Free Affidavit - District Court of Delaware - Delaware


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Case 1:04-cv-01338-JJF

Document 571-2

Filed 09/19/2006

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EXHIBIT A

Case 1:04-cv-01338-JJF

Document 571-2

Filed 09/19/2006

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Case 1:04-cv-01338-JJF

Document 571-2

Filed 09/19/2006

Page 3 of 30

EXHIBIT B

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 Page 4 ... Page Audiovox 10.2" Portable DVDLCD Shuttle System (DT102DOPKG) and other Overhead Mobilof 30 1 of 1
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Case 1:04-cv-01338-JJF

Document 571-2

Filed 09/19/2006

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EXHIBIT C

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 Page 6 Hon Hai Precision Industry Co., Ltd. information and related industry information from Hoover's of 30 1 of 3 Page

HOOVERS
A D&B COMPANY
2 Tzu Yu St.,

lM

Intelligence. Insight. Results. Learn More Or Subscribe Now:

Hon Hai Precision Industry Co., Ltd.
Tu-Cheng City Phone: 4-886-2-2268-3466 Taipei, Taiwan Fax: +886-2-2268-6204 ~ j ~ u ~ ~ ~ . f o x c o l l l l . ~ ~ ~ Hoover's'coverage by Jeff Dorscfi

Hon Hai Precision Industry may be the biggest company you never heard of. The company, more commonly known by its trade name, Foxconn, is one of the world's largest contract electronics manufacturers. It manufactures computer, consumer electronics, and communications products, including connectors, cable assemblies, enclosures, flat-panel displays, game consoles, motherboards, and servers, Hon Hai also provides design engineering and mechanical tooling services. The company's customers include Apple, Cisco, Dell, Nokia, and SoIij7. -Terry Gou founded Hon Hai in 1974to make plastic switches for televisions. CEO

Key Numbers
Key financials for Hon Hai Precision Industry Co., Ltd.
Company Type
Fiscal Year-End
2004 Sales (mil.)

Public (Taiwan: Full Quote December
$165935.7 43.4% $930.5 26.2% 166,509 78.8%

)

i-Year Sales Growth
2004 Net Income (mil.)

1-Year Net Income Growth
2004 Employees

i-Year Employee Growth

Ipo TIP: Want to stay abreast of the latest in -news? and start receiving exclusive Hoover's content delivered straight to your inbox. Each newsletter is delivered weekly to help you stay ahead of the

http ://www .hoovers.com/hon-hai/--ID-5

8638--/free-co-factsheet.xhtml?cm~ven=PAID&cm~cat.. 9/11/2006 .

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 Page 7 Hon Hai Precision Industry Co., Ltd. information and related industry information from Hoover'sof 30 2 of 3 Page

competition.

Key People
Key people and executives for Hon Hai Precision Industry Co., Ltd.
Chairman and CEO
Terry T.M. Gou (Subscribers see complete biographies -- &w scixnplc~)

uild ~ ~ e ~ ~ List to target decision makers by industry, geography, sales, t i ~ r e net income, and number of employees.

Top Competitors
Top competitors of Hon Hai Precision Industry Co., Ltd.
Fkxtronics
Sanxnina-SGI
_ _ ~ _ _ Solectron

ai: see more.

TIP: Analyze the ~ ~~ ~ ~ ~ view a ~ ~ head-to-head comparison of a firm'st ~ ~ a ~ ~~ profitability, operations, growth, and valuation versus that of its top three competitors.

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Industry ~ n ~ o ~ m a ~ i o n
Primary and secondary industries for Hon Hai Precision Industry Co., Ltd.

Electronics
_ _ l l _ _

___-Contract ~

l

e

~

t

~

~

~

~

~

s

Electronic Components Electronic Connectors
_ I

TIP: See what companies are creating the biggest impact each week with Hoover's Hottest Companies newsletter. and start receiving exclusive Hoover's content delivered straight to your inbox. Each

http://www.hoovers.com/hon-hai/--ID-5 8638--/free-co-factsheet.xhtml?cm~ven=PAID&cm~cat.. 9/11/2006 .

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 Page 8 Hon Hai Precision Industry Co., Ltd. information and related industry information from Hoover'sof 30 3 of 3 Page

newsletter is delivered weekly to help you stay ahead of the competition.

