`Case 6:20-cv-01215-ADA Document 56-5 Filed 02/16/22 Page 1 of 2
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`EXHIBIT D
`EXHIBIT D
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`Case 6:20-cv-01215-ADA Document 56-5 Filed 02/16/22 Page 2 of 2
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`Candescent Law Group
`
`1350 OLD BAYSHORE HWY, STE. 520 | BURLINGAME, CA 94010 | +1 925-644-1102
`
`January 21, 2022
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`VIA EMAIL
`
`Peter Mazur
`Devlin Law Firm LLC
`1526 Gilpin Ave.
`Wilmington, DE 19806
`PMazur@devlinlawfirm.com
`
`
`Re: Ocean Semiconductor Litigation Matters
`Purported Subpoenas to United Microelectronics Corporation
`
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`Dear Peter:
`
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`I write in response to your January 19, 2022 email to me. Your email attached purported
`FedEx delivery receipts and subpoenas to United Microelectronics Corporation (“UMC”). The
`delivery receipts appear to indicate that Ocean attempted to serve these subpoenas by mailing
`them via FedEx directly from your firm to UMC’s offices in Taipei, Taiwan.
`
`Your attempted service of these subpoenas by FedEx is improper and inconsistent with
`the Federal Rules of Civil Procedure and applicable Taiwan laws. Moreover, I am not
`authorized to accept service of subpoenas on behalf of UMC, and therefore your email to me
`attaching the subpoenas does not constitute effective service. Aside from the lack of effective
`service, UMC is outside the subpoena power of United States courts. Accordingly, UMC is
`under no obligation to respond to these subpoenas, and any response would be entirely voluntary.
`
`As I indicated in my January 12, 2022 email to you, UMC would be willing to discuss
`producing documents responsive to certain document requests in the subpoenas if Ocean is
`willing to significantly narrow the scope of its requests. Please let me know if Ocean would like
`to discuss this matter. I will generally be available either Monday or Tuesday next week.
`
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`Sincerely,
`
`
`
`Robert G. Litts
`
`
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