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Case 1:04-cv-00343-JJF Document 558-15 Filed O3/08/2007 Page1 0f 2

Case 1:04-cv-00343-JJF Document 558-15 Filed O3/08/2007 Page 2 of 2
Christenson, Cass
From: Chrlstenson, Cass
Sent: Thursday, March O1, 2007 1:25 PM
To: 'Scott Miller'; Frank C. Merldeth
Cc: 'Richard D. Kirk'; ‘Mark H. Krietzman'; ‘VaIerie W. Ho'; 'Steve P. Hassld‘; ‘Anne Shea Gaza';
'Frederick L. Cottrell Ill'; 'Tracy Roman'; 'Jeff Bove'; 'Jaclyn M. Mason'; 'Manuel C. Nelson';
'James Heisman' _
Subject: LG.PhiIlps LCD Co., Ltd. v. Tatung Co., et al., C.A. No. 04-343 JJF / Depositlons
Scott and Frank:
As discussed in yesterday's call, we would like to address and resolve deposition issues
with you. To that end:
l. We have requested more specifically what information you seek from Mr. Bang so that we
can better assess whether it is appropriate to proceed with his deposition. He really is
not a proper witness in this case, in our view, but a witness related to the other
proceedings concerning the side mount technology / patent(s). Nonetheless, if you explain
specifically what you intend to discuss with him we can better address this issue with
you.
2. LPL is designating Mr. Joo Sup Kim on the overlapping topics referencing DEC, Topics
lO(c) and l5(a)(5).
3. We would like to resolve the issues concerning the remaining topics in ViewSonic's
amended deposition notice for which LPL has not designated a witness. For some of these
topics, LPL does not have any information, but is willing to provide a witness if that is
necessary and we can reach an agreement. We propose the following resolution, which
involves compromise from both sides and would require agreement as to each part of the
proposal;
(a) LPL will designate one or more witnesses, subject to its objections, for deposition at
a mutually agreed time on Topics l5(a)(6), l5(b), l5(c), 2l(a), 23(a), 24(i), 25(a),
25(b), 27(a>, 27(d), and 28;
(b) LPL requests more information from Defendants concerning Topics 13(m), l3(n), l3(r),
l3(w), 20(b), 2l(b)(3), 2l(b)(4), 23(b), and 23(c). These topics appear to be duplicative
and redundant given the numerous other related and overlapping topics on the same and
similar issues. If Defendants specify for each of these topics what specific additional
information they believe is needed, we can discuss those issues and determine whether
further testimony is needed and/or whether other vehicles exist to provide that
information;
(c) LPL will not designate a witness on topics 24(f), 24(g), or 25(c). These topics are
improper because, among other reasons, they seek legal conclusions and expert opinion /
analysis. Defendants have numerous topics that relate to these issues and adequately
cover any discoverable facts and testimony from LPL. In addition, these issues will be
further addressed in the Markman briefing and expert discovery.
We look forward to your response. I can discuss this any time today between 2:00 and 6:00
p.m.
Regards,
Cass
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Case 1:04-cv-00343-JJF

Document 558-15

Filed 03/08/2007

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Case 1:04-cv-00343-JJF

Document 558-15

Filed 03/08/2007

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