See how Hon Hai Precision Industry Co., Ltd. ranks in standard industry listings such as Fortune 500, S&P500, and Dow Jones
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EXHIBIT D

Case 1:04-cv-01338-JJF

Document 571-2

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State Directory

I Help I Search Delaware :

Citizen Services

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Business Services

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Visitor Info.

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File Number: Entity Name: Entitv Kind: Residencv:

3979024

-oration Date / Formation Date:

06/02/2005

(mm/dd/yyyy)

FOXCONN TECH CORP. CORPORATION DOMESTIC

Entity Type: State:

GENERAL DE

REGISTERED AGENT INFORMATION

Name: Address: City: State: Phone:

OFFSHORE INCORPORATIONS (DELAWARE) LIMITED 1220 N. MARKET STREET SUITE 806 WILMINGTON DE

County: Postal Code:

NEW CASTLE 19801

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EXHIBIT E

Case 1:04-cv-01338-JJF EMSNow - News Archives

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Hon Hai to increase investment in lnnolux
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bY JulI3,2004 Hon Hai Precision Ind. Co. Ltd will increase investment in is Taiwan TFT-LCD t subsidiary InnoLux Display Corp. Shareholders quickly approved the investment plan, which will expand the company's stakes in lnnolux from 6 percent to 33 percent. According to Hon Hai Chairman Terry Gou, the company will be supplying half of Hon Hai's demand for TFT-LCD panels. The subsidiary's 5G plant is expected to be completed soon and will commence production of 14- and 15-inch TFT-LCD panels with an initial monthly capacity of 65,000 units.

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EXHIBIT E;

Document 571-2 Filed 09/19/2006 InternationalCase 1:04-cv-01338-JJFCapital Spending for Advanced TFT-LCD PanelPage 15... 30 1 of 4 Market Research - Rising Producti of Page

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Rising Capital Spending for Advanced TFT-LCD Panel Production in Taiwan
~

International Market Insight [IMI] 0Regions: EAP;Asia;East Asia;ADB c Country: Taiwan ! 0Divisions [County]: T'ai-pei

ID: 114707

i? Industry:

r Sector: !
~

Information & Communication Electronic Components
Report Date: 03/07/2003 Expires: 12/3112003

by: Shirley Wang approver: Eric McDonald

INTERNATIONAL COPYRIGHT, U.S. & FOREIGN COMMERCIAL SERVICE AND U.S. DEPARTMENT OF STATE, 2003. ALL RIGHTS RESERVED OUTSIDE OF THE UNITED STATES. Increase export sales opportunities for U.S. exporters.

Rising Capital Spending for Advanced TFT-LCD Panel Production in Taiwan Taiwan thin film transistor-liquid crystal display (TFT-LCD) panel makers are making ever effort to expand production capacity by building fifth-generation TFTLCD panel plants and installing new production lines in the existing facilities to increase their market competitiveness worldwide. Six fifth-generation TFT-LCD panel plants are either under construction or proposed with mass production to begin either in 2003 or early 2004. Capital expenditures for the year 2003 by local panel makers will be tremendous. A total of more than US$4.3 billion has already been earmarked by seven large panel manufacturers for production capacity expansion. Local demand for advanced TFT-LCD production facilities will be promising. This move is expected to provide foreign firms with excellent sales opportunities in the Taiwan market. 2. Among the seven large panel makers, AU Optronics Inc., one of Taiwan's leading optical product manufacturers, will spend over US$l .O billion in equipment 9/13/2006

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 International Market Research - Rising Capital Spending for Advanced TFT-LCD PanelPage 16 ... 30 2 of 4 Producti of Page

