IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`LG DISPLAY CO., LTD. AND LG DISPLAY AMERICA, INC.’S
`OBJECTIONS AND RESPONSES TO PLAINTIFFS DELAWARE DISPLAY
`GROUP LLC AND INNOVATIVE DISPLAY TECHNOLOGIES LLC’S
`FOURTH SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
`
`Defendants.
`
`Pursuant to the Federal Rules of Civil Procedure, Defendants LG Display Co., Ltd. and
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`LG Display America, Inc. (collectively, “LG Display” or “Defendants”), through their
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`undersigned counsel, hereby object and respond to Plaintiffs’ Fourth Set of Requests for
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`Production of Documents and Things (“Requests”) served by Plaintiffs Delaware Display Group
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`LLC (“DDG”) and Innovative Display Technologies LLC (“IDT”) (collectively, “Plaintiffs”) on
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`September 21, 2015, as follows.
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`PRELIMINARY STATEMENT
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`These answers are made solely for the purpose of this action. Each answer is
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`1.
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`subject to all objections, as to competence, relevance, materiality, propriety, and admissibility.
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`2.
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`LG Display’s responses are based upon information presently available to and
`
`located by LG Display. LG Display has not completed its investigation of the facts relating to
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`
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` C.A. No. 13-2109-RGA
`
`
`DELAWARE DISPLAY GROUP LLC
`and INNOVATIVE DISPLAY
`TECHNOLOGIES LLC,
`
`Plaintiffs,
`
`v.
`
`
`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC.,
`LG DISPLAY CO., LTD., and
`LG DISPLAY AMERICA, INC.,
`
`
`
`
`
`
`
`Pretech_000781
`
`K.J. Pretech Ex. 1025
`
`
`FOR THE DISTRICT OF DELAWARE
`
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`LG DISPLAY CO., LTD. AND LG DISPLAY AMERICA, INC.’S
`OBJECTIONS AND RESPONSES TO PLAINTIFFS DELAWARE DISPLAY
`GROUP LLC AND INNOVATIVE DISPLAY TECHNOLOGIES LLC’S
`FOURTH SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND THINGS
`
`Defendants.
`
`Pursuant to the Federal Rules of Civil Procedure, Defendants LG Display Co., Ltd. and
`
`LG Display America, Inc. (collectively, “LG Display” or “Defendants”), through their
`
`undersigned counsel, hereby object and respond to Plaintiffs’ Fourth Set of Requests for
`
`Production of Documents and Things (“Requests”) served by Plaintiffs Delaware Display Group
`
`LLC (“DDG”) and Innovative Display Technologies LLC (“IDT”) (collectively, “Plaintiffs”) on
`
`September 21, 2015, as follows.
`
`PRELIMINARY STATEMENT
`
`These answers are made solely for the purpose of this action. Each answer is
`
`1.
`
`subject to all objections, as to competence, relevance, materiality, propriety, and admissibility.
`
`2.
`
`LG Display’s responses are based upon information presently available to and
`
`located by LG Display. LG Display has not completed its investigation of the facts relating to
`
`
`
` C.A. No. 13-2109-RGA
`
`
`DELAWARE DISPLAY GROUP LLC
`and INNOVATIVE DISPLAY
`TECHNOLOGIES LLC,
`
`Plaintiffs,
`
`v.
`
`
`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC.,
`LG DISPLAY CO., LTD., and
`LG DISPLAY AMERICA, INC.,
`
`
`
`
`
`
`
`Pretech_000781
`
`K.J. Pretech Ex. 1025
`
`
`
`this case, discovery in this action, or its preparation for trial. The responses are given without
`
`prejudice to LG Display’s right to produce evidence of any additional facts. As such, these
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`responses are subject to supplementation and amendment as discovery in this case progresses,
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`should future investigation or discovery indicate that supplementation or amendment is
`
`necessary. LG Display reserves the right to make any use of, or introduce at any hearing or trial,
`
`documents that are responsive to these Requests, but discovered subsequent to LG Display’s
`
`service of these responses, including, but not limited to, any documents obtained in discovery
`
`herein.
`
`3.
`
`No incidental or implied admissions are intended by the responses herein. The
`
`fact that LG Display has answered or objected to any Request should not be taken as an
`
`admission that LG Display accepts or admits the existence of any “fact” set forth or assumed by
`
`such Request. That LG Display has answered part or all of any Request is not intended to be,
`
`and shall not be construed to be, a waiver by LG Display of any part of any objection to any
`
`Request.
