EXHIBIT A 

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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

UNIVERSAL CONNECTIVITY 

TECHNOLOGIES INC.,

Plaintiff,

v.

LENOVO GROUP LIMITED,

Defendant.

Case No. 2:23-cv-00449-JRG

JURY TRIAL DEMANDED

 

REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE (LETTER ROGATORY) 

TO OBTAIN DOCUMENTS FROM VIA LABS, INC. (TAIWAN)

TO THE APPROPRIATE JUDICIAL AUTHORITY OF TAIWAN:

The United States District Court, Eastern District of Texas, Marshall Division (the 

“Requesting Court”) presents its compliments to the Court of Taiwan, and respectfully requests 

international judicial assistance to compel VIA Labs, Inc. (“VIA”), located at 7F., No. 529-1, 

Zhongzheng Rd., Xindian Dist., New Taipei City 23165, Taiwan, to produce the documents

identified in the Letter Rogatory which is filed herewith as Exhibit A. The requested documents

are to be used in civil actions proceeding before the Requesting Court. The Requesting Court 

requests the assistance described herein as necessary in the interests of justice.

Background

This request is made pursuant to the All Writs Act, 28 U.S.C. § 1651 and 28 U.S.C. § 1781 

(permitting the transmittal of letters rogatory through the district courts and the Department of 

State); and the Law in Supporting Foreign Courts on Consigned Cases and Taiwan Code of Civil 

Procedure. The United States District Court for the Eastern District of Texas, Marshall Division 

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is a competent court of law and equity that properly has jurisdiction over these proceedings.

VIA is a Taiwanese corporation with a principal place of business at 7F., No. 529-1, 

Zhongzheng Rd., Xindian Dist., New Taipei City 23165, Taiwan. VIA conducts its business 

within your jurisdiction. On information and belief, VIA has or is likely to have possession of the 

documents specified in Exhibit A.

The Applicant for this letter is Universal Connectivity Technologies Inc. (“UCT”), which 

is the plaintiff in the above-captioned case, Universal Connectivity Technologies Inc. v. Lenovo 

Group Limited, Case No. 2:23-cv-00449-JRG (the “US Action”).

The production of documents specified in Exhibit A are intended for use at trial or directly 

in the preparation of trial and in the view of this Court will be relevant to claims in the case, 

including UCT’s claims to the allegations of patent infringement. The evidence sought in this 

Request goes to the heart of significant issues of fact and law that will influence the final 

adjudication of claims brought by the Plaintiff.

This request is made with the understanding that it will in no way require any person to 

commit any offense, or to undergo a broader form of inquiry than he or she would if the litigation 

were conducted in a Taiwanese court. This Court lacks authority to compel participation of these 

persons and, such participation being necessary in order that justice be served in the abovecaptioned proceedings, this Court respectfully requests assistance from the courts of Taiwan.

1. SENDER

The Honorable J. Rodney Gilstrap

United States District Court Judge 

United States District Court

Eastern District of Texas, Marshall Division 

100 East Houston Street

Marshall, Texas 75670

United States of America 

Phone: (903) 935-2295

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2. CENTRAL AUTHORITY OF THE REQUESTED STATE

Taiwan Shilin District Court

No. 190, Shihdong Rd., Shihlin District, Taipei City 111035 

Taiwan

3. PERSON TO WHOM THE EXECUTED REQUEST IS TO BE RETURNED

BC LAW GROUP, P.C.

Brett E. Cooper

bcooper@bc-lawgroup.com

Seth R. Hasenour

shasenour@bc-lawgroup.com

Jonathan Yim

jyim@bc-lawgroup.com

Drew B. Hollander

dhollander@bc-lawgroup.com

Ashley M. Ratycz

aratycz@bclgpc.com

200 Madison Avenue, 24th Floor

New York, NY 10016

Telephone: (212) 951-0100

4. SPECIFICATION OF DATE BY WHICH THE REQUESTING 

AUTHORITY REQUIRES RECEIPT OF THE RESPONSE TO THE 

LETTER OF REQUEST

To allow the parties sufficient time to analyze the requested documents for their use at trial 

and in pretrial filings, a response to the Letter Rogatory is requested by one month after the Taiwan 

Shilin District Court issues the Letter Rogatory or as soon thereafter as is reasonably possible, but

no later than January 31, 2025. The close of fact discovery in the U.S. litigation is May 30, 2025.