installations at its second fifth-generation TFT-LCD panel plant and at the color filter plant for the fifth-generation TFT-LCDs. The second fifth-generation TFTLCD plant, located in Long Tan, Taoyuan, is scheduled to begin trial production in March 2003 with initial output of 7,000 glass substrates for TFT-LCD panels. The production volume is expected to reach about 50,000 units by the end of 2003. Each glass substrate can be cut into 12 pieces of 17-inch TFT-LCD panels. Other leading TFT-LCD companies such as Chi Mei Optoelectronics Corp., Chunghwa Picture Tubes, Ltd. and HannStar Display Corp. are also speeding up capital investment in their fifth-generation TFT-LCD factories located at the Tainan Science-Based Industrial Park (TSBIP). During 2003, Chi Mei plans to spend US$725 million in equipment purchases for its new fifth-generation panel plant and another US$145 in expanding its existing facilities by adding more production lines. Chi Mei's fifth-generation panel plant will start volume production in the third quarter of 2003. Chi Mei will also invest about US$1.8 billion to build a sixgeneration plant for TFT-LCD panels in TSBIP in the foreseeable future. Chunghwa Picture will invest about US$580 million in its 4.5-generation panel plant, which is scheduled to begin production in the second quarter of 2003. Estimated total capital spending by HannStar for its fifth-generation panel plant will reach approximately US$700 million in 2003, an increase of 531.6 percent from the previous year. Construction of this panel plant will finish in the first quarter of 2004. HannStar will also break ground on a US$260 million joint venture with SinTek Optoelectronics Corp. in March 2003 for making color filters for fifthgeneration TFT-LCDs. The color-filter plant is scheduled to begin volume production in the first quarter of 2004 with initial output of 60,000 1,200mm x 1,300mm color filters a month. In 2003, Quanta Display Inc. will pour about US$435 million into its fifthgeneration TFT-LCD panel plant, which will begin volume production in mid2003. Innolux Display Corp, a subsidiary of Taiwan's Hon Hai Group, is scheduled to start construction of a fifth-generation TFT-LCD panel plant in April 2003. Innolux's new plant will be completed and begin mass production in the fourth quarter of 2004, making the company the fifth maker of fifth-generation panels in Taiwan. The plant will be located in Chunan, northern Taiwan and cost about US$667 million. Capital spending by Innolux for the year 2003 is estimated at US$290 million. Meanwhile, Toppoly Optoelectronics Corp. will make US$435 million capital investment in production capacity expansion. Capital Expenditures by Large Local Panel Makers in 2003 (Unit in US$ Million) Name of Firms
.
I
* -

Capital Expenditure in 2002
m r / r

Capital Expenditure in

Growth Rate

(%I

n

I Chunghwa Picture Tubes, I
Ltd. HannStar Display Corp. Quanta Display Inc.

$232.0
$110.0 $290.0

I

$580.0 $696.0 $435.0

I

150.0%
53 1.6% 50.0%

9113/2006

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 International Market Research - Rising Capital Spending for Advanced TFT-LCD PanelPage 17 ... 30 3 of 4 Producti of Page

Toppoly Optoelectronics Corp. Innolux Display Corp.

$580.0

$435.0 $290.0

-25.0%

-

-

Exchange Rate Used: US$l.OO=NT$34.50 3. Contact Information: U.S. firms wishing to learn more about the information are encouraged to contact the following individuals for assistance: Eric McDonald, Commercial Officer E-mail: eric.mcdonald@,mail.doc.cov or Shirley Wang, Commercial Specialist E-mail: shirley.wan-@,mail.doc.vov American Institute in Taiwan Commercial Section Rm.3207, No. 333, Keelung Road, Sec. 1 Taipei, Taiwan Tel: 886-2-2720-1550 Fax: 886-2-2757-7162 Postscript: The American Institute in Taiwan is a private non-profit corporation established to carry out relations between the people of the United States and the people on Taiwan. AIT's Commercial Section is charged with the mission of helping U.S. firms export their goods and services to Taiwan. To accomplish this mission we conduct a number of services on behalf of the U.S. Department of Comerce. AIT's Commercial Section offers a variety of resources and services (including market research, international partner search, advocacy, trade mission and trade shows) to assist U.S. companies entering the Taiwan market. The AIT Commercial Section can be reached at phone: 886-2-2720-1550, fax: 886-22757-7162. The AIT Commercial Section is also on the World Wide Web at the following address: http://www.ait.org.tw. If this report has alerted you to a commercial opportunity in Taiwan and you subsequently pursue it with successful results, please let us know. We track successes and want to know how our market reports and services are being used.

