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Case 1:04-cv-00343-JJF

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EXHIBIT G

RLF1-3157583-1

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE LG.PHILIPS LCD CO., LTD., Plaintiff, v. TATUNG COMPANY; TATUNG COMPANY OF AMERICA, INC.; and VIEWSONIC CORPORATION, Defendants. Civil Action No. 04-343-JJF

PLAINTIFF'S SIXTH SUPPLEMENTAL OBJECTIONS AND ANSWERS TO DEFENDANT TATUNG COMPANY'S FIRST SET OF INTERROGATORIES Plaintiff LG.Philips LCD Co., Ltd. ("LPL" or "Plaintiff," also referred to in Interrogatories as "LGP"), by counsel and pursuant to Fed. R. Civ. P. 33, objects and responds as follows to Defendant Tatung Company's ("Tatung") First Set of Interrogatories. PRELIMINARY STATEMENT & GENERAL OBJECTIONS LPL hereby incorporates its Preliminary Statement and its General Objections from Plaintiff's Objections and Answers to Defendant Tatung Company's First Set of Interrogatories, dated April 7, 2006. Those general objections apply to each Interrogatory herein and thus, for convenience, are not repeated after each Interrogatory, and are hereby incorporated into each response. This set of Objections and Responses incorporates into this single document all of LPL's previously-submitted supplemental objections and responses to Defendant Tatung Company's First Set of Interrogatories.

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INTERROGATORIES INTERROGATORY NO. 1: For each of the Patents-in-Suit, identify each and every TATUNG and TATUNG USA product by model number and/or other TATUNG or TATUNG USA designation made, used, offered for sale, sold in the U.S., or imported into the U.S. which LGP contends infringes the Patents-in-Suit (herein after, "Accused Product(s)") and identify each claim of each of the Patents-in-Suit that LGP contends is infringed by each Accused Product and where in each Accused Product the claim elements are located. OBJECTIONS AND ANSWER LPL objects to this Interrogatory to the extent that it seeks information protected by the attorney-client privilege or the work product doctrine. LPL also objects to this Interrogatory as vague and ambiguous, including with respect to the terms "TATUNG product" and "TATUNG USA product." LPL further objects to this Interrogatory because Tatung mischaracterizes as one interrogatory multiple interrogatories on separate subjects and defendants; in responding, LPL counts this Interrogatory as multiple interrogatories. Also, LPL objects to this Interrogatory as seeking information on claim construction and infringing products that is premature and unavailable, including because LPL is awaiting discovery from defendants. Further, LPL objects to this Interrogatory as calling for legal conclusions. Subject to and without waiving these objections and the general objections, and based upon the information presently available, LPL states as follows: LPL cannot currently identify all infringing Tatung brand and other products and defendants have failed to provide discovery sufficient for LPL to make such an assessment. LPL is aware of products that infringe the Patents-in-Suit, including Tatung L17AMTN monitors. Tatung's liability and TATUNG USA's liability, however, includes any type of unlawful conduct related to any infringing products, whether direct infringement, contributory infringement, and/or inducing infringement by others. Tatung and TATUNG USA, for example,

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have at least made, sold, offered for sale, and/or imported infringing products such as the L17AMTN monitor. With respect to the L17AMTN monitor, the infringed claims include, at least, claims 35, 36, and 55 of the `641 patent and claims 33, 34, 35, and 40 of the `718 patent, which are infringed literally. The following charts show infringement by comparing the claims of the Patents-in-Suit with the Tatung L17AMTN monitor (see corresponding Exhibit A, which is attached to these Interrogatory answers):

Claim in the `641 Patent
35. A rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising:

Tatung L17AMTN Monitor
The Tatung L17AMTN monitor contains a Chi Mei LM170E4-L02 flat panel TFT LCD module K. The LCD module K, in conjunction with the first support frame C, is rear mounted within the monitor. The monitor is a data processing device as it contains a video processor for processing video data. The monitor is also part of (i.e., a component of) a computer system, where a computer system constitutes a data processing device or system. The Chi Mei module K contains a backlight unit and an LCD panel. The LCD panel is a flat display panel that is located immediately in front of the backlight unit.

a backlight unit including a first frame having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight unit; and

The Chi Mei module K and, therefore, the backlight unit in the Chi Mei module K, are supported by the first support frame C. The first support frame C has screw holes D through its rear surface. Each of the screw holes D through the rear surface of the support frame C constitutes a fastening part, or at least a portion of a fastening part at the rear surface of a first frame. a second frame; The Tatung monitor has a front or second support frame M. wherein the flat display panel is Because the flat LCD panel is contained in the Chi Mei between the first frame and the second module K, the flat LCD panel must be positioned frame, the first frame of the backlight between the first support frame C and the second unit capable of being fixed to a support frame M. housing of the data processing device The four screw holes D through the rear surface of the through the fastening part at the rear surface of the first frame. first support frame C, together with the four screws B, 3

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Claim in the `641 Patent

Tatung L17AMTN Monitor
fix the first support frame C to the rear housing A. The rear housing A protects the monitor, and in particular, the components located behind or to the rear of the first support frame C, including the data processing circuitry. As the Tatung monitor is a data processing device, or a component of a computer (i.e., a data processing device), the housing associated with the monitor constitutes a housing of a data processing device. Each of the screw holes D through the rear surface of the first support frame C constitutes a fastening hole.

36. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a fastening hole. 55. A rear mountable flat panel display device comprising:

a first frame having a fastening part at a rear surface of the first frame;

a second frame; and

a flat display panel between the first and second frames;

wherein the first frame is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame.

The Tatung L17AMTN monitor contains a Chi Mei LM170E4-L02 flat panel TFT LCD module K. The LCD module K, in conjunction with the first support frame C, is rear mounted within the monitor. Thus, the Tatung monitor contains a rear mountable flat panel display device. The first support frame C has four screw holes D through its rear surface. Each of the four screw holes D constitutes a fastening part, or at least a portion of a fastening part at the rear surface of a first frame. The Tatung monitor employs a front frame M located at the front of the LCD module K. This front frame M constitutes a second support frame. The Chi Mei module K contains a flat LCD panel. Therefore, the flat LCD panel in the Chi Mei module K must be located between the first support frame C and the second support frame M. When the four screws B are installed, the four screws B, together with the four screw holes D through the rear surface of the first support frame C, fix the first support frame C to the rear housing A. The rear housing A protects the monitor, and in particular, the components located behind or to the rear of the first support frame C, including the data processing circuitry. As the Tatung monitor is a data processing device, or a component of a computer (i.e., a data processing device), the housing associated with the monitor constitutes a housing of a data processing device. 4

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Claims in the `718 Patent
33. A method of assembling a rear mountable flat panel display device capable of being mounted to a housing, comprising:

Tatung L17AMTN Monitor
The Tatung L17AMTN monitor includes a Chi Mei LM170E4-L02 flat panel TFT LCD module K, a first support frame C and a rear housing A. The Chi Mei module K and the support frame C are rear mounted to the rear housing A. The Tatung monitor was therefore assembled in accordance with a method of rear mounting a flat panel display device to a housing. The Chi Mei module K contains a flat LCD panel and a backlight unit. It is understood that the LCD panel is in front of (i.e., on top of) the backlight unit. It can thus be said that the Chi Mei module K is assembled by placing a flat LCD panel on top of a backlight unit. Just behind and providing support for the Chi Mei module K is the first support frame C. The first support frame C has four fastening elements that at least partially involve the four screw holes D. The screw holes D are used in fastening the first frame C to the rear housing A. Screw holes D go through the rear surface of the first support frame C and, therefore, it can be said that they are located on a rear surface of the first support frame C opposite the top surface (i.e., the front surface) of the backlight unit. The Tatung monitor includes a front or second support frame M. It is located at the front of the Chi Mei module K. It can therefore be said that the second frame M is placed on the flat display panel. Because the flat LCD panel is contained in the Chi Mei module K, the flat LCD panel must be positioned between the first support frame C and the second support frame M. Thus, it can be said that the Tatung monitor was assembled in accordance with a method that involved fixing the flat LCD panel, contained in the Chi Mei module K, between a first support frame C and a second support frame M. Each of the four screw holes D are fastening holes that constitutes a fastening element, or at least a portion of a fastening element. Each of the four screw holes D constitutes a fastening element, or at least a portion of a fastening element.

placing a flat display panel on a top surface of a backlight unit having a first frame, the first frame having a fastening element for fastening the first frame to the housing, said fastening element being located on a rear surface opposite the top surface of the backlight unit where the flat display panel is placed;

placing a second frame on the flat display panel; and

fixing the flat display panel between the first frame of the backlight unit and the second frame.

34. The method of claim 33, wherein the fastening element comprises a fastening hole. 35. The method of claim 33, wherein the fastening element comprises a screw hole.

