Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00485-JJF Document 674-4 Filed O3/20/2008 Page1 of 3
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Case 1 :05-cv-00485-JJF Document 674-4 Filed O3/20/2008 Page 2 of 3
ZELLE, HoEMANN, VOELBEL, MAsoN & GETTE
A LIMITED LiA¤u.mr PARTNERSHIP
BOSTON 44 MONTGOMERY STREET - SUITE 3400 Judith A. Zahid
DALLAS SAN FRANCISCO, CA 94104 [email protected]
LOS ANGELES 415-693-0700 TELEPHONE (415) 633-1916
MINNEAPOLIS 415-693-0770 FACSIMILE
SAN FRANCISCO www.zeIle.com
WASHINGTON, D.C.
BEIJ|NG"
SHANGHA|*
‘ln associaiion with ZY & Partners
December 6, 2006
Via U.S. and Electronic Mail
Jill D. Neiman
MORRISON FOERSTER
425 Market Street
San Francisco, California 94105-2482
jneiman@mof`o.com
Re: In re Intel Corp. Microprocessor Antitrust Litigation (MDL No. 1717-JIF)
Phil Paul v. Intel Corp. (C.A. No. 05-485-JJF)
Dear Ms. Neiman: `
As we indicated in our prior correspondence regarding document discovery, Class
Plaintiffs are moving forward with transaction data discovery. This letter sets forth what we
regard as responsive to the subpoena requests previously served with respect to such transaction
data, and describes what information we now seek. Class Plaintiffs have fully coordinated with
AMD in drafting this letter, and AMD will not be seeking any transactional data beyond what is
requested herein.
In the following context, information for a "transacti0n" shall include: a) date, b) bill-to
and ship-to customer number (or vendor number in the case of the cost data), c) quantity of
product shipped or purchased, d) net dollar revenues or cost, e) transaction price, f) transaction
type (shipment, rebate, credit, etc.), g) contract identification (if the transaction occurred under
contract), and h) product code or SKU.
In addition, for each transaction described below, we seek the lookup tables that link the
various codes in the data provided to fields that describe what the codes mean. In particular, for
each customer, vendor, product code or SKU, and contract number described in the data, we seek
all corresponding descriptive information in the form of lookup or translation tables.

Case 1 :05-cv-00485-JJF Document 674-4 Filed O3/20/2008 Page 3 of 3
Letter to Fujitsu
December 6, 2006
Page 2
Please provide the following:
(1) the net costs of x86 compatible chips, chipsets (north bridge and/or south bridge), and
products containing same that you purchased from January 2000 to the present - by transaction
for each chip type;
(2) the net sales prices of any x86 chips that you may have sold, if any, from January
2000 to the present — by transaction for each chip type;
(3) the net sales prices of any computer products containing x86 chips that you may have
sold from January 2000 to the present- by transaction for each computer product type;
(4) data reporting any rebates, credits, discounts, marketing/advertising funds, and other
payments not included in the transaction data; and
(5) quarterly financial information, specifically to include net revenues, costs of goods
sold (COGS), selling and marketing expenses, and other operational costs for any computer
containing x86 chips sold during the relevant time period. Ifthese costs carmot be disaggregated
at the product level, then aggregated figures should be provided.
If your client ca.n promptly provide us with more detailed information on how the
requested data is kept - i.e., (a) a list and description of each database or dataset Hom which the
requested data would be produced; (b) a "data dictionary" describing the included fields for each
database or dataset you list; (c) the time period covered by each database or dataset you list; and
(d) the software and computer system producing each database or dataset you list — Class
Plaintiffs will use their best efforts to scale back the above requests wherever possible.
We look forward to discussing this with you at your earliest convenience. The Court has
ordered that an agreement regarding discovery be reached by December 21, 2006. We are
confident that you will cooperate with us in meeting that deadline.
Warm regards,
6 J
Judith A. Zahid
cc: (Via Electronic Mail Only)
Jennifer Laser, O’Me1veny & Meyers
John Bright, Keller Rohrback
Bo Pearl, O’Melveny & Meyers
Sam Liversidge, Gibson Dunn