`
`
`
`January 31, 2020
`
`Via E-Filing
`The Honorable Leonard P. Stark
`J. Caleb Boggs Federal Building
`844 N. King Street
`Room 6124, Unit 26
`Wilmington, DE 19801-3556
`
`
`
`Re: Elm 3DS Innovations, LLC v. Samsung Elecs. Co. Ltd., et al.,
`C.A. No. 14-cv-1430-LPS
`
`
`Dear Chief Judge Stark,
`
`The parties in the above-referenced matter write to request the scheduling of a discovery
`teleconference.
`
`The following attorneys participated in a verbal meet and confer by telephone on December
`18, 2019:
`
`Delaware Counsel for Elm: Michael Farnan
`Lead Counsel for Elm: Nosson Knobloch
`Delaware Counsel for Samsung: Adam Poff
`Lead Counsel for Samsung: Phillip Citroen, Soyoung Jung and Allan Soobert
`
`
`
`In addition, the following attorneys participated in a verbal meet and confer by telephone on
`December 13, 2019:
`
`Delaware Counsel for Elm: Michael Farnan
`Lead Counsel for Elm: Nosson Knobloch
`Delaware Counsel for Samsung: Adam Poff
`Lead Counsel for Samsung: Soyoung Jung and Allan Soobert
`
`
`In addition, the following attorneys participated in a verbal meet and confer by telephone on
`December 9, 2019:
`
`Delaware Counsel for Elm: Brian Farnan
`Lead Counsel for Elm: Nosson Knobloch
`Delaware Counsel for Samsung: Adam Poff
`Lead Counsel for Samsung: Soyoung Jung and Phillip Citroen
`
`
`In addition, the following attorneys participated in a verbal meet-and-confer by telephone on
`October 24, 2019:
`
`
`Lead Counsel for Elm: Nosson Knobloch
`Lead Counsel for Samsung: Soyoung Jung and Phillip Citroen
`
`9 1 9 N . M A R K E T S T R E E T , 1 2 T H F L O O R , W I L M I N G T O N , D E 1 9 8 0 1
`P H O N E : ( 3 0 2 ) 7 7 7 – 0 3 0 0 · F A X : ( 3 0 2 ) 7 7 7 – 0 3 0 1 · W W W . F A R N A N L A W . C O M
`
`
`
`Case 1:14-cv-01430-LPS Document 244 Filed 01/31/20 Page 2 of 2 PageID #: 18082
`
`
`
`
`The following attorneys also participated in a verbal meet-and-confer by telephone on September 3,
`2019:
`
`
`Delaware Counsel for Elm: Michael Farnan
`Lead Counsel for Elm: Nosson Knobloch
`Delaware Counsel for Samsung: Adam Poff
`Lead Counsel for Samsung: Soyoung Jung and Phillip Citroen
`
`The above-named attorneys have also exchanged numerous emails and letters addressing these
`issues.
`
`There are three disputes requiring judicial attention:
`
`
`1. Samsung’s November 15, 2019 Objections and Responses to Elm’s Third Set of
`Common Interrogatories, and Elm’s efforts to obtain discovery about Samsung’s US
`and worldwide revenue.
`
`2. Samsung’s December 5, 2019 Objections and Responses to Elm’s Fourth Set of
`Interrogatories to Samsung, and Elm’s efforts to obtain discovery about Samsung’s
`revenue for components manufactured in or supplied from the United States.
`
`3. Whether issues 1 and 2 are mooted by Samsung’s commitment to produce the data
`and information responsive to them by no later than February 14.
`
`
`
`
`
`Counsel of Record (via E-File)
`
`
`cc:
`
`
`
`Respectfully submitted,
`
`/s/ Brian E. Farnan
`
`Brian E. Farnan
`
`2
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
