Case 1:04-cv-00343-JJF Document 552-2 Filed O3/08/2007 Page 2 of 3
Albany New York
Atlanta & 1dg€l_Lp Philadelphia
Brussels Anumcys M Law San Diego
D 1900 K Street, NW • Washington, DC 20006-1108 San Francisco
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CASS W. CHRISTENSON emit Aooness
(202) 496-7218 cchristenscn@mcl
V1A E—MAn. Ann U.S. MA11.
Scott R. Miller, Esq.
Connolly Bove Lodge & Hutz, LLP l
355 South Grand Avenue, Suite 3150 _ t
Los Angeles, CA 90071 I
Frank E. Merideth, Jr., Esq.
Greenberg Traurig, LLP
2450 Colorado Avenue, Suite 400 East
Santa Monica, CA 90404
Re: LG.Philips LCD Co., Ltd. v. Tatung, et al.; Civil Action No. 04-343 (JJF)
Dear Scott and Frank:
I write to follow up on our teleconference today concerning deposition issues. Dining
our call, you both agreed that you will depose Mr. Jong-Hwan Kim first before proceeding with
Mr. Cho's deposition as an inventor. Therefore, we understand that this issue is resolved.
Another issue that we discussed related to our understanding of how much time is
permitted for Rule 30(b)(6) testimony of each party in this case. With respect to LPL, I
confirmed that LPL intends to designate Mr. Jong-Hwan Kim to testify conceming primarily
topics related to patentand technology issues, and to designate Mr. Joo Sup Kim to testify
conceming topics related to business and damages issues. Scott confinnedlthat ViewSonic will
designate four Rule 30(b)(6) witnesses, Mr. Jue, Ms. Stetson, Mr. Volpe, and Mr. Ranucci.
Further, Mr. Jue will testify on the patent and technology topics, whereas the other three
witnesses will testify on business or damages issues. Scott declined to state more specifically
what issues will be addressed by ViewSonic's Rule 30(b)(6) witnesses. Frank confirmed that
Tatung and Tatung America will each have two Rule 30(b)(6) designees as previously discussed.
I attempted to confirm with you the amount of time that you anticipate needing to
complete Mr. Kim's deposition. We already have confirmed five days for his deposition, which
seems more than sufficient to cover any and all of his individual and Rule 30(b)(6) testimony.
Case 1:04-cv-00343-JJF Document 552-2 Filed O3/08/2007 Page 3 of 3
Scott R. Miller, Esq.
Frank E. Merideth, Jr., Esq.
February 22, 2007
Page 2
You both requested that we identify more specifically the topics for which LPL's two designees
will testify. You indicated that you understood our agreement to be that specific witness
designations will be exchanged five business days in advance of testimony, not five calendar
days, and you contended that designations from LPL should be provided today. l
We agree to your clarified proposal to exchange designation information for all witnesses
. five business days before the first Rule 30(b)(6) deposition. Accordingly, and subject to its
objections, LPL intends to designate witnesses as follows:
Mr. Jong-Hwan Kim on topics: 1-9; lO(a), (b); 11-12; 19; 20(a), (c); 21(b)(l)-(2); 22;
24(al-(el, (h). G). (kl; 25(d)—(¤); 26; 27(b). (c); 29; and 30;
Mr. Joo Sup Kim on topics: l3(a)-(1), (p), (q), (s)—(v); 14; l5(a)(l)-(4); 17 (which we
understand relates to topics in the same notice); and 18.
For topic 16, which relates to interrogatory answers, LPL assumes that interrogatory
answers will be discussed with whichever witness is designated for topics that correspond to the
substance of a particular answer or set of answers.
Cass . Christensen
J cc: Richard D. Kirk, Esq. (via e-mail)
Mark Krieizman, Esq. (via e-mail)
Valerie Ho, Esq. (via e—mail) I
Steve P. Hassid, Esq. (via a-mail)
Anne Shea Gaza, Esq. (via e-mail)
Frederick L. Cottrell, III, Esq. (via e-mail)
Manuel Nelson, Esq. (via e·maii)
Tracy R. Roman, Esq. (via e-mail)
Jeffrey B. Bcve, Esq. (via e-mail)
Jaclyn M. Mason, Esq. (via a-mail) ji
James D. Heisman, Esq. (via e-mail)
Case 1:04-cv-00343-JJF
Document 552-2
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Case 1:04-cv-00343-JJF
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