5. NAMES AND ADDRESSES OF THE PARTIES AND THEIR 

REPRESENTATIVES OF THE CASE (ARTICLE 3(B))

The evidence requested relates to the action Universal Connectivity Technologies Inc. v. 

Lenovo Group Limited, Case No. 2:23-cv-00449-JRG, United States District Court for the Eastern 

District of Texas. The parties and their representatives are listed herein as follows:

Plaintiff: Universal Connectivity Technologies Inc.

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Plaintiff’s Representatives:

BC LAW GROUP, P.C.

Brett E. Cooper

bcooper@bc-lawgroup.com

Seth R. Hasenour

shasenour@bc-lawgroup.com

Jonathan Yim

jyim@bc-lawgroup.com

Drew B. Hollander

dhollander@bc-lawgroup.com

Ashley M. Ratycz

aratycz@bclgpc.com

200 Madison Avenue, 24th Floor

New York, NY 10016

Telephone: (212) 951-0100

Defendant: Lenovo Group Limited

Defendant’s Representatives:

GILLAM & SMITH, LLP

Melissa R. Smith

(Texas State Bar No. 24001351)

303 South Washington Avenue

Marshall, TX 75670

Telephone: 903 934-8450

Facsimile: 903 934-9257

Email: melissa@gillamsmithlaw.com

KILPATRICK TOWNSEND & STOCKTON LLP

Steven D. Moore

Two Embarcadero Center, Suite 1900

San Francisco, CA 94111

Telephone: (415) 576-0200

Facsimile: (415) 576-0300

Email: smoore@ktslaw.com

Russell A. Korn

Joshua H. Lee

Christopher S. Leah

1100 Peachtree Street NE, Suite 2800

Atlanta, GA 30309

Telephone: (404) 815-6500

Facsimile: (404) 815-6555

Email: rkorn@ktslaw.com 

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Email: jlee@ktslaw.com

Email: cleah@ktslaw.com

Kasey E. Koballa

4208 Six Forks Road

Raleigh, NC 27609

Telephone: (919) 420-1700

Facsimile: (919) 420-1800

Email: kkoballa@ktslaw.com

WILLKIE FARR & GALLAGHER LLP

Aliza George Carrano 

DC Bar No. 995661 

acarrano@willkie.com 

Dane Sowers 

TX Bar No. 24126820 

dsowers@willkie.com 

1875 K Street, N.W. 

Washington, DC 20006-1238 

Telephone: (202) 303-1000 

DTO LAW 

Sudip Kundu 

skundu@dtolaw.com 

307 5th Avenue, 12th Floor 

New York, NY 10016 

Telephone: (646) 403-9901 

6. NATURE AND PURPOSE OF THE PROCEEDINGS AND SUMMARY OF 

THE FACTS

UCT filed the U.S. Action on September 28, 2023, alleging that Lenovo infringes U.S.

Patent Nos. 7,154,905 (“the ’905 Patent”), 7,187,307 (“the ’307 Patent”), 7,746,798 (“the ’798 

Patent”), 9,232,265 (“the ’265 Patent”), 8,680,712 (“the ’712 Patent”), 7,856,520 (“the ’520 

Patent”), 7,921,231 (“the ’231 Patent”), and 9,852,103 (“the ’103 Patent”) (collectively, “the 

Asserted Patents”). Specifically, UCT alleges that Lenovo products (computers, monitors, and 

docking stations) that support certain USB, PCIe and DisplayPort standards infringe the patentsin-suit. Dkt. No. 1.

The documents that UCT requests from VIA are highly relevant to UCT’s infringement 

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claims, Lenovo’s defenses, and alleged damages. They are directed at fundamental issues of the 

structure and operation of the VIA components incorporated in the accused Lenovo products. 

Lenovo has identified the specific model numbers of relevant VIA components in response to 

UCT’s interrogatories.

