Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 438 Filed O2/O2/2007 Page 1 of 2
Rica-mans, LAv·r0N & FtNGER
A PROFESSIONAL ASSOCIATION Z
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February 2, 2007 .
VIA EMAIL AND HAND DELIVERY
The Honorable Vincent J. Poppiti
Blank Rome LLP
1201 Market Street, Suite 800
Wilmington, DE 19801
Re: LG.PfziIf0s LCD C0., Ltd v. ViewSonic Corp., et al., C.A. No. 04643-JJF _
Dear Special Master Poppiti:
This letter responds to the letter from LG.Philips LCD Co., Ltd. ("LPL") requesting the
Special Master set deposition dates for Tatung Company and Tatung Company of America
(collectively, the "Tatung defendants") witnesses without completing the meet and confer
process.
LPL reports in its letter and certification that the Tatung defendants have refused to
"resume discussions conceming depositions and scheduling" and "refus[ed] to cooperate." In
_ fact, contrary to LPL’s assertions, the Tatung defendants agreed with LPL on the location of the
depositions and offered in writing to make their witnesses available at that location, at their
expense, and on mutually convenient dates. In addition, the Tatung defendants have identified I
for LPL who will serve as their 30(b)(6) witnesses. The only caveat offered was that the Tatung f
Company witnesses, who are all Taiwanese and reside in Taiwan, would not be available until
after the Lunar New Year (February 18-25, 2007), which is a recognized Asian holiday.
LPL also states in its letter that “Defendants have since refused to confirm a future meet
and confer date .... " This is not correct.
On January 26, 2007, LPL unilaterally re-noticed the depositions of Tatung Company’s
and Tatung Company of America’s 30(b)(6) depositions for Delaware rather than Los Angeles as A
previously stipulated. Notably absent from LPL’s Appendix A are any deposition dates for the I
LPL witnesses. At the Tatung defendants’ suggestion, LPL and Tatung attomeys met and J
conferred on locations and dates, agreed on locations and are clearing dates. The parties have ;
also agreed on the locations for the LPL depositions and are now waiting for LPL to provide
dates for those depositions.
R.LFl-3111657-1

Case 1 :04-cv-00343-JJF Document 438 Filed O2/O2/2007 Page 2 of 2
The Honorable Vincent J. Poppiti i
February 2, 2007
Page 2 i
The Tatung defendants submit that this motion is premature and should not be
determined unless the parties are unable to agree on dates.
Respectfully,
. trrtr . .... .... . .. ... - 2 .....
Anne Shea Gaza (#4093) g
ASG/afg
cc: Clerk of the Court (via hand delivery)
. Richard D. Kirk, Esquire (via electronic mail & hand delivery)
Jeffrey B. Bove, Esquire (via electronic mail & hand delivery)
Lora A. Brzezynski, Esquire (via electronic mail) .
Tracy R. Roman, Esquire (via electronic mail)
Scort R. Miller, Esquire (via electronic mail) E
rmx-3111657-1

Case 1:04-cv-00343-JJF

Document 438

Filed 02/02/2007

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Case 1:04-cv-00343-JJF

Document 438

Filed 02/02/2007

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