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Claims in the `718 Patent
40. A rear mountable method of assembling a liquid crystal display (LCD) device comprising:

Tatung L17AMTN Monitor
The Tatung L17AMTN monitor includes a Chi Mei LM170E4-L02 flat panel TFT LCD module K, a first support frame C and a rear housing A. The Chi Mei module K and the support frame C are rear mounted to the rear housing A. accordingly, the Tatung monitor was assembled in accordance with a rear mountable method of assembling a LCD device. The Chi Mei module K and the first support frame C are located just in front of the rear housing A. Therefore, the Chi Mei module K and the first support frame C are arranged on an inner surface of the rear housing A, where the rear housing A constitutes a display case. The Chi Mei module K and the first support frame C are attached to the rear housing A from the back of the rear housing A, in that the Chi Mei module K is supported by the first frame C, which is rear mounted to the rear housing A by the four screws B passing through the rear surface of the rear housing A and through the screw holes D at the rear surface of the first support frame C.

arranging the LCD device on a inner surface of a display case, wherein the display case has an inner surface and back;

attaching the LCD device to the display case from the back of the display case.

LPL will provide more detailed information regarding the infringing products and asserted claims at the appropriate time and based on further discovery, possibly including, for example, in expert reports and/or Markman briefing. LPL reserves the right to address the doctrine of equivalents if and when appropriate, and reserves the right to supplement this Interrogatory answer, if appropriate, when and if additional information becomes available, or otherwise. SUPPLEMENTAL RESPONSE & OBJECTION: LPL objects to this Interrogatory to the extent that it seeks information protected by the attorney-client privilege or the work product doctrine. LPL further objects to this Interrogatory because Defendants mischaracterize as one interrogatory multiple interrogatories on separate subjects; in responding, LPL counts this Interrogatory as multiple interrogatories. Also, LPL

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objects to this Interrogatory at least because it is premature in that it seeks information pertaining to or requiring claim construction, and because it seeks information pertaining to infringing products that are presently unavailable because LPL is still awaiting discovery from Tatung on such products. Subject to and without waiving these objections and the general objections, and based upon the information presently available, LPL states as follows: Tatung has refused and/or failed to provide discovery that would enable LPL to fully respond to this Interrogatory. The Tatung products that LPL is currently aware of that infringe the Patents-in-Suit include the: Tatung L17UCCT ("L17UCCT"), Tatung L17AMTN ("LTAMTN"), and Tatung L1705 ("L1705") monitors. Tatung's liability, however, includes any type of improper conduct related to any infringing products, whether by direct infringement, contributory infringement, and/or inducing infringement by others. Tatung, for example, has at least sold, offered for sale, and/or imported infringing products such as the L17UCCT, LTAMTN, and L1705 monitors. With respect to the L17UCCT monitors, the infringed claims include, at least, claims 35, 36, 38, 40-43, and 55-56 of the `641 Patent and claims 33-35 and 39-40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the LTAMTN monitors, the infringed claims include, at least, claims 35, 36, 38-43, 55-56 of the `641 Patent and claims 33-35 and 39-40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the L1705 monitors, the infringed claims include, at least, claims 35, 36, 38, 40-45, 55-56 of the `641 Patent and claims 33-35 and 39-40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents.

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The following charts show infringement by comparing the claims of the Patents-in-Suit with the L17UCCT, L17AMTN, and L1705 monitors:

Claims in the `641 Patent 35. A rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising: a backlight unit including a first frame having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight unit; and a second frame;

Tatung Monitors The L17UCCT, L17AMTN, and L1705 are each a rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising the following elements.

The L17UCCT, L17AMTN, and L1705 each have a backlight unit including a first frame having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight unit.

The L17UCCT, L17AMTN, and L1705 each have a second frame. The L17UCCT, L17AMTN, and L1705 each have a flat display panel that is between the first frame and the second frame, the first frame of the backlight unit capable of being fixed to a housing of the data processing device through the fastening part at the rear surface of the first frame.

wherein the flat display panel is between the first frame and the second frame, the first frame of the backlight unit capable of being fixed to a housing of the data processing device through the fastening part at the rear surface of the first frame. 36. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a fastening hole. 38. The rear mountable flat panel display device according to claim 36, wherein the fastening part includes at least two fastening holes at two corners of the first frame. 39. The rear mountable flat panel display device according to claim 36, wherein the fastening part includes four fastening holes at four corners of the first frame.

In addition to the elements listed above that pertain to the limitations of claim 35, the L17UCCT, L17AMTN, and L1705 each have a fastening part that includes a fastening hole. In addition to the elements listed above that pertain to the limitations of claim 36, the L17UCCT, L17AMTN, and L1705 each have fastening parts that include at least two fastening holes at two corners of the first frame. In addition to the elements listed above that pertain to the limitations of claim 36, the L17AMTN has fastening parts that include four fastening holes at four corners of the first frame.

