Filed: May 21, 2015
Latest Update: May 21, 2015
Summary: JOINT STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER AS MODIFIED JEFFREY S. WHITE , District Judge . Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff KlausTech, Inc. ("KlausTech") and Defendant AdMob, Inc. ("AdMob"), hereby stipulate through their respective counsel of record to amend the case deadlines set at the December 12, 2014 Case Management Conference (Dkt. No. 113) and amended in the Court's Order granting the parties' joint stipulation to extend selected case dead
Summary: JOINT STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER AS MODIFIED JEFFREY S. WHITE , District Judge . Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff KlausTech, Inc. ("KlausTech") and Defendant AdMob, Inc. ("AdMob"), hereby stipulate through their respective counsel of record to amend the case deadlines set at the December 12, 2014 Case Management Conference (Dkt. No. 113) and amended in the Court's Order granting the parties' joint stipulation to extend selected case deadl..
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JOINT STIPULATION TO EXTEND DEADLINES AND [PROPOSED] ORDER
AS MODIFIED
JEFFREY S. WHITE, District Judge.
Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff KlausTech, Inc. ("KlausTech") and Defendant AdMob, Inc. ("AdMob"), hereby stipulate through their respective counsel of record to amend the case deadlines set at the December 12, 2014 Case Management Conference (Dkt. No. 113) and amended in the Court's Order granting the parties' joint stipulation to extend selected case deadlines (Dkt. No. 124):
WHEREAS, the parties agreed to schedule AdMob's deposition of the inventor of the patent-in-suit, Robert Cezar, before the exchange of proposed claim constructions and identification of extrinsic evidence pursuant to Patent Local Rule 4-2 (currently scheduled for May 25, 2015);
WHEREAS, on February 11, 2015, in preparation for the deposition of Mr. Cezar, AdMob served its First Set Of Requests For Production Of Documents on KlausTech and served a Subpoena To Produce Documents, Information, or Objects and Testify At a Deposition on Mr. Cezar;
WHEREAS, Mr. Cezar is not available for deposition until June 18, 2015;
WHEREAS, counsel for KlausTech requires additional time to complete its document productions on behalf of both KlausTech and Mr. Cezar;
WHEREAS, counsel for both parties require certain scheduling accommodations, and the parties have sought to comply with the Northern District's Guidelines for Professional Conduct which dictate that lawyers should agree to reasonable requests for extensions of time when the legitimate interests of his or her client will not be adversely affected;
WHEREAS, the parties previously agreed to change the dates for Final Infringement Contentions from March 13, 2015 to March 30, 2015 and Amended Invalidity Contentions from March 27, 2015 to April 13, 2015, and submitted a joint stipulation on March 12, 2015 (Dkt. No. 123), which the Court granted (Dkt. No. 124);
WHEREAS, the Court has only set a case schedule through claim construction, and will address the post-claim construction schedule after the parties file a subsequent case management report upon issuance of a claim construction order;
WHEREAS, the proposed amended schedule would modify the dates for the technology tutorial, the claim construction hearing, and the interim claim construction deadlines;
NOW THEREFORE, good cause appearing, the parties through their undersigned counsel hereby stipulate and request that the Court grant the following amended schedule:
EVENT CURRENT DATE AMENDED DATE
Deposition of Robert Cezar — June 18-19, 2015
Parties to exchange Proposed Claim May 25, 2015 August 31, 2015
Constructions and provide preliminary
identification of extrinsic evidence pursuant
to Patent L.R. 4-2
Parties to file Joint Claim Construction and June 26, 2015 September 28, 2015
Prehearing Statement pursuant to Patent
L.R. 4-3
Last day to take discovery relating to claim July 31, 2015 October 26, 2015
construction and comply with Patent L.R.
4-4
Plaintiff to file opening claim construction Aug. 21, 2015 November 16, 2015
brief & supporting evidence pursuant to
Patent L.R. 4-5(a)
Defendant to file responsive claim Sept. 11, 2015 December 9, 2015
construction brief & supporting evidence
pursuant to Patent L.R. 4-5(b)
Plaintiff to file reply claim construction Sept. 25, 2015 December 23, 2015
brief & rebuttal evidence pursuant to Patent
L.R. 4-5(c)
Parties to file Amended, Final Joint Claim Sept. 29, 2015 December 30, 2015
Construction Statement, including only the
remaining disputed terms, phrases, and
clauses
Technology Tutorial Oct. 8, 2015 January 11, 2016
10:00 a.m. January 21, 2015 at 10:00 a.m.
Claim Construction Hearing Oct. 15, 2015 January 25, 2016 at
10:00 a.m. 1:30pm January 28, 2016 at
Mediation deadline 60 days after issuance of [No change] 10:00 a.m.
the Markman Order
IT IS SO STIPULATED
ATTESTATION
Pursuant to Local Rule 5-1(i)(3), I hereby attest that the concurrence in the filing of this document has been obtained from the signatories indicated in this e-filed document.
PURSUANT TO STIPULATION, IT IS SO ORDERED
