Free Order - District Court of Delaware - Delaware

U Case 1 :04-cv-00343-JJF Document 638 Filed O4/24/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT `
FOR THE DISTRICT OF DELAWARE

I W
l
Plaintiff, E
l
V- E Civil Action No. O4-343-JJF
TATUNG COMPANY; TATUNG E
COMPANY OF AMERICA, INC.; and :
VIEWSONIC CORPORATION, :
Defendants. E

STIPULATION AND ORDER REGARDING DISCOVERY SANCTIONS MOTIONS
IT IS HEREBY STIPULATED AND AGREED, by and among plaintiff LG.Philips LCD
Co., Ltd. ("LPL") and defendants Tatung Company, Tatung Company of America, Inc., and
ViewSonic Corporation (collectively "Defendants"), by and through their undersigned counsel,
and for the approval of the Special Master, as follows:
(1) Discovery-related sanctions motions are currently due to be filed by April 23, 2007,
as extended from the previous deadline of April 16, 2007. All ofthe parties hereto agree that
they will forego and refrain from filing any discovery-related motion seeking expenses and/or
sanctions, whether under Federal Rule of Civil Procedure 37 or otherwise, arising out of any of
the discovery taken in this case.
(2) The aforesaid agreement is not intended to preclude any party from filing: (a) any
motions in limine to exclude the admission of evidence at trial that has not been disclosed in
discovery or was not disclosed in a timely manner during discovery; (b) a motion for leave to
take additional discovery after the Court issues a ruling on claim construction, provided there are `
no requests for expenses or sanctions under Federal Rule 37 subsumed within or implied by said

Case 1:04-cv-00343-JJF Document 638 Filed O4/24/2007 Page 2 of 2
motion for leave to take additional discovery; or (c) asserting objections to evidence sought to be i
admitted at trial under the applicable Rules of Evidence.
THE BAYARD FIRM CONNOLLY BOVE LODGE & HUTZ LLP
/s/ Richard D. Kirk (rk0922) /s/ James D. Heisman (]`h2746)
Richard D. Kirk Jeffrey B Bove
Ashley B. Stitzer James D. Heisman
222 Delaware Avenue, Suite 900 Jaclyn M. Mason
P.O. Box 25130 1007 North Orange Street
Wilmington, DE 19899 P.O. Box 2207
(302) 655-5000 Wilmington, Delaware 19899-2207
Attorneys for Plaintw (302) 658-9141
LG.PhiI1ps LCD Co., Ltd. A ttarneys for Defendant ViewSonic
Corporation
RICHARDS, LAYTON & FINGER, P.A.
/s/ Anne Shea Gaza §ag4093)
Frederick L. Cottrell, III
Anne Shea Gaza
One Rodney Square
P.O. Box 551
Wilmington, DE 19899
(302) 651-7700
A ttorneys for defendants Tatung Company
and Tatung Company of America, Inc.
SO ORDERED thisZ// day ofApril, 2007.
I" 7
,1
-2-

Case 1:04-cv-00343-JJF

Document 638

Filed 04/24/2007

Page 1 of 2

Case 1:04-cv-00343-JJF

Document 638

Filed 04/24/2007

Page 2 of 2