UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, DC
`
`Before the Honorable Carl C. Charneski
`
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN DIGITAL TELEVISION PRODUCTS
`AND CERTAIN PRODUCTS CONTAINING
`
`SAME AND METHODS OF USING SAME
`
`\é'\é’&/*—/g/“QM
`
`Investigation N0- 337-TA~617
`
`RESPONDENTS’ OPPOSITION TO COMPLAINANTS’ MOTION IN LIMINE TO
`PRECLUDE RESPONDENTS’ USE OF DOCUMENTS
`
`AND TESTIMONY OF MARK EYER
`
`Respondents, as listed on the signature page, oppose the Motion In Limine of
`
`Complainants to Preclude Respondents’ Use of Documents and Testimony of Mark Eyer.
`
`I.
`
`INTRODUCTION
`
`Mark Eyer is a third-party witness who may be a co—inventor of the ‘074 patent. He
`
`produced documents in a relatively short time period and was questioned at his deposition with
`
`respect to all documents he produced. Importantly, Complainants’ expert, Dr. V. Michael Bove,
`
`Jr., relied on Eyer’s deposition testimony in his own July 10 supplemental report and
`
`Complainants did not object to the majority of Eyer’s documents when they filed objections to
`
`Respondents’ exhibits. Now, after Staff filed its pre—hearing brief indicating that it was a “close
`
`question” as to whether Eyer is a co—inventor of the ‘074 patent, Complainants belatedly seek to
`
`exclude all documents produced by Eyer, all Eyer testimony, and all testimony based upon
`
`

`
`Eyer’s documents or testimony. Complainants’ motion in Zimine lacks a factual basis, is
`
`overbroad, and should be denied.
`
`II.
`
`ARGUMENT
`
`A. Respondents’ counsel acted appropriately at Eyer’s deposition.
`
`Third-party Mark Eyer is designated to testify as a fact witness regarding his work at the
`
`Advanced Television Systems Committee (“ATSC”) and the development of ATSC standards.
`
`Complainants’ subpoena ad festificandum requested that Eyer present himself for a deposition
`
`“concerning the subject matter set forth in Attachment B” of the subpoena. See Declaration of
`
`Brian Koo in Support of Respondents’ Opposition to Complainants’ Motion In Limine to
`
`Preclude Respondents’ Use of Documents and Testimony of Mark Eyer, Exhibit A. With the
`
`permission of the Court, Eyer’s deposition took place on July 7, beginning at 9:00 a.m. and
`
`ending at 4:30 p.m., when Funai concluded the deposition. Complainants’ seek to exclude
`
`Eyer’s testimony by claiming deposition misconduct by Respondents’ counsel. These
`
`accusations are without merit.
`
`First, Eyer had not seen the ‘074 patent~at-issue in this Investigation before
`
`Complainants’ counsel showed the ‘O74 patent to him at his deposition. Complainants’ counsel
`
`then asked Eyer, without permitting him to read the patent or its prosecution history, whether he
`
`believed he was an inventor of claim 6 of the ‘074 patent.’ Eyer was directed by Respondents’
`
`counsel not to answer the question with the following explanation:
`
`[Complainants’ counsel is] using the words of the patent, and [Mr. Eyer is] not
`going to answer the question unless you give him an opportunity to review the
`patent and the prosecution history. If you would like to ask him how the two-part
`charmel number evolve -- or evolved in the ATSC standard, he would he happy to
`
`1 Claim 6 of the ‘O74 patent reads: “Apparatus according to claim 1, wherein said channel map
`information further associates said packet identifiers with first and second indentification
`numbers used in conjunction to identify said broadcast channel.”
`
`

