`
`
`
`
`
`
`Writer’s Direct Dial: 214-785-6683
`Writer’s Email: jperkins@bcpc-law.com
`
`
`Jamie Beaber
`Mayer Brown LLP
`1999 K Street, N.W.
`Washington, D.C. 20006-1101
`jbeaber@mayerbrown.com
`
`Re: Delaware Display Group, LLC and Innovative Display Technologies LLC v. LG
`Electronics, Inc., LG Electronics U.S.A., Inc., LG Display Co., Ltd., and LG Display
`America, Inc.; C.A. No. 1:13-cv-2109-RGA
`
`
`Dear Jamie:
`
`
`Based on the LG defendants’ insufficient document production, Plaintiffs will be moving
`the Court to compel compliance. The parties met and conferred on July 16, and the LG defendants
`promised a production that would address Plaintiffs’ complaints regarding outstanding discovery
`aside from the CAD file issue. As you know, Plaintiffs served their first document requests on
`December 12, 2014; therefore, LG’s document production was due several months ago. The
`identification and collection of the requested information should have, likewise, been completed
`months ago. But last week’s production by the LG defendants did little to advance the ball, and
`provides further proof that the LG defendants intend to drag their feet and slow play discovery
`unless the Court intervenes. This tactic is clear from the recent production where 71 of the 85
`documents collectively produced by the LG defendants were public SEC filings or foreign language
`documents. Many necessary and responsive documents remain outstanding.
`
`
`
`For example, the LG Display defendants have yet to produce financial information, other
`than publically available SEC filings. Further, while some information was produced by the LG
`Electronics defendants for the accused phones and tablets, no information was produced regarding
`other accused products, such as televisions and monitors.
`
`
`
`In addition, the LG defendants have yet to produce a single license agreement. And no
`supplier agreements have been produced for the BLUs or LCMs that the LG defendants do not
`manufacture. These documents were requested in Plaintiffs initial RFPs to the LG defendants, and
`these deficiencies were pointed out in Pat Conroy’s April 3, 2015 letter.
`
`
`
`Accordingly, the parties are at an impasse, and Plaintiffs will be seeking the Court’s
`assistance in bringing the LG defendants into compliance with their discovery obligations.
`
`
`Sincerely,
`
`
`
`James R. Perkins
`
`
`
`
`
`Pretech_000773
`
`K.J. Pretech Ex. 1022
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