 785-12 Filed O9/17/2007 Page 3 of 3
Frank E. Merideth, Jr., Esq.
July 17, 2007
Page 2
involving the office action in comiection with the ‘079 Application. However, we would like to
better understand Tatung’s position and why it now believes that a deposition is required (as
opposed to a declaration) and why such a deposition would be relevant.
I look forward to your response.
Very truly yours,
. Br
LAB:rla
cc: Mark H. Krietzman, Esq.
Valerie W. Ho, Esq.
DC:50489199.l

Case 1:04-cv-00343-JJF

Document 785-12

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EXHIBIT 11

Case 1:04-cv-00343-JJF

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Case 1:04-cv-00343-JJF

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