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Claims in the `641 Patent 40. The rear mountable flat panel display device according to claim 35, wherein the backlight unit comprises: a reflector unit adjacent the first frame; a light source unit adjacent the reflector unit; and a light guide unit adjacent the light source unit. 41. The rear mountable flat panel display device according to claim 40, further comprising a diffuser unit and a prism unit. 42. The rear mountable flat panel display device according to claim 35, wherein the fastening part is not visible from a viewing direction of the flat display panel. 43. The rear mountable flat panel display device according to claim 35, wherein the flat panel display device only shows the flat display panel and the second frame when viewed from a viewing direction of the display panel. 44. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a protruding portion protruding away from the flat display panel.

Tatung Monitors In addition to the elements listed above that pertain to the limitations of claim 35, the L17UCCT, L17AMTN, and L1705 each have a backlight unit comprising the following elements. The L17UCCT, L17AMTN, and L1705 each have a reflector unit adjacent the first frame. The L17UCCT, L17AMTN, and L1705 each have a light source unit adjacent the reflector unit. The L17UCCT, L17AMTN, and L1705 each have a light guide unit adjacent the light source unit. In addition to the elements listed above that pertain to the limitations of claim 40, the L17UCCT, L17AMTN, and L1705 each have a diffuser unit and a prism unit.

In addition to the elements listed above that pertain to the limitations of claim 35, the L17UCCT, L17AMTN, and L1705 each have a fastening part that is not visible from a viewing direction of the flat display panel.

In addition to the elements listed above that pertain to the limitations of claim 35, the L17UCCT, L17AMTN, and L1705 each have a flat panel display device that only shows the flat display panel and the second frame when viewed from a viewing direction of the display panel. In addition to the elements listed above that pertain to the limitations of claim 35, the L1705 has a fastening part that includes a protruding portion protruding away from the flat display panel.

45. The rear mountable flat panel In addition to the elements listed above that pertain to display device according to claim 44, the limitations of claim 44, the L1705 has a protruding wherein the protruding portion portion that includes a peg having a fastening hole. includes a peg having a fastening hole.

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Claims in the `641 Patent 55. A rear mountable flat panel display device comprising:

Tatung Monitors The L17UCCT, L17AMTN, and L1705 are each a rear mountable flat panel display device, the rear mounted flat panel display device comprising the following elements. The L17UCCT, L17AMTN, and L1705 each have a first frame having a fastening part at a rear surface of the first frame. The L17UCCT, L17AMTN, and L1705 each have a second frame. The L17UCCT, L17AMTN, and L1705 each have a flat display panel between the first and second frames. The L17UCCT, L17AMTN, and L1705 each have a first frame that is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame.

a first frame having a fastening part at a rear surface of the first frame;

a second frame; and

a flat display panel between the first and second frames; wherein the first frame is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame. 56. A rear mountable flat panel display device comprising:

The L17UCCT, L17AMTN, and L1705 are each a rear mountable flat panel display device, the flat panel display device comprising the following elements. The L17UCCT, L17AMTN, and L1705 each have a first frame having a fastening part at a rear surface of the first frame. The L17UCCT, L17AMTN, and L1705 each have a second frame. The L17UCCT, L17AMTN, and L1705 each have a flat display panel between the first and second frames. The L17UCCT, L17AMTN, and L1705 each have a first frame that is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame and the flat display panel is rear mounted.

a first frame having a fastening part at a rear surface of the first frame;

a second frame;

and a flat display panel between the first and second frames; wherein the first frame is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame and the flat display panel is rear mounted.

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Claims in the `718 Patent 33. A method of assembling a rear mountable flat panel display device capable of being mounted to a housing, comprising: placing a flat display panel on a top surface of a backlight unit having a first frame, the first frame having a fastening element for fastening the first frame to the housing, said fastening element being located on a rear surface opposite the top surface of the backlight unit where the flat display panel is placed; placing a second frame on the flat display panel; and

Tatung Monitors The L17UCCT, L17AMTN, and L1705 are each assembled via a method of assembling a rear mountable flat panel display device capable of being mounted to a housing, that method includes the following steps. The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes placing a flat display panel on a top surface of a backlight unit having a first frame, the first frame having a fastening element for fastening the first frame to the housing, the fastening element being located on a rear surface opposite the top surface of the backlight unit where the flat display panel is placed.

The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes placing a second frame on the flat display panel. The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes fixing the flat display panel between the first frame of the backlight unit and the second frame. In addition to the steps and/or elements listed above that pertain to the limitations of claim 33, the L17UCCT, L17AMTN, and L1705 each have a fastening element that comprises a fastening hole. In addition to the steps and/or elements listed above that pertain to the limitations of claim 33, the L17UCCT, L17AMTN, and L1705 each have a fastening element that comprises a screw hole. The L17UCCT, L17AMTN, and L1705 are each assembled via a rear mountable method of assembling a liquid crystal display (LCD) device, that method includes the following steps. The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes arranging a first frame on a light guide, the first frame having holes for

fixing the flat display panel between the first frame of the backlight unit and the second frame.

