EXHIBIT C
Case 2:04-cv-00400-PGR
Document 171-4
Filed 04/13/2007
Page 1 of 3
BAKER. & DANIELS LLP
EST. 1a63
300 North Meridian Street, Suite 2700 · Indianapolis, Indiana 46204 Tel. 317.237,03M · Fax 317.237.1000
www.bakerdanials.com
JOHN K. Hfir NING Attomey at taw
Direct 317.237.1317 john.hanning0hakerd.com
INDIANA WASHINGTON, D.C. CHINA
April 13, 2006
VIA FACSIMILE and U.S. MAIL Sid Leach,, Esq. SNELL & WILMER L.L.P. One Arizona Center 400 East Van Buren Phoenix, Arizona 85004-2202
Re: Hypercom Corporation vs. Verve L.L.C., and Omron Corporation United States District Court for the District of Arizona
Cause No. CV04-0400 PHX PGR
Dear Sid: We are preparing written discovery requests to serve on Hypercom Corporation. One of the requests seeks all confidential information produced by Hypercom to the International Trade Commission or to Verve during the action before the ITC. See In the Matter ofCertain Point o_f'8'ale Terminals and Components Thereof, Inv, No. 337-TA- 524. However, because Hypercom may require some time to prepare copies of these documents for production, we would like to reach an agreement that would allow us to review any confidential materials of Hypercom that Verve already possesses by virtue of their production in the ITC action. Please let us know whether you will agree to such a proposal. We would also like to receive copies of all documents listed on Hypercom's Rule 26(x)(1) Initial Disclosure Statement, served on January 17, 2006. Please produce copies of those documents within the next ten days, or before April 24, 2006. Sincerely yours,
JKH:jmp cc: Monica A. Liman-Wynn David P. Irmscher
BDDBOI 4375800v i
Case 2:04-cv-00400-PGR
Document 171-4
Filed 04/13/2007
Page 2 of 3
Sid Leach, Esq.
-2-
April 13, 2006
bm Herbert Kerner
BDDBOI 4375800v 1
Case 2:04-cv-00400-PGR
Document 171-4
Filed 04/13/2007
Page 3 of 3