`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`302 984 6000
`www.potteranderson.com
`
`Bindu A. Palapura
`Attorney at Law
`bpalapura@potteranderson.com
`302 984-6092 Direct Phone
`302 658-1192 Fax
`
`February 23, 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:
`
`We represent the plaintiff in the above-captioned matter and write to correct inaccuracies
`in defendant Costco’s February 19, 2016, letter submission.
`
`In its letter, Costco alleges that a contract document recently produced by Robert Bosch
`GmbH had been withheld from production by Robert Bosch LLC, and that the document’s
`contents show that “the pretrial discovery process in this case was compromised and warrants
`dismissal of the SAC with prejudice.”
`
`However, the document on which Costco bases this most recent request for dismissal is
`the global terms-and-conditions agreement applicable to sales by the Bosch group of companies
`to Ford Motor Company and its affiliates. It is a document to which Robert Bosch LLC did have
`access in the ordinary course of its business. Robert Bosch LLC therefore produced the
`document to Costco ten months ago, on April 23, 2015. It was Bates labeled BLLC1254358–
`392.
`
`Respectfully,
`
`/s/ Bindu A. Palapura
`
`Bindu A. Palapura
`
`BAP/msb/1217171/39026
`
`cc:
`
`Clerk of the Court (via hand delivery)
`Counsel of Record (via electronic mail)