`
`answer as a percipient witness and give you the facts of how that concept ended
`up in the A/65 standard.
`
`Funai Br., Ex. A, at 56:11-57:25. In short, Eyer is a lay witness who was neither prepared to nor
`
`given notice in the subpoena that he would be asked to opine on ultimate legal issues, such as
`
`claim construction or inventorship, especially with respect to a patent that he had never before
`
`seen until just moments before the question was asked. Complainants’ counsel’s attempt to elicit
`
`expert testimony from a lay witness such as Eyer was improper and Respondents’ counsel’s
`
`instruction “not to answer” was appropriate.
`
`Second, the topics listed on Attachment B to Complainants’ subpoena ad testificandum
`
`did not cover testimony regarding an earlier Eyer patent, U.S. Patent No. 5,982,411? Eyer
`
`testified that he had never studied the ‘411 patent in detail and that he last saw a draft of it when
`
`he was working at General Instrument, “so it’s been a long time since I’ve seen it.” Funai Br.,
`
`Ex. A at 138:] 1-139:1. Because the deposition subpoena did not cover the ‘411 patent and
`
`because Respondents’ counsel affirmatively told Complainants’ counsel that Eyer was not going
`
`to testify at trial regarding the ‘411 patent, he was directed not to answer further questions
`
`regarding that patent. Funai Br., Ex. A at 142:21—l44:1 and 145:5—10. Again, Complainants’
`
`counsel’s attempt to obtain expert opinion testimony from a lay witness such as Eyer was
`
`improper and Respondents’ counsel’s instruction “not to answer” was appropriate.
`
`Moreover, if Complainants’ counsel had wished to pursue questions regarding either the
`
`‘074 or the ‘411 patents, he could have contacted the Administrative Law Judge, pursuant to
`
`Ground Rule 2(u) which provides:
`
`If a witness testifying at a deposition is instructed by his attorney not to answer a
`question (on any basis other than a claim of privilege), and the question is not
`
`2 The ‘411 patent is addressed by Respondents’ expert, Anthony Wechselberger, in his expert
`report and deposition testimony.
`
`

`
`withdrawn, the parties shall contact the Administrative Law Judge by telephone
`so that the matter can be presented to the Administrative Law Judge for an
`immediate ruling.
`
`Complainants’ counsel did not avail himself of this procedure nor did he suggest that it be used.
`
`Additionally, with respect to Eyer being directed not to disclose what was discussed at his
`
`deposition preparation session with Steven Pepe (counsel for Polaroid in this Investigation), this
`
`instruction, too, was appropriate. There is a joint defense agreement to which all Respondents in
`
`this Investigation are a party. Eyer’s discussion with attorney Pepe was privileged because
`
`Sidley Austin’s (“Sidley”) representation of Eyer was pursuant to the joint defense agreement.
`
`Moreover, if on reflection, Complainants actually believed that Respondents’ counsel’s
`
`directions to not answer questions regarding the ‘074 or ‘41l patents or Eyer’s deposition
`
`preparation session were inappropriate, they dbuld have moved to compel responses to questions
`
`concerning these topics, pursuant to 19 C.F.R. § 210.33(a). Instead, Complainants “lay in wait”
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`and now seek the ultimate sanction of total exclusion of the facts surrounding the development of
`
`the ATSC standards and Eyer’s collaboration with the named inventors of the ‘074 patent in
`
`developing them. Such behavior on the part of Complainants should not be countenanced and
`
`their motion to preclude the admission of evidence concerning Eyer’s participation in the ATSC
`
`should be denied.
`
`B. Eyer produced documents in a timely fashion given the fact that he is a third»
`party witness, was preparing for his wedding, and going on his honeymoon
`during the relevant time period.
`
`This issue has been briefed by the parties with respect to Respondents’ request to file the
`
`second supplemental report of their expert, Dr. Jeffrey Krauss, and, for brevity’s sake, will be
`
`addressed in summary fashion. The timeline is as follows:
`
`June 16
`
`Agreement that Sidley will represent Eyer at his deposition and at the
`Hearing.
`
`

`
`June 22
`
`Eyer is married and leaves for his honeymoon.
`
`July 2
`
`July 3
`
`July 4
`
`July 6
`
`Eyer returns from his honeymoon and Sidley reminds him of the need to
`produce responsive documents.
`
`Eyer emails to Sidley two documents, a list of publicly available ATSC
`documents, and a list of nine documents that he will be producing. Sidley
`emails to Complainants the two documents, the list of ATSC documents,
`and the list of nine documents to be produced.
`
`Eyer emails to Sidley two General Instrument documents, that are marked
`confidential, and expresses concern that they should not be produced until
`the agreement with Sidley is amended to cover document production.
`
`Sidley meets with Eyer, amends the agreement as requested, reviews
`documents on Eyer’s computer and hand-delivers documents responsive to
`the subpoena to Complainants’ counsel in Seattle, including the two
`confidential General Instrument documents that were in Eyer’s possession.
`
`The following day, July 7, Eyer’s deposition was taken. Complainants’ counsel asked
`
`questions regarding all documents produced the previous day. The questions included those
`
`regarding the two confidential General Instrument documents and filled approximately 20 pages
`
`of the deposition transcript. It should be noted that taking depositions with recently produced
`
`documents is something that unfortunately occurs at times. For example, in this Investigation,
`
`during the deposition of Hideo Saito, Funai Electric Company’s 30(b)(6) witness, Complainants
`
`produced hundreds of pages of responsive documents on topics upon which Saito was to testify
`
`at the lunch break during the middle ofSaito ’s deposition.
`
`On July 10, after taking Eyer’s deposition, Complainants served the supplemental report
`
`of their expert, Dr. Bove, opining that Eyer did not invent the concept described in claim 6 of the
`
`‘D74 patent and citing to the rough transcript of Eyer’s deposition.3 On July 14, Respondents
`
`filed a motion for leave to file a second supplemental expert report of Dr. Krauss to (1) address
`
`3 Complainants did not request leave to file Dr. Bove’s supplemental report.
`
`

