Case 1:05-cv-00292-JJF Document 26 Filed 11/08/2005 Page 1 of 2
RICHARDS, LAYTON & FINGER
A PROFESSIONAL ASSOCIATION
ONE RODNEY SQUARE Q
920 NORrI-I KING STREET
MA1-rHEw vv. KING WILMINGTON, DELAWARE IBBOI D|;;°;§gA|[_;;;B,ER l
(302) 65:-7700 K,NG@R,_F_COM
FAx (302) 65 I-7701 _
November 8, 2005
VIA ELECTRONIC MAIL
The Honorable Joseph J. Farnan, Jr.
United States District Court
District of Delaware
844 King Street
Wilmington, DE 19801
Re: L.G. Philips LCD C0. Ltd. v. Tatung Company et. al., C.A. N0. 05-292
Dear Judge Farnan:
I write on behalf of the defendants to request a teleconference in the above captioned
case. We request the conference so the parties can address with the Court the discovery and
briefing schedules for plaintiffs motion for preliminary injunction.
Plaintiff filed its motion for preliminary injunction on November 1, 2005. On November
5, 2005, Defendants contacted opposing counsel seeking an agreement for an extension of time
to respond. Although that request was initially granted, counsel for Plaintiff has now informed l
Defendants that it will not agree to any extension to respond to the Motion beyond November 18
and will object to any discovery sought by Defendants.
Under the Local Rules, Defendants’ response to the motion is due November 15, 2005. .....
ln order to properly prepare a response Defendants’ must take the necessary discovery, search
and obtain the documents relevant to its nondnfringement and invalidity defenses and obtain
declarations in support of its defenses to Plaintiff s Motion. Defendants’ request an additional
two months in order to obtain the time necessary to properly prepare its response.
Defendants would like the opportunity, at the Court’s earliest convenience, to address
these issues with the Court and counsel for L.G. Philips. We believe a teleconference is an
appropriate vehicle to address these issues.
Case 1 :05-cv-00292-JJF Document 26 Filed 11/08/2005 Page 2 of 2 J
The Honorable Joseph J. Farnan, Jr. p
November 8, 2005 E
Page 2 ·
Defendants’ counsel is available at the Court’s convenience to participate in such a
Respectiiilly submitted, E
Matthew W. King
cc: Richard D. Kirk, Esq. (via hand delivery) Y
Gaspare J. Bono, Esq. (via telecopy) p'
. Rui-2942242-1 I ` :_