Free Remark - District Court of Delaware - Delaware

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CLOSED, JURY, PATENT

U.S. District Court [LIVE] Eastern District of TEXAS (Marshall) CIVIL DOCKET FOR CASE #: 2:07-cv-00176-TJW

Chi Mei Optoelectronics Corporation v. LG Phillips LCD Co., LTD et al Assigned to: Judge T. John Ward Cause: 35:271 Patent Infringement Plaintiff Chi Mei Optoelectronics Corporation a Taiwan Corporation

Date Filed: 05/04/2007 Date Terminated: 06/09/2008 Jury Demand: Plaintiff Nature of Suit: 830 Patent Jurisdiction: Federal Question

represented by Melissa Richards Smith Gillam & Smith, LLP 303 South Washington Avenue Marshall, TX 75670 903/934-8450 Fax: 903/934-9257 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Adam S Hoffman Irell & Manella LLP 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067-4276 310/277-1010 Fax: 310/203-7199 Email: [email protected] ATTORNEY TO BE NOTICED Alexander Chester Giza Irell & Manella LLP 1800 Ave of the Stars Ste 900 Los Angeles, CA 90067-4276 310/203-7143 Fax: 13102037199 Email: [email protected] ATTORNEY TO BE NOTICED Jonathan S Kagan Irell & Manella - Los Angeles 1800 Avenue of the Stars

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Suite 900 Los Angeles, CA 90067-4276 310/277-1010 Fax: 310/203-7199 Email: [email protected] ATTORNEY TO BE NOTICED Maclain Wells Irell & Manella - Los Angeles 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067-4276 310.277.1010 Fax: 310.203.7199 Email: [email protected] ATTORNEY TO BE NOTICED William Joss Nichols Irell & Manella - Los Angeles 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067-4276 310-277-1010 Fax: 310-203-7199 Email: [email protected] ATTORNEY TO BE NOTICED V. Defendant LG Display Co. Ltd a Korean Corporation represented by Franklin Jones, Jr Jones & Jones - Marshall 201 W Houston St PO Drawer 1249 Marshall, TX 75670 903/938-4395 Fax: 9039383360 Email: [email protected] TERMINATED: 08/15/2007 Gaspare J Bono McKenna Long & Aldridge LLP 1900 K Street NW Washington, DC 20006 202-496-7211 Fax: 202-496-7756 Email: [email protected] ATTORNEY TO BE NOTICED Jennifer Parker Ainsworth

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Wilson Sheehy Knowles Robertson & Cornelius PC 909 ESE Loop 323 Suite 400 P.O. Box 7339 Tyler, TX 75711-7339 903-509-5000 Fax: 903-509-5092 Email: [email protected] ATTORNEY TO BE NOTICED John William Lomas, Jr. McKenna Long & Aldridge LLP 1900 K Street NW Washington, DC 20006 202-496-7183 Fax: 202-496-7756 Email: [email protected] ATTORNEY TO BE NOTICED Mike C Miller Attorney at Law 201 W Houston Marshall, TX 75670 903/938-4395 Fax: 19039383360 Email: [email protected] TERMINATED: 04/11/2008 R Tyler Goodwyn, IV McKenna Long & Aldridge LLP 1900 K Street NW Washington, DC 20006 202-496-7143 Fax: 202-496-7756 Email: [email protected] ATTORNEY TO BE NOTICED Defendant LG Display America, Inc a California Corporation represented by Franklin Jones, Jr (See above for address) TERMINATED: 08/15/2007 LEAD ATTORNEY Gaspare J Bono (See above for address) ATTORNEY TO BE NOTICED Jennifer Parker Ainsworth (See above for address)

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ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED Mike C Miller (See above for address) TERMINATED: 04/11/2008 R Tyler Goodwyn, IV (See above for address) ATTORNEY TO BE NOTICED Counter Defendant Chi Mei Optoelectronics USA, Inc. represented by Adam S Hoffman (See above for address) ATTORNEY TO BE NOTICED Maclain Wells (See above for address) ATTORNEY TO BE NOTICED William Joss Nichols (See above for address) ATTORNEY TO BE NOTICED Counter Claimant LG Display Co, Ltd a Korean Corporation represented by Gaspare J Bono (See above for address) ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED R Tyler Goodwyn, IV (See above for address) ATTORNEY TO BE NOTICED V. Counter Defendant Chi Mei Optoelectronics Corporation a Taiwan Corporation Counter Claimant LG Display America, Inc represented by Gaspare J Bono represented by Alexander Chester Giza (See above for address) ATTORNEY TO BE NOTICED

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a California Corporation

(See above for address) ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED R Tyler Goodwyn, IV (See above for address) ATTORNEY TO BE NOTICED

V. Counter Defendant Chi Mei Optoelectronics Corporation a Taiwan Corporation Counter Claimant Chi Mei Optoelectronics Corporation a Taiwan Corporation V. Counter Defendant LG Display Co. Ltd a Korean Corporation represented by Gaspare J Bono (See above for address) ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED R Tyler Goodwyn, IV (See above for address) ATTORNEY TO BE NOTICED Counter Defendant LG Display America, Inc a California Corporation represented by Gaspare J Bono (See above for address) ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED R Tyler Goodwyn, IV (See above for address) represented by Alexander Chester Giza (See above for address) ATTORNEY TO BE NOTICED

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ATTORNEY TO BE NOTICED Counter Claimant LG Display Co. Ltd a Korean Corporation represented by Gaspare J Bono (See above for address) ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED Mike C Miller (See above for address) TERMINATED: 04/11/2008 R Tyler Goodwyn, IV (See above for address) ATTORNEY TO BE NOTICED Counter Claimant LG Display America, Inc a California Corporation represented by Gaspare J Bono (See above for address) ATTORNEY TO BE NOTICED John William Lomas, Jr. (See above for address) ATTORNEY TO BE NOTICED Mike C Miller (See above for address) TERMINATED: 04/11/2008 R Tyler Goodwyn, IV (See above for address) ATTORNEY TO BE NOTICED V. Counter Defendant Chi Mei Optoelectronics Corporation a Taiwan Corporation

Date Filed 05/04/2007

# 1

Docket Text COMPLAINT with JURY DEMAND against LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Filing fee $ 350.) , filed by Chi Mei Optoelectronics Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Civil Cover Sheet)(ehs, ) (Entered: 05/04/2007)

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05/04/2007 05/04/2007 05/04/2007 05/04/2007 05/09/2007 05/29/2007 4 5 2 3

