Free Motion to Continue - District Court of Delaware - Delaware

Case 1:05-cv-00292-JJF Document 204 Filed 06/O1/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT i
FOR THE DISTRICT OF DELAWARE A
LG. PHILIPS LCD CO., LTD., ) I
Plaintiff, ) C. A. No. 05—292 (JJF)
v. g DEMAND FOR JURY TRIAL
TATUNG COMPANY; )
TATUNG COMPANY OF AMERICA, INC.; )
CHUNGHWA PICTURE TUBES, LTD.; )
AND VIEWSONIC CORPORATION, ) i
Defendants. )
MOTION FOR CONTINUAN CE OF PRE—TRIAL CONFERENCE DATE
Defendants Tatung Company, Tatung Company of America, Inc., Chunghwa Picture
Tubes, Ltd. and Viewsonic Corporation ("Defendants”), by and through undersigned counsel,
hereby move this Court for a continuance of the pre-trial conference date in the above captioned
matter presently set for June 16, 2006. For the reasons set forth below, Defendants request that j
this Court issue an Order continuing the pre—trial conference date for approximately 20 days to
allow the parties to complete fact and expert discovery. In supponi of this motion, Defendants
state as follows:
l. On December 23, 2005 the Court entered a scheduling order in this case (the
“Scheduling Order") setting forth a pre—trial conference date of June 16, 2006.
2. In the same scheduling order the Court also set deadlines for the close of fact
discovery (February 2, 2006), disclosure of Plaintiffs expert reports (March 31, 2006),
disclosure of Defendants’ expert reports (April 14, 2006) and close of expert discovery (April
28), 2006.
RLFI-3020814-t

Case 1 :05-cv-00292-JJF Document 204 Filed 06/O1/2006 Page 2 of 4
3. Due to the complex nature of the litigation most, if not all, of the dates set forth in i
the Scheduling Order have been extended. Fact discovery did not close until early April, fact ‘
depositions remain in progress and expert discovery has not yet begun. Final expert reports will
be submitted on June 16, 2006 (the date of the pre-trial conference) and expert depositions will
continue for an additional two weeks.
4. The parties are currently working diligently to finish the remaining depositions
and exchange expert reports. Proceeding on the current schedule would cause a waste of j
resources because extensive supplemental pre-trial submissions will likely be necessary at the A
conclusion of expert discovery. Re-scheduling the pre-trial conference will allow the parties to
focus on the completion of fact and expert discovery and provide the Court with a complete pre- 2
trial order. The trial date of July 17, 2006 will not be affected by this Motion. E
WHEREFORE, the Defendants respectfully request that the Court enter an order re-
scheduling the pre-trial conference for a time approximately twenty days from the date at which 7
it is currently scheduled. 1
OF COUNSEL: Robert W. Vlfhetzel (#2288)
[email protected]
Christine A. Dudzik Matthew W. King (#4566)
Thomas W. Jenkins [email protected]
Howrey LLP Richards, Layton & Finger
321 North Clark Street, Suite 3400 One Rodney Square, P.O. Box 551 ,
Chicago, lllinois 60610 Wilmington, DE 19899
(312) 595-1239 (302) 651-7700
Attorneys for Defendants/Counterclaimants A
Teresa M. Corbin Chunghwa Picture Tubes, Ltd.; Tatung *
Glenn W. Rhodes Company; Tatung Company ofAme1ica, 1
Howrey LLP _ Inc.; and Viewsonic Corporation. ;
525 Market Street, Suite 3600 E
San Francisco, CA 94105 E
415.848.4900
Dated: June 1, 2006
RLF1 -20202 14-1

Case 1 :05-cv-00292-JJF Document 204 Filed 06/O1/2006 Page 3 of 4
Rule 7.1.1 Certification L
Counsel for Tatung Company, Tatung Company of America, Inc., Chunghwa Picture
Tubes, Ltd. and Viewsonic Corporation has consulted with counsel for plaintiff pursuant to
Delaware Local Rule 7.1.1 and understands that plaintiff will not consent to the relief sought
by this motion. I
Matthew W. King (#4566) E l
king@rltYcom
Dated: June l, 2006
RLFlr30208l4~l

Case 1 :05-cv-00292-JJF Document 204 Filed 06/O1/2006 Page 4 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE _
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June l, 2006, I electronically filed the foregoing document
with the Clerk of Court using CM/ECF which will send notification of such tiling, and hand E
delivered to the following:
Richard D. Kirk ;
The Bayard Firm {
222 Delaware Avenue, Suite 900 Z
P.O. Box 25130 `
Wilmington, DE 19899
l hereby certify that on June l, 2006, I sent the foregoing document by Electronic Mail,
to the following non—registered participants:
Gaspare J. Bono J
Matthew T. Bailey
Andrew J. Park g
Adrian Mollo c
McKenna Long & Aldridge LLP E
1900 K Street, NW g
Washington, DC 20006 l
Matthew W. King (#4566)
[email protected]
Richards, Layton 8.; Finger
One Rodney Square
P.O. Box 551
Wilmington, DE 19899
RLFI-2917974-1