7. EVIDENCE TO BE OBTAINED AND PURPOSE

UCT’s request for information from VIA seeks a narrowly targeted set of information.

Specifically, UCT seeks documents and source code for components that VIA supplies to Lenovo 

that are incorporated in the accused products. The documents that UCT requests from VIA are 

highly relevant to UCT’s infringement claims, Lenovo’s defenses, and alleged damages. They are 

directed at fundamental issues of the structure and operation of the VIA components incorporated 

in the accused Lenovo products. Lenovo has identified the specific model numbers of relevant 

VIA components in response to UCT’s interrogatories.

Accordingly, the discovery sought from VIA is at least relevant to the infringement 

issues. UCT’s narrowly-tailored requests for production of documents by VIA are important to 

understanding the structure and operation of the VIA components. UCT has no other reasonable 

method of obtaining this discovery relating to the VIA components.

The documents identified in Exhibit A are directed to these narrowly-tailored issues. The 

documents requested are not only relevant to the discovery of this case, but are also necessary for 

the trial of this case and may be so used by the parties. UCT has no other reasonable method of 

obtaining the documents sought by this Letter Rogatory other than from VIA. Further, the 

documents are not otherwise obtainable by this Court through its own compulsory process. The 

evidence sought in Taiwan through this request is necessary for this Court to do justice in this case. 

In the proper exercise of its authority, the Requesting Court has determined that there are 

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sufficient grounds to obtain the documentary evidence sought through this Letter Rogatory, as the 

evidence sought is directly relevant to the issues to be determined by the Requesting Court, and 

such evidence cannot be secured elsewhere or otherwise without the intervention of the appropriate 

judicial authorities in Taiwan.

It appears to the Requesting Court that VIA resides within your jurisdiction with its 

principal place of business at 7F., No. 529-1, Zhongzheng Rd., Xindian Dist., New Taipei City 

23165, Taiwan. This Requesting Court therefore requests that, in the furtherance of justice, you, 

by the proper and usual process of your Court, compel VIA to produce the documents identified 

in the Letter Rogatory which is filed herewith as Exhibit A.

It is, therefore, respectfully requested that the courts of Taiwan require VIA to produce

documents responsive to the requests for production in Exhibit A to this Letter of Request, to the 

extent that they are in the possession, custody, or control of VIA, and are not privileged under the 

applicable laws of Taiwan or the United States.

While this Requesting Court expresses no view at this time as to the merits in the abovecaptioned case, it believes the evidence sought here will be relevant to and either probative or disprobative of material facts relevant to the parties’ claims and defenses.

8. IDENTITY AND ADDRESS OF THE ENTTITES AND PERSONS TO BE 

EXAMINED

VIA Labs, Inc.

7F., No. 529-1, Zhongzheng Rd., Xindian Dist., New Taipei City 23165, 

Taiwan 

9. DOCUMENTS AND OTHER EVIDENCE TO BE EXAMINED

It would further the interests of justice if you would require VIA to produce or make 

available for inspection the documents set forth in Exhibit A to this Letter of Request.

10. SPECIFICATION OF PRIVILEGE OR DUTY TO REFUSE TO GIVE 

EVIDENCE UNDER THE LAW OF THE STATE OF ORIGIN

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Under the laws of the United States, a witness has a privilege to refuse to give evidence if 

to do so would disclose a confidential communication between the witness and his or her attorney 

that was communicated specifically for the purpose of obtaining legal advice and which privilege 

has not been waived. United States law also recognizes a privilege against criminal selfincrimination. Other limited privileges on grounds not applicable here also exist, such as 

communications between doctors and patients, husband and wife, and clergy and penitent. Certain 

limited immunities are also recognized outside the strict definition of privilege, such as the limited 

protection of work product created by attorneys during or in anticipation of litigation.

11. REIMBURSEMENT

UCT is willing to reimburse the reimbursable fees and costs incurred by VIA in complying 

with any order of the courts of Taiwan giving effect to this Request for International Judicial 

Assistance.

