Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00343-JJF Document 299 Filed 10/16/2006 Page 1 of 2
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QQQECTOR WILMINGTON, [DELAWARE; IQBOI (SO2} G51~75OQ
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October 16, 2006
BY HAND DELIVERY
The Honorable Vincent I Poppiti
Blank Rome LLP
Chase Manhattan Centre, Suite 800
Wilmington, DE 1980l-4226
Re: LG,P/ii/ips LCD Cor, Lid. vn ViewSonic Corp., et ml,
CA. No. 04-343~J}F
Dear Special Master Poppiti:
I am writing on behalf of defendants Tatung Co. and Tatung Company of America Inc,
(collectively, "Tatung"), On Friday, October 6, 2006, Tatung received plaintiffs motion to
compel and related docurnentsi Frankly, the motion came as a surprise since I was not informed
by counsel for plaintiff that the motion would be filed, had no opportunity to °°1TlG€IZ and confer"
on the substance of the motion and, perhaps most importantly, the motion did not comply with
Your Honor’s discovery dispute procedures entered on March 24, 2005 (the "Procedures”).
Pursuant to Your I·lonor’s Procedures, a party wishing to submit a discovery dispute to
Your Honor must tirst consult with opposing counsel on "wl1ether the issue can be presented to
the Special Master by way of teleconference rather than written sub1nissions"l It is clear that
plaintiff did not comply with paragraph 2 of the Procedures. Instead, it has written a letter,
presumably pursuant to paragraph 3 of the Procedures. Under that paragraph, the due date for
our response would be today. However, after receiving plaintiff s motion, counsel for Tatung
immediately began a "1neet and confer" process through an exchange of several letters.
For these reasons, Tatung respectfully suggests that if the issues raised by plaintiff cannot
be resolved this week, then Tatung will file a substantive response on October 2.3, 2006,
followed by a teleconference, if Your Honor believes one is necessary.
nlm-2070751-a

Case 1:04-cv-00343-JJF Document 299 Filed 10/16/2006 Page 2 of 2
The Honorable Vincent Jl Poppiti
October 16, 2006
Page 2
Should Your Horror wish to discuss this or any other matter, counsel is available at Your
1·Ionor’ s convenience.
Respectfully,

QA/\ L , GHZQQ »- =·——·>—
Frederick L, Cottrell, III (#2555)
FLC,IIl/arg
cc: Clerk of the Court (By Electronic Filing)
Richard Kirk, Esquire
Cormac T. Connor, Esquire
Lora Brzezynski, Esquire
Mark Krietzman, Esquire
Scott R, Miller, Esquire
RL.? % {307075 I - I

Case 1:04-cv-00343-JJF

Document 299

Filed 10/16/2006

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Case 1:04-cv-00343-JJF

Document 299

Filed 10/16/2006

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