34. The method of claim 33, wherein the fastening element comprises a fastening hole.

35. The method of claim 33, wherein the fastening element comprises a screw hole.

39. A rear mountable method of assembling a liquid crystal display (LCD) device comprising:

arranging a first frame on a light guide, the first frame having holes for coupling a LCD panel to a supporting

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Claims in the `718 Patent frame, the supporting frame having a front surface and a rear surface; and

Tatung Monitors coupling an LCD panel to a supporting frame, the supporting frame having a front surface and a rear surface. The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes coupling the LCD panel, the light guide to the first frame from the rear surface of the supporting frame. The L17UCCT, L17AMTN, and L1705 are each assembled via a rear mountable method of assembling a liquid crystal display (LCD) device, that method includes the following steps. The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes arranging the LCD device on an inner surface of a display case, wherein the display case has an inner surface and back. The method of assembling each of the L17UCCT, L17AMTN, and L1705 includes attaching the LCD device to the display case from the back of the display case.

coupling the LCD panel, the light guide to the first frame from the rear surface of the supporting frame.

40. A rear mountable method of assembling a liquid crystal display (LCD) device comprising:

arranging the LCD device on a inner surface of a display case, wherein the display case has an inner surface and back; attaching the LCD device to the display case from the back of the display case.

LPL will provide more detailed information regarding the infringing products and asserted claims at the appropriate time and based on further discovery, possibly including, for example, in expert reports and/or Markman briefing. LPL reserves the right to supplement this Interrogatory answer, if appropriate, when and if additional information becomes available, or otherwise. SUPPLEMENTAL RESPONSE & OBJECTION: LPL objects to this Interrogatory to the extent that it seeks information protected by the attorney-client privilege or the work product doctrine. LPL further objects to this Interrogatory because Defendants mischaracterize as one interrogatory multiple interrogatories on separate subjects; in responding, LPL counts this Interrogatory as multiple interrogatories. Also, LPL 12

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objects to this Interrogatory at least because it is premature in that it seeks information pertaining to or requiring claim construction, and because it seeks information pertaining to infringing products that are presently unavailable because LPL is still awaiting discovery from Tatung on such products. Subject to and without waiving these objections and the general objections, and based upon the information presently available, LPL states as follows: Tatung has refused and/or failed to provide discovery that would enable LPL to fully respond to this Interrogatory. The Tatung products that LPL is currently aware of that infringe the Patents-in-Suit include the: American Dynamics ADMNC1LCD15 (the "ADMNC1LCD15"); American Dynamics ADMNC1LCD17 (the "ADMNC1LCD17"); Tatung ADMNC1LCD17 (the "Tatung ADMNC1LCD17"); American Dynamics (Unidentified but inspected at Greenberg Traurig's office on January 16, 2007 and includes module model number M170EN06 (the "Unidentified American Dynamic Product"); Tatung L17AMTN (the "Tatung L17AMTN"); Unidentified product with designation P42HSMT identified at Greenberg Traurig's office on January 16, 2007 (the "P42HSMT"); Tatung P46 (the "Tatung P46T"); Triview TLM 1505 (the "Triview FST1503RV-4B"); Tatung TLM 1703T (the "Tatung TLM-1703T"); Triview TLM-1703 (the "Triview TLM-1703"); Tatung TLM-1705 (the "Tatung TLM-1705"); Triview TLM-1705 (the "Triview TLM-1705"); Triview TLM-1903 (the "Triview TLM-1903"); Tatung V23CLTT (the "Tatung V23CLTT"); Taung V23DLWX-U12 (the "Tatung V23DLWX-U12"); Tatung V27CMTT-U01 (the "Tatung V27CMTT-U01"); Tatung V30CMTT-U01 (the "Tatung V30CMTT-U01"); and Triview V30CMTT-U62 (the Triview V30CMTT-U62") products. Tatung's liability, however, includes any type of improper conduct related to any infringing products, whether by direct infringement, contributory infringement, and/or inducing infringement by others. Tatung, for example, has at least sold, offered for sale, and/or imported

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infringing products such as the ADMNC1LCD15; the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTTU01; and Triview V30CMTT-U62 products. The following charts show infringement by comparing the claims of the Patents-in-Suit with ADMNC1LCD15; the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and Triview V30CMTT-U62 products:

Claims in the `641 Patent 35. A rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising:

Tatung Products The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 are each a rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising the following elements. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview 14

a backlight unit including a first frame having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight

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Claims in the `641 Patent unit; and

Tatung Products TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a backlight unit including a first frame having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight unit. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a second frame. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a flat display panel that is between the first frame and the second frame, the first frame of the backlight unit capable of being fixed to a housing of the data processing device through the fastening part at the rear surface of the first frame. In addition to the elements listed above that pertain to the limitations of claim 35, The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a fastening part that includes a fastening hole. 15

a second frame;

wherein the flat display panel is between the first frame and the second frame, the first frame of the backlight unit capable of being fixed to a housing of the data processing device through the fastening part at the rear surface of the first frame.

36. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a fastening hole.

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Claims in the `641 Patent 38. The rear mountable flat panel display device according to claim 36, wherein the fastening part includes at least two fastening holes at two corners of the first frame.

Tatung Products In addition to the elements listed above that pertain to the limitations of claim 36, the ADMNC1LCD15; the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Tatung L17AMTN; the Triview FST1503RV-4B; the Triview TLM-1703; the Tatung TLM-1705; and the Triview TLM-1705; each have fastening parts that include at least two fastening holes at two corners of the first frame. In addition to the elements listed above that pertain to the limitations of claim 36, the ADMNC1LCD15; the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Tatung L17AMTN; the Tatung TLM-1705; and the Triview TLM-1705; has fastening parts that include four fastening holes at four corners of the first frame. In addition to the elements listed above that pertain to the limitations of claim 35, the ADMNC1LCD15; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Tatung TLM-1705; and the Triview TLM-1705 has a fastening part that includes a protruding portion protruding away from the flat display panel. In addition to the elements listed above that pertain to the limitations of claim 44, the Triview FST1503RV4B; the Tatung TLM-1703T; the Tatung TLM-1705; and the Triview TLM-1705 has a protruding portion that includes a peg having a fastening hole. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 are each a rear mountable flat panel display device, the rear mounted flat panel display device comprising the following elements. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the 16

39. The rear mountable flat panel display device according to claim 36, wherein the fastening part includes four fastening holes at four corners of the first frame. 44. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a protruding portion protruding away from the flat display panel.

45. The rear mountable flat panel display device according to claim 44, wherein the protruding portion includes a peg having a fastening hole.

55. A rear mountable flat panel display device comprising:

a first frame having a fastening part at a rear surface of the first frame;

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Claims in the `641 Patent

Tatung Products Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a first frame having a fastening part at a rear surface of the first frame.

a second frame; and

The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a second frame. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a flat display panel between the first and second frames. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a first frame that is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame.

a flat display panel between the first and second frames;

wherein the first frame is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame.

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Claims in the `641 Patent 56. A rear mountable flat panel display device comprising:

Tatung Products The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 are each a rear mountable flat panel display device, the flat panel display device comprising the following elements. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a first frame having a fastening part at a rear surface of the first frame. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a second frame. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a flat display panel between the first and second frames.

a first frame having a fastening part at a rear surface of the first frame;

a second frame;

and a flat display panel between the first and second frames;

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Claims in the `641 Patent wherein the first frame is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame and the flat display panel is rear mounted.

Tatung Products The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a first frame that is capable of being fixed to a housing of a data processing device through the fastening part at the rear surface of the first frame and the flat display panel is rear mounted.

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Claims in the `718 Patent 33. A method of assembling a rear mountable flat panel display device capable of being mounted to a housing, comprising:

Tatung Monitors The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 are each assembled via a method of assembling a rear mountable flat panel display device capable of being mounted to a housing, that method includes the following steps. The method of assembling each of the ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 includes placing a flat display panel on a top surface of a backlight unit having a first frame, the first frame having a fastening element for fastening the first frame to the housing, the fastening element being located on a rear surface opposite the top surface of the backlight unit where the flat display panel is placed. The method of assembling each of the ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 includes placing a second frame on the flat display panel. The method of assembling each of the ADMNC1LCD15; the ADMNC1LCD17; Tatung 20

placing a flat display panel on a top surface of a backlight unit having a first frame, the first frame having a fastening element for fastening the first frame to the housing, said fastening element being located on a rear surface opposite the top surface of the backlight unit where the flat display panel is placed;

placing a second frame on the flat display panel; and

fixing the flat display panel between the first frame of the backlight unit

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Claims in the `718 Patent and the second frame.