`
`new information obtained from Eyer’s documents and deposition testimony and (2) rebut Dr.
`
`Bove’s supplemental report.
`
`On July 21, the Staff served its pre-hearing brief indicating that it is a “close question” as
`
`to whether Eyer is a co-inventor of the ‘O74 patent. Nevertheless, on July 23, the day party
`
`objections to exhibits were due, Complainants did not object to the majority of documents
`
`produced by Eyer. Not until July 24, three days after the Staff filed its pre-hearing brief, did
`
`Complainants oppose the filing of Dr. Krauss’ report that addresses the new information
`
`obtained from Eyer and Dr. Bove’s supplemental report addressing the same. It was then that
`
`Complainants began vehemently complaining that Eyer’s documents were not produced in a
`
`timely fashion.
`
`And now, regardless of the facts that Complainants’ expert relied upon Eyer’s deposition
`
`testimony in his supplemental report and that Complainants failed to object to the majority of
`
`documents produced by Eyer, Complainants file a motion in Zimine to exclude any and all
`
`testimony regarding Eyer. Eyer’s documents and testimony, however, are important in
`
`determining the underlying facts and reaching the proper decision in this Investigation.
`
`Therefore, because Complainants do not demonstrate that they have been unfairly prejudiced in
`
`any way in their motion in limine to preclude the use of Eyer’s documents and testimony, it
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`should be denied.
`
`III.
`
`CONCLUSION
`
`For the foregoing reasons, Respondents respectfully request that the Court deny the
`
`Motion In Limine of Complainants to Preclude Respondents’ Use of Documents and Testimony
`
`of Mark Eyer.
`
`

`
`Date: Aug 6, 2008
`
`Respectfully submitted,
`
`ATTORNEYS FOR VIZIO, INC., AMTRAN TECHNOLOGY CO., LTD.,
`PROVIEW INTERNATIONAL HOLDING, LTD., PROVIEW TECHNOLOGY
`(SHENZHEN) CO., LTD., AND PROVIEW TECHNOLOGY, INC.
`
`By
`
`/J (
`
`/ _
`
`Peter H. Kang
`Georgia K. Van Zanten
`SIDLEY AUSTIN LLP
`555 California Street
`
`San Francisco, California 94104
`Tel: (415) 772-1200
`Fax: (415) 772-7400
`
`Edward G. Poplawski
`Samuel N. Tiu
`Jim 8. Zeng
`SIDLEY AUSTIN LLP
`
`555 West Fifth Street
`Los Angeles, California 90013
`Tel: (213) 896-6000
`Fax: (213) 896-6600
`
`Brian Koo
`
`SIDLEY AUSTIN LLP
`
`1501 K Street, NW
`Washington, DC 20005
`Tel:
`(202) 736-8471
`Fax:
`(202) 736-8711
`
`ATTORNEYS FOR SYNTAX-BRILLIAN CORPORATION
`
`By:
`
`‘/
`
`D5-3171 S ô+n 1
`
`!?/£’./
`
`Rosa S. Jeong
`Philippe M. Bruno
`Mark L. Hogge
`GREENBERG TRAURIG LLP
`
`2101 L Street, NW, Suite 1000
`Washington, DC 20037
`Tel: (202) 331-3100
`Fax: (202) 331-3101
`
`

