Free Affidavit - District Court of Delaware - Delaware

Case 1:05-cv-00292-JJF Document 221 Filed 06/13/2006 Page 1 of 3 i
IN THE UNITED STATES DISTRICT COURT E
FOR THE DISTRICT OF DELAWARE _
LG. PHILIPS LCD CO., LTD., )
)
Plaintiff, ) C.A. No. 05-292 (J J F) E
l ¥
v. )
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TATUNG COMPANY; ) A
TATUNG COMPANY OF AMERICA, INC.; ) I
CHUNGHWA PICTURE TUBES, LTD.; ) .
AND VIEWSONIC CORPORATION, )
>
Defendants. )
AFFIDAVIT OF MATTHEW W. KING IN SUPPORT OF DEFENDANTS’ MOTION
FOR PARTIAL SUMMARY JUDGMENT ON DAMAGES UNDER 35 U.S.C. § 287
STATE OF DELAWARE )
) ss.
NEW CASTLE COUNTY )
Matthew W. King, being duly sworn, deposes and says:
`l. My name is Matthew W. King. I am an attorney with the law firm of Richards,
Layton & Finger, PA, One Rodney Squme, Wilmington, DE 19899.
2. I am counsel for Defendants Chunghwa Picture Tubes, Ltd., Tatung Company,
Tatung Company of America, Inc. and Viewsonic Corporation in the above-captioned matter. ‘
3. I submit this affidavit in support of Defendants’ Motion For Partial Summary
Judgment On Damages Under 35 U.S.C. § 287. -
4. Attached hereto as Exhibit 1 is a true and correct copy of a letter from Jeong-
Hwan Lee, Vice President of LG. Philips, to Cheng-Yuan Lin, President of Chunghwa Picture i
Tubes, Ltd dated February 8, 2002.
RLFI-30257694

Case 1 :05-cv-00292-JJF Document 221 Filed 06/13/2006 Page 2 of 3 i
5. Attached hereto as Exhibit 2 is a true and correct copy of a letter from Jeong-
Hwan_Lee, Vice President of L.G. Philips, to Cheng—Yuan Lin, President of Chunghwa Picture
Tubes, Ltd dated February 27, 2002.
6. Attached hereto as Exhibit 3 is a true and correct copy of Plaintiff s L
Supplemental Responses And Objections To Defendants’ First And Second Sets Of E
Interrogatories.
7. Attached hereto as Exhibit 4 is a true and correct copy of Defendant Tatung
Cornpany’s Supplemental Response To Plaintiffs Amended First Set Of interrogatories.
8. Attached hereto as Exhibit S is a true and correct copy of Defendant Tatung
Company of America Inc.’s Supplemental Response To Plaintiffs Amended First Set Of I
_ interrogatories.
9. Attached hereto as Exhibit 6 is a true and correct copy of Defendant Viewsonic
Corporation’s Supplemental Response To Plaintiff s Amended First Set Of interrogatories. S
10. Attached hereto as Exhibit 7 is a tme and correct copy of United States Patent
NO. 5,019,002.
Matthew W. King (#4566)
SWORN TO AND SUBSCRIBED before me, a Notary Public for the State and County U
aforesaid, on this! g day of June, 2006. U
5 I 7 . R -
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. . . NOW P”lP}3l5r~. .1.s|.ANKENSHIP P
My Commission Expires: OO Nm-ARY pggrig .
· STATE QF DE LAWARE
itiiy Commission Expires May 9, 2007
2
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Case 1 :05-cv-00292-JJF Document 221 Filed 06/13/2006 Page 3 of 3
UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 13, 2006, I electronically filed the foregoing
document with the Clerk of Court using CM/ECE, which will send notification of such filing to,
and also hand delivered same to: 1
Richard D. Kirk e
Morris James Hitchens & Williams LLP
222 Delaware Avenue, Suite 900 Q
Wilmington, DE 19899 ·
I HEREBY CERTIFY that on June 13, 2006, I sent the foregoing document by Electronic I
Mail to the following non—registered participants:
Gaspare J. Bono I
Matthew T. Bailey
Andrew J. Park E
Adrian Mollo
McKenna Long & Aldrige LLP
1900 K Street, NW
Washington, DC 20006 {
Matthew W. King (#4566)
[email protected]
Richards, Layton & Finger
One Rodney Square
PO Box 551
Wilington, DE 19899 I