Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 398 Filed O1/08/2007 Page 1 of 2
RICHARDS, L.AYT0N & FINGER
A PROFESSIONAL ASSOCIATION I
ONE R0r:>1~1EY SQUARE
ANNE at-IEA Gam P‘O‘ BOX 55* DIRECT DML ‘
Wu.M|N0r0N, DELAWARE ESBSQ DD?) 65*7539
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(302)S51-7700
FA>< (302) SSI-770l
” WWW. FILFZCOM l
Q J anuary 8, 2007
BY E—MAIL & HAND DELIVERY p
- The Honorable Vincent J. Poppiti
BLANK ROME LLP
Chase Manhattan Center
1201 Market Street, Suite 800
Wilmington, DE 19801
Re: LG.PhiZz,os LCD Co., Ltd v. ViewSonic Corp., at al.,
C.A. No. 04-343-JJF
Dear Special Master Poppiti:
Tatung Company and'Tatung Company of America, Inc. (collectively, "Tatung") does
not in the ordinary course of business categorize the mounting structures used in their products.
Tatung does have knowledge, in most cases, of whether the LCD or PDP devices it uses in its
products (which are components that Tatung does not make, but purchases from third parties)
have side holes for mounting or front holes for motmting. Tatung can categorize the manner in
which LCDs or PDPs are mounted in its products by reference to defined common features.
In most Tatung products the LCD module is mounted to an internal tray or bracket inside
the product. The tray or LCD bracket is then connected to the exterior case.
In the California litigation involving the family of patents derived from US Patent No.
5,835,139, LPL asked Tatung to categorize how the LCD was mounted in the tray or brackets l
which LPL claimed was the "housing." Tatung provided a table to LPL which indicated how the
LCD modules are mounted.
There are two obstacles to the categorization process. The first is reaching agreement
with LPL on the defined terms; the second is making the categorization. Tatung believes, based
on the differences between the plaintiff and defendants in connection with the terms in the I
l California case and with claims construction in this case, that the first obstacle may be difficult I
nerr-3102227-1 I

Case 1 :04-cv-00343-JJF Document 398 Filed O1/08/2007 Page 2 of 2
The Honorable Vincent J. Poppiti E
January 8, 2007
Page 2
to overcome. lf agreement can be reached on the definitions, Tatung estimates that the .
categorization will take 30 days to accomplish. 2
Respectfully,
/57 A1/me Shea Gaza
Anne Shea Gaza
(#4092) (
ASG/afg ‘
cc: Clerk of the Court (By Electronic Filing) 1
Richard Kirk, Esquire (via electronic mail)
Cormac T. Connor, Esquire (via electronic mail) i
Lora Brzezynski, Esquire (via electronic mail)
Mark Krietzman, Esquire (via electronic mail)
Scott R. Miller, Esquire (via electronic mail)
Jeffrey B. Bove, Esquire (via electronic mail)
Rm -3 102232-1

Case 1:04-cv-00343-JJF

Document 398

Filed 01/08/2007

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Case 1:04-cv-00343-JJF

Document 398

Filed 01/08/2007

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