Tatung Monitors ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 includes fixing the flat display panel between the first frame of the backlight unit and the second frame. In addition to the steps and/or elements listed above that pertain to the limitations of claim 33, the ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a fastening element that comprises a fastening hole. In addition to the steps and/or elements listed above that pertain to the limitations of claim 33, the ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 each have a fastening element that comprises a screw hole. The ADMNC1LCD15; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; and the Triview TLM-1705 each have a stepped hole. The ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic 21

34. The method of claim 33, wherein the fastening element comprises a fastening hole.

35. The method of claim 33, wherein the fastening element comprises a screw hole.

36. The method of claim 33, wherein the fastening element comprises a stepped hole.

40. A rear mountable method of assembling a liquid crystal display

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Claims in the `718 Patent (LCD) device comprising:

Tatung Monitors Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 are each assembled via a rear mountable method of assembling a liquid crystal display (LCD) device, that method includes the following steps. The method of assembling each of the ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 includes arranging the LCD device on an inner surface of a display case, wherein the display case has an inner surface and back. The method of assembling each of the ADMNC1LCD15; the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; and the Triview V30CMTT-U62 includes attaching the LCD device to the display case from the back of the display case.

arranging the LCD device on a inner surface of a display case, wherein the display case has an inner surface and back;

attaching the LCD device to the display case from the back of the display case.

LPL will provide more detailed information regarding the infringing products and asserted claims at the appropriate time and based on further discovery, possibly including, for example, in expert reports and/or Markman briefing. LPL reserves the right to supplement this

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Interrogatory answer, if appropriate, when and if additional information becomes available, or otherwise. SUPPLEMENTAL RESPONSE & OBJECTION: LPL objects to this Interrogatory to the extent that it seeks information protected by the attorney-client privilege or the work product doctrine. LPL further objects to this Interrogatory because Defendants mischaracterize as one interrogatory multiple interrogatories on separate subjects; in responding, LPL counts this Interrogatory as multiple interrogatories. Also, LPL objects to this Interrogatory at least because it is premature in that it seeks information pertaining to or requiring claim construction, and because it seeks information pertaining to infringing products that are presently unavailable because LPL is still awaiting discovery from Tatung on such products. Subject to and without waiving these objections and the general objections, and based upon the information presently available, LPL states as follows: Tatung has refused and/or failed to provide discovery that would enable LPL to fully respond to this Interrogatory. The Tatung products that LPL is currently aware of that infringe the Patents-in-Suit include the: American Dynamics ADMNC1LCD17 (the "ADMNC1LCD17"); Tatung ADMNC1LCD17 (the "Tatung ADMNC1LCD17"); American Dynamics (Unidentified but inspected at Greenberg Traurig's office on January 16, 2007 and includes module model number M170EN06 (the "Unidentified American Dynamic Product"); Tatung L17AMTN (the "Tatung L17AMTN"); Tatung L17UCCT (the "Tatung L17UCCT"); Unidentified product with designation P42HSMT identified at Greenberg Traurig's office on January 16, 2007 (the "P42HSMT"); Tatung P46 (the "Tatung P46T"); Triview TLM 1505 (the "Triview FST1503RV-4B"); Tatung TLM 1703T (the "Tatung TLM-1703T"); Triview TLM1703 (the "Triview TLM-1703"); Tatung TLM-1705 (the "Tatung TLM-1705"); Triview TLM1705 (the "Triview TLM-1705"); Triview TLM-1903 (the "Triview TLM-1903"); Tatung 23

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V23CLTT (the "Tatung V23CLTT"); Taung V23DLWX-U12 (the "Tatung V23DLWX-U12"); Tatung V27CMTT-U01 (the "Tatung V27CMTT-U01"); Tatung V30CMTT-U01 (the "Tatung V30CMTT-U01"); Triview V30CMTT-U62 (the "Triview V30CMTT-U62"); Hewlett-Packard w22 RG556AA (the "HP RG556AA"); Ilo L15FCBT (the "Ilo L15FCBT"); and Hitachi 37HDL52 (the "Hitachi 37HDL52") products. Tatung's liability, however, includes any type of improper conduct related to any infringing products, whether by direct infringement, contributory infringement, and/or inducing infringement by others. Tatung, for example, has at least sold, offered for sale, and/or imported infringing products such as the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTTU01; Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 products. With respect to the ADMNC1LCD17 products, the infringed claims include, at least, claims 35-36, 38-39, and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung ADMNC1LCD17 products, the infringed claims include, at least, claims 35-36, 38-39, and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Unidentified American Dynamic Product products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of

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the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung L17AMTN products, the infringed claims include, at least, claims 35-36, 38-39, and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the L17UCCT monitors, the infringed claims include, at least, claims 3536, 38 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the P42HSMT products, the infringed claims include, at least claims 55 of the `641 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung P46T products, the infringed claims include, at least, claims 55-56 of the `641 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Triview FST1503RV-4B products, the infringed claims include, at least, claims 35-36, 38-39, 44-45, and 55-56 of the `641 Patent and claims 33-36 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung TLM-1703T products, the infringed claims include, at least, claims 35-36, 44-45 and 55-56 of the `641 Patent and claims 33-36 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Triview TLM-1703 products, the infringed claims include, at least, claims 35-36, 38, and 55-56 of the `641 Patent and claims 33-36 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung TLM-1705 products, the infringed claims include, at least, claims 35-36, 38-39, 44-45, and 55-56 of the `641 Patent and claims 33-36 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With