E-GOV SEALED SUMMONS Issued as to Chi Mei Optoelectronics Corporation. (ehs, ) (Entered: 05/04/2007) Magistrate Consent Form Mailed to Chi Mei Optoelectronics Corporation (ehs, ) (Entered: 05/04/2007) Form mailed to Commissioner of Patents and Trademarks. (ehs, ) (Entered: 05/04/2007) Filing fee: $ 350.00, receipt number 2-1-2523 (ehs, ) (Entered: 05/04/2007) E-GOV SEALED SUMMONS Issued as to LG Phillips LCD Co., LTD, LG Philips LCD America, Inc.. (ch, ) (Entered: 05/09/2007) ***FILED IN ERROR, PLEASE IGNORE.*** NOTICE by LG Phillips LCD Co., LTD Stipulation and Agreement Not to Contest Sufficiency of Process or Sufficiency of Service of Process and to Extend Time to Respond to the Complaint (Attachments: # 1 Melissa Smith Signature)(Jones, Franklin) Modified on 5/30/2007 (sm, ). (Entered: 05/29/2007)

05/30/2007

***FILED IN ERROR, WRONG EVENT, MUST REFILE AS A STIPULATION TO EXTEND TIME*** . Document # 5, Notice. PLEASE IGNORE.*** (sm, ) (Entered: 05/30/2007)

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NOTICE of Attorney Appearance by Franklin Jones, Jr on behalf of all defendants (Jones, Franklin) (Entered: 05/30/2007) NOTICE of Attorney Appearance by Mike C Miller on behalf of all defendants (Miller, Mike) (Entered: 05/30/2007) STIPULATION Joint Stipulation to Extend Time to File Answer by LG Phillips LCD Co., LTD. (Jones, Franklin) (Entered: 05/30/2007) Answer Due Deadline Updated for LG Phillips LCD Co., LTD to 8/13/2007; LG Philips LCD America, Inc. to 8/13/2007 per stipulation filed. (sm, ) (Entered: 06/01/2007)

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MOTION to Change Venue Defendants' Motion to Transfer This Case to Delaware by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc.. (Attachments: # 1 Affidavit Declaration of Mike C. Miller, Esq.# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit D# 6 Exhibit E (Part 1 of 2)# 7 Exhibit E (Part 2 of 2)# 8 Exhibit F# 9 Exhibit G# 10 Exhibit H# 11 Text of Proposed Order Order Granting Defendants' Motion to Transfer)(Jones, Franklin) (Entered: 06/15/2007) MOTION for Extension of Time to File Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend Time to Respond to Defendants' Motion to Transfer This Case to Delaware by Chi Mei Optoelectronics Corporation. (Attachments: # 1 Text of Proposed Order)(Smith, Melissa)

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(Entered: 06/27/2007) 06/28/2007 11 RESPONSE to Motion re 10 MOTION for Extension of Time to File Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend Time to Respond to Defendants' Motion to Transfer This Case to Delaware Defendants' Response to Plaintiff's Motion to Extend Time to Respond to Defendants' Motion to Transfer filed by LG Phillips LCD Co., LTD. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Text of Proposed Order)(Jones, Franklin) (Entered: 06/28/2007) APPLICATION to Appear Pro Hac Vice by Attorney Jonathan S Kagan for Chi Mei Optoelectronics Corporation (RECEIPT 2-1-2742). (rml, ) (Entered: 07/05/2007) REPLY to Response to Motion re 10 MOTION for Extension of Time to File Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend Time to Respond to Defendants' Motion to Transfer This Case to Delaware Plaintiff Chi Mei Optoelectronics Corporation's Reply in Support of its Motion to Extend Time to Respond to Defendants' Motion to Transfer filed by Chi Mei Optoelectronics Corporation. (Smith, Melissa) (Entered: 07/09/2007) ORDER granting 10 Pla Chi Mei Optoelectronics Corporation Opposed Motion to Extend time to Respond to Dft Motion to Transfer this case to Delaware. Deadline for response is 7/11/07. Signed by Judge T. John Ward on 7/10/07. (ch, ) (Entered: 07/10/2007) RESPONSE in Opposition re 9 MOTION to Change Venue Defendants' Motion to Transfer This Case to Delaware Plaintiff Chi Mei Optoelectronics Corporation's Opposition to Defendants' Motion to Transfer filed by Chi Mei Optoelectronics Corporation. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Text of Proposed Order)(Smith, Melissa) (Entered: 07/11/2007) REPLY to Response to Motion re 9 MOTION to Change Venue Defendants' Motion to Transfer This Case to Delaware Defendants' Reply Memorandum In Support of Their Motion to Transfer This Case To Delaware filed by LG Phillips LCD Co., LTD. (Jones, Franklin) (Entered: 07/18/2007) NOTICE by LG Philips LCD America, Inc. Defendants' Unopposed Notice of Entry of Order of Consolidation by the District Court of Delaware (Attachments: # 1 Exhibit)(Jones, Franklin) (Entered: 07/26/2007) SUR-REPLY to Reply to Response to Motion re 9 MOTION to Change Venue Defendants' Motion to Transfer This Case to Delaware filed by Chi Mei Optoelectronics Corporation. (Kagan, Jonathan) (Entered: 07/30/2007) ***FILED IN ERROR, PLEASE IGNORE.*** MOTION for Extension of Time to File Response/Reply Defendants' Opposed Motion to Extend Time to Respond to the Complaint by LG Phillips LCD Co., LTD. (Attachments: # 1 Text of Proposed Order)(Jones, Franklin) Modified on 8/6/2007 (sm, ). (Entered: 08/06/2007)

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08/06/2007

***FILED IN ERROR, PER ATTY, WRONG DOCUMENT FILED, ATTY WILL REFILE*** . Document # 19, Motion. PLEASE IGNORE.*** (sm, ) (Entered: 08/06/2007)

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MOTION for Extension of Time to File Response/Reply Defendants' Opposed Motion to Extend Time to Respond to the Complaint by LG Phillips LCD Co., LTD. (Attachments: # 1 Text of Proposed Order)(Jones, Franklin) (Entered: 08/06/2007) RESPONSE in Opposition re 20 MOTION for Extension of Time to File Response/Reply Defendants' Opposed Motion to Extend Time to Respond to the Complaint Plaintiff Chi Mei Optoelectronics Corporation's Opposition to Defendants' Motion to Extend Time to Respond to the Complaint filed by Chi Mei Optoelectronics Corporation. (Attachments: # 1 Text of Proposed Order) (Smith, Melissa) (Entered: 08/06/2007) MOTION for Leave to File Defendants' Motion for Leave to File Response to Plaintiff's Sur-Reply by LG Phillips LCD Co., LTD. (Attachments: # 1 Exhibit A# 2 Text of Proposed Order)(Jones, Franklin) Additional attachment(s) added on 8/8/2007 (sm, ). (Entered: 08/07/2007) ORDER denying 20 Motion for Extension of Time to File Response/Reply . Signed by Judge T. John Ward on 8/7/07. (ch, ) (Entered: 08/07/2007) RESPONSE in Opposition re 22 MOTION for Leave to File Defendants' Motion for Leave to File Response to Plaintiff's Sur-Reply Plaintiff Chi Mei Optoelectronics Corporation's Opposition to Defendants' Motion for Leave to File Response filed by Chi Mei Optoelectronics Corporation. (Attachments: # 1 Text of Proposed Order)(Smith, Melissa) (Entered: 08/07/2007) LG Phillips LCD Co., Ltd's ANSWER to Complaint with Jury Demand, COUNTERCLAIM Against Plaintiff and Additional Party Chi Mei Optoelectronics USA, Inc. against Chi Mei Optoelectronics Corporation by LG Phillips LCD Co., LTD. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Miller, Mike) (Entered: 08/13/2007) LG Phillips LCD America Inc.'s ANSWER to Complaint with Jury Demand, COUNTERCLAIM against Chi Mei Optoelectronics Corporation by LG Philips LCD America, Inc..(Miller, Mike) (Entered: 08/13/2007) MOTION to Withdraw Defendants' Unopposed Motion for Withdrawal of Counsel by LG Phillips LCD Co., LTD. (Attachments: # 1 Text of Proposed Order)(Jones, Franklin) (Entered: 08/14/2007) ORDER granting 27 Dft's Unopposed Motion for Withdrawal of Counsel . Signed by Judge T. John Ward on 8/15/07. (ch, ) (Entered: 08/15/2007) MOTION for Extension of Time to File Agreed and Stipulated Motion for Extension of Time to Answer or Otherwise Respond to Defendants' Counterclaims and Waiver of Service of Process by Chi Mei Optoelectronics

