222 Dri ;\\V.i\Rl’ Avrwtsr, Surirr 900
P O. Box 25150
\‘<(1ri11x<;mx. D1? 19899
Zrv<1<>i»1 l’·>u l}lll\l’ltIl‘~: NH01
[X PII iT O XI S {wi".] ;·liTM'> ‘.'J{1$ili:‘!Jl!?l;
\\’\\ \\ l)1l}`1ll`Lll`ll`lIl (0111
502-6S5—5t><>r>
( Fax) ;%oz~
(302) 429-4208
rl
FILED ELECTRONICALLY
The Honorable Joseph J. Farnan
United States District Court
844 North King Street
Wilmington, DE 19801
RE: LG.P/iilzps LCD C0., Ltd. v. T cztung Company, et al.
C.A. No. 04-343-JJF
Dear Judge Faman:
I represent plaintiff LG.Philips LCD Co., Ltd. ("LPL"). On September 20, 2005,
on behalf of LPL, I filed a Response to Tatung’s Objections to the Special l\/Iaster’s
Report and Recommendation [D.I. 206], along with a Declaration of Richard D. Kirk [D.I
207]. The declaration itself was not confidential, but the exhibits to the declaration are
documents that have been marked confidential. I thus tiled those exhibits (just the
exhibits) under seal. That is to say, the document that was uploaded to the ECF system
did not contain the exhibits; hard copies of the exhibits were served on counsel and have
been delivered to the Court.
Unless instructed otherwise, I do not plan to file a "redacted" or pubic declaration
since any such filing would be exactly the same as what was tiled on September 20,
2005.
If I am mistaken, I would be happy to comply with any counter—directive.
Respectfully submitted,
Richard D. Kirk
RDK/slh
3 1066-1
cc: Clerk of the Court (by hand)
All counsel as shown on the attached certificate
602729vl
Case 1:04-cv-00343-JJF Document 209 Filed O9/26/2005 Page 2 of 2
CERTIFICATE OF SERVICE
The undersigned counsel certifies that, on September 26, 2005, he electronically
filed the foregoing document with the Clerk ofthe Court using CM/ECF, which will send
automatic notification of the filing to the following:
Richard L. Horwitz, Esq. Jeffrey S. Goddess, Esq.
David E. Moore, Esq. Jessica Zeldin, Esquire
Potter Anderson & Corroon LLP Rosenthal, Monhait, Gross & Goddess
1313 N. Market St., 6m Fl. Mellon Bank Center, Suite 1401
Wilmington, DE 19801 Wilmington, DE 19801
The undersigned counsel fiirther certifies that copies ofthe foregoing document
were sent by hand to the above counsel and by email and first class mail to the following
non—registered participants:
Julian M. Baum, Esq. Scott Miller, Esq.
Robert C. Weems, Esq. Tracy Roman, Esq.
Baum & Weems Bingham McCutchen LLP
58 Katrina Lane 355 South Grand Ave., 44th Floor
San Anselmo, CA 94960 Los Angeles, CA 90071-3106
/s/ Richard D. Kirk (rk0922)
Richard D. Kirk
571447vI
Case 1:04-cv-00343-JJF
Document 209
Filed 09/26/2005
Page 1 of 2
Case 1:04-cv-00343-JJF
Document 209
Filed 09/26/2005
Page 2 of 2