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respect to the Triview TLM-1705 products, the infringed claims include, at least, claims 35-36, 38-39, 44-45, and 55-56 of the `641 Patent and claims 33-36 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Triview TLM-1903 products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung V23CLTT products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung V23DLWX-U12 products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung V27CMTT-U01 products, the infringed claims include, at least, claims 3536 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Tatung V30CMTT-U01 products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Triview V30CMTT-U62 products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the HP RG556AA products, the infringed claims include, at least, claims 35-36, 44 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are

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infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Ilo L15FCBT products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. With respect to the Hitachi 37HDL52 products, the infringed claims include, at least, claims 35-36 and 55-56 of the `641 Patent and claims 33-35 and 40 of the `718 Patent, which are infringed literally, or, in the alternative, under the doctrine of equivalents. The following charts show infringement by comparing the claims of the Patents-in-Suit with the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 products:

Claims in the `641 Patent 35. A rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising:

Tatung Products The ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 are each a rear mountable flat panel display device capable of being mounted to a data processing device, the flat panel display device comprising the following elements. The ADMNC1LCD17; Tatung ADMNC1LCD17; the 27

a backlight unit including a first frame

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Claims in the `641 Patent having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight unit; and

Tatung Products Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 each have a backlight unit including a first frame having a fastening part at a rear surface of the first frame, a flat display panel adjacent to the backlight unit. The ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 each have a second frame. The ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM-1705; the Triview TLM1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTTU01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 each have a flat display panel that is between the first frame and the second frame, the first frame of the backlight unit capable of being fixed to a housing of the data processing device through the fastening part at the rear surface of the first frame. In addition to the elements listed above that pertain to the limitations of claim 35, the ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the Triview FST1503RV-4B; the Tatung 28

a second frame;

wherein the flat display panel is between the first frame and the second frame, the first frame of the backlight unit capable of being fixed to a housing of the data processing device through the fastening part at the rear surface of the first frame.

36. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a fastening hole.

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Claims in the `641 Patent

Tatung Products TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 each have a fastening part that includes a fastening hole.

38. The rear mountable flat panel display device according to claim 36, wherein the fastening part includes at least two fastening holes at two corners of the first frame.

39. The rear mountable flat panel display device according to claim 36, wherein the fastening part includes four fastening holes at four corners of the first frame. 44. The rear mountable flat panel display device according to claim 35, wherein the fastening part includes a protruding portion protruding away from the flat display panel.

In addition to the elements listed above that pertain to the limitations of claim 36, the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Tatung L17AMTN; the Tatung L17UCCT; the Triview FST1503RV-4B; the Triview TLM-1703; the Tatung TLM-1705; and the Triview TLM-1705; each have fastening parts that include at least two fastening holes at two corners of the first frame. In addition to the elements listed above that pertain to the limitations of claim 36, the ADMNC1LCD17; the Tatung ADMNC1LCD17; the Tatung L17AMTN; the Tatung TLM-1705; and the Triview TLM-1705; has fastening parts that include four fastening holes at four corners of the first frame. In addition to the elements listed above that pertain to the limitations of claim 35, the Triview FST1503RV4B; the Tatung TLM-1703T; the Tatung TLM-1705; the Triview TLM-1705, and the HP RG556AA has a fastening part that includes a protruding portion protruding away from the flat display panel. In addition to the elements listed above that pertain to the limitations of claim 44, the Triview FST1503RV4B; the Tatung TLM-1703T; the Tatung TLM-1705; and the Triview TLM-1705 has a protruding portion that includes a peg having a fastening hole.

45. The rear mountable flat panel display device according to claim 44, wherein the protruding portion includes a peg having a fastening hole.

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Claims in the `641 Patent 55. A rear mountable flat panel display device comprising:

Tatung Products The ADMNC1LCD17; Tatung ADMNC1LCD17; the Unidentified American Dynamic Product; the Tatung L17AMTN; the Tatung L17UCCT; the P42HSMT; the Tatung P46T; the Triview FST1503RV-4B; the Tatung TLM-1703T; the Triview TLM-1703; the Tatung TLM1705; the Triview TLM-1705; the Triview TLM-1903; the Tatung V23CLTT; the Tatung V23DLWX-U12; the Tatung V27CMTT-U01; the Tatung V30CMTT-U01; the Triview V30CMTT-U62; the HP RG556AA; the Ilo L15FCBT; and the Hitachi 37HDL52 are each a rear mountable flat panel display device, the rear mounted flat panel display devi