EXHIBIT 3
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Case 1:04-cv—00343-JJF Document 608-4 Filed 03/30/2007 Page 2 of 4
Albany New York
Atlanta Philadelphia
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Denver 1900 K Street, NW · Washington, DC 20006-1 108 San Fwncisw
Tel: 202.496 7500 • Fax: 202 496.7756
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(202) 496-7439 cccnnortigmckennalong com
March 19, 2007
Bv E··MArrr Ann US Mme
Steve P. Irlassid, Esq.
Greenberg Traurig, LLP
2450 Colorado Avenue, Suite 40015.
Santa Monica, California 90404
[email protected]
Re: LG.Phi!ips LCD C0., Ltd. v. Tatrmg, et ul.;
C'iviIActi0rz No. 04—343 (JJF)
Dear Steve:
We have reviewed your letters of March 15, 2007 and {ind them to be calculated only to
waste time and to distract LPL from preparing to depose Tatung’s witnesses.
Your letter concerning `1`atungfs Document Requests suggests that, prior to writing that
letter, you reviewed neither LPL’s document production nor Tatung’s document requests.
Between Tatung’s First and Second Sets of Requests for Production of Documents and Things,
Tatung has propounded at total of l7l different requests for production on LPL. Your letter,
which was sent I5 days before the close of discovery and at a time when Tatung knows that LPL
is preparing to depose Tatung’s deposition witnesses, claims that Tatung has disputes concerning
all but l0 of its 17l requests. Given all ofthe hearings and related motion practice that have
occurred thus far in this case, your decision to wait until the 15 days before the close of
discovery and almost 19 months alter Tatung served its First Set of Requests to try to
manufacture disputes about l60 different Document Requests shows only that Tatung is using
your letters to try to sap l..PL’s resources and distract attention from Tatung’s own discovery
deficiencies.
To date, LPL has produced over l3.500 pages of documents in response to Tatung’s and
ViewSonic’s document requests. This volume of documents has been produced in response not
only to Taturtg’s l7l difierent requests for production, but also to the similar discovery requests
propounded by ViewSonic. Accordingly, LPL maintains that, subject to its objections to
Tatung’s discovery requests and to issues that are currently before the Special Master, LPL has
already produced documents responsive to Tatungfs requests.
Case 1:04-cv—OO343-JJF Document 608-4 Filed O3/30/2007 Page 3 of 4
Steve Hassid, Esq.
March 19, 2007
Page 2
By raising, at this late date, purported disputes concerning almost all of `liatungfs l7l
document requests, your letter fails to identify any particular deficiencies in Ll’l.’s production
and, in contrast, fails to account for the substantial amount of responsive documents that LPL has
produced. Your letter fails to take into account, moreover, the fact that Tatung and LPI., have
engaged in negotiations about many, if not most, of these same requests since at least July .2006
and, thus, fails to recount the parties` positions on any of those requests. Your letter tails to
recognize that most ol` Tatung’s requests seek the same types of information that ViewSonic
seeks through its own Document Requests and, therefore, completely ignores the fact that most
of those same issues have already been brietied amd argued `oetbre the Special Master and that
Tatung has joined many of those motions. ln fact, your letter arrives after the Special Master has
conducted no fewer than l2 separate discovery hearings since December 28, 2006 and, in
advance of three of those hearings, had set three successive briehng periods during which the
parties were instructed to raise any discovery disputes. It the 160 different disputes that your
letter asserts were actually viable, then Tatung surely would not have waited to raise them until
ajTer· the majority of LPL’s witnesses have already been deposed. Furtherrnore, rather than
aggressively pursuing its purported disputes concerning i60 different document requests, Tatung
has concealed these purported disputes and is springing them on LPL now in an effort to distract
LPL from its efforts to prepare to depose Tatung’s witnesses.
if Tatung has any real disputes about any ofthe 160 requests listed in your letter that do
not also pertain to issues that are already before the Special Master or that the Special Master has
already ruled upon, please state them with specificity, We cannot begin to understand the nature
of your purported disputes until you do so. Further, we cannot agree to hold a meet-and—conier
with you until you have provided us with speciiic requests that you believe to be in dispute and
until you identify with specificity what types ol` documents or information you believe has not
been produced. To do otherwise would be a complete waste otitirne.
Finally, with respect to your letter seeking to inspect Tatung products that are in l.,PL’s
possession, please explain why that inspection is necessary As you know, LPL previously
identitied all '1'atung products that it had in its possession prior to the March 9, 2007 hearing.
LPL will supplement that list pursuant to the April 6th deadline set by the Special Master during
the March l2, 2007 hearing. Thus, other than harassment, we do not see why Tatung needs to
inspect its own products simply because they are in l.,PL’s possession. Further, we believe that
Tatung’s request is designed to try to probe into L.PL’s attorneys’ thought processes and mental
impressions so, in order to protect L.PL’s attorney work product, we must know why it is
necessary tor Tatung to physically inspect its own products that are in LPL’s possession.
Case 1:04-cv—OO343-JJF Document 608-4 Filed O3/30/2007 Page 4 of 4
Steve lrlassid, Esq.
March 19, 2007
Page 3
We leak forward to receiving your responses.
Sincerely,
Cormac Z o`mior·
ee: Debbie Peuratian, Esq. (via email)
Frank E. Mericleth, J rz, Esq. (via email)
Mark H. Krietzman, Esq. (via email)
Charlene Oh, Esq. (via email)
Valerie W. H0, Esq. (via email)
William Tran, Esq. (via email)
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