Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00292-JJF Document 188 Filed 05/05/2006 Page 1 of 3
Ricnanos, Lavrow & Fzwc-san
A PROFESEAONAE. ASSOCZEATION
Owe Rouwrszv Souamr
MATTHEW W Keno SEO NORTH KING STREET Gmac? Dun. Numean
WILMINGTON, DELAWARE IBBOS 3O2_65 [_·78BI
(302) 651-7700 s mx (zeal eenrzvoa
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May 5, 2006
BY ELECTRONIC FILING
The Honorable Joseph J. liarnan
United States District Court
844 North King Street
Wilmington, DE l980l
Re: LG'. Philips LCD C0., Ltd. v. Tarzmg Company et al.
Case No. 05-292 (JJF)
Dear Judge Farnan:
Further to Defendants’ oral request during the April 25, 2006 hearing and Your Honor’s
Order of May l, 2006, Defendants hereby submit their formal request that the following
specifically identified discovery from Chunghwa Picture Tubes, Ltd, v. LG.Philips LCD Co.,
Ltd., et al., Civil Action No. 05-0189 CBM (JTLX), pending in the United States District Court
for the Central District of California ("the ‘8i0 case") be admitted in this case:
• All Financial Data discovery, discovery responses, testimony, documents and
things produced or provided in the ‘8l0 case, including any such discovery
provided hy Hewlett-Packard Company, may be used in this case, Civil Action
Nor 05-292 (IFF).
Defendants further request the this Court, consistent with the Protective Orders
previously entered in this case, as well as the other pending cases between the parties, enter an
Order that, "Any person who receives in discovery produced in the ‘8i0 case concerning another
party ’s pending patent app1ication(s) or prosecution history tile(s) relating to a pending patent
application that has not been published (that is not otherwise publicly available) shall not be
substantively involved in drafting, tiling or prosecuting any patent applications (including any
continuations, continuations-in-part, or divisionals thereof and/or any reissue or reexarnination
applications), selecting or identifying the subject matter of any patent claims, or preparing or
drafting of any patent claims, or providing instruction, direction or advice regarding these
prosecution activities, where the application or claims are directed to side·mounting LCD panels
in notebook computers or other products until one (I) year after the conclusion of their
participation in the above captioned action. These restrictions do not apply, however, to
providing general legal advice on procedural aspects of patent prosecutior1."
RLFI-30lll64-l

Case 1 :05-cv-00292-JJF Document 188 Filed 05/05/2006 Page 2 of 3
The Honorable Joseph F. Farnan
May 5, 2006
Page .2
Defendants appreciate this Court’s prompt attention to this issue.
Respectfully submitted, _J_/
. J l, ’ '9
. . , /1%-* ~
A/l/l/@@700 DU M/(//®
" Matthew W. King (#4566)
fmwk
cc: Christine A. Dudzik, Esq. (by electronic mail)
Glenn Rhodes, Esq. (by electronic mail)
Richard Kirk, Esq. (by hand delivery)
Robert Whetzel, Esq.
Gaspare Bono, Esq. (by electronic mail)
RLFI-30lIl64-E

Case 1 :05-cv-00292-JJF Document 188 Filed 05/05/2006 Page 3 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
l HEREBY CERTIFY that on May 5, 2006, I electronically tiled the foregoing document
with the Clerk of Court using CM/ECI: which will send notification of such tiling, and hand
delivered to the following:
Richard D, Kirk
The Bayard Firm
22..2 Delaware Avenue, Suite 900
PO, Box 25130
Wilmington, DE l9899
I hereby certify that on May 5, ,2006, I sent the foregoing document by Electronic Mail,
to the following nornregistered participants:
Gaspare J A Bono
Matthew T, Bailey
Andrew J. Park
Adrian Mollo
McKenna Long & Alclridge LLP
1900 K Street, NW
Washington, DC 20006
, j (
— _1 `
i. Alyssa In liwartz (#4 Sl)
scnwartz lf.coin
Richards, Layton & Finger
One Rodney Square
PO, Box 55}
Wilmington, DE l9899
raw a an 17974- 1