Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-OO602—GIV|S-LPS Document 24 Filed O1/15/2008 Page 1 of 1
Monnrs, NICHOLS, ARSHT & TUNNELL LLP
1201 NORTH MARKET STREET
P.O. Box 1347
WILMINGTON, DELAWARE 19899—134e7
302 658 9200
THoMAs C. GRIMM 302 658 3989 FAX
302 351 9595
202 425 4661FAx Jilliuafy 15, 2008
tgi·[email protected]
The Honorable Leonard P. Stark VL4 ELECTRONIC FILING
United States District Court
for the District of Delaware
844 North King Street
Wilmington, DE 19801
Re: Konica Minolta Business Solutions USA., Inc. v. Screentone
Systems Cong., et al., C.A. No. 07-602-GMS
I Dear Judge Stark:
This is submitted in response to your order of January 8, 2008 instructing Konica
Minolta to submit a letter on its position regarding the motion filed by Screentone Systems
Corporation to Stay or Transfer Pending Resolution of Issues by the Eastern District of Texas,
the First-Filed Court, or, in the Alternative, Motion to Dismiss (D.I. 15), in light of the motion
filed with the Judicial Panel on Multidistrict Litigation by Canon U.S.A., Inc., Eastman Kodak
Company, Panasonic Corporation of North America; Ricoh Americas Corporation; Kyocera
Mita America, Inc., and Konica Minolta Business Solutions Inc. (MDL No. 1926 — In Re:
Halftone Color Separations (‘809) Patent Litigation).
Konica Minolta does not oppose a stay of this action until the time that the
Judicial Panel on Multidistrict Litigation rules on the pending motion for MDL treatment.
Absent MDL treatment of this and the related matters, for the reasons stated in its
opposition brief Konica Minolta believes that the present dispute between the parties is properly
before this Court and Konica Minolta opposes a stay of this matter pending resolution of issues
by the Eastern District of Texas, should those issues not otherwise be resolved in the interim.
Respectfully, I _
Thomas C. Grimm #1098)
cc: Clerk of the Court (by hand)
_ Thomas N. Tarnay, Esq. (by email)
Karen V. Sullivan, Esq. (by efiling & email)
Edward R. Nelson, III, Esq. (by email)

Case 1:07-cv-00602-GMS-LPS

Document 24

Filed 01/15/2008

Page 1 of 1