`
`GENERAL OBJECTIONS
`
`LG Display makes the following numbered general objections to the requests,
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`instructions and definitions set forth in Plaintiffs’ Requests, which objections are incorporated by
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`reference into each and every request response that follows:
`
`1.
`
`LG Display objects to each Request and the Definitions and Instructions to the
`
`extent they seek to impose obligations and duties upon LG Display greater or different than those
`
`requirements mandated by the Federal Rules of Civil Procedure, the Local Rules for the United
`
`States District Court for the District of Delaware, any other applicable local rules, or any order
`
`entered in this case.
`
`
`
`2
`
`Pretech_000782
`
`
`
`2.
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`LG Display objects to each Request to the extent it seeks information, documents,
`
`or things (a) not maintained in the ordinary course of business, and/or (b) the collection or
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`investigation of the documents or things sought by the request would require an unreasonable
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`amount of time and resources.
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`3.
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`LG Display objects to each Request as unduly burdensome to the extent it seeks
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`information, documents, or things that (a) are not in LG Display’s possession, custody, or control
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`as those terms are defined in Federal Rule of Civil Procedure 34 and/or (b) are as easily available
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`to Plaintiffs as to LG Display.
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`4.
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`LG Display objects to each Request to the extent it seeks discovery regarding
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`events transpiring after the filing date of the suit. Without waiving this objection, LG Display
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`may provide discovery regarding events after the date of the filing of this suit or any applicable
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`counterclaim. LG Display will also consider, on a case-by-case basis, specific supplemental
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`discovery regarding events transpiring after the date of such filing.
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`5.
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`LG Display objects to each Request to the extent it seeks confidential or
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`proprietary information, documents, or things pertaining to LG Display’s business, technology
`
`and/or economic relationships. LG Display will only produce or provide such responsive
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`information, documents or things pursuant to protective order and upon receipt of permission
`
`from third parties, if necessary.
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`6.
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`LG Display objects to each Request to the extent it seeks information, documents,
`
`or things protected from disclosure by the attorney-client privilege, the attorney work product
`
`doctrine, the joint defense or common-interest privilege, or by any other privilege or immunity
`
`under federal or state statutory, constitutional or common law. The inadvertent production of
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`any information or documents that contain information that is privileged, were prepared in
`
`
`
`3
`
`Pretech_000783
`
`
`
`anticipation of litigation or for trial, or that are otherwise protected from discovery, shall not
`
`constitute a waiver of any privilege or any ground for objection to discovery with respect to such
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`information or documents, or the subject matter thereof, or of the right of LG Display to object to
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`the use of any such document or information during any subsequent proceeding, hearing, or trial.
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`LG Display will produce a privilege log of any responsive, privileged documents withheld from
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`production, if any, subject to the reservation that work product and attorney-client privileged
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`documents generated after the filing date of the instant action need not be identified on the
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`privilege log.
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`7.
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`LG Display objects to the extent that each Request is not limited by a reasonable
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`or relevant time period, except to the extent it bears on invalidity, and consequently is overbroad,
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`unduly burdensome, and/or not relevant to a claim or defense of a party and not reasonably
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`calculated to lead to the discovery of admissible evidence.
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`8.
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`LG Display objects to each Request as being overly broad and unduly
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`burdensome to the extent it requires LG Display to provide any information, documents or things
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`beyond what LG Display is able to locate from a reasonable search of its files.
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`9.
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`LG Display objects to each Request to the extent it seeks legal contentions, calls
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`for a legal conclusion, and/or seeks information before the Court has construed the claims or
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`before the time specified and agreed to by the parties for such disclosure and as set forth in any
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`scheduling order entered in this case, and/or a time otherwise agreed to by the parties or
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`established by the Court for such disclosure.
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`10.
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`LG Display objects to any Request to the extent it improperly seeks to obtain
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`expert opinions prior to the period for expert discovery or improperly seeks anything other than
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`LG Display’s present contentions.
`
`
`
`4
`
`Pretech_000784
`
`
`
`11.
