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Case 1:04-cv-00343-JJF Document 475-2 Filed O2/16/2007 Page1 of 4

Case 1 :04-cv-00343-JJF Document 475-2 Filed 02/16/2007 Page 2 of 4
,.,,..., McKenna Long ,,,,,
Denver & @g€Lw San Francisco
'·°‘ A"9E'°’ 1900 K Street, NW · Washington, DC 20006 W¤¤hi¤9¢¤¤t DC
_ _ 202.4%.7500 · Fax: 202.496.7756
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CORIVIAC T. CONNOR emu. ADDRESS
(202) 496-7439 [email protected]
September 11, 2006
Vu. Eivmp imo U.S. MA11.
Scott R. Miller
Connolly Bove Lodge & Hutz LLP
Wells Fargo Center
South Tower, Suite 3150
355 South Grand Avenue
Los Angeles, CA 90071
[email protected]
Re: LG.Philips LCD C0., Ltd. v. ViewSonic Corporation, et ul.;
U.S. District Court Case N0. 04-343 JJF
Dear Scott:
This letter follows the two meet-and—confer sessions that we conducted last week, during
which we reviewed, in part, ViewSonic’s and LPL’s respective positions in regard to the letter-
motion to compel that ViewSonic tiled with Special Master Poppiti on September 6, 2006. As
you requested on September 8, this letter confirms LPL”s positions with respect to the Doctunent
Requests addressed in ViewSonic’s lettenmotion. Based on LPL’s representations and
ViewSonic`s responses to same, we have agreed to submit a one-line stipulation to Special
Master Poppiti informing him that the issues raised in ViewSonic’s letter-motion are now moot.
Despite knowing that we had previously scheduled a conference call to discuss discovery
issues, ViewSonic elected to tile its 1etter—motion before the conference call began. Even so, as
we anticipated, the meet-and-confer sessions were productive, in that LPL was able to clarify its
responses to the document requests covered by ViewSonic’s letter-motion and to discuss and
better understand ViewSonic’s discovery requests and positions. ViewSonic’s letter—motion to
compel covered ViewSonic’s document requests 63-66, 77, 78, 100-03, ll4—16, 119 and 120.
As stated in the motion, ViewSonic sought responsive documents from LPL for each of these
requests, based on the asstunption that LPL intends to produce responsive documents as to each
Request. Consistent with your September 8 email to Cass Christensen, LPL generally represents
that "there are no responsive documents other than those documents: (i) that fall outside of
LPL’s interpretations placed on the requests; (ii) documents that are not being produced based on
objections interposed by LPL; and/or (iii) documents which LPL agreed to produce as a

Case 1 :O4—cv-00343-JJF Document 475-2 Filed O2/16/2007 Page 3 of 4
Scott R. Miller
September 11, 2006
Page 2
supplement to request nos. 114-116.” More specifically, as discussed in greater detail during our
meet·and-confer conference calls last week, LPL informed ViewSonic as follows:
· Requests 63-66 » Because LPL does not make any products covered by the
technology taught by the Patents-in-Suit, LPL does not have any documents or
things that are responsive to these Requests.
· Requests 77 & 78 — We explained that the scope of any production of doctunents
- in this case, especially those pertaining to mounting techniques, must be
reciprocal. Because ViewSonic has only agreed to produce documents related to
the single exemplar product identified in the Complaint, LPL, in kind, will limit
any production in response to Requests 77 and 78 to products that use technology
taught by the Patents-in-Suit. Based on that limitation, LPL does not have any
documents or things that are responsive to these Requests.
¤ Request 100 — All responsive documents have been produced.
· Request 101 ~ LPL objects to this Request to the extent that it is not limited to
products that use technology taught by the Patents-in-Suit. Based on that
limitation, LPL does not have any additional documents or things that are
responsive to this Request.
· Requests 102 & 103 — Limiting its responses to documents related to rear-
mounting technology, LPL does not have any documents or things that are
responsive to these Requests.
· Requests 114-16 — Based on our discussions, we understand that ViewSonic’s
Request 114 is focused on licenses related to patents that address mounting
technology or any technology that is related to mounting technology (which you
suggested should be defined by LPL, not by ViewSonic). We also understand
that Request 115 seeks license agreements, assignments, covenants not to sue, and
forbearances of rights regarding the Patents-in-Suit. Further, as to Request 116,
we understand that this request is intended to combine aspects of Requests 114
and 115, so as to seek documents reflecting license rates for mounting technology
established by standards bodies. As we discussed, LPL already has produced
potentially responsive documents in pending cases and, as you requested, LPL
will re-produce in this case those documents and any other additional responsive
documents with respect to Requests 1 14, 1 15, and 116. LPL will make a
document production by September 18, as you requested, and supplement
thereafter as necessary. LPL’s position is that ViewSonic should also produce its
license agreements and related documents concerning the relevant subject matter
in this case, as requested by LPL and discussed during our teleconference.
· Request 119 — LPL does not have any documents or things that are responsive to
this Request.

Case 1 :04-cv-00343-JJF Document 475-2 Filed 02/16/2007 Page 4 of 4
Scott R. Miller
September ll, 2006
Page 3
· Request 120 —— LPL has already produced to ViewSonic all responsive documents
and things that are responsive to this Request.
Please prepare and circulate as soon as possible the short stipulation mooting
ViewSonic’s letter—rnotion so that we can approve and tile same by tomorrow, September 12,
2006. Thank you.
Sincerely;
Cormac T'. onnor
(Admitted only in Colorado. Supervised by
Lara A. Brzezynski, a member 0f the D. C. Bar. }
CTC:vvk
cc: Tracy R. Roman (via email)
Mark H. Krietzman (via email)
Valerie W. Ho (via email)
oc;s0432zs9.1

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