Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-00343-JJF Document 423-2 Filed O1/29/2007 Page 1 of 3
McKenna Long _
Atlanta • San Diego
er Aldrrdger. _
Denver Ammq,5 at Law San Francisco
l-05 A¤9€l¤5 1900 K Street, NW • Washington, DC 20006 W¤5hl¤9Y°¤· DC
202.4%.7500 • Fax; 202.4%.7756
Philadelphia wwvv.mckennaIong.com Br¤S$¢|$
REL S. AIVIBROZY EM/ML Aooaess
(202) 496-7593 ram [email protected]
January 24, 2007
VIA E-MAIL AND U.S. MArL
Frank E. Merideth, Jr.
Greenberg Traurig LLP
2450 Colorado Avenue
Suite 400E
Santa Monica, CA 90404
[email protected]
Re: LG.PhiIips LCD Co., Ltd. v. ViewSonic Corporation, etal.;
U.S. District Court Case No. 04-343 JJF
Dear Frank:
As requested by Special Master Poppiti during the January 19, 2007 hearing, LPL
identifies the following nine broad categories directed to all of TatLmg’s visual display products.
We believe that these categories not only capture all the possible permutations of the possible
mounting systems, but it also works with each parties} proposed claim constructions.
In regard to your concern raised in your January Sth letter to the Court that definitions
may be a problem, we offer two comments. First, see our correspondence of January l8th stating
that any definition Tatung relies on to identify the aspects of the flat panel display device in a
given category makes no difference to LPL - we simply need to know what that definition is.
Second, given the parties have briefed the construction (Le., meaning) of the terms needed to
categorize the Tatung products by "mounting system," (ag., housing and first frame), your
concern about definitions is moot.
LPL’s proposed categories are as follows:
Category 1: Visual display product includes a first frame having a fastening element(s) located
on the rear surface of the first frame, the fastening element(s) positioned on or
inside the border of the flat display panel.
Category 2: Visual display product includes a first frame having a fastening element(s) located
on the rear surface of the first frame, the fastening element(s) positioned outside
the border of the flat display panel but not extending beyond any of the four edges
of the flat panel display device.

Case 1:04-cv-00343-JJF Document 423-2 Filed O1/29/2007 Page 2 of 3
Frank Merideth
January 24, 2007
Page 2
Category 3: Category 1 + Visual display product includes a fastening ele1nent(s) located on a
flange of the first frame that extends beyond any of the four edges of the flat panel
display device.
Category 4: Category 2 + Visual display product includes a fastening element(s) located on a
flange of the first frame that extends beyond any of the four edges of the flat panel
display device.
Category 5: Category 1 + Visual display product includes a side mounting fastening
element(s).
Category 6: Category 2 + Visual display product includes a side mounting fastening
element(s).
Category 7: Not Categories l or 2. Visual display product includes a fastening element(s)
located on a flange of the first frame that extends beyond any of the four edges of
the flat panel display device and does not include a side mounting fastening
element(s).
Category 8: Not Categories l or 2. Visual display product includes a side mounting fastening
element(s) and does not include a fastening element(s) located on a flange of the
first frame that extends beyond any of the four edges of the flat panel display
device and does not include a side mounting fastening element(s).
Category 9: Category 7 + Category 8. Visual display product includes a side mounting
fastening element(s) and a fastening element(s) located on a flange of the first
frame that extends beyond any of the four edges of the flat panel display device.
Please provide us with your response by Friday if possible, as we need to inform Special
Master Poppiti if we were able to agree on the mounting system categories for the Tatung
products no later than Monday January 29, 2007. Of course this entire exercise could be avoided
if you simply provided us with the categories that Tatung employed in producing the Tatung Co.
documents.
Reg
07/ f%% Z.
Rel S. Ambrozy J
RSA:ms
cc: Tracy R. Roman (via email)

Case 1:04-cv-00343-JJF Document 423-2 Filed O1/29/2007 Page 3 of 3
Frank Merideth
January 24, 2007
Page 3
Scott R. Miller (via email)
Mark H. Krietzman (via email)
Valerie W. Ho (via email)
Jong P. Hong (via email)
Manuel Nelson (via email)
Steve Hassid (via email)
Anne Shea Gaza (via email)
Fred Cottrell (via email)
Jaclyn Michel Mason (via email)
Jeffrey B. Bove (via email)
Richard Horwitz (via email)
DC.50457783.l

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