`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`302 984 6000
`www.potteranderson.com
`
`David E. Moore
`Partner
`Attorney at Law
`dmoore@potteranderson.com
`302 984-6147 Direct Phone
`302 658-1192 Fax
`
`January 21, 2016
`
`VIA ELECTRONIC-MAIL
`The Honorable Leonard P. Stark
`The United States District Court for the District of Delaware
`J. Caleb Boggs Federal Building
`844 N. King Street
`Wilmington, DE 19801-3568
`
`Re:
`
`Robert Bosch LLC v. Alberee Products, Inc., et al.
`(C.A. No. 12-574-LPS)(Cons.)
`
`Dear Chief Judge Stark:
`
`Costco writes to the Court complaining of “. . . Robert Bosch LLC’s total failure to
`comply with the Court’s Order . . . .” (D.I. 289). It is true that Robert Bosch LLC has not
`produced any documents in response to the Court’s order, because Robert Bosch LLC has not
`had and does not have any access to responsive documents other than those it produced long
`ago. However, it is also true that Robert Bosch GmbH has committed to search for all the
`documents that were the subject of Costco’s demands, and that Robert Bosch GmbH had begun
`its production of these documents even before Costco’s most recent letter.
`
`In view of these facts, which are explained in more detail in Robert Bosch LLC’s pending
`motion pursuant to Fed. R. Civ. P. 60 (filed prior to Costco’s letter to the Court), the Bosch
`parties both respectfully suggest that no telephone conference is necessary at least until Costco
`has filed its response to that Rule 60 motion and explained what additional discovery it will not
`receive and still seeks.
`
`Respectfully,
`
`/s/ David E. Moore
`
`David E. Moore
`
`DEM/msb/1214622/39026
`
`cc:
`
`Clerk of the Court (via hand delivery)
`Counsel of Record (via electronic mail)
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