Free Declaration - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 646-3 Filed 05/02/2007 Page1 of 3

i C 1 :04- -00343-JJF — F` 05/02/2007 Page 2 of 3
Albany ase CV New York
mane SI 1(ig€tti» *"**'·¤d¤'¤***¤
Brussels Almmfys al Law San Diego
Denver _ 1900 K Street, NW • Washington, DC 20006-1108 San Francisco
Tel: 202.496.75OO • Fax: 202.496.7756
Los Angeles www.mckenna|0ng.com Washington, D.C.
CASS W. CHRISTENSON Emu. ADDRESS
(202) 496-7218 [email protected]
January 22, 2007
BY FEDERAL EXPRESS AND E-MAIL
Scott R. Miller, Esq.
Connolly Bove Lodge & Hutz, LLP
355 South Grand Avenue, Suite 3150
Los Angeles, CA 90071
Re: LG.Philips LCD Co., Ltd. v. Tatung, etal.; Civil Action No. 04-343 (JJF)
Dear Scott:
Enclosed please find additional documents produced by LPL, reflecting bates numbers
LPL—09463 through LPL-09762. Please note that the enclosed documents are designated Highly
Sensitive Confidential and should not be disclosed to anyone except as provided in the protective
order in this case.
The enclosed production includes a spreadsheet (bates nos. LPL-09463 to LPL-09762)
that is responsive to ViewSonic’s Document Request No. 82. Please note that this information is
also responsive to other document requests, including, for example, ViewSonic’s Document
Request Nos. 84, 85, and 87. Regarding ViewSonic’s Document Request Nos. 83 and 102, LPL
is not aware of any responsive documents.
With respect to ViewSonic’s Document Request No. 103, LPL searched for the
documents that we understand that ViewSonic is seeking based on the December 28, 2006
teleconference. LPL is unaware of any responsive documents, including joint venture
agreements, concerning inventorship by parties other than LPL of mounting teclmology other
than front motmting. LPL also does not have documents concerning any transfer of interest from
LPL to any other party related to LPL’s mounting technology. During the December 28, 2006
teleconference, you specifically referred to an agreement from 1996 between Digital Equipment
Corporation and LG Electronics Inc. (the "DEC Agreement") as a document that ViewSonic
deemed potentially responsive. The DEC Agreement, however, has no bearing on reannounting
technology or any claims or defenses in this case. Further, copies of the DEC Agreement were
produced by parties other than LPL in the California case, including a copy produced by CPT
and designated "CONFIDENTlAL" (bates nos. CPT095472 to CPT095548). Based on the
protective order in the California case, please provide written consent from CPT and any other
necessary party if you would like for us to produce this CPT document to you.

Case 1:04-cv-00343-JJF Document 646-3 Filed 05/02/2007 Page 3 of 3
Scott Miller
January 22, 2007
Page 2
If you have any questions, or would like to discuss this further, pleas et us k ow.
Cass . Christenson
Enclosures
cc: Frank Meredith, Esq. (via overnight delivery, with enclosures)
Mark H. Krietzman, Esq. (via e-mail, w/o enclosures)
Valerie Ho, Esq. (via e-mail, w/o enclosures)
Frederick L. Cottrell, III, Esq. (via e-mail, w/o enclosures)
Tracy R. Roman, Esq. (via e-mail, w/o enclosures)
Manuel Nelson, Esq. (via email, w/o enclosures)
Jeffrey B. Bove, Esq. (via e-mail, w/o enclosures)
Jaclyn M. Mason, Esq. (via e-mail, w/o enclosures)
Richard Kirk, Esq. (via e-mail, w/o enclosures)
DC;50456474.l

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