For additional information regarding market research specific to your products and services, ask about our Flexible Market Research and Customized Market Analysis programs by contacting us a t 18OO-USA-TRAD(E) or www.export.gov o r www.buyusa.com. Both reports provide timely, customized, reliable answers to your inquiries about a market and its receptivity to your products and services.
To the best of our knowledge, the information contained in this report is accurate as of the date published. However, The Department of Commerce does not take responsibility for actions readers may take based on the information contained herein. Readers should always conduct their own d u e diligence before entering into business ventures or other commercial arrangements. The Department of Commerce can assist companies in these endeavors.

9/13/2006

Case 1:04-cv-01338-JJF Document 571-2 Filed 09/19/2006 Page 18 of Page International Market Research - Rising Capital Spending for Advanced TFT-LCD Panel Producti... 30 4 of 4

Created: 2005-09-01
Updated: 2006-02-28

Important Notices

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EXHIBIT G

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Hon Hai to challenge NT$2 Trillion for turnover
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b Y Jan 27,2006 The combined turnover of the Hon Hai Group, the largest Taiwaneseprivate manufacturer, topped the NT$I trillion mark in 2005, three years ahead of the company's original schedule, and affaining the NT$2 trillion mark looks like a definite possibility for the group in the future, announced Terry Guo, chairman of the group, on Jan. 26.

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At an annual growth rate of more than 50%, the group expects to see its turnover exceed the NT$2 trillion mark by 2008, not only consolidating its status as Taiwan's largest private manufacturer but also making it the largest EMS (Electronic Manufacturing Service) maker in the world.

__ LCD
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Guo originally set the goal for the group of attaining NT$1 trillion in turnover by 2008, when he planned to retire. With the attainment of the goal ahead of the schedule, people expressed concern about whether he would make good on his pledge to retire. However, during the joint year-end party of the group's three subsidiaries, Guo expressed his firm determination to challenge the NT$2 trillion turnover mark, without any hint about retirement. v~~~.dciincarporated.con
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Guo reported that Hon Hai Precision chalked up NT$670 billion worth of turnover in 2005, and Hong Kong-listed Foxconn International Holdings raked in NT$200 billion of turnover. After adding the turnover of other subsidies, the combined turnover of the group exceeded NT$I trillion. In view of the expected fast growth of the group, especially certain subsidiaries, the NT$2 trillion turnover mark no longer appears to be a dream beyond the reach of the group.

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In 2005, Hon Hai subsidiary InnoLux Co. saw rising production from its enhanced fourth-generation and fifth-generation panel production lines, as well as the inauguration of a colored filter plant, enabling its turnover to reach NT$51.3 billion, a growth of more than 16 times. Tuan Hsing-chien, president of the company, is confident that Innolux's turnover in 2006 will double to exceed the NT$100 billion mark.

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EXHIBIT H

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Innolux expects to turn profitable
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By Lisa Wang STAFF REPORTER Friday, Oct 07, 2005,Page 10
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lnnolux Display Corp (%@I% ), a Taiwanese computer flat-panel maker, yesterday said it started booking profits in the third quarter after three years of operation, paving the way for an initial public offering next year. lnnolux primarily makes thin-film-transistor (TFT) liquid-crystal-display (LCD) screens for computers as well as monitors for its parent company, Hon Hai Precision Inc (%%G%@), which supplies desktop computers to computer giant Dell Inc. "Innolux should have started making profits in the third quarter, slightly lagging behind Taiwan's two largest TFT-LCD players," Innolux's president Tuan Hsing-chien (6Etf.g) said on the sidelines of a display forum arranged by a government agency yesterday.

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Tuan declined to give detailed financial results. AU Optronics Corp (?!Zg%%), Taiwan's top LCD screen maker, returned to profitability in the second quarter, riding on recovering demand, while No.2 player Chi Mei Optoelectronics Corp (;$.%%T) expected to eke out profits a quarter later. Market researcher Displaysearch also turn more positive on the sector. The Austin-based

