Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 578 Filed O3/13/2007 Page 1 of 2
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March 13, 2007
BY E-MAIL & HAND DELIVERY
The Honorable Vincent J . Poppiti
BLANK ROME LLP
Chase Manhattan Center
1201 Market Street, Suite 800
Wilmington, DE 19801
Re: LG.Phil§ns LCD Co., Lid v. ViewSonic Corp., at al., CA. No. 04-343-JIF
Dear Special Master Poppiti:
During our telephonic conference yesterday, counsel for LG Philips, without complying
with the required meet and confer procedures, requested an order be issued requiring Tatung
America to produce its CAD/CAM drawings for all of its products based on the representation
that Tatung America had produced CAD/CAM drawings of some, but not all, of its products. Mr.
Kirk followed up this oral request with a written request for the same relief by his letter of March
12, 2007. The Tatung defendants requested an opportunity to investigate this claim prior to the
hearing today. Here is their response.
Because the Bates number provided during the conference call was not valid (it was not a
production number used), counsel for Tatung Company initially requested that LG Philips
identify the specitic Tatung America CAD/CAM drawings by Bates number. A copy of the
email is attached as Exhibit A. Counsel for LG ?hilips failed to respond.
Counsel for Tatung then reviewed the most recent production for Tatung America and
reconiirnied that `latung America did not generate CAD/CAM drawings for its products.
Counsel for the Tatung defendants then examined the March 12, 2007 letter from Mr.
Kirk. They believe that letter is inaccurate because it suggests that the drawings attached were
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Case 1:04-cv-00343-JJF Document 578 Filed O3/13/2007 Page 2 of 2
The Honorable Vincent J. Poppiti
March I3, 2007
Page 2
CAD/CAM drawings generated by Tatung America. indeed, the excerpt hom the Tatung
Presentation appears intended to create that impression. In fact, the drawings that are attached are
engineering drawings which appear in a Service Manual for a 17 inch multimedia monitor
manufactured by Topvision Display `fecimologies, inc. ("`i`opvision”). These drawings were
provided by Topvision and were not created by the Tatung defendants. Topvision has no
affiliation with the Tatung defendants. The Topvision Service Manual was produced by Tatung
because it purchased products from Topvision.
Thus, it is clear that this issue is a "red herring" which should not have been brought to
the attention of Your Honor. This easily could have been confirmed had LG Philips compiled
with the meet and confer procedure or more carefully examined the Tatung America production
before making its unfounded accusation.
Respectfully,
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Frederick L. Cottrell, III
(#2555)
FLC,HI/afg
Enclosures
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. Miller, Esquire (via electronic mail)
Jeffrey B. Bove, Esquire (via electronic mail)
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Case 1:04-cv-00343-JJF

Document 578

Filed 03/13/2007

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Case 1:04-cv-00343-JJF

Document 578

Filed 03/13/2007

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