`
`ATTORNEYS FOR TPV INTERNATIONAL, LTD., TPV INTERNATIONAL (USA),
`INC., TOP VICTORY ELECTRONICS (TAIWAN) CO., LTD., AND ENVISION
`PERIPHERALS, INC.
`
`
`
`Mark A. Samuels
`
`V. James Adduci II
`
`Ryan K. Yagura
`O’1\/IELVENY & MYERS LLP
`400 South Hope Street
`Los Angeles, California 90071
`Tel: (213) 430-6000
`Fax: (213) 430-6407
`
`Sarah E. Hamblin
`ADDUCI MASTRIANI & SCHAUMBERG, LLP
`1200 Seventeenth Street, NW, Fifth Floor
`Washington, DC 20036
`Tel: (202) 467-6300
`Fax; (202) 466~2006
`
`

`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, DC
`
`Before the Honorable Carl C. Charneski
`
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN DIGITAL TELEVISION PRODUCTS
`AND CERTAIN PRODUCTS CONTAINING
`
`SAME AND METHODS OF USING SAME
`
`Q9/‘%/Q/\J‘~J\2
`
`111VeSfigafi0n N0- 337'TA'617
`
`[PROPOSED] ORDER NO. j: DENYING COMPLAINANTS’ MOTION IN
`LIMINE TO PRECLUDE RESPONDENTS’ USE OF DOCUMENTS
`
`AND TESTIMONY OF MARK EYER
`
`Before the Court is the Complainants’ Motion In Limine to Preclude
`
`Respondents’ Use of Documents and Testimony of Mark Eyer. Having considered the
`
`record, the memoranda filed on behalf of Complainant, Respondents, and the Staff; the
`
`documents cited therein; and the applicable law; Complainants’ Motion is hereby
`
`DENIED.
`
`IT IS ORDERED THAT the documents and testimony of Mark Eyer shall not
`
`be precluded from use by the Respondents.
`
`IT IS SO ORDERED.
`
`Dated:
`
`, 2008
`
`By:
`
`Carl C. Charneski
`
`Administrative Law Judge
`
`

`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, DC
`
`Before the Honorable Carl C. Charneski
`
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN DIGITAL TELEVISION PRODUCTS
`
`AND CERTAIN PRODUCTS CONTAINING
`
`SAME AND METHODS OF USING SAME
`
`2/€\./\J"<~2\g/‘s2
`
`Investigation No. 337-TA-617
`
`DECLARATION OF BRIAN KOO IN SUPPORT OF RESPONDENTS’
`
`OPPOSITION TO COMPLAINANTS’ MOTION IN LIMINE TO PRECLUDE
`
`RESPONDENTS’ USE OF DOCUMENTS AND TESTIMONY OF MARK EYER
`
`I, Brian Koo, declare as follows:
`
`1.
`
`I am an attorney at the firm of Sidley Austin LLP, counsel for Respondents
`
`Vizio, Inc., AmTRAN Technology Co., Ltd., Proview International Holdings, Ltd.,
`
`Proview Technology (Shenzhen) Co., Ltd., and Proview Technology, Inc. in this action.
`
`I submit this declaration in support of Respondents’ Opposition to Complainants’ Motion
`
`In Limine to Preclude Respondents’ Use of Documents and Testimony of Mark Eyer.
`
`2.
`
`Attached hereto as Exhibit A is a true, correct, and partial copy of the
`
`subpoena ad test'zficcmdum for Mark Eyer. Only the subpoena ad testificandum and its
`
`Attachment B are included in this Exhibit.
`
`I declare under penalty of perjury under the laws of the United States of America
`
`that the foregoing is true and correct. Executed this sixth day of August 2008 at
`
`Washington, District of Columbia.
`
`

