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excerpts from Doc 309
We think this is a very complicated task and defendants seemed to agree with that sentiment
on August , 5 . Defendant agree that this is a complicated task.

As the court observed and sought to avoid if possible , full blown discovery in this case will be very expensive .

. For example , defendantsCanon inc,Hoya Corporation, Kyocera corporation D&M holding Inc, and Panasonic Corporation located inJAPAN.

Defendants D&Gtechnology Corporation and HTC corporation are TAIWANESECorporation.

Thus it is expected that the large majority of documents maintained by those defendants are in

languages other than English and therefore will require translation , more ever deposition of these

defendants will need to be taken overseas with translator.

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