12. RECIPROCITY REGARDING LETTER ROGATORY

In the spirit of comity and reciprocity, the United States District Court for the Eastern 

District of Texas, Marshall Division hereby requests international judicial assistance in the form 

of this Letter Rogatory to obtain the documents identified in Exhibit A. This Court expresses its 

sincere willingness to provide similar assistance and to honor similar appropriate requests from a 

court in Taiwan if future circumstances should require.

For the foregoing reasons, this Court hereby issues this letter rogatory requesting the 

production of the VIA’s documents as follows:

13. DOCUMENTS

If acceptable, the Competent Court of Taiwan shall require that VIA produce the

documents requested in Exhibit A.

This Letter Rogatory is signed and sealed by Order of the Court made on the date set forth

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Dated: __________________

__________________________________

Honorable J. Rodney Gilstrap

United States District Court Judge

United States District Court

Eastern District of Texas, Marshall Division

United States of America

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EXHIBIT A

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EXHIBIT A

DEFINITIONS

As used herein, the following definitions shall apply to the requests for the production of

documents contained herein (the “Requests”):

1. “Accused Feature(s)” means the functionalities accused in UCT’s complaint 

and/or infringement contentions, including but not limited to Lenovo’s use of the functionality in 

any of the following USB Implementers Forum and/or VESA standards: USB 3.0 or later, USB-C 

1.0 or later, USB4 1.0 or later, USB Power Delivery 2.0 or later, DisplayPort 1.0 or later, 

DisplayPort Alt Mode 1.0 or later, HDMI Alt Mode for USB-C, and/or PCIe 3.0 or later.

2. “Accused Product(s)” means the products listed in UCT’s complaint and/or 

infringement contentions, including but not limited to Lenovo products (laptops, desktops, 

working stations, monitors, docking stations, and/or SSDs) that support USB 3.0 or later, USB-C 

1.0 or later, USB4 1.0 or later, USB Power Delivery 2.0 or later, DisplayPort 1.0 or later, 

DisplayPort Alt Mode 1.0 or later, HDMI Alt Mode for USB-C, and/or PCIe 3.0 or later.

3. “UCT” means Universal Connectivity Technologies Inc. and all past and present 

officers, directors, affiliates, brokers, agents, representatives, employees, servants, and all persons 

acting directly or indirectly under its control, including any attorney.

4. “Communication” shall mean, including its usual and customary meaning, any 

transmission, conveyance, or exchange of a word, statement, fact, thing, idea, document, 

instruction, information, demand or question by any medium, whether by written, oral, or other 

means, including but not limited to electronic communications and electronic mail.

5. “Concerning” means directly or indirectly mentioning, constituting, discussing or 

describing, relating to, pertaining to, or being connected with a stated subject matter or any aspect 

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thereof.

6. “Document” or “documents” are used herein in their broadest sense as set forth in 

the Federal Rules of Civil Procedure. These words mean and include all written, printed, typed, 

recorded, or graphic matter of every kind and description, both originals and copies, and all 

attachments and appendices, within your possession, custody, or control. Without limiting the 

foregoing, the terms “document” and “documents” shall include all agreements, contracts, 

communications, correspondence, facsimile, letters, opinion letters, telegrams, telexes, telefaxes, 

messages, memoranda, records, reports, books, summaries or other records of telephone 

conversations or interviews, summaries or other records of personal conversations or interviews, 

minutes, summaries, other records of meetings and conferences, statements obtained from 

witnesses, summaries or other records of negotiations, other summaries, diaries, diary entries, 

calendars, appointment books, time records, instructions, work assignments, forecasts, progress 

reports, statistical data, statistical statements, financial statements, work sheets, work papers, 

drafts, graphs, charts, tables, accounts, analytical records, consultants’ and experts’ report, 

appraisals, bulletins, notes, notices, marginal notations, notebooks, telephone records, bills, 

statements, records of obligation and expenditure, invoices, lists, journals, printouts, compilations, 

tabulations, analyses, studies, surveys, expense reports, microfilm, microfiche, tape or disc 

recordings, sound recordings, video recordings, film, tape, photographs, programs, electronic mail 

(“e-mail”) and data compilations from which information can be obtained (including matter used 

in data processing), and other printed, written, handwritten, typewritten, recorded, stenographic, 

computer-generated, computer-stored, or electronically stored matter, however and by whomever 

produced, prepared, reproduced, disseminated, or made. The words “document” and “documents” 

also include all copies of documents by whatever means made, except that where a document is 

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produced, identical copies of it that do not contain any markings, additions, or deletions that are 

different from the original do not have to be separately produced.

