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` Case 1 :04-cv-00343-JJF Document 647 Filed 05/O2/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
A FOR THE DISTRICT OF DELAWARE
LGPHILIPS LCD CO., LTD.,
Plaintiff,
v_ Civil Action No. 04-343 (JJF)
7 TATUNG CO.;
A TATUNG COMPANY or AMERICA, mc., AND EXl“¤l*i'S 22*23
VIEWSONTC CORPORATION,
Defendants.
g DEFENDANT VIEWSONIC CORPORATION’S D. DEL. LR 7.1.1
CERTIFICATION CONCERNING VIEWSONIC’S MOTION
s TO COMPEL LPL re REQUEST FOR PRODUCTION 128
SUBMITTED TO SPECIAL MASTER POPPITI ON MAY 2, 2007
Pursuant to D. Del. LR 7.1.1, defendant ViewSonic Corporation (“ViewSonic") submits
this certification of its counse1’s efforts to resolve the refusal by plaintiff LG.Philips LCD Co.,
i Ltd. ("LPL") to produce any substantive discovery in response to ViewSonic’s new discovery
· requests served February 23 and 28, 2007. This certification specifically relates to ViewSonic’s
_ May 2, 2007 Motion to Compel LPL re Request for Production 128 submitted
i contemporaneously herewith. I
Paragraphs 1 and 2 ofthe January 17, 2007 Amended Scheduling Order (DI 401)
(respectively amending paragraphs 4(e) and 4(cl) of the August l8, 2005 Scheduling Order)
U I permitted ViewSonic to serve additional discovery requests directed to claims 38-39, 44-45, and _
56 of the ’64l patent ("new1y asserted claims of the ’64l patent") and claim 36 of the ’718 patent
(collectively “newly asserted claims") by no later than February 28, 2007 so that proper
responses could be timely served by no later than March 30, 2007.. ln compliance with the
A Court’s directive, on February 23, 2007, ViewSonic served Request for Production ("RFP") Nos.
l21·l27, Interrogatory ("ROG”) Nos. 30-34, and Request for Admission (“RFA") Nos. 34-37,
and on February 28, 2007, ViewSonic served RFP Nos. 128-130, and ROG Nos. 35-37. Copies
I 1

g Case 1:O4—cv—OO343-JJF Document 647 Filed 05/O2/2007 Page 2 of 3
of these discovery requests are enclosed as Exhibits 1-5. LPL’s responses thereto, the last of
which were served on March 30, 2007, are provided as Exhibits 6-10.
A On April 13, 2007, ViewSonic advised via a letter LPL that LPL’s responses to the new
discovery requests were deficient, and requested to meet and confer regarding the deficient
responses. Exhibit 11.
On April 18, 2007 ViewSonic and LPL met and conferred regarding ViewSonic’s new
_ discovery requests. The substance of the April 18 meet and confer is summarized in the email
enclosed as Exhibit 12. The relevant portions of the transcript of the January 19, 2007
proceedings referenced in Exhibit 12 are provided at Exhibit 20.
The parties continued to meet and confer on April 19, 2007. The substance of the April
19 meet and confer is summarized in the emails enclosed as Exhibits 13-14. The relevant
` portions of the transcript of the December 28, 2006 proceedings referenced in Exhibit 14 and
elsewhere are provided at Exhibit 21.
The parties continued to meet and confer on April 24, 2007. The substance of the April
p 24 meet and confer is summarized in the emails enclosed as Exhibits 15-18.
A p On May 1, the parties completed their meet and confer. The parties reached on
agreement on RFAS 34-36, and appear to resolve their dispute regarding RFPs 121-122 and
ROGs 30-31. The parties could not reach an agreement regarding the technical discovery
n ViewSonic seeks, which is the subject of ViewSonic’s present motion. See Exhibits 19, 19-1.
The relevant portions of the transcript of the March 9, 2007 proceedings referenced in Exhibit 19
‘ are provided at Exhibit 22. This transcript is designated Highly Sensitive Confidential. `
LPL’s February 16, 2007 correspondence regarding LP’s partial identification of
products with "holes" on the rear surface is provided at Exhibit 23. A document with pages
bates labeled LPL11775 to LPL11780, which was enclosed with LPL’s February 16, 2007 letter,
is designated Highly Sensitive Confidential.
Relevant portions of the prosecution history of LPL’s U.S. Patent No. 6,501,641 cited in
ViewSonic’s instant motion are provided at Exhibit 24.

y Case 1 :04-cv-00343-JJF Document 647 Filed 05/O2/2007 Page 3 of 3
Date: May 2, 2007 Respectfully submitted,
Connolly Bove Lodge & Hutz LLP
Of Counsel: By: /s/ James D. Heisman
Scott R. Miller (CA Bar No. 112656) Jeffrey B. Bove (#0998)
Connolly Bove Lodge & Hutz LLP James D. Heisman (#2746)
355 South Grand Avenue, Suite 3150 Jaclyn M. Mason (#4737)
Los Angeles, CA 90071 The Nemours Building, 8th floor
1007 North Orange Street
Tracy R. Roman (CA Bar No. 199031) Wilmington, DE 19801
Raskin Peter Rubin & Simon LLP Telephone: (302) 658—9141
1801 Century Park East Facsimile: (302) 658-5614
Suite 2300
Los Angeles, CA 90067 Attorneys for Defendant
_ ViewSonic Corporation
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