`
`Exhibit A
`
`

`
`UNITED STATES INTERNATIONAL TRADE CONIMISSION
`
`WASHINGTON, DC
`
`Before the Honorable Carl C. Charneski
`
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN DIGITAL TELEVISIONS AND
`
`CERTAIN PRODUCTS CONTAINING SAME
`AND METHODS OF USING SAME
`
`
`Investigation. No. 337-TA—617
`
`SUBPOENA AD TESTIFICAND UM
`
`To: Mark K. Eyer
`14917 NE167 St
`
`Woodinville, WA 98072
`
`nn NOTICE: By authority of section 337 of the Tariff Act of 1930, as amended (19
`
`U.S.C. § 13371), 5 U.S.C. § 556(c)(2), and pursuant to 19 CFR. § 210.32 ofthe Rules of
`
`Practice and Procedure of the United States International Trade Commission, and upon an
`
`application for subpoena made by Complainants Funai Corporation, Inc. and Funai Electric Co.,
`
`Ltd.,
`
`A
`
`YOU ARE HEREBY ORDERED to present yourself for purposes of your deposition
`
`upon oral examination on June 17, 2008 at 9:30 am at the office of Esquire Deposition Services,
`
`Bank of America Tower, 701 Fifth Avenue, Suite 6630, Seattle, WA 98104, or such other date
`
`and time as mutually agreed, concerning the subject matter set forth in Attachment B hereto.
`
`This deposition will be taken before a Notary Public or other person authorized to
`
`administer oaths and will continue from day to day until completed.
`
`

`
`Any motion to “limit or quash this subpoena shall. be filed within 10 days after the receipt
`
`thereof.
`
`IN WITNESS WHEREOF the undersigned of the United States Intemational’
`Trade Commission has hereunto set his hand: and caused the seal of said United
`States Intemationai Trade Commission to bezaffixed at Washington, DC. on this
`day of__W.§`~]n , 2008..
`
`
`
`‘Gar-1' C.-:--Cliarfieski
`Administrative -Law Judge
`United’ States International Trade
`Commission.
`
`

`
`ATTACHMENT B
`
`DEFINITIONS
`
`All term definitions set forth in Complainant Funai Electric Company, _Ltd.’s First Set
`
`of Requests to Respondents for Production of Documents and Things are incorporated herein
`
`by reference.
`
`TOPICS OF DEPOSITION
`
`1.
`
`Any communications with or regarding any Respondent, including, but not
`
`limited to any communications or meetings between You and any Respondent.
`
`2.
`
`3.
`
`4.
`
`Your knowledge of the claims in this Investigation.
`
`Your knowledge and awareness of either or both of the Funai Patents.
`
`Your knowledge concerning any claim by you or Respondents that you
`
`collaborated on the inventions disclosed in the ‘O74 patent.
`
`5.
`
`Your knowledge concerning any claim that you worked with the named inventors
`
`on the ‘G74 patent and were aware of such inventors’ work.
`
`6.
`
`Your knowledge relating to any claim that you contributed to the conception of
`
`the inventions disclosed in the ‘O74 patent.
`
`7.
`
`Your knowledge relating to any claim by you or Respondents that you are a co-
`
`inventor on the ‘074 patent.
`
`8.
`
`Your knowledge relating to any evaluation, investigation, or analysis by You,
`
`consultants or agents concerning, referring or relating to either or both of the Funai Patents or
`
`any foreign counterparts to either or both of the Funai Patents.
`
`9.
`
`Any and all materials prepared for anyone concerning any issue on which you
`
`have been asked to opine related to the Funai patents.
`
`

`
`10.
`
`Any testimony you have been asked to offer or plan to offer at the hearing in this
`
`investigation.
`
`1 1.
`
`Your knowledge concerning any of the affirmative defenses asserted by
`
`Respondents in this investigation, including but not limited to, invalidity, unenforceability, or
`
`non-infringement of the Funai Patents.
`
`12.
`
`13.
`
`Any communications regarding this Investigation.
`
`Any communications that relate to any Respondent product.
`
`14.
`
`Any communications that concern, refer or relate to either or both of the Funai
`
`Patents.
`
`Funai reserves the right to revise the above listed matters prior to the date of the
`
`deposition to include matters regarding documents that are produced by Mark Eyer after the date
`
`of this Notice and prior to the deposition. Funai further reserves the right to reopen the
`
`deposition if documents or information are provided or otherwise identified during or after the
`
`deposition that have not been previously produced to Funai.
`
`

