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EXHIBIT A

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EXHIBIT B

Exhibit B
Affected Defendants Matrix
Meet & Confer Authentication Declaration Linkage Declarations Communications with LCD Suppliers Optrex/ Samsung SDI Declaration

Affected Defendant

Apple June 30, 2008 June 17, 2008 June 24, 2008 June 12, 2008 July 3, 2008 June 20, 2008 June 25, 2008 June 6, 2008 June 19, 2008 July 2, 2008 Yes Unknown Yes Yes Yes Unknown Unknown Yes Yes Unknown

June 30, 2008

Yes

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Audiovox

Dell

Eastman Kodak

Argus

Navman

Nikon

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Olympus

Pentax-Hoya

Sony

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Sony Ericson

LEGEND:

Agreement in Principle

Agreement in Concept, Specific Details to be Worked Out Under Consideration

In Dispute

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EXHIBIT C

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EXHIBIT D
FULLY REDACTED

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EXHIBIT E

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800 BOYLSTON STREET 25TH FLOOR BOSTON, MA 02199-7080 TEL: 617-267-2300 FAX: 617-267-8288 www.rkmc.com

ALAN E. MCKENNA 617-859-2719

July 11, 2008

VIAE-MAIL
COUNSEL (per attached list) Re: Honeywell International Inc., et al v. Apple Computer, Inc., et al. Court File No. c.x. No. 04-1338-KAJ (consolidated) Our File No.: 019896.0229

Dear Counsel: Pursuant to Special Master Poppiti's instructions during the June 23,2008 telephone conference, we have now conducted initial meet and confer conferences with each of you. We are scheduled to conduct a global meet and confer on July 15th. We propose having the call at 3:00 p.m. Eastern. If that time poses a problem for anyone, please let us know so that we can work together for a suitable time during the afternoon of July 15. In advance of the global meet and confer next week, we thought it might be helpful to further enlighten the group as a whole as to where the issues stand, in the hopes that our call on July 15th can be as productive as possible. Honeywell remains willing to work with you to find an efficient and amicable resolution to the issues before Special Master Poppiti, but expects the customer defendants to meaningfully participate in this process, especially since they are the ones who raised this issue and they are the ones who are seeking relief. Now that we have conducted meet and confer conferences, you are all aware of Honeywell's position with respect to a timely and orderly resolution of the issues facing the Special Master regarding the customer defendants' attempts to be dismissed from this matter. As you all know, the issues before the Special Master arose as a result of the customer defendants' request to be dismissed from this action based on the '371 licenses entered to date. For the reasons set forth in prior correspondence, and as preliminarily discussed with Judge Farnan on April 2, 2008, it remains Honeywell's position that more is required than simply pointing to an existing license agreement. In fact, during the April 2, 2008 Status Conference, Judge Farnan made it clear that Honeywell would be entitled to limited discovery to assist in determining whether a particular customer defendant is covered by a particular license. To avoid the cost and

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expense of formal discovery, Honeywell has been willing to work with each of your clients to develop an informal way to resolve these issues. To that end, Honeywell has provided each of you with a proposal aimed at resolving the issues through the use of sworn declarations from your clients and the relevant LCD module manufacturers. Specifically, Honeywell has proposed obtaining a declaration from your individual clients that would cover two issues. First, it would authenticate the original disclosures made regarding the LCD modules at issue. Rather than rely upon letters from outside counsel, Honeywell needs to confinn the authenticity of the disclosures made by your clients and the manner in which the search for relevant LCD modules was conducted. To date, only one or two of you have raised any real concern with this portion of Honeywell's proposal. Second, this declaration would confirm that your client does not use/purchase accused modules from Samsung SDI or Optrex, two module manufacturers that remain in the case and are not licensed under the '371 patent. Honeywell is willing to accept either a declaration that your client has not purchased any modules from either entity, or a declaration that your client has not purchased any of the specifically-accused modules from either entity. As we have explained, that choice is up to you and your client. These entities have designated the alphanumeric module identifiers as highly confidential in this matter. Honeywell is currently working to be able to provide such lists to you, but does not yet have that permission from Samsung SDI or Optrex. Again, aside from questions as to logistics, only one or two of you has expressed concern with providing such a declaration. With respect to logistics, Honeywell would propose that this portion of the declaration cover the period from January 18, 1994 (date of issuance of the' 371 patent) forward. Lastly, based on the issues in the various license agreements as we have discussed and as addressed in Matt Woods' May 13, 2008 letter, Honeywell has proposed that the customer defendants obtain a declaration from the relevant module manufacturer(s) that would provide the linkage between a given customer defendant and the license granted. Since it is the customer defendants' motion to dismiss at issue (i. e., their burden), and since Honeywell does not have the information necessary to make such a linkage, it is the customer defendants' burden to obtain such linkage. As we have repeatedly stated, Honeywell is willing to participate in the process of obtaining such declarations in order to ensure that the efforts are directed to Honeywell's concerns, but the nature of the issue, as well as the customer defendants' ongoing business relationship with the manufacturers, make it more reasonable and efficient for the customer defendants to take the lead. I note in this regard that many of the agreements at issue envision that if a customer wants to be dismissed from a case, the licensee must first demonstrate to Honeywell by written documentation that the license covers the sales to the customers in question. With respect to the particulars ofthis declaration from the LCD manufacturer, by way of example and as we have discussed with many of you, it is Honeywell's position that this

