RICHARDS, LAYTON Sk l;-INGEFQ
A PHOFESSEO NAL ASSOCIATION
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ANNE SHEA GMA Wu.Ma:~:o·r0i~i, Detnwmar; is-arson 303.55 ,-7539
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August E0, 2007
REDACTED - PUBLIC VERSION
The I-Ionorabie Vincent L Poppiti
BLANK ROME LLP
Chase Manhattan Center
i20l Marlcet Street, Suite 800
Wilmington, DE 1980l
Re: LG.Phi!igs LCD C0., Ltd. v. ViewSonic cr nl., C.A. No. 04-343-JJF
Dear Special Master Poppiti:
LPL’s motion to compel production of assembly instructions is based entirely on a
misrepresentation of the record and reflects an inadequate review of the Tatung Det`endants’
document productions.
LPL attaches the July i l, 2007 email from Cormac Connor to Valerie Ho requesting the
production of assembly instructions discussed in Vincent Liu’s deposition (Exhibit B to LPL’s
motion), but fails to mention anywhere in the motion or Rule 7.irl certification that the Tatung
Defendants’ counsel, including Ms. Ho, actually met and conferred with Mr. Connor on July 12,
2007, the day after Mr. Connor sent his email. During that meet and confer, LPL was informed
that Tatung already had produced all oi the assembly instructions for the accused products that it
could locate after performing a diligent search. LPL omitted any mention • the parties’ actual
meet and confer in order to create the impression that its request for assembly instructions was
ignored by the Tatung Defendants (when it was not), thereby manufacturing a false basis for this
motion.
Had LPL bothered to conduct even a cursory review of the â€l`atung Defendants†document
productions, it would have noticed the documents entitled ‘“ASSEI\/IBLY fNSTRUCTlONS." In
fact, Tatung produced close to 1000 pages of assembly instructions relating to the accused
products. Attached as Exhibits A and B hereto are two examples of the assembly instructions
produced by Tatung. Instead of diligently reviewing the productions, LPL has engaged in a
practice of making inaccurate claims that documents have not been produced and sending
harassing letters to the Tatung Defendants.
Moreover, LPL has tailed to provide even a cursory explanation for why the assembly
instructions are even relevant at this juncture. LPL has never suggested that the exploded view
diagrams and CAD/CAM drawings produced by Tatung are insufiicient for its purposes, and in
Rliil-3133307-1
Case 1:04-cv-00343-JJF Document 758 Filed 08/10/2007 Page 2 of 2
fact, has accused a nunzber of products based exclusively on the drawings provided (ever: though
it subsequently coniirmed that many of those allegations will be withdrawn if the Special
Mastefs claim constructions are adopted)
Accordingly, LPI/s motion has no merit, is harassing, and should be denied as moot.
Re5pectfi1lly,
Glmi All//LM Ur
Anne Shea Gaza (#4093)
ASG/afg
Enclosures
cc: Cierk ofthe Court (By Electronic Filing)
All Counsel of Record (via electronic mail)
marx-zisxzoir-1
Case 1:04-cv-00343-JJF
Document 758
Filed 08/10/2007
Page 1 of 2
Case 1:04-cv-00343-JJF
Document 758
Filed 08/10/2007
Page 2 of 2
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