Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01338-JJF

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Document 562

Filed 09/13/2006

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September 13, 2006 VIA ECF Honorable Kent A. Jordan United States District Court for the District of Delaware 844 N. King Street Wilmington, DE 19801

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Re:

Honeywell International Inc., et al. v. Apple Computer, Inc., et al. USDC-D. Del. - C.A. 04-1338-KAJ

Dear Judge Jordan: On behalf of Casio Computer Co., Ltd. ("Casio Computer"), we write to respond to Honeywell's September 7 letter to the Court regarding discovery (D.I. 549). Casio Computer shares many of the concerns about Honeywell's approach to discovery that have already been voiced by other defendants, including the improper focus of Honeywell's original discovery requests on the Honeywell-crafted definition of "Accused Structure," Honeywell's unilateral demands for supplementation by a date certain (without conducting a proper meet and confer), and Honeywell's dilatory approach in identifying which specific LCD products are the subject of the case. Casio Computer will not burden the record by further discussing those concerns here. Nonetheless, Casio Computer has produced documents to Honeywell and will continue toward diligently completing its production on a rolling basis. Casio Computer is also prepared to work with Honeywell to address any other outstanding discovery issues, including, expected dates for Casio Computer to supplement its interrogatory answers, as well as Honeywell's deficiencies regarding document production and interrogatory answers. Respectfully, /s/ Thomas L. Halkowski Thomas L. Halkowski TLH/sb cc Clerk of Court (via hand delivery) Counsel of Record (via ECF)

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80036854.doc