`Sent:
`To:
`Cc:
`
`Subject:
`
`Philip,
`
`Lee, Joseph (OC)
`Monday, November 02, 2020 3:24 PM
`Philip Wang
`Tzeng, Lin (Bay Area); jdavid@lernerdavid.com; rroeser@haltomdoan.com; Jennifer
`Doan; vsharma@lernerdavid.com; ggewirtz@lernerdavid.com; #C-M LGD SOLAS - LW
`TEAM; Josh Thane; Cole Riddell; Davis, Blake (Bay Area); solas@raklaw.com
`RE: Solas OLED Ltd. v. LG Display Co., Ltd. et al.
`
`I still have not received a response to my email below. Please let us know by COB today whether Solas will agree to
`Defendants’ proposal. If not, please let us know when you are available for a meet and confer tomorrow. Thanks.
`
`Joe
`
`From: Lee, Joseph (OC)
`Sent: Thursday, October 29, 2020 6:10 PM
`To: 'Philip Wang' <pwang@raklaw.com>
`Cc: Tzeng, Lin (Bay Area) <Linfong.Tzeng@lw.com>; jdavid@lernerdavid.com; rroeser@haltomdoan.com; Jennifer Doan
`<jdoan@haltomdoan.com>; vsharma@lernerdavid.com; ggewirtz@lernerdavid.com; #C-M LGD SOLAS - LW TEAM
`<LGDSOLAS.LWTEAM@lw.com>; Josh Thane <jthane@haltomdoan.com>; Cole Riddell <criddell@haltomdoan.com>;
`Davis, Blake (Bay Area) <Blake.Davis@lw.com>; solas@raklaw.com
`Subject: RE: Solas OLED Ltd. v. LG Display Co., Ltd. et al.
`
`Philip,
`
`While Defendants disagree with Solas’s characterization of Defendants’ invalidity contentions, in an effort at
`compromise, Defendants are willing to identify no more than 15 references on which Solas will need to provide a more
`detailed response to Defendants’ interrogatory no. 14 if Solas will commit to providing such a response by November
`6th. Note that this identification of references is done only for purposes of Solas’s supplementation of interrogatory no.
`14 and otherwise has no binding effect on Defendants. Please confirm whether Solas will agree to commit to
`supplementation and we can send you the list of references to focus on for the supplementation. If not, please let me
`know if Solas is available tomorrow (October 30th) for a meet and confer regarding the issue.
`
`Joe
`
`From: Philip Wang <pwang@raklaw.com>
`Sent: Wednesday, October 28, 2020 6:48 PM
`To: Lee, Joseph (OC) <Joseph.Lee@lw.com>
`Cc: Tzeng, Lin (Bay Area) <Linfong.Tzeng@lw.com>; jdavid@lernerdavid.com; rroeser@haltomdoan.com; Jennifer Doan
`<jdoan@haltomdoan.com>; vsharma@lernerdavid.com; ggewirtz@lernerdavid.com; #C-M LGD SOLAS - LW TEAM
`<LGDSOLAS.LWTEAM@lw.com>; Josh Thane <jthane@haltomdoan.com>; Cole Riddell <criddell@haltomdoan.com>;
`Davis, Blake (Bay Area) <Blake.Davis@lw.com>; solas@raklaw.com
`Subject: Re: Solas OLED Ltd. v. LG Display Co., Ltd. et al.
`
`Joe,
`
`1
`
`LG Display
`Exhibit 1032
`LG Display v. Solas
`IPR2020-01238
`
`Ex. 1032-001
`
`
`
`Thanks for your email. Solas reserves the right to supplement its rog responses during discovery, esp. as new
`information/discovery is provided. As to Defendants’ rog 14 on validity, we think it prematurely calls for expert
`opinions. It’s also overbroad and unduly burdensome, as Defendants’ invalidity contentions are vague and
`ambiguous and purport to assert an unbounded number of references/combinations. If you’re willing to
`appropriately narrow the scope of this request, we can consider further.
`
`Philip
`
`Philip Wang
`Russ August & Kabat
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`310 826-7474
`pwang@raklaw.com
`
`On Oct 27, 2020, at 8:32 PM, Joseph.Lee@lw.com wrote:
`
`Philip,
`
`On our October 21st call, Solas told us it would get back to us by October 26th regarding supplementing
`its interrogatories, including in particular interrogatory no. 14 asking for the bases for Solas’s contention
`that the asserted patents are valid. As explained a number of times, including in my email below, Solas’s
`responses are insufficient and need to be supplemented. The only supplemental interrogatory response
`Solas has served since that meeting was to interrogatory no. 9 and does not address the deficiencies
`previously raised. Please confirm that Solas will supplement its responses by noon Pacific tomorrow.
`Otherwise, we understand from Solas’s lack of supplementation that the parties are at an impasse.
`
`Joe
`
`2
`
`Ex. 1032-002
`
`
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