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researcher yesterday raised its third-quarter outlook for the TFT-LCD industry. Revenues for global LCD makers will grow 46 percent year-on-year to US$12.1 billion, about 8 percent higher than the researcher's previous estimate, it said in a statement.
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Tuan yesterday told reporters that lnnolux last week filed an application for an initial public offering (IPO) on the Taiwan Stock Exchange. "The IPO will give lnnolux easier access to raise funds in the future," Tuan said. He expects lnnolux shares will traded on the main bourse by the third or fourth quarter of next year. lnnolux has not set a price to float the 2.1 billion shares outstanding. According to stock-exchange rules, only money-making companies are qualified to list on the local stock markets. With most of its output going to Hon Hai, lnnolux would be able to weather industry downturns better than other panel players, Daniel Wang (?E@%), an analyst with Primasia Securities in Taipei, said. lnnolux now has two plants - a less advanced 4.5-generation fab and a fifth-generation (5G) fab, Tuan said. The company ramped up the cost-efficient 5G plant in the second quarter, with a monthly output of 50,000 glass substrates, he said. lnnolux plans to boost output to around 75,000 units per month by the third quarter of 2006, he added. lnnolux posted sales of NT$24.08 billion in the first eight months of the year, jumping from NT$I . billion a year ago. Tuan yesterday declined to comment on recent speculation that 9 lnnolux was in talks with Taiwan's No.3 LCD panel maker Chunghwa Picture Tubes Inc about a merger. Innolux's shares, which trade on the gray market ahead of a stock-exchange listing, fell

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0.72 percent to NT$35.87 on average yesterday. This story has been viewed 1660 times.
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Wed, Sep 22, 2004 Front Page Taiwan News World News Editorials Sports Business World Business Features Photo News More Business

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early to say whether we'll make liquid-crystal displays seek an (LCDs) used in computers, said overseas 1isting'. I it Plans to sell its first shares Tuan Hsingpublicly in 2006 to help raise ehien, Innolux funds for expansion. president

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The company will go public here, innolux president Tuan Hsing-chien (@+?@) said in an interview. "It's still too early to say whether we'll seek an overseas listing," he said.

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Hon Hai Precision Industry Co (%%E%@) founded Innolux, the newest of the nation's six makers of computer-sized flat-panel displays. Hon Hai, the country's largest electronics company by sales, I should help Innolux run at capacity next year, Best View in Mozilla when rivals struggle to prevent losses because of

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excess production, analysts said. "Hon Hai should be able to absorb all of Innolux's output," said Henry Wang, an analyst with WitsView Technology Corp (rffif?%$t%) in Taipei. "Perhaps there will be a good story for the company's share sale after 2005." Tuan declined to say how much would be raised from the sale. lnnolux will open its first two factories by the end of this year to make screens for desktop computer monitors and smaller products. A third plant will make color filters for the displays.
The company's plans come as Corning, the world's largest maker of glass used in t h e screens, said

South Korean and Japanese flat-panel makers have slowed the opening of new factories because of overcapacity. Corning declined to say which companies have delayed their plans. South Korea's Samsung Electronics Co, the world's biggest screen maker, and rivals may face losses in their display units by next year because of a supply glut that resulted from too much investment in the production of television-sized screens, investors and analysts said earlier this month. Prices of LCDs are tumbling as consumers remain reluctant to pay up to US$5,000 for flat-screen
TVS.

Consumers won't buy LCD TVs until the prices drop to about three times what it costs to buy a tube television, said investors such as Charles

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Isaac, who counts shares in AU Optronics Corp ( E S%%) Taiwan among the equivalent of US$1I of billion that Zurich-based Swissca Portfolio Management invests in stocks globally. "You can't make LCDs just for the sake of making LCDs," Tuan said. For now, lnnolux will focus on producing screens for desktop monitors, the biggest market for the panels, said Tuan, who was previously president of AU Optronics, the world's third-largest LCD maker. Sales of LCDs measuring more than 10 inches diagonally will rise 50 percent to US$36 billion this year, with monitors accounting for more than half of total shipments, according to market researcher Displaysearch. lnnolux will spend US$693 million to boost its output this year, the world's fourth-largest investment in the industry during the period, Texas-based researcher Displaysearch said earlier. Innolux in March signed a NT$20 billion (US$590 million) loan to expand production. Pion Hai earlier this year said it may increase its stake in lnnolux to as much as a third from about 6 percent. The company will sell its monitor screens exclusively to Hon Hai, Tuan said. "Hon Hai's desktop monitor business is small now,"' Tuan said. "It'll grow quickly." He declined to provide details.
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