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Case 1:04-cv—00343-JJF Document 660-2 Filed 05/10/2007 Page1 of 3
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Case 1:04-cv—00343-JJF Document 660-2 Filed 05/10/2007 Page 2 of 3
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April 4, 2007
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Cass W. Christensen, Esq,.
Mciierma Long & Aldridge LLP
1900 K Street, NW.
Washington, DC. .20006
Re: LG Philips LCD Co, Lid vs. ViewSonic Corporation, at al
Delaware District Court, Case No. 04-343 lll?
Dear Cass:
This responds to your April 3, 2007 letter,
With respect to LPL’s "motion concerning deposition testimony," LPL never asked for, and did
not participate in, a meeting of counsel prior to tiling this motion on March 30, 2007.. ln fact,
the stated purpose of our April 2 meet and confer, which took piece after LPL already had filed
its motions, was to discuss 'l`atung’s document production, and not LPL’s "motion concerning
deposition testimony? Most of our discussion on April 2 focused on Tatung’s document
production. At the end of that discussion, you did ask in a perfunctory manner whether I had
any proposais regarding I..PL’s ‘°motion concerning deposition testimony? i stated that if you
had a proposal, you should raise it since this is LPL’s motion. I further stated that contrary to
your contention, LPL had made no prior requests to resolve the disputes concerning Mr. Shiifs
or Mr, Sun’s deposition testimony and you were unable to point to any such prior requests It
is, therefore, our position that LPL.‘s "motion concerning deposition tcstirnony" was improperly
filed because it did not comply with the meet and center requirements set forth in the District
of Delaware Local Rules and as reiterated hy the Special Master at the previous hearings.
With respect to "Iatung’s document production, l agreed to investigate the foilowing:
I) Whether Tatung has any documents reflecting US. customer numbers for customers who
have purchased the accused products.
2) Whether Tatung has trip reports that reter to the accused products (either by model number
or product size). l did not agree to produce all trip reports pertaining to trips to the United
States regarding all products. Trip reports regarding unaccused products are irreievant and not
discoverable,.
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Case 1 :04-cv—00343-JJF Document 660-2 Filed 05/10/2007 Palcjew nhll M l UIZA 7 ·)..
Cass W. Christensen, Esq.
` April 4, 2007
l Page 2
.3) Whether Tatung has profit and loss statements for the period prior to QI 2005.
4) Whether Tatung has additional communications with customers (for example, with
Viewsonic and Hitachi) regarding the accused products, including sales Forecasts.
5) Whether Tatung has printouts ofinformation posted on the website provided by l~IP that
relate to the accused HP product.
Please note that after performing a diligent, reasonable search, we believe all correspondence
between `fatung and HTP relating to the accused HP product have been produced. lf additional
responsive documents are located, we of course will supplement our production.
I will let you know when we have completed our investigation regarding the items set forth
above.
Very truly yours,
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V erie W. Ho
cc: Rel Acmbrozy (via email) E
Lora Btzezynslci (via email) {
Richard Kick (via email)
Scott Miller (via email)
Jetirey Bove (via email) _
James Heisman (via email)
Tracy Roman (via email)
Frank Merideth (via email)
Mark Krrietzman (via email)
Allan Jansen (via email)
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Case 1:04-cv-00343-JJF

Document 660-2

Filed 05/10/2007

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Case 1:04-cv-00343-JJF

Document 660-2

Filed 05/10/2007

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Case 1:04-cv-00343-JJF

Document 660-2

Filed 05/10/2007

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