Free Letter - District Court of Delaware - Delaware

Case 1:07—cv—00449-JJF Document 121 Filed 06/05/2008 Page 1 of 2
YOUNG CONAWAY STARGATT & TAYLOR, LLP
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June 5, 2008 T
BY HAND DELIVERY AND E-FILE
The Honorable Joseph J. Farnan, Jr.
United States District Court
844 North King Street p ,
Wilmington, Delaware 19801 l
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Re: Samsung Electronics Co., Ltd, et al. v. ON Semiconductor Corp., et al.,
Civil Action No. 06-720 (JJF)
ON Semiconductor Corp., et al. v. Samsung Electronics Co., Ltd., et al.,
Civil Action No. 07-449 (JJF)
el
Dear Judge Farnan: l
This letter is in response to ON Semi’s June 4, 2008 letter to Your Honor regarding the
continued claim construction hearing in the above-captioned case. At the initial claim
construction hearing on May 21, 2008, Your Honor instructed the parties to suggest dates in June
for a continued hearing with expert witnesses. ON Semi subsequently proposed to Samsung the
last two weeks of June for the continued hearing. Samsung explained its two expert witnesses
(circuit and process technologies) were not both available in the last two weeks of June, but were
available on June 9 and 10th. In the alternative, Samsung suggested the parties consider dates in
July to propose to the Court. Instead, ON Semi filed its letter requesting that the Court-set a
continued claim construction hearing with experts in the last two weeks of June when ON Semi’s
experts are available (and prepared) and when Samsung’s experts are not available.
ls
Samsung respectfully requests that the Court set a date for the continued hearing when
both side’s experts are available. Samsung’s expert on the process technologies, Dr. Bravman—
a Stanford University engineering professor——is not available in the last two weeks of June due
to prior commitments. Samsung’s circuit technology expert, Mr. Joseph McAlexander, has prior
commitments that require him to be out of the country from June 20 until the end of the month.
Moreover, the last two weeks of June present scheduling issues because of ongoing deposition
scheduling, including two witnesses ON Semi offered for deposition in Arizona last night in that
same time period. Accordingly, with the Court’s permission, Samsung requests the Court permit 1
the parties to schedule the continued claim construction hearing on dates outside of June 2008,
preferably after the scheduled close of fact discovery on July 11, 2008.
DB02:6876740.l 0658881001

Case 1:07—cv—00449-JJF Document 121 Filed 06/05/2008 Page 2 of 2
Yormo CoNAwAY STARGATT & TAYLOR, LLP
The Honorable Joseph J . Farnan, Jr.
June 5, 2008 y
Page 2 ;
Samsung is available at the convenience of the Court should Your Honor have any F
qUCSlLlOl“1S OI' CO1“1C€I'1'1S.
Respectfully submitted,
Andrew A. Lundgren (N o. 44
AAL .
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cc: Karen Jacobs Loudon, Esquire (by e-mail)
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DBO2:6876740.l 2 O65888_1()()1