Free Letter - District Court of Delaware - Delaware

Case 1:O4—cv—O1337-JJF Document 341 Filed O9/15/2008 Page 1 of 2
Cnoss & S1MoN, LLC
Amy E. Evrms* ATTORNEYS AT LAW soss12xeooNrYoFF1C.e.·
acVanS@gyOgg]aw_COm NORTH MARKET STREET 17577 NASSAU COMMONS
HTH Froon — BLVD.
MAILING ADDRESS; WILMHQGTON, DELAWARE 19801 SUITE 102
ltll;rZ3’飣L’3?LL 19899-1380 3°2“’";i§?§?§,§f§,§{,Q{Zlg§,$Q24(FAX)
* Also admitted in New York
September 15, 2008
. BY E-FILING, E-MAIL,
and HAND DELIVERY
The Honorable Vincent J. Poppiti A V
Blank Rome LLP .
Chase Manhattan Centre
1201 Market Street, Suite 800
Wilmington, DE 19801
Re:
Honeywell Intl Inc., et al v. Apple Computer Inc., etal
» 1:04-cv-1338
Honeywell Intl Inc., etal v. Audiovox Corporation, et al
l:04—cv—1337
Honeywell International Inc. et al v. Citizen Watch Co Ltd
et al
l:05—cv—874
Optrex America Inc. v. Honeywell Intl Inc., etal
1:04-cv—l536
Dear Judge Poppiti:
We write on behalf of Hartford Computer to share the concerns and positions set
forth by Sony and Apple in their letters dated September 12, 2008. Three years ago'
Hartford Computer identified the suppliers of the LCD modules included in its accused
products——AU Optronics, All Around Co., Ltd. and Picvue. AU Optronics was
voluntarily dismissed on April 3, 2006. Based on the docket, it does not appear that All
Around Co., Ltd. and Picvue have ever been served, and certainly have not participated in
the instant litigation.
To the extent Hartford Computer is not dismissed from these proceedings, it
would be difficult, if not impossible, to meaningfully participate in supplemental
Markman proceedings as to modules and manufacturers that have_never been the subject
of discovery, or even infringement contentions by Honeywell. Accordingly, Hartford

Case 1 :04-cv-01337-JJF Document 341 ' Filed O9/15/2008 Page 2 of 2
CRoSs & S1MoN, LLC
September 15, 2008
Page 2 of 2 `
Computer respectfully requests that it too be dismissed on the same grounds as those set i
forth in Sony’s and Apple's letters of September 12, 2008.
Counsel is available at the Court’s convenience to address any questions or
COHCSIHS.
Respectfully submitted, ‘
(DE Bar No. 3829)
cc: Michael Bregenzer, Esquire (via e—mail)
Brian Roche (via e-mail)
All Counsel of Record (via e—filing and/or e—mai1)
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