STIPULATION AND [PROPOSED] ORDER SUPPLEMENTING THE JOINT CASE MANAGEMENT STATEMENT

JON S. TIGAR, District Judge.

Pursuant to the Court's Order (D.I. 101), Plaintiff American Navigation Systems, Inc. ("AmNav") and Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively "Samsung")1 hereby submit this stipulation and proposed order supplementing the parties' Joint Case Management Statement (D.I. 91).

WHEREAS AmNav alleges that both Samsung and Apple Inc. ("Apple") infringe the same patent, U.S. Patent No. 5,902,347 (the "`347 Patent"), in two cases captioned American Navigation Systems, Inc. v. Apple, Inc., 3:14-cv-05297-JST ("Apple-AmNav case") and American Navigation Systems, Inc. v. Samsung Electronics Co., Ltd., et. al., 3:14-cv-05298-JST ("Samsung-AmNav case"); and

WHEREAS the Court has ordered the parties to file a statement by March 18, 2015, informing the Court if they agree to have ten common terms construed in total for both the AmNav-Samsung and AmNav-Apple cases (in compliance with the ten-term limit in the local patent rules) or to set a telephonic case management conference for March 25, 2015 at 4:00 p.m. if the parties could not file the statement (D.I. 101).

IT IS HEREBY STIPULATED AND AGREED that, pursuant to the Court's order (D.I. 101), the parties will construe a total of ten common claim terms (or less) of the `347 Patent across both the AmNav-Samsung and AmNav-Apple cases, that the parties will have a single claim construction hearing for both cases, and that the March 25, 2015 telephonic case management conference is vacated.2

CASE MANAGEMENT ORDER

The above STIPULATION AND PROPOSED ORDER SUPPLEMENTING THE JOINT CASE MANAGEMENT STATEMENT is Approved and all parties shall comply with its Provisions.

IT IS SO ORDERED.