STIPULATED REQUEST BY PHILIPS AND ACER TO EXTEND DEADLINE FOR OPENING EXPERT REPORTS; ORDER

HAYWOOD S. GILLIAM, JR., District Judge.

Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiffs Koninklijke Philips N.V. and U.S. Philips Corp. ("Philips") and Defendants Acer Inc. and Acer America Corporation (collectively, "Acer"), through counsel, hereby respectfully file this stipulated request to extend the current April 18, 2019 deadline for each of Philips and Acer to serve their respective opening expert reports solely as it pertains to the disputes between Philips and Acer by two weeks, i.e., to May 2, 2019.

WHEREAS, the current deadline for serving opening expert reports in these consolidated cases is April 18, 2019 (see Docket No. 631).

WHEREAS, Philips and Acer have been involved in extensive settlement negotiations for the past several weeks.

WHEREAS, Philips and Acer are actively working in good faith toward a settlement of their portion of this dispute, but require time to finalize the terms of that potential settlement, and then memorialize those terms in a formal written agreement.

WHEREAS, Philips and Acer are each large international companies — one based in the Netherlands the other based in the Republic of China, Taiwan — with multiple levels of approvals required for settlement language and/or changes to such settlement language.

WHEREAS, Philips and Acer both desire to invest their time, effort, and legal resources into completion of such a written settlement agreement, rather than in continuing this litigation through the preparation of opening expert reports.

WHEREAS, neither Philips nor Acer desire or request that this submission impact the opening expert report deadline or any other deadline in these consolidated cases that pertain to any other parties besides Philips and Acer.

WHEREAS, accordingly, under Civil Local Rule 6-2(a)(3), Philips and Acer confirm that this requested extension of the deadline for opening expert reports solely as to the Philips/Acer disputes is not intended to impact: (a) any other deadlines as they pertain to Philips or Acer; or (b) the opening expert reports deadline or any other deadline in these consolidated cases as they pertain to any other parties besides Philips and Acer.

WHEREAS, under Civil Local Rule 6-2(a)(2), the parties report that the parties have made and the Court has approved seven previous stipulations seeking to modify the schedule in these consolidated cases: (a-b) two granting Philips' unopposed requests for an additional week of time to file reply briefs supporting its motion to partially consolidate these matters; (c) one granting Defendants' unopposed motion for a letter rogatory; (d) one granting Defendants' request for discovery into documents produced by Philips; (e) one granting the parties' stipulated request to extend fact discovery for the depositions of certain individuals and entities; (f) one granting the parties' stipulated request to extend the briefing schedule regarding Defendants' motion to amend their invalidity contentions; and (g) one granting the parties' stipulated request to extend the deadlines relating to expert discovery and dispositive and Daubert motions (see Docket Nos. 464, 465, 582, 593, 594; 601; and 631).

WHEREAS, the parties also sought additional extensions of time from the District of Delaware before transfer of these actions to this Court, but have not reported those here because they do not believe Civil Local Rule 6-2(a)(2) calls for them.

NOW, THEREFORE, Philips and Acer, through counsel, hereby stipulate to and respectfully request that the Court extend the current April 18, 2019 deadline for each of Philips and Acer to serve their respective opening expert reports solely as it pertains to the disputes between Philips and Acer to May 2, 2019.

CIVIL L.R. 5-1(i) ATTESTATION

I, Chris Holland, hereby attest that I have been authorized by counsel for the parties listed above to execute this document on their behalf.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.