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In re TFT-LCD Antitrust Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO DIVISION)


December 14, 2009

IN RE: TFT-LCD (FLAT PANEL) ANTITRUST LITIGATION

MDL No. 1827

REQUEST FOR INTERNATIONAL

This Document Relates to:

JUDICIAL ASSISTANCE (LETTER ROGATORY) FOR SERVICE ON MITSUI ALL DIRECT PURCHASER ACTIONS & COMPANY (TAIWAN), LIMITED

To the Appropriate Judicial Authority in Taiwan:

The United States District Court for the Northern District of California presents its compliments to the Appropriate Judicial Authority in Taiwan and respectfully requests international judicial assistance to effect service of process in connection with a civil proceeding currently pending before this Court.

directly purchased a Thin Film Transistor-Liquid Crystal Display ("TFT-LCD") Product in the

"TFT-LCD Products" are defined to include both TFT-LCD panels as well as products containing

Plaintiffs allege that, beginning in at least on January 1, 1996, the defendants conspired, combined, and contracted to fix, maintain, and/or stabilize prices for the TFT-LCD

NATURE AND PURPOSE OF THE PROCEEDING

Plaintiffs brought an antitrust class action on behalf of all persons and entities who United States from the named defendants between January 1, 1996 and December 11, 2006.

TFT-LCD panels.

Products that were sold in the United States. Plaintiffs allege that as a result of defendants' conspiracy, plaintiffs paid higher prices for TFT-LCD Products than they would have paid if the conspiracy had not occurred.

decree: that this action may proceed as a class action; that defendants violated Section 1 of the Sherman Act, U.S.C. §1; that plaintiffs and members of the Class shall recover damages 15 sustained by them as provided by federal antitrust laws; that defendants shall be permanently enjoined and restrained from continuing the alleged conspiracy; and that plaintiffs shall recover their costs of this suit.

It has been represented to this Court that defendant Mitsui & Co. (Taiwan), Ltd. is a company organized and existing under the laws of Taiwan, with its principal place of business at:

Plaintiffs pray that the Court enter judgment on their behalf, and that the Court MITSUI & CO. (TAIWAN), LTD. Tunnan Tower 21F No. 97 Tunhua South Rd. Section 2 Taipei City, 106 Taiwan Mitsui & Co. (Taiwan), Ltd. at the above address in the manner prescribed for the service of similar documents under the laws of Taiwan: Summons in a Civil Action; Third Amended Direct

Purchaser Plaintiffs' Consolidated Complaint (with Exhibit A); Standing Order for All Judges of the Northern District of California-Contents of Joint Case Management Statement; this Court's

Re: Cases Designated For Electronic Filing; and the ECF Registration Information Handout.

Co. (Taiwan), Ltd. to execute an affidavit of service as provided by Taiwanese law;

international litigation support firm, the affidavit of service and a copy of the documents which were served.

United States Code, to extend similar assistance to the Tribunals of Taiwan in like cases.

highest consideration.

ASSISTANCE REQUESTED

This Court respectfully requests that the Taiwanese judicial authorities:

1. Cause one copy of the following document to be served upon Defendant Standing Order; this Court's Case Management Conference Order; this Court's Standing Order

2. Cause the person who serves the documents upon an officer of Mitsui &

3. Return through diplomatic channels to Legal Language Services, plaintiffs' The Courts of the United States are authorized by statute, Section 1696, Title 23, This Court extends to the Judicial Authorities of Taiwan the assurances of its

Respectfully Requested, Dated: December _____, 2009

The Honorable Susan Illston District Court Judge, Northern District of California 450 Golden Gate Avenue, Courtroom 10, 19th Floor San Francisco, California 94102

20091214

© 1992-2009 VersusLaw Inc.



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