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Corporation. (Attachments: # 1 Text of Proposed Order)(Smith, Melissa) (Entered: 08/23/2007) 08/23/2007 30 ORDER granting 22 Defendants' Motion for Leave to File Response to Plaintiff's Sur-reply. Plaintiff's response to Defendants' Response to Plaintiff's Sur-reply Regarding the Motion to Transfer this Case to Delaware should be filed within five (5) business days of this order. Such response should not exceed two (2) pages. Signed by Judge T. John Ward on 8/23/07. (kjr, ) (Entered: 08/23/2007) ORDER granting 29 Motion for Extension of Time to File response to deft's counterclaims. Deadline for pltf to file their response extended to 10/9/07. Signed by Judge T. John Ward on 8/24/07. (ehs, ) (Entered: 08/24/2007) SURREPLY to SURREPLY to REPLY to Response to Motion re 9 MOTION to Change Venue, Defendants' Motion to Transfer This Case to Delaware< (Plaintiff Chi Mei Optoelectronics Corporation's Response to Defendants' Supplemental Brief Regarding Its Motion to Transfer RE: 30 order) filed by Chi Mei Optoelectronics Corporation. (Smith, Melissa) Modified on 8/31/2007 (sm, ). (Entered: 08/30/2007) Additional Attachments to Main Document: 32 Reply to Response to Motion,.. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Smith, Melissa) (Entered: 09/04/2007) APPLICATION to Appear Pro Hac Vice by Attorney Alexander Chester Giza for Chi Mei Optoelectronics Corporation. (APPROVED) (FEE PAID) 2-1-3084 (ch, ) (Entered: 10/05/2007) CMO's and CMO USA's ANSWER to Counterclaim by LPL, COUNTERCLAIM against all defendants by Chi Mei Optoelectronics Corporation(a Taiwan Corporation). (Attachments: # 1 Exhibit Ex A to Reply/Counterclaims# 2 Exhibit Ex B to Reply/Counterclaims)(Giza, Alexander) (Entered: 10/09/2007) CMO's ANSWER to Counterclaim by LPLA by Chi Mei Optoelectronics Corporation(a Taiwan Corporation).(Giza, Alexander) (Entered: 10/09/2007) EARLY DISCOVERY ORDER - the court, sua sponte, orders the following. Signed by Judge T. John Ward on 10/23/07. (ch, ) (Entered: 10/23/2007) LG Phillips LCD Co., Ltd.'s and LG Philips LCD America Inc.'s ANSWER to Counterclaim (CMO's Related Counterclaims), COUNTERCLAIM LG. Philips Co., Ltd's and LG. Phillips LCD America Inc,'s Related Counterclaims against Chi Mei Optoelectronics Corporation by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc..(Miller, Mike) (Entered: 11/02/2007) NOTICE by LG Phillips LCD Co., LTD Notice of Compliance with PR 3-1 (Miller, Mike) (Entered: 11/08/2007) NOTICE of Disclosure by Chi Mei Optoelectronics Corporation Compliance with PR 3-1 & 3-2 (Giza, Alexander) (Entered: 11/08/2007) ANSWER to Counterclaim of LPL and LPLA by Chi Mei Optoelectronics

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Corporation.(Giza, Alexander) (Entered: 11/26/2007) 12/11/2007 42 ORDER - Status Conference set for 1/8/2008 09:00 AM before Judge T. John Ward and Judge Chad Everingham. Signed by Judge T. John Ward on 12/11/07. (ch, ) (Entered: 12/11/2007) NOTICE of Attorney Appearance by R Tyler Goodwyn, IV on behalf of LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Goodwyn, R) (Entered: 12/13/2007) NOTICE of Attorney Appearance by Gaspare J Bono on behalf of LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Bono, Gaspare) (Entered: 12/13/2007) NOTICE by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. re 9 MOTION to Change Venue Defendants' Motion to Transfer This Case to Delaware Notice of Case Reassignment by the District Court of Delaware Related to Defendants' Pending Motion to Transfer this Case to Delaware (Attachments: # 1 Exhibit A# 2 Exhibit B)(Miller, Mike) (Entered: 12/14/2007) NOTICE of Attorney Appearance by John William Lomas, Jr on behalf of LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Lomas, John) (Entered: 12/26/2007) NOTICE by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. of Compliance with P.R. 3-3 (Lomas, John) (Entered: 12/27/2007) NOTICE of Disclosure by Chi Mei Optoelectronics USA, Inc., Chi Mei Optoelectronics Corporation Compliance with P.R. 3-3 & 3-4 (Giza, Alexander) (Entered: 12/28/2007) NOTICE by Chi Mei Optoelectronics Corporation re 45 Notice (Other), Notice (Other) regarding Delaware case (Giza, Alexander) (Entered: 01/07/2008) Minute Entry for proceedings held before Judge T. John Ward and Judge Chad Everingham: Status Conference held on 1/8/2008. Claim construction hearing date and trial date were given to parties. Parties are to meet and confer regarding a scheduling order and discovery order. (Court Reporter Susan Simmons.) (shd, ) (Entered: 01/09/2008) 50 Minute Entry for proceedings held before Judge T. John Ward and Judge Charles Everingham: Status Conference held on 1/8/08. Counsel for the parties appeared and were asked if they consented to Judge Everingham. Depending on their answer, they were then given Markman and jury selection dates for the appropriate court. The parties are to meet and confer regarding a scheduling order and discovery order, and the parties have 14 days to submit the proposed orders. The Court further instructed the parties that the time for complying with P.R. 3-1 would be 10 days after the date of the parties filing their proposed orders. Court Adjourned. (Court Reporter Susan Simmons) (jml) (Entered: 01/09/2008) ORDER - parties shall submit their proposed docket control and discovery orders to the court on January 22, 2007. Deadlines under the local patent rules, the court deems February 5, 2007 to be the date of the initial case management

