Free Letter - District Court of Delaware - Delaware


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Date: December 31, 1969
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State: Delaware
Category: District Court of Delaware
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Case 1:04-cv—00343-JJF Document 697-2 Filed 06/20/2007 Page 1 of 4
EXHIBIT A

Case 1:04-cv—00343-JJF Document 697-2 Filed 06/20/2007 Page 2 of 4
~t _ 222 Unis tx: Rt5,f\\’1Li.’U·,S · - 900
ii. HE BAYARD FIRM X A r;~o£e<;ir2;sra0
_____,1____:1__,__________,__m____,_________________________ _____ Wit.M¤NGrc>N. DE 19899
A F E R N E Y S -§¥I|EIl'|'I5LAWFiRMSWORLDW1DE
302-{:55-5000
(Fax) 302-5586395
llicltcrci D Kirk
BY EMAII. AND BY I~L»’·\i~lD
3o2~42e-42os
rkirkfgibayurdtirm com
June 1,2007
The Honorable Vincent .t. Poppiti
Blank Rome LLP

Wilmington, DE l9801
Re: LGZP/rilnvs LCD C0., Ltd it ViewSonic; CA. N0. 04643 JJ}?
Dear Special Master Poppiti:
l write in response to Your Honors request l` or a proposal on submissions and argument
regarding: (l) any unresolved discovery issues raised in the December 23, 2006 hearing; and (2)
whether additional discovery is appropriate based on the Courts Markman ruling Except as
noted below, LPL, Tatung and ViewSonic respect‘t"ul1y jointly propose the following schedules;
I. Unresolved Discovery Issues from Prior Motions
l. LPL, Tatung and ViewSonic will identity by 5 pm EDT Friday, June i, the issues that
each believes to remain unresolved from the December 23, 2006 hearing before the Special
Master, and attempt to resolve those issues. Counsel will attempt to resolve such issues, and will
complete such discussions by June 5
2 LPL also seeks (I) from ViewSonic the discovery described in LP1..’s May 8, 2007
submission; and (2) from Tatttng all sales figures For accused products, not limited to U.S. sales
and shipments As discussed during the May 23, 2007 bearing with the Special Master, if LPL is
permitted to pursue new discovery motions, ViewSonic respectfully requests a similar
opportunity to tile new motions on prior discovery requests. Counsel will attempt to resolve
such issrres, and will complete such discussions by June 5
3.. Each. party may submit a letter oi up to two pages by 5:00 p m. EDT on June 6, 2007,
to bring to the Special Mestefs attention issues from the December 28 hearing that remain
unresolved No new briefing will be submitted on the underlying discovery issues, unless
requested by the Special Master
4 Oral argument by teleconiizrence will be on or alter June 8, 2007, at a time to c set by
tire Special Master
!t52t·l6v-I

Case 1:04-cv—00343-JJF Document 697-2 Filed 06/20/2007 Page 3 of 4
Tire. BAYARD Finttt
The Honorable Vincent J. Poppiti
June l, 2007
Page 2
5 By way of status, ViewSonic notes that its May 8, 2007 submission (DM3I—l) to the
Special Master seeking sales inforrnation remains pending. if the parties cannot resolve this
issue by lune 5, ViewSonic will so advise the Special Master and request that this motion be
placed on the Special Mastefs calendar at the Special Master’s earliest convenience LPL
believed that this issue was resolved but, if the issue cannot be resolved by further discussion,
LPL respectfully proposes that LFL submit its opposition to VletvSonic*s May 8 submission by
June 8, 2007.

l. No later than by SZUU p rn EDT three business days after the preliminary claim
constructions are issued by the Special Master, LPL, Tatung and ViewSonic may each submit a
letter of up to Your pages addressing why additional discovery is or is not necessary based on the
preliminary claim constructions.
2 No later titan three business days after such opening submissions, each party may
submit a letter of up to two pages responding to each initial submission addressing why
additional discovery is or is not necessary based on the prelimintuy claim constructions.
3. Oral argument by teleconference will be set by the Special Master.
if Your Honor has any questions, counsel would be pleased to respond
fsf Richard D Kirk (ri<0922)
cc: all counsel shown on attached certificate

Case 1:04-cv—00343-JJF Document 697-2 Filed 06/20/2007 Page 4 of 4
CERTIFICATE OF SERVICE
The undersigned counsei certilies that copies of the foregoing document were
served as follows:
BY EMAIL ON JUNE 1, 2007 AND BY HAND ON JUNE 2, 2007:
Jeffrey B Bove, Esq Frederick L Cottreil, Ill, Esq.
Jaclyn M. Mason, Esq Anne Shea Gaza, Esq
Connolly Sov Lodge & I——Iutz LLP Richards, Layton & Finger
1007 North Orange Street One Rodney Square
PO Box 2207 F O Box E5}
Wilmington, Deiawtare 19899-2207 Wilmington, DE 19899
BY EMAIL ON JUNE I, 2007 AND BY U S MAIL ON JUNE 2, 2007:
Scott R. Miller, Esq Valerie I-Io, Esq.
Connolly Bove Lodge & Hutz LLP Mark H Krietzman, Esq
355 South Grand Avenue Frank C. Mendeth, lr , Esq
Suite 3150 Greenberg Traurig LLP
Los Angeles, CA 90071 2450 Colorado Avenue, Suite 400E
Santa Monica, CA 90404
Tracy Roman, Esq.
Raskin Peter Rubin & Simon LLP
i80l Century Park East, Suite 2300
Los Angeles, CA 90067
/s/ Richard D. Kirk ($09223
Richard D Kirk
¢·>:um-t

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