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`LG Display’s response to each Request is hereby made without waiver of, and
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`with the intentional preservation of:
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`a) all questions as to the competence, relevance, materiality, privilege,
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`confidentiality, authenticity and admissibility as evidence for any purpose of
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`the information or documents, or the subject matter thereof, in any aspect of
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`this or any other court action or judicial or administrative proceeding or
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`investigation;
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`b) the right to object on any ground to the use of any such information or
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`documents, or the subject matter thereof, in any aspect of this or any other
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`court action or judicial or administrative proceeding or investigation;
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`c) the right to object at any time for any further response to this or any other
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`request for information or production of documents including all objections as
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`to burdensomeness, vagueness, overbreadth and ambiguity;
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`d) the right to object on any ground to any further requests involving or relating
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`to any of the paragraphs in these discovery requests; and
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`e) the right at any time to revise, correct, supplement or clarify the responses and
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`objections propounded herein.
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`12.
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`Production of documents or information responsive to any request should not be
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`construed as:
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`a) an admission or stipulation that the documents or their content or subject
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`matter are properly discoverable or relevant;
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`b) a waiver by LG Display of its General Objections or of the specific objections
`
`asserted in response to a specific request; or
`
`
`
`5
`
`Pretech_000785
`
`
`
`c) an agreement that requests for similar information will be treated in a similar
`
`manner.
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`13.
`
`LG Display objects to each request to the extent it seeks “all” subject matter, such
`
`as e.g., “all documents,” as overbroad and unduly burdensome. “All” shall be understood to
`
`mean the information, documents or things that LG Display is able to locate using reasonable
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`diligence and judgment concerning the whereabouts of responsive information and documents.
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`Such phraseology should not be construed as a representation that each and every piece of
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`information, documents or things in the possession of LG Display has been examined in
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`connection with these responses or any production pursuant thereto.
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`14.
`
`LG Display objects to the definition of the term “LGD” as overly broad, vague,
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`ambiguous and unduly burdensome and seeking to obtain information protected by attorney-
`
`client privilege, the work-product immunity doctrine, the joint defense or common-interest
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`privilege, or by any other privilege or immunity under federal or state statutory, constitutional or
`
`common law, with its use of, without limitation, the terms “predecessors, successors, assigns,
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`agents, employees, officers, directors, affiliates, partners, subsidiaries, parent corporations,
`
`investors, attorneys, or other persons or entities acting on its behalf.” In responding to each
`
`Request, LG Display will provide information, documents, or things as they pertain to LG
`
`Display Co., Ltd. and/or LG Display America, Inc. Moreover, LG Display states that the
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`production of information, documents, or things by LG Display Co., Ltd. in response to the
`
`Requests does not necessarily mean that such information, documents, or things are also within
`
`the possession, custody, or control of LG Display America, Inc.
`
`15.
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`LG Display objects to the definition of the term “LGE” as overly broad, vague,
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`ambiguous and unduly burdensome and seeking to obtain information protected by attorney-
`
`
`
`6
`
`Pretech_000786
`
`
`
`client privilege, the work-product immunity doctrine, the joint defense or common-interest
`
`privilege, or by any other privilege or immunity under federal or state statutory, constitutional or
`
`common law, with its use of, without limitation, the terms “predecessors, successors, assigns,
`
`agents, employees, officers, directors, affiliates, partners, subsidiaries, parent corporations,
`
`investors, attorneys, or other persons or entities acting on its behalf.”
`
`16.
`
`LG Display objects to the definition of the term “KJ PRETECH” as overly broad,
`
`vague, ambiguous and unduly burdensome and seeking to obtain information protected by
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`attorney-client privilege, the work-product immunity doctrine, the joint defense or common-
`
`interest privilege, or by any other privilege or immunity under federal or state statutory,
`
`constitutional or common law, with its use of, without limitation, the terms “predecessors,
`
`successors, assigns, agents, employees, officers, directors, affiliates, partners, subsidiaries, parent
`
`corporations, investors, attorneys, or other persons or entities acting on its behalf.”
`
`17.
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`LG Display objects to the definition of the terms “DOCUMENT” and “THING”
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`to the extent they seek to impose requirements and obligations on LG Display differing from or
`
`exceeding those set forth in Federal Rules of Civil Procedure or the Local Rules for the United
`
`States District Court for the District of Delaware, and/or any order entered in this case.
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`18.
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`LG Display objects to the use of the terms “PERSON” and “PERSONS” to the
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`extent that the terms are undefined. In responding to Plaintiffs’ Requests, the term
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`“PERSON(S)” will be given its ordinary and customary meanings. LG Display also objects to
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`these definitions to the extent it refers to any individuals or entities that are not known to LG
`
`Display.
`
`19.