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conference. Disclosure of Asserted Claims and Infringement Contentions is due on February 19, 2007.. Signed by Judge T. John Ward on 1/9/08. (ch, ) (Entered: 01/09/2008) 01/10/2008 52 APPLICATION to Appear Pro Hac Vice by Attorney William Joss Nichols for Chi Mei Optoelectronics USA, Inc. and Chi Mei Optoelectronics Corporation. (APPROVED)(FEE PAID) 2-1-3381 (ch, ) (Entered: 01/11/2008) APPLICATION to Appear Pro Hac Vice by Attorney Maclain Wells for Chi Mei Optoelectronics USA, Inc. and Chi Mei Optoelectronics Corporation. (APPROVED)(FEE PAID) 2-1-3381 (ch, ) (Entered: 01/11/2008) APPLICATION to Appear Pro Hac Vice by Attorney Adam S Hoffman for Chi Mei Optoelectronics USA, Inc. and Chi Mei Optoelectronics Corporation. (APPROVED)(FEE PAID) 2-1-3381 (ch, ) (Entered: 01/11/2008) NOTICE of filing proposed docket control and discovery orders by Chi Mei Optoelectronics Corporation, LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Attachments: # 1 Proposed Discovery Order)(ehs, ) (Entered: 01/23/2008) DISCOVERY ORDER. Signed by Judge T. John Ward on 2/1/08. (ch, ) (Entered: 02/01/2008) NOTICE by LG Phillips LCD Co., LTD Notice of Setting of Trial Date in Related Delaware Case Relevant to Defendants' Pending Motion to Transfer This Case to Delaware (Miller, Mike) (Entered: 02/15/2008) DOCKET CONTROL ORDER - Amended Pleadings due by 11/15/2008.,Discovery due by 7/7/2009.,Joinder of Parties due by 8/1/2008.,Markman Hearing set for 5/7/2009 09:00 AM before Judge T. John Ward.,Motions due by 7/17/2009.,Proposed Pretrial Order due by 7/13/2009., Jury Selection set for 8/3/2009 09:00AM before Judge T. John Ward., Pretrial Conference set for 7/24/2009 09:00 AM before Judge T. John Ward. Mediation deadline 7/7/09. All other deadlines are set forth herein. Signed by Judge T. John Ward on 3/4/08. (ch, ) (Entered: 03/04/2008) NOTICE of Disclosure by Chi Mei Optoelectronics Corporation (Smith, Melissa) (Entered: 03/05/2008) NOTICE of Disclosure by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Lomas, John) (Entered: 03/05/2008) NOTICE by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. of Party Name Change (Lomas, John) (Entered: 03/10/2008) NOTICE of Attorney Appearance by Jennifer Parker Ainsworth on behalf of LG Phillips LCD Co., LTD, LG Philips LCD America, Inc. (Ainsworth, Jennifer) (Entered: 03/18/2008) Consent MOTION for Name Changes of Defendants/Counterclaim Plaintiffs and to Amend the Case Caption by LG Phillips LCD Co., LTD, LG Philips LCD America, Inc.. (Attachments: # 1 Text of Proposed Order)(Ainsworth, Jennifer) (Entered: 03/18/2008)

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ORDER granting 63 Motion for Name change of Dft/Counterclaim Plaintiffs and to Amend the case caption. Accordingly, LG Display Co Ltd is the named dft in this action and replaces LG Philips LCD Co Ltd. Also LG Display America, Inc. is the named dft in this action and replaces LG Philips LCD America, Inc. All future filing should reflect such change. Signed by Judge T. John Ward on 3/24/08. (ch, ) (Entered: 03/24/2008) MEMORANDUM OPINION and ORDER - granting deft's motion to transfer this case to the District of Delaware. Signed by Judge T. John Ward on 3/31/08. (ehs, ) (Entered: 03/31/2008) Pursuant to Local Rule 83(b) Clerk will hold the transfer of this case for twenty days pending a response by the parties (ehs, ) (Entered: 03/31/2008)

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MOTION for Extension of Time to Complete Discovery Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend The Time to Respond to Defendant LG Display Co. LTD's First Set of Interrogatories by Chi Mei Optoelectronics Corporation. (Attachments: # 1 Exhibit A# 2 Text of Proposed Order)(Smith, Melissa) (Entered: 04/07/2008) RESPONSE in Opposition re 66 MOTION for Extension of Time to Complete Discovery Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend The Time to Respond to Defendant LG Display Co. LTD's First Set of Interrogatories filed by LG Display Co. Ltd. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D)(Ainsworth, Jennifer) (Entered: 04/08/2008) REPLY TO RESPONSE TO 66 MOTION for Extension of Time to Complete Discovery Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend The Time to Respond to Defendant LG Display Co. LTD's First Set of Interrogatories Plaintiff Chi Mei Optoelectronics Corporation's Reply in Support of Its Opposed Motion to Extend the Time to Respond to Defendant LG Display Co., Ltd.'s First Set of Interrogatories filed by Chi Mei Optoelectronics Corporation. (Smith, Melissa) Modified on 4/10/2008 (sm, ). (Entered: 04/09/2008) MOTION to Withdraw as Attorney by LG Display Co. Ltd. (Attachments: # 1 Text of Proposed Order)(Miller, Mike) (Entered: 04/09/2008) NOTICE FROM CLERK re 68 Response in Support of Motion. THis entry has been modified to reflect that it is a REPLY. (sm, ) (Entered: 04/10/2008)

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ORDER granting 69 Motion to Withdraw as Attorney. Attorney Mike C Miller terminated. Signed by Judge T. John Ward on 4/11/08. (ehs, ) (Entered: 04/11/2008) STIPULATION re 66 MOTION for Extension of Time to Complete Discovery Plaintiff Chi Mei Optoelectronics Corporation's Opposed Motion to Extend The Time to Respond to Defendant LG Display Co. LTD's First Set of Interrogatories by Chi Mei Optoelectronics Corporation, LG Display Co. Ltd, LG Display America, Inc. (Ainsworth, Jennifer) (Entered: 04/15/2008) NOTICE by Chi Mei Optoelectronics Corporation re 65 Memorandum &