7. “Hardware” means any form of electronic components, interconnections, circuits 

(both analog and digital), semiconductor devices, circuit boards, and assemblies of same.

8. “Lawsuit” means the case captioned Universal Connectivity Technologies Inc. v. 

Lenovo Group Limited, Civil Action No. 2:23-cv-00449-JRG, pending in the United States District 

Court for the Eastern District of Texas.

9. “Patents-in-Suits” means United States Patent Nos. 7,154,905 (“the ’905 Patent”), 

7,187,307 (“the ’307 Patent”), 7,746,798 (“the ’798 Patent”), 9,232,265 (“the ’265 Patent”), 

8,680,712 (“the ’712 Patent”), 7,856,520 (“the ’520 Patent”), 7,921,231 (“the ’231 Patent”), and 

9,852,103 (“the ’103 Patent”) (collectively, the “Asserted Patents”).

10. “Relate to,” “related to,” “in relation to,” and “relating to” mean, in addition to 

their customary and usual meaning, bearing upon, discussing, identifying, referring to, pertaining 

to, or concerning.

11. “Lenovo” means Lenovo Group Limited and all past and present officers, 

directors, affiliates, brokers, agents, representatives, employees, servants, and all persons acting 

directly or indirectly under its control, including any attorney.

12. “Software” means any form of code, including source code, object code, complied 

code, byte code, interpreted code, firmware, and any form of code stored in any storage medium 

or received by a device.

13. “Source code” means any text or symbols that are written in a human-readable 

programming language or visual representation and any data files associated with the humanreadable or visual representation. Source code for different versions of software may exist, where

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a version is referenced by a build number, product version number, or other designation as 

identified by Your source code control system and/or software development practices. Source 

code for hardware includes but is not limited to schematics, Register Transfer Level (RTL), and 

netlists of hardware components. A reference to “source code” shall mean all versions released 

as a commercial product or used in the construction of a commercial product. Source code includes 

manifests, build files, “make” files or build scripts for aggregating, compiling, or associating 

multiple source code files in any way and any output files produced by aggregation, compilation, 

or association of multiple source code files.

14. “Technical Reference Manual” means all documents that refer or relate to a 

description of a product’s technical specifications, features, design, components, troubleshooting, 

setup, operation, use, and/or general technical maintenance.

15. “VIA Labs, Inc.,” “VIA,” “You,” and “Your” means VIA Labs, Inc. and all past 

and present officers, directors, affiliates, brokers, agents, representatives, employees, servants, and 

all persons acting directly or indirectly under its control, including any attorney.

16. “VIA Chipsets” means any chipset that VIA has supplied to Lenovo that is 

responsible for the DisplayPort, PCIe, and/or USB functionality of the Accused Products. This 

includes functionality set forth in any of the following USB Implementers Forum and/or VESA 

standards: USB 3.0 or later, USB-C 1.0 or later, USB4 1.0 or later, USB Power Delivery 2.0 or 

later, DisplayPort 1.0 or later, DisplayPort Alt Mode 1.0 or later, HDMI Alt Mode for USB-C, 

and/or PCIe 3.0 or later.

INSTRUCTIONS FOR SCHEDULE A

1. Unless otherwise defined all words and phrases used herein shall be accorded their 

usual meaning and shall be interpreted in their common ordinary sense.

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2. If there is any question as to the meaning of any part of these Requests or Topics, 

or an issue as to whether production of responsive documents would impose an undue burden on 

you, the undersigned counsel for UCT should be contacted promptly.

3. Each of the Requests for Production contained herein requires you to produce all 

documents in your actual or constructive possession, custody, or control.

4. Unless stated otherwise, documents produced in response to these Requests

should be fully inclusive for the period of January 2017-Present.

