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

Case 1:04-cv-00343-JJF Document 747-3 Filed 08/03/2007 Page 2 of 3
Albany McKenna Long .....
Atlanta {s I Philadelphia
Brussels & Am“ %@g€LLP Sacramento
D€““"’ 1900 1< street, NW · washington, DC 200064108 Sa" D"*9°
LOS A¤0¤l¤5 tel; 202.496.75OO · Fax: 202.496.7756 SM Ft¤¤¤l¤¤¤
www.mckennalong.com Washington, D.C.
CASS W. CHRISTENSON EMAlL ADDRESS
(202) 496-7218 [email protected]
July 27, 2007
VIA E-MAIL AND U.S. MAIL
Manuel Nelson, Esq.
Connolly Bove Lodge & Hutz, LLP
333 South Grand Avenue, Suite 2300
Los Angeles, CA 90071
Re: LG.Philips LCD C0., Ltd. v. T atung, et al.,
Civil Action No. 04-343 (JJF)
Dear Manuel:
I write in response to your July 23, 2007 letter that was emailed to me on July 24, 2007,
while I was away on vacation without email access. We have proposed a meet and confer today
to discuss the issues that you raised and some concerns that we have with ViewSonic’s recent
document productions. We hope to resolve or narrow these issues with you at your earliest
convenience.
Because we expect to discuss these issues with you in detail, I will not respond here to
each of the points that you raised in your letter. Generally, however, please note the following:
l. LPL has produced exploded view drawings for certain modules that show the relative
location of parts and thus address the assembly of those parts / products, but for many products
we have determined that such drawings are not available;
2. We are investigating the alleged "legibility problem" and will discuss this with you by
telephone. It would be helpful to better understand ViewSonic’s specific concerns regarding the
documents referenced in your letter. We look forward to speaking with you;
3. To the extent that certain documents are duplicative, ViewSonic can determine
whether any differences exist between similar documents and can determine whether to use one
or more sets of documents. Duplication of documents is possible, however, as we attempted to
be inclusive in LPL’s production, which may have resulted in some overlap;
4. We are still investigating Dr. Silzars’ background and ViewSonic has not explained
the reason for the delay in disclosing this expert;

Case 1:04-cv-00343-JJF Document 747-3 Filed 08/03/2007 Page 3 of 3
Manuel Nelson, Esq.
July 27, 2007
Page 2
5. We do not agree that it would be appropriate for ViewSonic to further depose LPL,
especially given the already extensive and burdensome number of depositions of LPL in this
case. Further, we dispute the extent of any inequitable conduct defense in this case, and
ViewSonic still has not sought to assert such a defense. In addition, your proposal for
depositions in Los Angeles is contrary to the parties’ prior agreement regarding deposition
location.
In addition, we would like to discuss deficiencies in ViewSonic’s recent document
productions. For example, ViewSonic’s production is extremely limited and appears to be
missing some communications between ViewSonic and its OEM suppliers. In addition, the
correspondence that ViewSonic produced is unsigned and presumably does not include the date
of the correspondence. Please reproduce the actual copies of all communications as soon as
possible as we intend to raise this with the Special Master if necessary on Tuesday’s call. We
also look forward to ViewSonic’s production today of communications with Ta ng entities.
We look forward to discussing these issues with Vie Sonic as soon ossi e.
Cass W. Christenson
cc: Counsel of Record (via email)

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