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Opinion Plaintiff Chi Mei Optoelectronics Corporation's Request for Reconsideration of Order Granting LG Display's Motion to Transfer (Attachments: # 1 Exhibit A)(Smith, Melissa) (Entered: 04/18/2008) 04/21/2008 73 NOTICE by LG Display Co. Ltd, LG Display America, Inc re 72 Notice (Other), Notice (Other) (Response to Plaintiff's Request for Reconsideration of Order Granting LG Display's Motion to Transfer) (Ainsworth, Jennifer) (Entered: 04/21/2008) NOTICE by LG Display Co. Ltd, LG Display America, Inc (Notice of Order Denying CMO's Motion to Dismiss in Related Delaware Case That Establishes CMO's Pending Request for Reconsideration of This Court's Transfer Order Should be Denied) (Attachments: # 1 Exhibit A# 2 Exhibit B)(Ainsworth, Jennifer) (Entered: 04/30/2008) ORDER - before the court is Plaintiffs Notice of Request for Reconsideration of Order granting LG Display's Motion to Transfer 72 and related briefing. Though filed as notice, the court treats this as a motion for reconsideration. After careful consideration, this motion is DENIED. The court reaffirms its ruling in the Memorandum Opinion and order issued on 3/31/08. Doc # 65 . Signed by Judge T. John Ward on 5/27/08. (ch, ) (Entered: 05/27/2008) Interdistrict transfer to the District of Delaware. Certified copy of Docket Sheet, Complaint, and transfer order were sent to US District Court District of Delaware, J. Caleb Boggs Federal Building, Lockbox 18, 844 North King Street, Wilmington, DE 19801 (ch, ) (Entered: 06/09/2008)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation Counterclaim Defendants. CHI MEI OPTOELECTRONICS CORPORATION'S REPLY TO LG.PHILIPS LCD AMERICA, INC.'S COUNTERCLAIMS Plaintiff and Counterclaim Defendant Chi Mei Optoelectronics Corp. ("CMO") hereby replies to the allegations of Defendant and Counterclaim Plaintiff LG.Philips LCD America, Inc. ("LPLA") set forth in Paragraphs 48-67 of its Counterclaims ("LPLA Counterclaims"). In a separate pleading filed concurrently, CMO asserts additional related counterclaims against Defendants and Counterclaim Plaintiffs LG.Philips LCD Co., Ltd. and LPLA (collectively "Defendants"). JURY TRIAL DEMANDED Civil Action No. 2:07-CV-00176-TJW JURY TRIAL DEMANDED

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CMO'S REPLY TO THE LPLA COUNTERCLAIMS 1. Answering Paragraph 48 of the LPLA Counterclaims, CMO admits that LPLA

asserts counterclaims against CMO but denies that LPLA is entitled to any of the relief it seeks. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 2. Answering Paragraph 49 of the LPLA Counterclaims, CMO admits that

Defendant LPLA is a corporation organized and existing under the laws of California, having its principal place of business at 150 East Brokaw Road, San Jose, California 95112. 3. Answering Paragraph 50 of the LPLA Counterclaims, CMO admits that it is a

Taiwanese corporation having its principal place of business in Tainan, Taiwan 74147, R.O.C. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 4. paragraph. 5. Answering Paragraph 52 of the LPLA Counterclaims, CMO admits that LPLA Answering Paragraph 51 of the LPLA Counterclaims, CMO admits this

purports to base its Counterclaims on 35 U.S.C. § 100 et seq. and that there is a justiciable controversy between LPLA and CMO regarding the validity and infringement of the claims of United States Patent Nos. 6,008,786 ("the '786 Patent"); 6,013,923 ("the '923 Patent"); 5,619,352 ("the '352 Patent"); and 6,734,926 ("the '926 Patent") (collectively "the CMO Patents"). Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 6. Answering Paragraph 53 of the LPLA Counterclaims, CMO admits that LPLA

alleges that the Court has jurisdiction over the Counterclaims for declaratory relief under the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, under the laws of the United States concerning actions relating to patents, 28 U.S.C. § 1338(a), and under 28 U.S.C. § 1331. Insofar as the allegations of this paragraph purport to state legal conclusions, no response thereto is required. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph.

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7.

Answering Paragraph 54 of the LPLA Counterclaims, CMO admits the

allegations of this paragraph, except that, insofar as the allegations of this paragraph purport to state legal conclusions, no response thereto is required. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. RESPONSE TO COUNTERCLAIM COUNT I CLAIM FOR DECLARATORY JUDGMENT OF INVALIDITY OF THE '786 PATENT, THE '923 PATENT, THE '352 PATENT, AND THE '926 PATENT AGAINST CMO 8. Answering Paragraph 55 of the LPLA Counterclaims, CMO refers to and

incorporates its above responses to Paragraphs 48-54 of the LPLA Counterclaims. 9. Answering Paragraph 56 of the LPLA Counterclaims, CMO admits the

allegations of this paragraph. 10. Answering Paragraph 57 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 11. Answering Paragraph 58 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 12. Answering Paragraph 59 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 13. Answering Paragraph 60 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 14. Answering Paragraph 61 of the LPLA Counterclaims, CMO admits that it has

asserted the CMO Patents against Defendants. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. RESPONSE TO COUNTERCLAIM COUNT II CLAIM FOR DECLARATORY JUDGMENT OF NON-INFRINGEMENT OF THE '786 PATENT, THE '923 PATENT, THE '352 PATENT, AND THE '926 PATENT AGAINST CMO 15. Answering Paragraph 62 of the LPLA Counterclaims, CMO refers to and

incorporates its above responses to Paragraphs 48-61 of the LPLA Counterclaims.

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16.

Answering Paragraph 63 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 17. Answering Paragraph 64 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 18. Answering Paragraph 65 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 19. Answering Paragraph 66 of the LPLA Counterclaims, CMO denies the allegations

of this paragraph. 20. Answering Paragraph 67 of the LPLA Counterclaims, CMO admits that it has

asserted the CMO Patents against Defendants. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. AFFIRMATIVE DEFENSES CMO asserts the following affirmative defenses. CMO also reserves the right to add defenses that may be supported by the facts upon the completion of discovery. First Affirmative Defense 21. LPLA has failed to state a claim for which relief can be granted. PRAYER FOR RELIEF ON LPLA'S COUNTERCLAIMS WHEREFORE, CMO demands judgment against LPLA by: a. b. c. d. e. f. g. h. An order and decree that the CMO Patents are infringed by LPLA; An order and decree that the CMO Patents are not invalid; Granting the relief requested in CMO's Complaint against Defendants. Dismissing LPLA's Counterclaims with prejudice; A determination that LPLA take nothing by reason of its Counterclaims; A determination that no equitable relief issues to LPLA; A determination that no monetary relief be awarded to LPLA; A determination that no costs or attorneys' fees be awarded to LPLA;

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i.

