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Case 1:04-cv—OO343-JJF Document 607-6 Filed O3/30/2007 Page 2 of 4
McKenna Long
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Bmmm Armmuys at mw San Diego
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Steve P. Hassid, Esq
Greenberg “I`raurig, LLP
2450 Coiorado Avenue, Suite 4005
Santa Monica, Caiifomia 90404
[email protected]
Re: LG.Phih]vs LCD C0., Ltd. v. Tufrcng, el tri.;
CivilActi0r1 N0. 04'~343 {JJF)
Dear Steve:
We have reviewed your letters of March 15, 2007 and iind them to be calculated oniy to
waste time and to distract LPL from preparing to depose Tatung’s witnesses
Your letter concerning '1`atung’s Document Requests suggests that, prior to writing that
letter, you reviewed neither i..PL’s document production nor 'iâ€atung’s document requests
Between `i`atung‘s First and Second Sets oi Requests for Production oil Documents and Things,
Tatung has propounded at total of i71 different requests for production on LPL. Your letter,
which was sent 15 days before the close oi` discovery and at a time when Trttung icnows that LPI,.
is preparing to depose Tatung's deposition witnesses, ciaims that Tatung has disputes concerning
all but I0 of its 173 requests, Given all of the hearings and related motion practice that have
occurred thus for in this case, your decision to wait until the 15 days before the ciose of
discovery and airnost i9 rnontits aiter Taturrg served its First Set of Requests to try to
rnzrnuiiicrure disputes about 160 different Document Requests shows only that Tatung is using
your letters to try to sap l..Pt.’s resources and distract attention from Tatung’s own discovery
deficiencies.
To date, LPL has produced over 13,500 pages of documents in response to Tatung’s and
ViewSonic’s document requests. `ihis volume of documents has been produced in response not
only to `iatung’s i7i different requests for production, but also to the similar discovery requests
propounded by ViewSonic. Accordingly, LP}. maintains that, subject to its objections to
Tatungfs discovery requests and to issues that are currently before the Special Muster, LPI,. has
already produced documents responsive to Tatung‘s requests.
Case 1:04-cv—OO343-JJF Document 607-6 Filed O3/30/2007 Page 3 of 4
Steve Hassid, Esc;.
March 19, 2007
Page 2
By raising, at this late date, purported disputes concerning almost all of Tatung‘s i7l
document requests, your letter Tails to identify any particular deliciencies in LPL’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 LPL hav
engaged in negotiations about many, if not most, of these same requests since at least luty 2006
and, thus, fails to recount the parties’ positions on any of those requests. Your Eetter fails to
recognize that most of 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 briefed and argued before the Special Master and that
Tatung has joined many of those motions. In tact, your letter arrives after the Special Master has
conducted no fewer than 12 separate discovery hearings since December 28, 2006 and, in
advance of three of those hearings, had set three successive briefing periods during which the
parties were instructed to raise any discovery disputes, If the 160 different disputes that your
letter asserts were actually viable, then Tatung surely would not have waited to raise them untii
after the majority of L.PI..'s witnesses have already been deposed, Furthermore, rather than
aggressively pursuing its purported disputes concerning 160 different document requests, Tatung
has concealed these purported disputes and is springing them on LVL now in an eiiort to distract
LPL, from its efforts to prepare to deposc Tatung’s witnesses.
if `Tatung has any real disputes about any of the l60 requests listed in your letter that do
not aiso pertain to issues that are already before the Special Master or that the Special Master has
already ruled upon, please state them with speeiiicity. We cannot begin to understand the nature
of your purported disputes untii you do so, Further, we cannot agree to hold it meet—anci·-confer
with you until you have provided us with specific requests that you beiieve to be in dispute and
until you identify with specificity what types of documents or information you believe has not
been produced, To do otherwise would be a complete waste oftime.,
Finally, with respect to your letter seeking to inspect Tatnng products that are in i..PL’s
possession, please explain why that inspection is necessary. As you know, LPL previously
iclentiiiecl all Tatung products that it had in its possession prior to the March 9, 2007 hearing
LPL will supplement that list pursuant to the April oth deadline set by the Special Master during
the March 12, 2,007 hearing., Thus, other than hartissrnent, 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
Tatttng’s request is designed to try to probe into i..PL’s attorneys thought processes and mental
impressions so, in order to protect LPL‘s attorney work product, we must know why it is
necessary lor `iatung to physically inspect its own products that are in LPI/s possession,
Case 1:04-cv—OO343-JJF Document 607-6 Filed O3/30/2007 Page 4 of 4
Steve l-lassici, Esq.
lviarch 19, 2007
Page 3
We lack forward te receiving your responses.
Sincerely,
./" `\
L...-. " "·——~~
Cormac ' clhrler
ce: Debbie Peuratian, Esq. (via email)
Frank Meridelh, Jr., Esq. (via email)
Mark H. l~Lrielzmzm, Esq. (via email)
Charlene Oh, Esq. (via email)
Valerie W. H0, Esq. (via email)
William Tran, Esq. (vie email)
¤c:smum1 l
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