Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-00343-JJF Document 665 Filed 05/16/2007 Page 1 of 4
I IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LGPHILIPS LCD CO., LTD.,
Plaintiff,
CIVIL ACTION NO. 04-343-JJF
v.
[EXHIBITS 6-26 HERETO
TATUNG CO.;
TATUNG cor/LPANY or AMERICA, INC. ; AND ARE FILED UNDER SEAL]
VIEWSONIC CORPORATION,
Defendants.
DECLARATION OF JAMES D. HEISMAN
IN SUPPORT OF DEFENDANT VIEWSONIC CORPORATION’S
RESPONDING CLAIM CONSTRUCTION BRIEF
James D. Heisman, being duly sworn, deposes and says as follows:
_ I am a partner of Connolly Bove Lodge & Hutz, LLP, counsel of record for ViewSonic
Corporation in this action. I submit this declaration in support of ViewSonic Corporation’s
Responding Claim Construction Brief.
1. Attached as Exhibit 6 hereto is a true and correct copy of Figure 4C from the
‘64l patent with two arrows superimposed thereon.
2. Attached as Exhibit 7 hereto are true and correct transcripts of excerpts from
A LPL’s Opening Brief.
3. Attached as Exhibit 8 hereto is a true and correct copy of UK Patent No.
2346464.
4. Attached as Exhibit 9 hereto is a true and correct copy of the Judgment rendered
by the Trial Court in the litigation between the identified parties in the United Kingdom.
5. Attached as Exhibit 10 hereto is a true and correct copy ofthe Decision ofthe
` Court of Appeals in the litigation between the identified parties in the United Kingdom.
6. Attached as Exhibit 11 hereto is a true and correct copy of the English translation
of Korean Patent Application No. 44475, the document marked as Exhibit 5 during the
deposition of Jong Hwan Kim in this action. `
7. Attached as Exhibit 12 hereto is a true and correct copy of the English translation
of Korean Patent Application No. 44973, the doctunent marked as Exhibit 16 during the
V deposition of Jong Hwan Kim in this action.

Case 1 :04-cv-00343-JJF Document 665 Filed 05/16/2007 Page 2 of 4
‘ 8. Attached as Exhibit 1 hereto is a true and correct copy of the Invention
Disclosure Form for Application No. AW 98-221, the document marked as Exhibit 1 during the
deposition of Jong Hwan Kim in this action.
9. Attached as Exhibit 14 hereto is a true and correct copy of the English translation
of the Invention Disclosure Form for Application No. AW 98-221, the document marked as
Exhibit 3 during the deposition of Jong Hwan Kim in this action.
· 10. Attached as Exhibit 15 hereto is a true and correct copy ofthe Invention
Disclosure Form No. AW 98-222, the document marked as Exhibit 2 during the deposition of`
Jong Hwan Kim in this action.
11. Attached as Exhibit 16 hereto is a true and correct copy ofthe English translation
ofthe Invention Disclosure Form No. 98-222, the document marked as Exhibit ll during the
deposition of Jong Hwan Kim in this action.
· 12. Attached as Exhibit 17 hereto is a true and correct copy ofthe UK disclosure
statement, the document marked as Exhibit 23 during the deposition of Young Woo Cho in this
action.
13. Attached as Exhibit 18 hereto are true and correct copies of the cover page, the
index page and various pages of deposition testimony of Young Woo Cho, taken in this action.
14. Attached as Exhibit 19 hereto are true and correct copies of the cover page, index
. page and deposition transcript pages of the deposition testimony of` Jong Hwan Kim, taken in this
action pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure.
15. Attached as Exhibit 20 hereto is a true and correct copy of Figures 4A and 4B
from the ‘641 patent which was marked as Exhibit 24 and specifically testified to during the
deposition of Young Woo Cho in this action.
16. Attached as Exhibit 21 hereto are true and correct copies of Figures 4A and 4B
_ from the ‘64l patent which was marked as Exhibit 55 and specifically testified to during the
deposition of Jong Hwan Kim in this action.
17. Attached as Exhibit 22 hereto is a true and correct copy of Responses of LPL to
ViewSonic Interrogatories Nos. 5, 7, and 11 in this action.
18. Attached as Exhibit 23 hereto is a true and correct copy of U.S. Patent No.
6,411,501 (the "`501 patent") to Cho, etal.
A 19. Attached as Exhibit 24 hereto is a true and correct copy of U.S. Patent No.
5,379,182, (the "` 182 patent") to Fujimori.
20. Attached as Exhibit 25 hereto are true and correct copies ofthe cover page, the
index page and various pages ofthe deposition transcript of William Bohannon, taken in this
action.

Case 1 :04-cv-00343-JJF Document 665 Filed 05/16/2007 Page 3 of 4
· 21. Attached as Exhibit 26 hereto is a true and correct copy of a side—by-side
depiction of Figure 4C ofthe ‘641 patent and Figure 6 of USPN 5,835,139 (the “` 139 patent") to
Yun et al.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws ofthe
United States of America that the foregoing is true and correct. This Declaration is executed this
16th day of May, 2007, in Wilmington, Delaware.
· ‘ By: /s/ James D. Heisman
James D. Heisman (#2746)

V Case 1 :04-cv-00343-JJF Document 665 Filed 05/16/2007 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on May 16, 2007, a true copy of the foregoing document was hand
delivered to the following persons and was electronically filed with the Clerk of the Court using
CM/ECF which will send notification of such tiling to the following and the document is
available for viewing and downloading from CM/ECF:
Richard D. Kirk Anne Shea Gaza
The Bayard Firm Frederick L. Cottrell III
222 Delaware Avenue, Suite 900 Richards, Layton & Finger, P.A.
Wilmington, DE 19801 One Rodney Square
Wilmington, DE 19801
1 hereby certify that on May 16, 2007,1 have sent by email the foregoing document to the
following non-registered participants:
Cass W. Christensen Mark H. Krietzman
Lora A. Brzezynski Valerie W. Ho
Rel S. Ambrozy Frank E. Merideth, Jr.
McKenna Long & Aldridge LLP Steve P. Hassid
1900 K Street, NW Greenberg Traurig, LLP
Washington, DC 20006 2450 Colorado Avenue, Suite 400E
Santa Monica, CA 90404
Tracy R. Roman
Raskin Peter Rubin & Simon
1801 Century Park East 23rd Floor
Los Angeles, CA 90067
By: /s/ James D. Heisman
‘ James D. Heisman (#2746)
[email protected]
534937_1.DOC

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