Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 581 Filed O3/14/2007 Page 1 of 2
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ANNE SHEA GAM WI1..MtNGTON, DELAWARE IQBOE Draecrr DIAL
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March 14, 2007
BY E—MAIL & HAND DELIVERY
The Honorable Vincent J. Poppiti
BLANK ROME LLP
Chase Manhattan Center
1201 Market Street, Suite 800
Wilmington, DE l980l
Re: LG.?/nlips LCD Co., Lid v. ViewSonic Corp., er cr]., CA,. No, 04—343~.lJF
Dear Special Master Poppiti:
Tatung Company and Tatung Company of` America, Inc. (collectively, the "Tatung
Det`endants") respectfuliy request that LG.Philips LCD Company, Ltdfs ("LPL") motion to
continue the deposition of Oliver Shih be considered today on an expedited basis if convenient
with the Special Masters and LPL*s attorneys calendars. As Your Honor is aware, this issue was
raised on Friday March 9, 2007 and at that time Your Honor determined that Mr. Shih’s
deposition should proceed without delay. There is no substantive reason to reconsider the prior
ruling. Mix Shih‘s deposition was noticed, his deposition dates were agreed to and he is in Los
Angeles prepared to testify. Had the Special Master ruled that his deposition was to be
continued, he would have returned to Taiwan last Friday. Further, LPL is proceeding with the
deposition of Mr. Sl1ih's counterpart at Viewsonic.
Mr. Shih is prepared to testify on all of the subjects for which he has been
designated. The delay of his testimony is unnecessary, would be expensive and greatly
inconvenient for Mr. Shih. The Tatung Defendants respectiiiily submit that Mr. Shih ought to be
deposed under the order established by the Court. Accordingly, the Tatung Defendants
respectfully request that Your Honor summarily deny LPL’s motion or, in the alternative,
convene a hearing on the motion, if at all possible, today.
RLlil·3l267lB·1

Case 1 :04-cv-00343-JJF Document 581 Filed O3/14/2007 Page 2 of 2
The Honorable Vincent J , Poppiti
March 14, 2007
Page 2
Respectfully,
Anne Shea Gaza
(#4093)
ASG/afg
cc: Clerk of Court (via CM/ECP)
Richard Kirk, Esquire (via electronic mail)
Cormac T. Connor, Esquire (via electronic mail)
Mark Krietzman, Esquire (via electronic mail)
Scott R. Milier, Esquire (via electronic mail)
Jeffrey B. Bove, Esquire (via electronic mail)
RLFi—3i267l8-l

Case 1:04-cv-00343-JJF

Document 581

Filed 03/14/2007

Page 1 of 2

Case 1:04-cv-00343-JJF

Document 581

Filed 03/14/2007

Page 2 of 2