`
`
`
`
`
`
`
`January 26, 2022
`
`
`BY ELECTRONIC FILING
`
`The Honorable Jennifer L. Hall
`United States District Court, District of Delaware
`844 N. King Street
`Wilmington, DE 19801-3568
`
`Adam W. Poff
`P 302.571.6642
`F 302.576.3326
`apoff@ycst.com
`
`
`
`Re:
`
`ELM 3DS Innovations, LLC v. Samsung Electronics Co., Ltd., et al.,
`C.A. No. 14-1430-LPS-JLH
`
`Dear Judge Hall:
`
`Samsung respectfully requests clarification regarding the Court’s January 13, 2022 Oral
`Order in Elm 3DS Innovations, LLC v. Samsung Electronics Co., Ltd., et al. D.I. 459. In that
`order, the Court denied Samsung’s request to compel production of two amendments to the
`Engagement Agreement and granted-in-part Samsung’s request to compel production of the Term
`Sheet by ordering production of a redacted version. Id.
`
`Samsung seeks clarification on this order because Samsung’s discovery dispute letter brief
`sought both the Term Sheet, as well as any other related documents affecting Ron Epstein’s
`compensation. See D.I. 449 at 2–3. The Court addressed and ordered production of a redacted
`version of the Term Sheet, but the Court’s order did not address other related documents.
`Samsung, therefore, respectfully requests clarification on the scope of the Court’s order regarding
`production by Elm of other related documents affecting Ron Epstein’s compensation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Adam W. Poff
`
`Adam W. Poff (No. 5199)
`
`Counsel of Record (via E-Filing and E-Mail)
`Clerk of the Court (via Hand Delivery)
`
`
`
`
`
`
`
`
`
`cc:
`
`
`
`
`
`
`