Free Redacted Document - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 560 Filed 03/09/2007 Page 1 of 4
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March 2, 2007
BY EMAIL & HAND DELIVERY
The Honorable Vincent J. Poppiti REDACTED
BLANK ROME LLP
Chase Manhattan Center PUBLIC VERSION
1201 Market Street, Suite 800
Wilmington, DE 19801
Re: LG.Philzps LCD Co., Ltd. v. ViewSonic Cmp., et ai., C,A. No. 04~343~JJF
Dear Special Master Poppiti:
In advance of the telephonic hearing scheduled for 11:00 EST today and in response to
M12 Kirk’s letter of March 1, 2007 attaching certain correspondence concerning ongoing
discovery discussions between Tatung and LPL, the Tatung Defendants respectfully submit a
summary of the documents and information provided to LPL to assist Your Honor in evaluating
the Tatung Defendants’ compliance with their discovery obligations.
During the period from late January 2007 to the present, the Tatung Defendants have
produced close to 10,000 pages of documents which include the following:
• Additional highly confidential Tatung America work instructions for urzaccused products,
Tatung America has produced all ofthe work instructions it could locate after performing
a diligent search, including work instructions for sample products that have never been
sold.
• Additional highly confidential Tatung exploded view drawings for urmccu.sedp1*0duc£.s..
Tatung has produced all ofthe exploded view drawings it could locate after performing a
diligent search, including drawings for new products from this quarter (quarter 1, 2007).
• Highly confidential sales summaries ironi 2002 to the present containing model, price
and quantity information for all of the visual display products identified in the Tatung
Defendants interrogatoty responses. Notably, most of the sales data pertain to
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Case 1:04-cv-00343-JJF Document 560 Filed O3/O9/2007 Page 2 of 4
The Honorable Vincent J. Poppiti
March 2, 2007
Page 2
• Highly confidential Tatung CAD/CAM drawings of components for certain accused
products.
• Additional highly contidential technical documents pertaining to certain accused
products.
• Service manuals for certain accused products.
• Bills ofimaterials/parts lists for certain accused products.
• Highly confidential OEM and ODM agreements with Tatung’s customers.
• Documents relating to the Tatung Det`endants’ organizational structure.
• 'l`atung’s annual reports.
• Highly confidential purchase orders, invoices and bills of lading for certain accused
products.
• Highly confidential documents sufficient to identify the Tatung Def`endants’ customers
and distributors.
• Highly confidential communications between Tatung and its customers regarding certain
accused products.
• Brochures and advertisements.
• A correlation ot` Tatung model numbers to HP model numbers.
• Additional prior art related documents.
The documents identitied above are responsive to a number of LPI. Document Requests,
including Nos. 6,7, l0, 13, 15, l6, 25, Sl, 52, 57, 59, 61, 62, 64, 65, 67, 68, 69 and 70.
ln addition, the Tatung Defendants have served amended and supplemental interrogatory
responses identifying, among other things, additional products and prior art.
The Tatung Defendants have made available for inspection, and LPL has examined,
disassembled and photographed, more than 40 monitor and television products.
Tatung also has provided to LPL an amended chart which identities the exploded view
drawing(s) (by hates nu1nber(s)) that cover particular senles or groups of products. All of the
products identified in Tatung’s amended and supplemental interrogatory responses have been
categorized. Altogether, Tatung produced at least 66 drawings covering 307 products. (See
Amended Chart at Exhibit A.) After performing a diligent search, Tatung was unable to locate
drawings for three products-
Finally, Tatung will be producing today so—called "Process Flow Cha1ts" for certain
accused products.
It is important to remember that what the Tatung Defendants agreed to produce during
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Case 1:04-cv-00343-JJF Document 560 Filed O3/O9/2007 Page 3 of 4
The Honorable Vincent .l. Poppiti
March 2, 2007
Page 3
the parties’ December 2006 meet and confers and during the January 2007 hearing were l)
documents sufficient for LPI. to evaluate infringement; 2) sales summaries; and 3) additional
documents pertaining to the three previously identified accused products. The Tatung
Defendants have lived up to this agreement. Until November 2006, LPL had accused only one
Tatung product of infringing the patents—in—suit.. In November, LPL identified two additional
accused products. It was not until midafauuazjy 2007 that LPL ildcntyied 14 additional accused
products, As a result, the Tatung Defendants have been forced to engage in piecemeal
supplementations and are still in the process locating additional responsive documents pertaining
to some ofthe newly identified accused products.
Because LPL now has all of the infomation it needs to evaluate infringement (including
the amended categorization chart, the exploded view drawings and the work instructions for all
products), the Tatung Defendants respectfully request that Your Honor set a deadline by which
LPL must identify all allegedly infringing Tatung and Tatung America products.
Respectfully,
do/l L., peat? K
Frederick L. Cottrell, Ill
l*LC,lllJafg
cc: Clerk of Court (via CM/ECP)
Richard Kirk, Esquire (via electronic mail)
Cormac T. Connor, Esquire (via electronic rnail)
Lora Brzezynski, Esquire (via electronic mail)
Mark lirietzman, Esquire (via electronic mail)
Scott R. Miller, Esquire (via electronic mail)
Jeffrey B. Bove, Esquire (via electronic mail)
arti-suzmsai

Case 1:04-cv-00343-JJF Document 560 Filed O3/O9/2007 Page 4 of 4
UNITED STATES DISTRICT COGRT
DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
I hereby certify that on March 9, 2007 I caused to be served by hand delivery the
foregoing document and electronically tiled the same with the Cieric of Court using CM/ECF
which will send notiEcation of such tiling(s) to the following:
Richard D. Kirk, Esquire Jefiiey B. Bove, Esquire
The Bayard Finn James Heisman, Esquire
222 Delaware Avenue #900 Jaclyn Mr Mason, Esquire
Wilmington, DE 19899 Connolly Bove Lodge & Hutz LLP
1007 North Orange Street
RO. Box 2207
Wilmington, DE 19899
I hereby certify that on March 9, 2007 I caused to be sent the foregoing document to the
following non-registered participants in the manner indicated below:
VIA FEDERAL EXPRESS VIA FEDERAL EXPRESS
Gaspare J. Bono, Esquire Tracy R. Roman, Esquire
Rel S. Ambrozy, Esquire Raslcin Peter Rubin & Simon LLP
Lora A. Brzezynski, Esquire i80i Century Park East, Suite 2.300
Cass W. Christensen, Esquire Los Angeles, CA 90067
Mci<'.enna Long & Aidridge LLP
1900 K Street, NW. VIA FEDERAL EXPRESS
Washington DC. 20006 Scott R. Miller, Esquire
Connolly Bove Lodge dt Hutz LLP
.355 South Grand Avenue
Suite 3150
Los Angeles, CA 9007}
Anne Shea Gaza (#4093)
Gaza@rlf,com
RLFI-296713i-1

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