Free Status Report - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 747-8 Filed 08/O3/2007 Page1 of 3

Case 1:04-cv-00343-JJF Document 747-8 Filed 08/03/2007 Page 2 of 3
McKenna Long .....
Atlanta Philadelphia
Brussels Ammcys M Law Sacramento
D“"“*' 1900 1< street, NW · washington, DC 20006-1108 Sa" D"’9"’
ws A¤0€*€$ ra; 202.4%.7500 · Fax; 202.4%.7756 San F~=¤¤15¤<>
www.mckenna|ong.com Washington, D.C.
REL S. AMBROZY EMAnL ADDRESS
(202) 496-7693 [email protected]
July 31, 2007
VIA E-MAIL AND U.S. MAIL
Valerie W. Ho, Esq.
Greenberg Traurig LLP
2450 Colorado Avenue
Suite 400E
Santa Monica, CA 90404
Ho V@GT LA W com
Re: LG.Phil1ps LCD C0., Ltd. v. WewSonic Corporation, et al.;
U.S. District Court Case No. 04-343 JJF
Dear Valerie:
This letter follows up on Cormac Connor’s July 11 e-mails to you regarding Tatung
Company’s assembly instructions and module specifications.
As you know, Cormac has been out of the office and so unless we missed it, we still have
not received the assembly instructions or module specifications for Tatung Company monitors
that Mr. T.H. Liu referred to during his June 6 deposition. Specifically during his deposition,
Mr. Liu testified that "[w]e have assembly instructions to assemble monitors." (See Liu Depo. at
131:8-9.) Mr. Liu further testified that Tatung uses the instructions to assemble monitors and
that the instructions show the positions of the screw holes and where the screws should be
inserted in products. (ld at 131:14—132:6.) Further, we requested during Mr. Liu’s deposition
that all copies of module specifications for accused Tatung products be produced. (See id.)
Mr. Meredith stated during the deposition that all assembly instructions and module
specifications had been produced to the extent they exist. (Id at 120:22-121:10). LPL is not
aware of any assembly instructions or module specifications that have been produced. Please
note that Tatung’s assembly instructions are distinct from the work instructions that have
previously been produced by Tatung America. On July ll, Cormac Connor requested that
Tatung provide Bates ranges for any assembly instructions or module specifications that have
been produced. To date, Tatung has not identified any Bates ranges.

Case 1:04-cv-00343-JJF Document 747-8 Filed 08/03/2007 Page 3 of 3
Valerie W. Ho, Esq.
July 31, 2007
Page 2
Please provide the assembly instructions and module specifications identified by Mr. Liu
in his deposition for all accused products. If you maintain that these have been produced, then
please provide the Bates ranges. If we do not receive these documents promptly, we will seek all
appropriate relief from the Special Master. Please note that we intend to raise this issue with the
Special Master for decision during the August 7th hearing. Accordingly, we will bring this
matter to his attention this week, unless we are able to resolve this matter with you immediately.
t
‘ Rel S. Ambrozy
DC:5049l376.l

Case 1:04-cv-00343-JJF

Document 747-8

Filed 08/03/2007

Page 1 of 3

Case 1:04-cv-00343-JJF

Document 747-8

Filed 08/03/2007

Page 2 of 3

Case 1:04-cv-00343-JJF

Document 747-8

Filed 08/03/2007

Page 3 of 3