`
`LG Display incorporates by reference the General Objections set forth above in
`
`the specific objections and responses set forth below. LG Display may repeat a General
`
`
`
`7
`
`Pretech_000787
`
`
`
`Objection for emphasis or some other reason. The failure to repeat any General Objection does
`
`not waive any General Objection to the Request. LG Display reserves its right to amend its
`
`General Objections, any specific objection or response.
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`DOCUMENT REQUESTS
`
`REQUEST FOR PRODUCTION NO. 55:
`
`
`
`All documents that are the basis of LGD’s contentions in its financial statements that
`
`LGE has significant influence over LGD’s management and affairs.
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 55:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects to this Request to the
`
`extent it is vague, ambiguous, or subject to varying interpretation. LG Display further objects
`
`that the documents and information sought by this Request are outside the possession, custody,
`
`or control of LG Display and may be more readily obtained from other sources. LG Display
`
`further objects to this Request as overly broad, unduly burdensome, and neither relevant nor
`
`reasonably calculated to lead to the discovery of admissible evidence.
`
`
`
`8
`
`Pretech_000788
`
`
`
`REQUEST FOR PRODUCTION NO. 56:
`
`
`
`If LGD contends that it has a common interest with LG Corporation with respect to this
`
`Litigation, all documents supporting that contention.
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 56:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects to this Request to the
`
`extent that it seeks a legal conclusion and/or presents a question of law. LG Display further
`
`objects to this Request to the extent it is vague, ambiguous, or subject to varying interpretation.
`
`LG Display further objects that the documents and information sought by this Request are
`
`outside the possession, custody, or control of LG Display and may be more readily obtained
`
`from other sources. LG further objects to this Request as overly broad, unduly burdensome, and
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`neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
`
`REQUEST FOR PRODUCTION NO. 57:
`
`
`
`If LGD contends that it has a common interest with LGE with respect to this Litigation,
`
`all documents supporting that contention.
`
`
`
`9
`
`Pretech_000789
`
`
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 57:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects to this Request to the
`
`extent that it seeks a legal conclusion and/or presents a question of law. LG Display further
`
`objects to this Request to the extent it is vague, ambiguous, or subject to varying interpretation.
`
`LG Display further objects that the documents and information sought by this Request are
`
`outside the possession, custody, or control of LG Display and may be more readily obtained
`
`from other sources.
`
`
`
`Subject to and without waiving the foregoing general and specific objections, to the
`
`extent LG Display understands this Request and based on its current knowledge, LG Display
`
`responds as follows: LG Display does not have any relevant, non-privileged documents to
`
`produce in response to this Request.
`
`REQUEST FOR PRODUCTION NO. 58:
`
`
`
`All documents relating to this Litigation that LGD has shared with LG Corporation.
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 58:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`
`
`10
`
`Pretech_000790
`
`
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects that the documents and
`
`information sought by this Request are outside the possession, custody, or control of LG Display
`
`and may be more readily obtained from other sources. LG Display further objects to this
`
`Request as overly broad, unduly burdensome, and neither relevant nor reasonably calculated to
`
`lead to the discovery of admissible evidence.
`
`REQUEST FOR PRODUCTION NO. 59:
`
`
`
`All documents relating to LGD’s fee arrangement with its lawyers in this Litigation.
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 59:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects to this Request as overly
`
`broad, unduly burdensome, and neither relevant nor reasonably calculated to lead to the
`
`discovery of admissible evidence.
`
`
`
`11
`
`Pretech_000791
`
`
`
`REQUEST FOR PRODUCTION NO. 60:
`
`
`
`All documents relating to attorneys’ fees or filing fees associated with the inter partes
`
`review proceedings relating to any and all of the Asserted Patents, including documents
`
`sufficient to identify which party is paying those fees.
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 60:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects to this Request to the
`
`extent it is vague, ambiguous, or subject to varying interpretation. LG Display further objects
`
`that the documents and information sought by this Request are outside the possession, custody,
`
`or control of LG Display and may be more readily obtained from other sources. LG Display
`
`further objects to this Request as overly broad, unduly burdensome, and neither relevant nor
`
`reasonably calculated to lead to the discovery of admissible evidence.
`
`REQUEST FOR PRODUCTION NO. 61:
`
`
`
`All documents relating to communications between KJ Pretech and LGD, concerning any
`
`litigation of the Asserted Patents or any inter partes review proceedings relating to any of the
`
`Asserted Patents.
