STIPULATED REQUEST TO MODIFY HEARING DATE AND BRIEFING SCHEDULE FOR WORD TO INFO, INC.'S MOTION FOR LEAVE TO AMEND INFRINGEMENT CONTENTIONS

WILLIAM H. ORRICK, District Judge.

TO THIS HONORABLE COURT AND ALL PARTIES AND THEIR COUNSEL OF RECORD HEREIN:

WHEREAS Plaintiff Word to Info, Inc. ("WTI") filed its Motion for Leave to Amend Infringement Contentions (Dkt. 116) on Thursday, March 31, 2016, and noticed a hearing date for May 11, 2016;

WHEREAS Defendant Google Inc. ("Google") and WTI previously submitted a joint stipulation (Dkt. 125) requesting a modification in the hearing date and briefing schedule for this motion so that it could be heard together with a cross-motion to strike WTI's infringement contentions that Google informed WTI it intended to bring;

WHEREAS the Court granted this stipulation, as modified (Dkt. 126), and set the hearing date for May 18, 2016; the due date for Google's opposition to WTI's motion to April 19, 2016; and the due date for WTI's reply to May 4, 2016;

WHEREAS counsel for Google is not available for a hearing on May 18, 2016;

WHEREAS counsel for Google contacted the calendar clerk on April 13, 2016, to inquire about the Court's schedule and the calendar clerk informed Google that the Court is not available for the hearing on May 25 or June 1, 2016;

WHEREAS Google and WTI agree that hearing WTI's Motion for Leave to Amend Infringement Contentions and Google's cross-motion to strike plaintiff's infringement contentions at the same time would be more efficient for both the Court and the parties and that a modified hearing date of June 8, 2016, would permit these motions to be heard at the same time;

WHEREAS Google and WTI now request that the hearing date be moved to June 8, 2016;

WHEREAS, in the alternative, if more convenient for the Court, Google and WTI also agree that the hearing date could be set for the same date as the claim construction tutorial currently scheduled in this action, June 10, 2016;

WHEREAS Google and WTI agree that there is good cause for modifying the briefing schedule for WTI's Motion for Leave to Amend Infringement Contentions (Dkt. 116), and WTI and Google now request that Google's opposition to WTI's Motion for Leave to Amend Infringement Contentions be filed by Wednesday, April 27, 2016, and WTI's reply in support of WTI's Motion for Leave to Amend Infringement Contentions be filed by Wednesday, May 18, 2016; and

WHEREAS the parties' stipulation does not change any other dates in the current schedule and does not accelerate or extend any other time frames set in the Local Rules or in the Federal Rules;

IT IS STIPULATED AND REQUESTED that, subject to the Court's approval, the hearing date for Plaintiff's Motion for Leave to Amend Infringement Contentions be June 8, 2016, or in the alternative, at the Court's preference, June 10, 2016; that Google's opposition to WTI's Motion for Leave to Amend Infringement Contentions be due April 27, 2016; that WTI's reply in support of WTI's Motion for Leave to Amend Infringement Contentions be due May 18, 2016.

CIVIL L.R. 6-2 DECLARATION

In accordance with Civil Local Rule 6-2, I declare that good cause supports the parties' stipulated request for modifying the hearing date for Plaintiff Word to Info, Inc.'s Motion for Leave to Amend Infringement Contentions to June 8, 2016, or in the alternative at the Court's preference, June 10, 2016; setting the due date for Google's opposition to WTI's Motion for Leave to Amend Infringement Contentions to April 27, 2016; and setting the due date for WTI's reply in support of WTI's Motion for Leave to Amend Infringement Contentions to May 18, 2016. The requested modifications will permit Google Inc.'s forthcoming cross-motion to strike Plaintiff's infringement contentions and WTI's Motion for Leave to Amend Infringement Contentions to be heard at the same time.

The parties previously stipulated to an extension of time to the date of February 12, 2016, for Facebook, Inc. to serve its Invalidity Contentions; the date of February 19, 2016, for Google Inc. to serve its Invalidity Contentions; the date of February 26, 2016, for the Exchange of Proposed Terms for Claim Construction; and the date of March 4, 2016, for the Exchange of Preliminary Constructions because Plaintiff and Defendant Google Inc. were meeting and conferring regarding Plaintiff's Infringement Contentions. The Court entered its order granting this stipulation on February 26, 2016.

The parties subsequently agreed to the date of March 18, 2016, for the Exchange of Preliminary Constructions and the date of April 1, 2016, for the submission of the parties' Joint Claim Construction and Prehearing Statement pursuant to Patent L.R. 4-3. The Court entered its order granting this stipulation on March 29, 2016.

The parties then agreed to the date of April 8, 2016, for the submission of the parties' Joint Claim Construction and Prehearing Statement pursuant to Patent L.R. 4-3. The Court entered its order granting this stipulation on April 4, 2016.

The parties also previously agreed to modify the hearing date for WTI's Motion for Leave to Amend Infringement Contentions from May 11, 2016, to May 25, 2016; the due date for Google's opposition to that motion to April 19, 2016; and the due date for WTI's reply in support of that motion to May 4, 2016. The Court granted this stipulation, as modified, and set the hearing date to May 18, 2016.

The current stipulated request does not change any other dates in the current schedule, including the scheduled claim construction hearing on June 17, 2016, and does not accelerate or extend any other time frames set in the Local Rules or in the Federal Rules.

The hearing is set for the same date as the claim construction tutorial, June 10, 2016. PURSUANT TO STIPULATION, IT IS SO ORDERED.