A determination that CMO be awarded its costs and attorneys' fees incurred in

defense against the LPLA Counterclaims; and j. Such other and further relief as the Court may deem just and proper. DEMAND FOR JURY TRIAL Counterclaimant Chi Mei Optoelectronics hereby demands trial by jury on all issues. Dated: October 9, 2007 Respectfully submitted,

By:

/s/ Alexander C.D. Giza Alexander C.D. Giza

GILLAM & SMITH Melissa Smith (Attorney-in-Charge) 303 S. Washington Ave. Marshall, TX 75670 Tel: (903) 934-8450 Fax: (903) 934-9257 Of counsel: IRELL & MANELLA LLP Jonathan S. Kagan Alexander C.D. Giza 1800 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Attorneys for Plaintiff and Counterdefendants Chi Mei Optoelectronics and Chi Mei Optoelectronics USA Certificate of Service The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to FED. R. CIV. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by U.S. mail, on this the 9th day of October, 2007. /s/ Alexander C.D. Giza

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORP. V. LG PHILLIPS LCD CO., LTD, ET AL. § § § § § ORDER The court, sua sponte, orders the following: 1. Any party claiming patent infringement shall comply with P.R. 3-1 and 3-2 within 15 days from the date of this order; Any party opposing a claim of patent infringement shall comply with P.R. 3-3 and 3-4 in accordance with the deadline provided in those rules; The parties may conduct discovery relevant to these disclosures subject to the following limitations: 30 interrogatories per side; 30 requests for admission per side; 30 requests for production per side; 25 hours of party depositions per side; 25 hours of third-party depositions per side; the depositions of any inventors; and unlimited depositions on written questions directed toward third parties. Discovery "relevant to these disclosures" includes discovery relating to the technical operation of the accused products, as well as the identity of and technical operation of any products reasonably similar to any accused product. It also includes discovery into the scope and content of any identified prior art references, as well as any issues related to whether the reference in fact constitutes prior art. The parties may also conduct discovery into any jurisdictional issues, subject to the above limits. The provisions of the Patent Rules, including P.R. 2-2, will apply to discovery conducted pursuant to this order. Consistent with the court's calendar, the court will set this case for a Scheduling Conference at a future date and time to address requests for additional discovery. SIGNED this 23rd day of October, 2007.

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__________________________________________ T. JOHN WARD UNITED STATES DISTRICT JUDGE

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation Counterclaim Defendants. CHI MEI OPTOELECTRONICS CORPORATION'S NOTICE OF DISCLOSURE Chi Mei Opotoelectronics Corporation ("CMO") hereby notifies the Court that on November 7, 2007, it furnished LG.Philips LCD Co., Ltd. and LG.Philips LCD America, Inc., with the disclosures required under (1) Patent L.R. 3-1, (2) Patent L.R. 3-2, and (3) this Court's Order of October 23, 2007 (Docket #37). Civil Action No. 2:07-CV-00176-TJW

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Dated: November 8, 2007

Respectfully submitted,

By:

/s/Alexander C.D. Giza Alexander C.D. Giza

GILLAM & SMITH Melissa Smith (Attorney-in-Charge) 303 S. Washington Ave. Marshall, TX 75670 Tel: (903) 934-8450 Fax: (903) 934-9257 Of counsel: IRELL & MANELLA LLP Jonathan S. Kagan Alexander C.D. Giza 1800 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Attorneys for Plaintiff and Counterdefendants Chi Mei Optoelectronics and Chi Mei Optoelectronics USA

Certificate of Service The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to FED. R. CIV. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by U.S. mail, on this the 8th day of November, 2007. /s/ Alexander C.D. Giza

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation Counterclaim Defendants.

Civil Action No. 2:07-CV-00176-TJW JURY TRIAL DEMANDED

JURY TRIAL DEMANDED

CHI MEI OPTOELECTRONICS CORPORATION'S REPLY TO LG.PHILIPS LCD COMPANY'S AND LG.PHILIPS LCD AMERICA INC.'S RELATED COUNTERCLAIMS Plaintiff and Counterclaim Defendant Chi Mei Optoelectronics Corp. ("CMO") hereby replies to the allegations of Defendants and Counterclaim Plaintiffs LG.Philips LCD Co., LTD., ("LPL") and LG.Philips LCD America, Inc., ("LPLA") (collectively "Defendants") set forth in Paragraphs 37-65 of their Related Counterclaims ("Defendants' Related Counterclaims").

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RESPONSE TO DEFENDANTS' RELATED COUNTERCLAIMS 1. Answering Paragraph 37 of Defendants' Related Counterclaims, CMO admits that

Defendants assert counterclaims against CMO but deny that Defendants are entitled to any of the relief they seek. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 2. Answering Paragraph 38 of Defendants' Related Counterclaims, CMO admits that

LPL is a company registered under the laws of Korea with its head office at 18th Floor, West Tower, LG Twin Towers, 20 Yoido-dong, Youngdungpo-gu, Seoul, Republic of Korea 150-721. 3. Answering Paragraph 39 of Defendants' Related Counterclaims, CMO admits that

LPLA is a corporation organized and existing under the laws of California, having its principal place of business at 150 East Brokaw Road, San Jose, California 95112-4203. 4. Answering Paragraph 40 of Defendants' Related Counterclaims, CMO admits that

it is a Taiwanese corporation having its principal place of business in Tainan, Taiwan 74147, R.O.C. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 5. Answering Paragraph 41 of Defendants' Related Counterclaims, CMO admits the

allegations in this paragraph. 6. Answering Paragraph 42 of Defendants' Related Counterclaims, CMO admits that

Defendants purport to base their Counterclaims on the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, and the Patent Laws of the United States. CMO further admits that there is a justiciable controversy between Defendants and CMO regarding the validity and infringement of the claims of United States Patent Nos. 6,134,092 ("the '092 Patent") and United States Patent No. 7,280,179 ("the '179 Patent") (collectively "the CMO Patents"). Insofar as the allegations of this paragraph purport to state legal conclusions, no response thereto is required. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 7. Answering Paragraph 43 of Defendants' Related Counterclaims, CMO admits that

Defendants allege that the Court has jurisdiction over the Related Counterclaims under the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, under the laws of the United States -2-

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concerning actions relating to patents, 28 U.S.C. § 1338(a), and under 28 U.S.C. § 1331. Insofar as the allegations of this paragraph purport to state legal conclusions, no response thereto is required. 8. Answering Paragraph 44 of Defendants' Related Counterclaims, CMO admits the

allegations of this paragraph, except that, insofar as the allegations of this paragraph purport to state legal conclusions, no response thereto is required. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. RESPONSE TO COUNTERCLAIM COUNT VIII CLAIM FOR DECLARATORY JUDGMENT OF INVALIDITY OF THE '092 PATENT AND THE '179 PATENT AGAINST CMO 9. Answering Paragraph 45 of Defendants' Related Counterclaims, CMO refers to

and incorporates its above responses to Paragraphs 37-44 of the Defendants' Counterclaims. 10. Answering Paragraph 46 of Defendants' Related Counterclaims, CMO admits the

allegations of this paragraph. 11. Answering Paragraph 47 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. 12. Answering Paragraph 48 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. 13. Answering Paragraph 49 of Defendants' Related Counterclaims, CMO admits that

it has asserted the CMO Patents against the Defendants. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. RESPONSE TO COUNTERCLAIM COUNT IX CLAIM FOR DECLARATORY JUDGMENT OF NON-INFRINGEMENT OF THE '092 PATENT AND THE '179 PATENT AGAINST CMO 14. Answering Paragraph 50 of Defendants' Related Counterclaims, CMO refers to

and incorporates its above responses to Paragraphs 37-49 of the Defendants' Counterclaims. 15. Answering Paragraph 51 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. 16. Answering Paragraph 52 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. -3-

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17.