5. The use of the singular form of any word includes the plural and vice versa, and 

the terms “all,” “any,” “each,” and “every” shall be construed as both “each” and “every” to bring 

within the scope of these Requests and Topics any and all information which might otherwise be 

construed to be outside their scope. The past tense shall be construed to include the present and 

future tenses and vice versa, so as to make each Request inclusive rather than exclusive. “And” 

and “or” shall be construed either disjunctively or conjunctively as necessary to bring within the 

scope of these Requests any and all information that might otherwise be construed to be outside 

their scope.

6. Pursuant to Rule 45(d) of the Federal Rules of Civil Procedure, please produce the 

requested documents as they are kept in the usual course of business. For example, a document 

that is part of a file, docket, or other grouping, should be physically produced together with all 

other documents from said file, docket, or grouping, in the same order or manner of arrangement 

as the original. E-mail attachments should be produced with or following their corresponding emails. Source code should be produced in an electronic form that maintains the original character 

encoding of the text or symbols, such as ASCII or Unicode text files, searchable by characterbased tools without the need for Optical Character Recognition (OCR) of a binary image (for 

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example, TIFF) file, or PDF files for symbol-based source code such as schematics. Source code 

should maintain the original character encoding of the text, where applicable, and maintain format 

control characters including but not limited to tab, space, and quotation characters to maintain the 

original programmer-intended indenting structure. Source code production also includes a 

representation of the hierarchical organization of source code components if the source code is 

maintained hierarchically in the ordinary course of Your business. For example, if source code is 

maintained in the ordinary course of business as a hierarchy of directories and files, the names and 

relationships between directories and files convey important information about the structure of the 

design reflected by the source code and this information is relied upon by designers. If the source 

code is not produced in a manner that reproduces the hierarchy of directories and files in which it 

is maintained in the ordinary course of business, producing a human-readable or visible

representation of the structure of that hierarchy of directories and files maintained by You in 

the ordinary course of its business is a required aspect of producing the source code.

7. If you do not respond to any Request for Production in full or produce documents 

or things in response to any portion of a Request for Production, state the precise reason for failing 

to do so and provide all documents or things called for by that portion of the Request for Production 

to which you do not object and/or refuse to respond. If a legal objection is made, set forth the 

specific nature of the grounds for that objection. If you cannot or will not respond to only a portion 

of any Request, provide a full response to the remaining portion, and specifically set forth (i) the 

fact that the response is incomplete, and (ii) the reasons or grounds for any omission or for your 

inability or refusal to complete the response. If you can respond to a Request only in part on the 

basis of information available at the time of the response, (i) provide a response on the basis of 

that information, (ii) indicate your response is so limited, and (iii) provide a further response, in 

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accordance with paragraph three of these Instructions, when further information becomes 

available.

8. If any information, document or thing is withheld from production on the basis of 

privilege, work product, immunity, third-party confidentiality requirements, or any similar claim, 

then You shall produce a privilege log within a reasonable time as agreed by the Parties or as 

ordered by the Court.

9. All documents that constitute electronically stored information shall be produced 

as single-page TIFFs with image load files showing production numbers and document breaks or 

as otherwise agreed by the parties. UCT reserves the right to request production of electronically 

stored information in its native format and/or with associated metadata where necessary.

10. All the Requests contained herein are of a continuing nature and require you, in 

accordance with Federal Rule of Civil Procedure 26(e), to produce promptly for inspection and 

copying any documents or things that you reasonably may acquire, obtain, locate, or identify 

between the time of the initial response to these Requests and the time of the final disposition of 

this action.

REQUESTS FOR PRODUCTION

1. Source code sufficient to show the operation of the Accused Features for each of 

the VIA Chipsets, including the source code for hardware design and specification language 

descriptions, such as SDL, HDL, VHDL, iHDL, Verilog, System Verilog, or RTL, and the source 

code for higher software programming design languages, such as C and C++ programming 

languages. 

2. Technical documents sufficient to show the operation of the Accused Features for 

each of the VIA Chipsets that VIA has supplied to Lenovo. 

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