`
`
`
`12
`
`Pretech_000792
`
`
`
`RESPONSE TO REQUEST FOR PRODUCTION NO. 61:
`
`
`
`LG Display incorporates herein its Preliminary Statement and General Objections set
`
`forth above. LG Display objects to this Request to the extent that it seeks to elicit information or
`
`obtain documents subject to and protected by the attorney-client privilege, the attorney work-
`
`product doctrine, the joint defense privilege, the common interest doctrine, and/or any other
`
`applicable privilege or immunity. LG Display objects to this Request to the extent that it seeks
`
`documents that are premature and contrary to the procedure set forth in the Federal Rules of
`
`Civil Procedure, the Local Rules for the United States District Court for the District of Delaware,
`
`or any scheduling order entered in this case. LG Display further objects to this Request to the
`
`extent it is vague, ambiguous, or subject to varying interpretation. LG Display further objects
`
`that the documents and information sought by this Request are outside the possession, custody,
`
`or control of LG Display and may be more readily obtained from other sources. LG Display
`
`further objects to this Request as overly broad, unduly burdensome, and neither relevant nor
`
`reasonably calculated to lead to the discovery of admissible evidence.
`
`
`
`Subject to and without waiving the foregoing general and specific objections, to the
`
`extent LG Display understands this Request and based on its current knowledge, LG Display
`
`responds as follows: LG Display does not have any relevant, non-privileged documents to
`
`produce in response to this Request.
`
`
`
`13
`
`Pretech_000793
`
`
`
`Respectfully submitted,
`
`
`
`ROSS ARONSTAM & MORITZ LLP
`
` /s/ Benjamin J. Schladweiler
`David E. Ross (#5228)
`Benjamin J. Schladweiler (#4601)
`100 S. West Street, Suite 400
`Wilmington, DE 19801
`(302) 576-1600
`dross@ramllp.com
`bschladweiler@ramllp.com
`
`Counsel for Defendants LG Display Co., Ltd.
`and LG Display America, Inc.
`
`
`
`
`
`Of Counsel:
`
`Jamie B. Beaber
`Kfir B. Levy
`Baldine B. Paul
`Anita Y. Lam
`Alison T. Gelsleichter
`Tiffany A. Miller
`MAYER BROWN LLP
`1999 K Street NW
`Washington, D.C. 60606
`(202) 263-3000
`jbeaber@mayerbrown.com
`klevy@mayerbrown.com
`bpaul@mayerbrown.com
`alam@mayerbrown.com
`agelsleichter@mayerbrown.com
`tmiller@mayerbrown.com
`
`Robert G. Pluta
`Amanda K. Streff
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`(312) 701-8641
`rpluta@mayerbrown.com
`astreff@mayerbrown.com
`
`
`
`Dated: October 21, 2015
`
`
`
`14
`
`Pretech_000794
`
`
`
`CERTIFICATE OF SERVICE
`
`I, Benjamin J. Schladweiler, hereby certify that on October 21, 2015, I caused the
`
`
`
`foregoing LG Display Co., Ltd. and LG Display America, Inc.’s Objections and Responses to
`
`Plaintiffs Delaware Display Group LLC and Innovative Display Technologies LLC’s Fourth
`
`Set of Requests for Production of Documents and Things to be served as indicated upon the
`
`Jeffrey R. Bragalone
`Patrick J. Conroy
`Justin B. Kimble
`Daniel F. Olejko
`T. William Kennedy, Jr.
`BRAGALONE CONROY P.C.
`Chase Tower
`2200 Ross Avenue, Suite 4500W
`Dallas, TX 75201
`jbragalone@bcpc-law.com
`pconroy@bcpc-law.com
`jkimble@bcpc-law.com
`dolejko@bcpc-law.com
`bkennedy@bcpc-law.com
`
`Counsel for Plaintiffs Delaware
`Display Group LLC and Innovative
`Display Technologies LLC
`
` /s/ Benjamin J. Schladweiler
`Benjamin J. Schladweiler (#4601)
`
`
`
`
`
`following counsel of record:
`
`Joseph J. Farnan, Jr.
`Brian E. Farnan
`Michael J. Farnan
`FARNAN LLP
`919 North Market Street
`12th Floor
`Wilmington, DE 19801
`farnan@farnanlaw.com
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Counsel for Plaintiffs Delaware
`Display Group LLC and Innovative
`Display Technologies LLC
`
`
`
`
`
`
`
`Pretech_000795
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