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declaration must include, at a minimum, statements showing that the customer defendant is covered by the various provisions that form the license grant (e.g., date restrictions, limitations in Definitions Sections, monetary limits/sales caps). These issues are especially relevant given the foreign nature of the sales at issue and the customer defendants' claim of exhaustion. So far, the response has been mixed on this issue.' Some of you have explained that your clients have already made contact with their licensed supplier and done the "due diligence" required to obtain such confirmation. For that group, Honeywell needs to confirm the type of the information you have obtained in the form of a sworn declaration from the module manufacturer. Other customer defendants have not flat out rejected this idea but have been unwilling to adopt it as of yet and/or indicated you needed to discuss it with your clients. A minority in the group has expressed objection to this concept as a whole. Aside from raising potential questions and objections to Honeywell's proposal, at this time no customer defendant has proposed alternate positive steps to verify/document in a meaningful way that they are covered by the licenses. Since the issues before Special Master Poppiti relate to the customer defendants' attempts to be dismissed from this action - and since it is their burden - we expect to hear any counter-proposals the customer defendants may have during the July 15th call. Many of you have indicated you would raise the issues we have discussed with your clients and report back to us. If anyone wishes to do so in advance of the call on July 15th, please let us know. Otherwise, we hope that next Tuesday we can further the discussion regarding Honeywell's proposal and reach the point where we are able to make a joint proposal to the Special Master for the orderly resolution ofthe customer defendant's attempts to be dismissed from this matter. Again, please inform us if3:00 p.m. Eastern on July 15th poses a problem. Ifwe do not hear any objection to that time, we will circulate call-in information bye-mail no later than close of business on Monday.

recognize that not every customer defendant falls into the same category in this regard due to individual issues with particular license agreements (i.e., since not all of the license agreements are identical and have the same covered products definitions, sales cap, etc. Honeywell acknowledges that such a declaration may not be required from a select few licensed end manufacturers.). Honeywell will, of course, continue to address these individualized issues on a customer defendant by customer defendant basis as we have done during the meet and confer process.

1 We

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In the meantime, if anyone has any questions, please do not hesitate to contact me or Daniel White of our office.

Very truly yours,

az;:;;V~IL.L.P
Alan E. MCKe:;Jj,,/' cc: Thomas C. Grimm, Esq. Matthew L. Woods, Esq. Anthony A. Froio, Esq. Stacie E. Oberts, Esq. Daniel M. White, Esq.

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Apple Computer Inc.
Thomas L. Halkowski Fish & Richardson P.e. 919 N. Market Street, Suite 1100 PO Box 1114 Wilmington, DE 19899-1114 Office: (302) 652-5070 Fax: (302) 652-0607

Audiovox Communications
D. Joseph English Duane Morris LLP 505 9th Street N.W. Suite 1000 Washington, DC 2004-2166 Office: (202) 776-7800 Fax: (202) 776-7801

Dell
Roderick B. Williams Vinson & Elkins The Terrace 7, Suite 100 2801 Via Fortuna Austin, TX 78746-7568 Office: (512) 542-8400 Fax: (512) 236-3218

Eastman Kodak
Neal Slifkin Harris Beach LLP 99 Garnsey Road Pittsford, NY 14534 Office: (585) 419-8800 Fax: (585) 419-8801

Hartford Computer Group, Inc. (Argus)

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Brian D. Roche Reed Smith, LLP 10 S. Wacker Drive, 40th Floor Chicago, IL 60606-7507 Home Address: Office: (312) 207-1000 Fax: (312) 207-6400

Navman
Brad P. Lyerla Marshall, Gerstein & Boron LLP 233 W. Wacker Dr. 6300 Sears Tower Chicago, IL 60606-6357 Office: (312) 474-6300 Fax: (312) 474-0448

Nikon Corp. and Nikon Inc.
Barry W. Graham Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P. 901 New York Avenue, NW Washington, D.C. 20001-4413 Office: (202) 408-4000 Direct: (202) 408-4017 Fax: (202) 408-4400

Olympus Corp. and Olympus America Inc.
Richard M. Rosati Kenyon & Kenyon One Broadway New York, NY 10004-1050 Office: (212) 425-7200 Fax: (212) 425-5288

Pentax (now Hoya)

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Michael J. Fink Greenblum & Bernstein, P.L.C. 1950 Roland Clarke Place Reston, VA 20191-1411 Office: (703) 716-1191 Fax: (703) 716-1180

Robert Hails Kenyon & Kenyon 1500 K Street, NW Washington, DC 20005-1257 Office: (202) 220-4200 Fax: (202) 220-4201

Sony Ericcson Mobile Communications AB and Sony Ericcson Mobile Communications USA Inc.
Francis DiGiovanni Conolly Bove Lodge & Hutz LLP The Nemours Building -8th Floor 1007 North Orange Street PO Box 2207 Wilmington, DE 19899-2207 Office: (302) 658-9141 Fax: (302) 658-5614

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