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Case 1:04-cv-00343-JJF Document 591-2 Filed O3/16/2007 Page1 of 3

Case 1:04-cv-00343-JJF Document 591-2 Filed O3/16/2007 Page 2 of 3
Atlanta San Diego
Denver & gg€LLP San Francisco
ms Marie 1900 K Street, NW · Washington, DC 20006 W¤=h¥¤gr¤¤. DC
202.4%.7500 • Fax; 202.496. 7756
Pl'·*l¤d¤'Phi¤ www.mckennalong.com B0-¤S5¢|5
CORMAC T. CONNOR emit. ADDRESS
(202} 495-7439 [email protected]
September 29, 2006
Vis E-Maul AND U.S. Msn.
Scott R. Miller
Connolly Bove Lodge & Hutz LLP
Wells Fargo Center
South Tower, Suite 3150
355 South Grand Avenue
Los Angeles, CA 900?l
[email protected]
Re: LG.Phi!ips LCD Co., Ltd. v. ViewSonic Corporation, et ol.;
U.S. District Court Case No. 04-343 JJ F
Dear Scott:
In its Supplemental Responses. ViewSonic offered to sell samples ofits products to LPL.
During our negotiations on September 22, we asked ViewSonic to provide a list ofthe products
that are available and the prices for each. On September 28, you sent us a letter in which you
informed us that the list of available products can be found at the website
http://store. viewsonic. com.
only a small fraction of the products about which LPL is interested. Specifically, of the 216
model numbers listed in ViewSonic’s supplemental response to lnterrogatory 2, only 30
monitors (22 LCD displays and eight LCD televisions) are listed on ViewS0nic’s website. Of
those that are listed, only I4 (seven LCD displays and seven LCD televisions) are listed as
available or "in stock." Furthermore, four ofthe LCD televisions listed for sale on VicwSonic`s
website are not identified in ViewSonic’s response to lnterrogatory 2: N2060w, N3260w,
N3760w and N4060w. Accordingly, barely 6% of the products listed in ViewSonic’s response
are available for sale on ViewSonic’s website.
lf this is the best that ViewSonic can do, then its offer to allow LPL to purchase samples
of its products is neither feasible nor responsive to LPL’s discovery requests. LPL’s pending
motion to compel seeks an order compelling responses to the very same document requests for
which ViewSonic offered to sell products to LPL. (See Doc. Reqs. 2, 3, 46 & 4?.) Unless
ViewSonic can provide LPL with a comprehensive listing ofproducts, LPI. will simply allow the

Case 1:04-cv-00343-JJF Document 591-2 Filed O3/16/2007 Page 3 of 3
Scott R. Miller
September 29, 2006
Page 2
Special Master to resolve this issue, as the relevant Document Requests have already been raised
in LPL’s pending motions to compel.
Sincergylwx
Cormac T. `onfior
(Admitted on! in Colorado. Supervised by
Lora A. Brzezyns/ci, a member ofthe D. C. Bar.)
CTC:vvk
cc: Tracy Roman (via email)
Manual Nelson (via email)
DC:50435989.l

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