`
`In the matter ofCERTAIN DIGITAL TELEVISION PRODUCTS AND CERTAIN
`PRODUCTS CONTAINING SAME AND METHODS OF USING SAME
`Inv. N0. 337-TA-617
`
`U.S. International Trade Commission
`
`Before the Honorable Carl C. Charneski
`
`CERTIFICATE OF SERVICE
`
`I, Brian Koo, hereby certify that copies of:
`
`(1) RESPONDENTS’ OPPOSITION TO COMPLAINANTS’ MOTION IN LIMINE To PRECLUDE
`RESPONDENTS’ USE OF DOCUMENTS AND TESIMONY OF MARK EYER,
`(2) DECLARATION OF BRIAN KOO IN SUPPORT OF SAID RESPONDENTS’ OPPOSITION, and
`(3) PROPOSED ORDER DENYING COMPLAINANTS’ MOTION IN LIMINE TO PRECLUDE
`RESPONDENTS’ USE OF DOCUMENTS AND TESIMONY OF MARK BYER
`
`were served upon the following parties on this 6th day of August 2008 as indicated:
`
`International Trade Commission
`
`The Honorable Marilyn R. Abbott
`Secretary
`U.S. International Trade Commission
`
`500 E Street, SW, Room 112-A
`Washington, DC 20436
`
`The Honorable Carl C. Charneski
`
`Administrative Law Judge
`U.S. International Trade Commission
`
`500 E Street, SW
`Washington, DC 20436
`
`David 0. Lloyd, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`
`500 E Street, SW, Room 401-I
`Washington, DC 20436
`david.llOyd@us1'tc.gov
`
`By Electronic Filing
`
`2 copies by Hand Delivery
`
`1 copy by Hand Delivery
`
`

`
`Counsel for Comglainants Funai Electric Co, Ltd. and Funai Cor]_)_., Inc.
`
`1 copy by Email and First Class Mail
`
`1 copy by Email
`
`1 copy by Email
`
`1 copy by Email
`
`1 copy by Email
`
`(3. Brian Busey, Esq.
`John L. Kolakowski, Esq.
`Teresa M. Summers, Esq.
`MORRISON & FOERSTER LLP
`
`2000 Pennsylvania Avenue, NW, Suite 5500
`Washington, DC 20006
`gbusey@mOfo.com
`jko1akowski@mofo.com
`tsummers@mofo.com
`
`Harold J. McE1hinny, Esq.
`MORRISON & FOERSTER LLP
`
`425 Market Street
`
`San Francisco, CA 94105
`hmcelhinny@mofo.com
`
`Karl J. Kramer, Esq.
`David M. Alban, Esq.
`MORRISON & FOERSTER LLP
`
`755 Page Mill Road
`Palo Alto, CA 94304
`kkramer mofo.com
`
`da1ban@mofo.com
`
`Mark W. Danis, Esq.
`Louise Stoupe, Esq.
`MORRISON & FOERSTER LLP
`
`Shin Marunouchi Building
`1-5-1 Marunouchi
`
`Chiyoda—ku, Tokyo 100-6529 Japan
`mdanisgagmofocom
`1stoupe@mofO.com
`
`F. David Foster
`James B. Altman
`
`David F. Nickel
`MILLER AND CHEVALIER CHARTERED
`
`655 Fifteenth Street, NW, Suite 900
`Washington, DC 20005
`dfoster@milchev.com
`]'altman@milchev.com
`
`

`
`Counsel for Respondent Syntax—Brillian Corn.
`
`1 copy by Email
`
`Rosa S. Jeong, Esq.
`Philippe M. Bruno, Esq.
`Mark L. Hogge, Esq.
`GREENBERG TRAUIG, LLP
`2101 L Street, NW, Suite 1000
`Washington, DC 20037
`jeongr@gt1aw.com
`bruno
`tlaw.com
`
`ho
`
`em tlaw.com
`
`Counsel for Respondents TPV Technology, Ltd., TPV International {USA}, Inc., To};
`Victogy Electronics (Taiwan) Co., Ltd., & Envision Peripherals, Inc.
`
`Mark A. Samuels, Esq.
`Brian M. Berliner, Esq.
`Ryan K. Yagura, Esq.
`Vision L. Winter, Esq.
`O’M1~:LvENY & MYERS LLP
`
`400 South Hope Street
`Los Angeles, California 90071«2899
`msamuels@omm.com
`bberliner@omm.co1n
`gyagura@o1nm.com
`Vwinter@,orn1n.corn
`
`V. James Adduci II, Esq.
`Sarah E. Hamblin, Esq.
`ADDUCI,1VIASTRIANI& SCHAUMBERG, L.L.P.
`1200 Seventeenth Street, NW, Fifth Floor
`Washington, DC 20036
`adduci@adducci.com
`hamblin@add.uci.com
`
`1 copy by Email
`
`1 copy by Email
`
`/Eiajuu/- M0
`
`Brian Koo