Answering Paragraph 53 of Defendants' Related Counterclaims, CMO admits that

it has asserted the CMO Patents against Defendants. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. RESPONSE TO COUNTERCLAIM COUNT X CLAIM FOR DECLARATORY JUDGMENT OF UNENFORCEABILITY OF THE '179 PATENT AGAINST CMO 18. Answering Paragraph 54 of Defendants' Related Counterclaims, CMO refers to

and incorporates its above responses to Paragraphs 37-53 of the Defendants' Counterclaims. 19. Answering Paragraph 55 of Defendants' Related Counterclaims, CMO admits that

the '179 Patent speaks for itself. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 20. Answering Paragraph 56 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. 21. Answering Paragraph 57 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. 22. Answering Paragraph 58 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. 23. Answering Paragraph 59 of Defendants' Related Counterclaims, CMO admits that

the '179 Patent claims priority at least to earlier-filed Taiwanese Patent Application No. 92130636, filed November 3, 2003, as listed on the face of the '179 Patent. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 24. Answering Paragraph 60 of Defendants' Related Counterclaims, CMO admits the

allegations of this paragraph. 25. Answering Paragraph 61 of Defendants' Related Counterclaims, CMO admits the

allegations of this paragraph. 26. Answering Paragraph 62 of Defendants' Related Counterclaims, CMO admits that

LPL filed its First Amended Answer to AU Optronics's Amended Counterclaims and Additional Counterclaims on August 8, 2007, in the United States District Court for the District of Delaware

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in Civil Action No. 06-726-GMS. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 27. Answering Paragraph 63 of Defendants' Related Counterclaims, CMO admits that

LPL filed its Answer to Plaintiff's Complaint and Counterclaims Against Plaintiff and Additional Party Chi Mei Optoelectronics USA, Inc., in the instant case. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 28. Answering Paragraph 64 of Defendants' Related Counterclaims, CMO admits that

it asserts that the '179 Patent is enforceable and that Defendants assert that this patent is unenforceable. Except as expressly admitted herein, CMO denies each and every allegation contained in this paragraph. 29. Answering Paragraph 65 of Defendants' Related Counterclaims, CMO denies the

allegations of this paragraph. AFFIRMATIVE DEFENSES CMO asserts the following affirmative defenses. CMO also reserves the right to add defenses that may be supported by the facts upon the completion of discovery. First Affirmative Defense 30. Defendants have failed to state a claim for which relief can be granted. Second Affirmative Defense 31. Defendants cannot prevail on their Counterclaims because the CMO Patents are

valid and enforceable, and are infringed by Defendants. PRAYER FOR RELIEF ON DEFENDANTS' COUNTERCLAIMS WHEREFORE, CMO demands judgment against Defendants by: a. b. c. d. Defendants; e. Dismissing Defendants' Counterclaims with prejudice; -5An order and decree that the CMO Patents are infringed by Defendants; An order and decree that the CMO Patents are not invalid; An order and decree that the CMO Patents are enforceable; Granting the relief requested in CMO's Complaint and Counterclaims against

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f. g. h.

A determination that Defendants take nothing; A determination that no costs or attorneys' fees be awarded to Defendants; and Such other and further relief as the Court may deem just and proper. DEMAND FOR JURY TRIAL

CMO hereby demands trial by jury on all issues. Dated: November 26, 2007 Respectfully submitted,

By:

/s/Alexander C.D. Giza Alexander C.D. Giza

GILLAM & SMITH Melissa Smith (Attorney-in-Charge) 303 S. Washington Ave. Marshall, TX 75670 Tel: (903) 934-8450 Fax: (903) 934-9257 Of counsel: IRELL & MANELLA LLP Jonathan S. Kagan Alexander C.D. Giza 1800 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Attorneys for Plaintiff and Counterdefendants Chi Mei Optoelectronics and Chi Mei Optoelectronics USA

Certificate of Service The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to FED. R. CIV. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by U.S. mail, on this the 26th day of November, 2007. /s/ Alexander C.D. Giza

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORP. V. LG PHILLIPS LCD CO., LTD, ET AL. § § § § § ORDER This case is set for a status conference in Marshall, Texas, on January 8, 2008, at 9:00 a.m., before the Honorable T. John Ward and the Honorable Chad Everingham. The purpose of the conference will be to assign a claim construction hearing date and a trial setting. The parties shall be prepared to inform the Court whether they will consent to trial before the Magistrate Judge. SIGNED this 11th day of December, 2007.

CIVIL NO. 2:07-CV-176(TJW)

__________________________________________ T. JOHN WARD UNITED STATES DISTRICT JUDGE

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation, Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation, Counterclaim Defendants. Civil Action No. 2:07-cv-00176-TJW

NOTICE OF APPEARANCE Notice is hereby given that R. Tyler Goodwyn is entering his appearance as counsel for Defendants, LG.Philips LCD Co., Ltd. and LG.Philips LCD America, Inc., for the purpose of receiving notices from the Court. December 13, 2007 BY: /s/ R. Tyler Goodwyn R. Tyler Goodwyn McKenna Long & Aldridge LLP 1900 K Street, N.W. Washington, D.C. 20006 Phone: (202) 496-7500 / Fax: (202) 496-7756

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document was filed electronically in compliance with Local Rule CV-5(a) on December 13, 2007. As such, this document was served on the counsel of record, listed below, all of whom have consented to electronic service. Local Rule CV-5(a)(3)(A). Melissa Richards Smith Gillam & Smith, LLP 303 South Washington Avenue Marshall, TX 75670 Alexander Chester Giza Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276 Jonathan S. Kagan Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276

/s/ R. Tyler Goodwyn

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation, Plaintiff, Civil Action No. 2:07-cv-00176-TJW v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. JURY TRIAL DEMANDED CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation, Counterclaim Defendants. NOTICE OF CASE REASSIGNMENT BY THE DISTRICT COURT OF DELAWARE RELATED TO DEFENDANTS' PENDING MOTION TO TRANSFER THIS CASE TO DELAWARE Defendants LG.Philips LCD Co., Ltd. ("LPL") and LG.Philips LCD America, Inc. ("LPL America") filed a Motion to Transfer This Case to Delaware on June 15, 2007. (Docket #9.) LPL and LPLA America hereby provide notice to this Court that, on December 14, 2007, the District Court of Delaware reassigned the Delaware Action involving LPL, LPL America, Chi JURY TRIAL DEMANDED

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Mei Optoelectronics ("CMO"), and Chi Mei Optoelectronics USA, Inc. ("CMO USA") to the Honorable Joseph J. Farnan, Jr. Notice is being given because, in opposing transfer, CMO acknowledged that "[l]ast year, Judge Farnan presided over another patent infringement action involving the `002 patent, that included a claim construction hearing as well as a nine-day trial." (Docket #15, at 14; internal quotation omitted.) CMO then argued: "Whatever efficiency advantages might have existed from a transfer to Judge Farnan, however, are now gone: on July 3, 2007 the Delaware case was reassigned to Judge Sleet . . . ." (Id.) The case reassignment in Delaware renders this argument invalid. A copy of the Notice of Electronic filing with the docket text for this entry in the lead Delaware case is attached as Exhibit A. A copy of the Notice of Electronic filing with the docket text for this entry in the other consolidated case is attached as Exhibit B.

