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Case 1:04-cv-00343-JJF Document 643-2 Filed 05/01/2007 Page1 of 3

Case 1:04-cv-00343-JJF g/icument 643-2 Filed 05/01/2007 Page 2 of 3
Albany New York
Atlanta & Philadelphia
Brussels Amimeys at Law San Diego
De 1900 K Street, NW • Washington, DC 20006-1 108 San Francisco
“““ rei; 202.4%.7500 · Fax: 202.496.7756
Los Angeles www.mCkennal0ng.C0m Washington, D.C.
CASS W. CHRISTENSON EMAIL ADDRESS
(202) 496-7218 April 26, 2007 [email protected]
VIA E-MAIL AND U.S. MAIL
Frank E. Merideth, Jr., Esq.
Greenberg Traurig, LLP
2450 Colorado Avenue, Suite 400 East
Santa Monica, CA 90404
Re: LG.Philips LCD Co., Ltd. v. Tatung, et al.; Civil Action No. 04-343 (JJF)
Dear Frank:
I write concerning the Declaration of Oliver Shih that Tatung submitted to Special Master
Poppiti on April 20, 2007. The declaration is insufficient and fails to comply with the Special
Master's instructions. The Special Master attempted to accommodate Tatung by allowing Tatung
to provide a sworn declaration, as a possible substitute to further testimony, only if doing so
would provide LPL with complete information concerning inducement and accused products.
Mr. Shih's declaration does not provide any information concerning Tatung's communications or
conduct with respect to accused products supplied to and for the U.S. market. Further, paragraph
two is limited only to meetings within the U.S. (not other relevant meetings, teleconferences, and
communications) and does not even specify which employees were consulted, whether those
employees reviewed any records, etc. Paragraph three does not state whether all trip reports
were reviewed, and is contrary to Tatung's prior agreement to produce documents, including trip
reports, that relate generally to sales and marketing for the U.S., not just documents that
specifically reference accused products. Paragraph four is conclusory and self-serving, requiring
cross-examination. LPL objects to Mr. Shih's declaration on all of these grounds. The Special
Master concluded that Tatung was not prepared at the deposition and Mr. Shih's declaration only
compounds this problem and is contrary to the record.
Please let me know what times tomorrow or on Monday, April 30, you are available to
discuss these issues.
my “/yl
Cass Christenson
CWC:ea

Case 1:04-cv-00343-JJF Document 643-2 Filed 05/01/2007 Page 3 of 3
Frank E. Merideth, Jr., Esq.
April 26, 2007
Page 2
cc: Richard D. Kirk, Esq. (via e-mail)
SCOU R. Miller, Esq. (via e—maiI)
Mark Krietzman, Esq. (via e-mail)
Valerie W. H0, Esq. (via e-mail)
Steve P. Hassid, Esq. (via email)
Anne Shea Gaza, Esq. (via e-mail)
Frederick L. Cottrell, III, Esq. (via e-mail)
Manuel Nelson, Esq. (via e—mail)
Tracy R. Roman, Esq. (via e-mail)
Jeffrey B. Bove, Esq. (via e-mail)
Jaclyn M. Mason, Esq. (via e-mail)
James D. Heisman, Esq. (via e-mail)

Case 1:04-cv-00343-JJF

Document 643-2

Filed 05/01/2007

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EXHIBIT A

Case 1:04-cv-00343-JJF

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Case 1:04-cv-00343-JJF

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