`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MINNESOTA
`
`In re Chien-Min Sung Subpoena Upon
`3M Company
`
`C.A. No. 23-mc-00104-JFD
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`RESPONDENT CHIEN-MIN SUNG’S CROSS MOTION TO COMPEL
`AND FOR SANCTIONS
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`Pursuant to Rules 37 and 45 of the Federal Rules of Civil Procedure, Respondent
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`Dr. Chien-Min Sung (“Dr. Sung”) hereby moves the Court to compel Movant 3M
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`Company (“3M”) to produce documents and testimony responsive to the subpoena issued
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`to 3M in Chien-Min Sung v. Texas Instruments, Inc., No. 4:23-cv-753-SDJ, pending in
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`the U.S. District Court for the Eastern District of Texas. Dr. Sung also moves the Court
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`to award him all reasonable expenses, including attorney’s fees and costs, incurred by Dr.
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`Sung in opposing 3M’s Motion to Quash improperly filed in this District. Dr. Sung’s
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`Cross-Motion relies on the accompanying Memorandum of Law.
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`1
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`IPR2024-00534
`Samsung Electronics Co. Ltd. et al v. Chien-Min Sung
`Samsung's Exhibit 1040
`Ex. 1040, Page 1
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`
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`CASE 0:23-mc-00104-JFD Doc. 15 Filed 11/22/23 Page 2 of 2
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`Dated: November 22, 2023
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`
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`s/ Jessica M. A. Thomas
`David R. Fairbairn (No. 28,125)
`Jessica M. A. Thomas (No. 395,245)
`KINNEY & LANGE, P.A.
`333 S. 7th Street, Suite 2700
`Minneapolis, MN 55402-2438
`Email: drfairbairn@kinney.com
` jthomas@kinney.com
`Telephone: (612) 339-1863
`Facsimile: (612) 339-6580
`
`Alex Chan (to be admitted pro hac vice)
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`achan@devlinlawfirm.com
`
`Attorneys for Respondent
`CHIEN-MIN SUNG
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`2
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`EX1040, Page 2
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