Respectfully submitted, Law Office of Mike C. Miller, P.C.

/s/ Mike C. Miller______________________ Mike C. Miller Texas State Bar No. 14101100 Law Office of Mike C. Miller, P.C. 201 West Houston Street Marshall, Texas 75670 Phone: (903) 938-4395 Facsimile: (903) 938-3360 Attorneys for Defendants LG.Philips LCD Co., Ltd. and LG.Philips LCD America, Inc.

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OF COUNSEL: Gaspare J. Bono R. Tyler Goodwyn Lora A. Brzezynski McKenna Long & Aldridge LLP 1900 K Street, NW Washington, D.C. 20006 (202) 496-7500 December 14, 2007

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CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a) on December 14, 2007. As such, this document was served on the counsel of record, listed below, all of whom have consented to electronic service. Local Rule CV-5(a)(3)(A). Melissa Richards Smith Gillam & Smith, LLP 303 South Washington Avenue Marshall, TX 75670 Alexander Chester Giza Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276 Jonathan S. Kagan Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276 /s/ Mike C. Miller

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation, Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation, Counterclaim Defendants. Civil Action No. 2:07-cv-00176-TJW

NOTICE OF APPEARANCE Notice is hereby given that John W. Lomas, Jr. is entering his appearance as counsel for Defendants, LG.Philips LCD Co., Ltd. and LG.Philips LCD America, Inc., for the purpose of receiving notices from the Court. December 26, 2007 BY: /s/ John W. Lomas, Jr. John W. Lomas, Jr. McKenna Long & Aldridge LLP 1900 K Street, N.W. Washington, D.C. 20006 Phone: (202) 496-7500 / Fax: (202) 496-7756

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document was filed electronically in compliance with Local Rule CV-5(a) on December 26, 2007. As such, this document was served on the counsel of record, listed below, all of whom have consented to electronic service. Local Rule CV-5(a)(3)(A). Melissa Richards Smith Gillam & Smith, LLP 303 South Washington Avenue Marshall, TX 75670 Alexander Chester Giza Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276 Jonathan S. Kagan Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276

/s/ John W. Lomas, Jr.

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation, Plaintiff, Civil Action No. 2:07-cv-00176-TJW v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. JURY TRIAL DEMANDED CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation, Counterclaim Defendants. LG.PHILIPS LCD CO., LTD.'S AND LG.PHILIPS LCD AMERICA, INC.'S NOTICE OF COMPLIANCE WITH P.R. 3-3 Defendants LG.Philips LCD Co., Ltd. ("LG.Philips") and LG.Philips LCD America, Inc. hereby give notice that it complied with P.R. 3-3 by serving its P.R. 3-3 Invalidity Contentions on Chi Mei Optoelectronics Corp. on December 27, 2007 pursuant to this Court's October 23, 2007 Order (Docket #37). JURY TRIAL DEMANDED

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Respectfully Submitted,

/s/ John W. Lomas, Jr Mike C. Miller, Esq. Texas State Bar No. 14101100 Law Office of Mike C. Miller, P.C. 201 West Houston Street Marshall, Texas 75670 Tel: (903) 938-4395 Fax: (903) 938-3360 [email protected]

Gaspare J. Bono, Esq. R. Tyler Goodwyn, Esq. John W. Lomas, Jr., Esq. McKenna Long & Aldridge LLP 1900 K Street, NW Washington, D.C. 20006 Tel: (202) 496-7500 Fax: (202) 496-7756 [email protected] [email protected] [email protected] Attorneys for Defendants/Counterclaim Plaintiffs LG.Philips LCD Co., Ltd., and LG.Philips LCD America, Inc. December 27, 2007

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CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a) on December 27, 2007. As such, this document was served on the counsel of record, listed below, all of whom have consented to electronic service. Local Rule CV-5(a)(3)(A). Melissa Richards Smith Gillam & Smith, LLP 303 South Washington Avenue Marshall, TX 75670 Alexander Chester Giza Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276 Jonathan S. Kagan Irell & Manella LLP 1800 Ave of the Stars, Suite 900 Los Angeles, CA 90067-4276 /s/ John W. Lomas, Jr.

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. LG.PHILIPS LCD CO., LTD., and LG.PHILIPS LCD AMERICA, INC., Counterclaim Plaintiffs, v. CHI MEI OPTOELECTRONICS CORPORATION; and CHI MEI OPTOELECTRONICS USA, INC., a Delaware Corporation Counterclaim Defendants. CHI MEI OPTOELECTRONICS CORPORATION'S AND CHI MEI OPTOELECTRONICS USA, INC.'S NOTICE OF DISCLOSURE Chi Mei Optoelectronics Corporation and Chi Mei Optoelectronics USA, Inc. (collectively, "CMO") hereby notify the Court that CMO has served Defendants and Counterclaim Plaintiffs LG.Philips LCD Co., Ltd and LG.Philips LCD America, Inc. (collectively, "LPL") with the disclosures required under (1) Patent L.R. 3-3 and (2) Patent L.R. 3-4. Civil Action No. 2:07-CV-00176-TJW

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Dated: December 28, 2007

Respectfully submitted,

By:

/s/Alexander C.D. Giza Alexander C.D. Giza

Melissa R. Smith LEAD ATTORNEY State Bar No. 24001351 Harry L. Gillam, Jr. State Bar No. 07921800 GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, Texas 75670 Telephone: (903) 934-8450 Facsimile: (903) 934-9257

Of Counsel: Jonathan S. Kagan (Pro Hac Vice) Alexander C.D. Giza (Pro Hac Vice) IRELL & MANELLA LLP 1800 Avenue of the Stars, Suite 900 Los Angeles, California 90067-4276 Telephone: (310) 277-1010 Facsimile: (310) 203-7199 Attorneys for Plaintiff and Counterdefedants, CHI MEI OPTOELECTRONICS and CHI MEI OPTOELECTRONICS USA

Certificate of Service The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to FED. R. CIV. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by U.S. mail, on this the 28th day of December, 2007. /s/ Alexander C.D. Giza

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION CHI MEI OPTOELECTRONICS CORPORATION, a Taiwan Corporation Plaintiff, v. LG.PHILIPS LCD CO., LTD., a Korean Corporation, and LG.PHILIPS LCD AMERICA, INC., a California Corporation, Defendants. AND RELATED COUNTERCLAIMS Civil Action No. 2:07-CV-00176-TJW

NOTICE IN RESPONSE TO LG.PHILIPS LCD CO. S NOTICE OF CASE REASSIGNMENT BY THE DISTRICT COURT OF D