Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01337-JJF Document 344 Filed O9/17/2008 Page 1 of 2
Potter
M Anderson
tk. Corroon LLP
”.l3‘;3 North Market Street E1:;lg;grA· Rnvncr
P0 BOX 951 [email protected]
l W1l=T1i¤gY<>¤, DE @899-0951 {302) 984-6140 Direct Phone
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www.p0tter*ar1de1·son.oom -
September 17, 2008
BY E-FILE, HAND DELIVERY AND }l‘.——l\/IAIL
The Honorable Vincent J. Poppiti
Blank Rome LLP .
Chase Manhattan Centre _
120l Market Street, Suite 800 `
Wilmington, DE l980l
Re: Honeywell lnt’l Inc., et al. v. Apple Computer, Inc., et al.
D. Del., C.A. Nos. 04—l338—JJF
Honeywell lnt’l Inc. et al v. Audiovox Corporation, et al.,
D. Del., C.A. No. 04-I337-JJF
Optrex America Inc. v. Honeywell lut’l Inc., et al.
D. Del., C.A. No. 04-l536·JJF
Dear Judge foppitia
l write on behalf of the Manufacturer Defendants FUJ IFILM, Optrex, Samsung SDI, and
lnnolux regarding allocation among the parties of the Special Master’s fees, a topic Your Honor
raised at the conclusion of our in—person conference on September 4, 2008.
As directed, all Defendant groups have discussed this matter with counsel for Honeywell.
We have agreed with Honeywell that, for issues related to case management, such as the
scheduling issues that we are currently discussing, Your l—lonor’s fees will be split three ways:
l/3 to be paid by Honeywell; 1/ 3 to be paid by the Manufacturer Defendants; and l/3 to be paid
by the Customer Defendants. Going forward, issues addressed by the Special Master will be
split two ways, with Honeywell to pay % and the Customer Defendants and/or Manufacturer
Defendants, depending on the group of Defendants involved in a particular issue, as a group to
pay %. Of course, when an issue is defendant-specific (ag., the current dispute between
Honeywell and Citizen or a case dispositive motion by one or more defendants), Your Honor’s
fees will be split evenly between Honeywell and that particular defendant or defendants.

Case 1:04-cv-01337-JJF Document 344 Filed O9/17/2008 Page 2 of 2
The Honorable Vincent J. Poppiti
September 17, 2008
Page 2
Should you have any questions, counsel are available at the Special Mastefs convenience.
Respectfully,
Philip A. Rovner
p1”OV1“l€1`@pOtlZ€I’{:1I1 PAR/mes/883009
cc: All Counsel of Record »~ by CM-ECP