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Case 1:04-cv-00343-JJF Document 747-5 Filed 08/O3/2007 Page1 of 3

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Albany New York
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Lee Angeles Tel; 202.4%.7500 · Fax: 202.496.7756 See Ft¤¤<*$<<>
www.mckennalong.com Washington, D.C.
CASS W. CHRISTENSON EMAIL ADDRESS
(202) 496-7218 August 1, 2007 cchristenson@mckenna|ong.com
BY E-MA11, AND U.S. MAIL
Tracy R. Roman, Esq.
Raskin Peter Rubin & Simon, LLP
1801 Century Park East,Suite 2300
Los Angeles, CA 90067
Re: LG.Philips LCD Co., Ltd. v. ViewSonic Corporation, et al.
U.S. District Court Case No. 04-343 JJF
Dear Tracy:
I write to follow up on our July 30, 2007 telephone call. During our call, we discussed
the various issues that ViewSonic raised in its July 27, 2007 letter to Special Master Poppiti.
We resolved the issues concerning legibility of certain pages. As we agreed, yesterday
we produced larger size copies to the extent that we were able to do so. As we discussed,
however, we were not able to provide better copies of some documents.
We also discussed LPL’s production of documents relevant to parts and assembly. We
believe that LPL’s production is appropriate and responds to ViewSonic’s relevant document
requests, consistent with discussions during recent teleconferences with the Special Master.
Nonetheless, we agreed to investigate further concerning whether LPL has available service or
repair manuals with the type of information that we discussed, corresponding to the LPL
modules for which we have provided discovery. Based on our continuing efforts, we understand
that LPL is able to produce nine (9) service manual documents that correspond to those top-
selling modules. Reserving all of LPL’s rights and objections, we will agree to produce those
service manuals, in the spirit of cooperation and in order to resolve this issue. We will produce
those documents as soon as we can, probably at the end of this week. So far, LPL has not been
able to locate any additional service or repair manuals for LPL’s top-selling modules. lf we do
find any such manuals, however, we will let you know promptly.
With respect to ViewSonic’s reference to samples of LPL’s modules in its July 27 letter
to the Special Master, I explained that we understand ViewSonic to be seeking module samples
for the time period before 1999 for the top ten module products that are the subject of discovery.
I also inquired as to what specific information ViewSonic expects to discover from the modules
that ViewSonic believes is not available from the documents we produced for those modules.
You had suggested that you would respond yesterday to let us know what module samples are
sought and what information they would show that is not provided in the documents already

Case 1:04-cv-00343-JJF Document 747-5 Filed 08/03/2007 Page 3 of 3
Tracy R. Roman, Esq.
August l, 2007
Page 2
produced, but you have not yet responded with this information. In any event, we have
confirmed that LPL does not keep old modules, so this issue presumably is moot.
With respect to ViewSonic’s reference to further depositions, I reaffirmed LPL’s
objection to any further depositions of LPL’s witnesses. I also indicated, however, that we are
willing to discuss with you ways to resolve issues without the need for further depositions of
LPL. For example, we discussed our willingness to attempt to reach agreements concerning
authenticity of documents, so as to avoid the need for testimony on those issues. You agreed
that, after you review LPL’s documents, including the replacement documents that we sent to
you yesterday, you will let us know more specifically what issues ViewSonic seeks to address
through deposition, so that we can discuss possible alternatives. We look forward to hearing
from you.
Finally, we also discussed LPL’s concerns regarding various documents that LPL is
awaiting from ViewSonic, including documents from OEMs, documents concerning
correspondence with Tatung, and documents related to specific ViewSonic products. With
respect to ViewSonic’s communications with Tatung, you agreed to let us know the status of that
production, which was ordered by the Special Master. Yesterday, you sent an email to me stating
that ViewSonic was unable to locate any responsive documents, but was continuing to search.
Please confirm whether any responsive documents exist.
Regarding ViewSonic’s recent production of documents from one OEM supplier, I
explained that LPL objects to ViewSonic’s limited production, including because ViewSonic did
not undertake appropriate efforts to obtain or demand documents. I also requested actual signed
and dated copies of letters from ViewSonic to OEMs regarding the documents, as we received
only unsigned, undated documents. I also asked whether ViewSonic had any telephone
discussions with the OEMs concerning this discovery. You agreed to let me know whether
ViewSonic made any efforts to obtain documents by telephone. If so, please describe those
efforts sufficiently so that we can assess the extent, nature, and timing of any discussions. You
stated that all correspondence to and from the OEMs had been produced. You also stated that
ViewSonic was unable to find the signed copies of correspondence sent to the OEM companies,
but then yesterday you sent an email to me stating that you have now located signed copies and
would produce them to us, with additional emails. You disputed LPL’s position that
ViewSonic’s efforts were inadequate, and we agreed that this is a disputed issu .
We look forward to hearing from you and to speaking again b ore the August 7
teleconference with respect to the above issues to the extent att ey remai pen.
Cass . Christenson
CWC:ea
cc: All Counsel of Record

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