Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00485-JJF Document 62 Filed 06/O2/2006 Page 1 of 3
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A PROFESSIONAL. ASSOCHATION
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June 2, 2006
VIA HAND DELIVERY
The Honorable Vincent J . Poppiti
Blank Rome LLP
Chase Manhattan Centre, Suite 800
1201 North Market Street
Wilmington, DE 19801-4226
Re: Advanced Micr·o Devices, Inc., et al. v. Intel Corporation, et al. C.A. No. 05-
441-·.}JF, In re Intel Corporation, C.A. N0. 05~MI)~1717—JJF, and Phil Paul,
et al. v. Intel Corgoration, CLA. 05-485-JJF
Dear Judge Poppiti:
In anticipation of the hearing set for June 12, 2006, to discuss the Protective Order
in the above matter, the following is a list of documents Your Honor may wish to review before
the hearing. For your convenience, we have included the docket item numbers from the
Advanced Micro Devices Inc. v. Intel Corp., C.A. No, 05-441 docket:
DI. 109 Joint Proposed Order re: Protective Order Approval Process (Proposed Protective
Order attached as Exhibit A)
Dj. l 15 Stiputation and Order Regarding Protective Order Approval Process
Dt l2'? Objections by Hewlett Packard
D.I. 128 Objections by Egenera
D1 1.32 Objections by Best Buy
D.I.. 1.33 Objections by Fujitsu Ltd., NEC Corp., Sony Corp., Sony Elecs. Inc., Toshiba
Corp.
DI, 134 Objections by Circuit City
D.I. 136 Objections by Acer Am, Corp.
D.I. 1.39 Objections by ASE C{}l1'1]Z)lllQ€!1"'l`EZCl1S., inc., Avnet Inc., Ingram Micro inc., Synnex
Corp., Tech Data Corp,
D.I, 141 Objections by Microsoft Corp.
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Case 1:05-cv-00485-JJF Document 62 Filed 06/O2/2006 Page 2 of 3
The Honorable Vincent J . Poppiti
June 2, 2006
Page 2
1).1. 142 Objections by Int’l Business Machine Corp.
1).1. 143 Objections by Dell
D.l. 144 Objections by Lenovo Group
D.l. 145 Objections by Fry’s Elecs.
Di. 148 Response of Intel Corp., et al. to the Objections of the Third Parties to the
Protective Order
Di. 149 Response of Advanced Micro Devices Inc., et al. to the Objections of the Third
Parties to the Protective Order
D.I. 150 Letter to the Honorable Joseph J. Farnan, lr. re: Revised Protective Order
D.I. 151 Letter to the Honorable Joseph J. Farnan, Jr. re: Revised Protective Order
Letter to The Honorable Joseph J. Farnari dated May 19, 2006 from Wiliam A.
Streff, lr., Esq., re: l·Iitachi’s comments to the Proposed Protective Order (not
etiled)
If Your Honor should need copies of any ofthe foregoing, we will be happy to
provide them to you.
On a related matter, the parties will provide notice to third parties of the hearing
scheduled for June 12, 2006 ("Notice") so that third parties have an opportunity to attend the
hearing and be heard on the matter. However, we anticipate that there will be many third parties
who elect not to travel to Delaware for the hearing, and instead would prefer to rely on the
arguments and objections contained in their papers. We would like to represent to third patties
in the Notice that their failure to attend in person will not prejudice their position and that the
Special Master will consider all objections presented in the papers as well as at the hearing. The
following is what we propose to send in the Notice to third parties:
"Upon receipt of the third party responses and objections to the
Proposed Protective Order as well as InteI’s and Plaintil’t`s’
responses to those objections, this matter has been referred to the
Special Master by Judge Farnan. The Special Master has called a
hearing to be held on June l2 at 10:00 a.1n. at the United States
District Courthouse in Wilmington, DE. At this hearing, any
interested third party who tiled objections may attend. If a third
party elects not to attend the hearing, the Special Master will
consider the objections submitted and rule on that basis."
Intel has informed us that it opposes the inclusion of the last sentence of this
proposed Notice and will send a letter explaining why. AMI) believes it would be burdensome
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Case 1:05-cv-00485-JJF Document 62 Filed 06/O2/2006 Page 3 of 3
The Honora‘ole Vincent J . Poppiti
3 une 2, 2006
Page 3
and costly for the third parties and the litigants to require every third party to attend in person
and restate their written objections.
Please let us know as soon as possible whether this Notice accurately reflects how
the Court intends to handle this hearing. Once we receive approval (cr revised language), we
will notify each third party of the hearing,
l` Respectfully,
_;}\J\ [_,(/xyteéf J-;
Frederick L, Cottrell, III (#2555)
FLC,1ll/cm}
cc: Richard L. Horwitz, Esquire (via hand delivery)
James L. Holzman, Esquire (via hand delivery)
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