`
`#:14372
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`George C. Lombardi (pro hac vice)
`glombardi@winston.com
`WINSTON & STRAWN LLP
`35 West Wacker Drive
`Chicago, IL 60601-9703
`Telephone:(312) 558-5600
`Facsimile: (312) 558-5700
`
`E. Danielle T. Williams (pro hac vice)
`dwilliams@winston.com
`WINSTON & STRAWN LLP
`300 South Tryon Street, 16th Floor
`Charlotte, NC 28202
`Telephone:(704) 350-7700
`Facsimile: (704) 350-7800
`
`
`Dustin J. Edwards (pro hac vice)
`dedwards@winston.com
`WINSTON & STRAWN LLP
`800 Capitol St., Suite 2400
`Houston, TX 77002-2925
`Telephone:(713) 651-2600
`Facsimile: (713) 651-2700
`
`Diana Hughes Leiden (SBN: 267606)
`dhleiden@winston.com
`WINSTON & STRAWN LLP
`333 S. Grand Avenue, 38th Floor
`Los Angeles, CA 90071-1543
`Telephone:(213) 615-1700
`Facsimile: (213) 615-1750
`
`Attorneys for Defendants
`BANK OF AMERICA
`CORPORATION
`and BANK OF AMERICA, N.A.
`
`UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`Case No. 2:20-cv-07872-GW-PVC
`NANTWORKS, LLC, a Delaware limited
`liability company, and NANT
`
`DEFENDANTS’ NOTICE OF
`HOLDINGS IP, LLC, a Delaware limited
`MOTION AND MOTION TO
`liability company,
`STRIKE CERTAIN OPINIONS IN
`
`DR. SCHONFELD’S OPENING
`Plaintiffs,
`EXPERT REPORT REGARDING
`
`INFRINGEMENT
`vs.
`
`
`BANK OF AMERICA CORPORATION,
`Date: May 2, 2024
`a Delaware corporation, and BANK OF
`Time: 8:30 am
`AMERICA, N.A., a national banking
`Courtroom: 9D
`association,
`
`
`Judge: Honorable George H. Wu
`
`
`
`
`
`
`PUBLIC/REDACTED VERSION OF DOCUMENT PROPOSED TO BE FILED
`UNDER SEAL IN ITS ENTIRETY
`
`
`
`
`
`
`
`Defendants.
`
`
`
`
`DEFENDANTS’ MOTION TO STRIKE THE EXPERT REPORT OF DR. DAN SCHONFELD
`CASE NO. 2:20-CV-07872-GW-PVC
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 306-2 Filed 03/26/24 Page 2 of 2 Page ID
`
`#:14373
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
` PLEASE TAKE NOTICE that on May 2, 2024 at 8:30 a.m., or as soon thereafter
`as the matter may be heard in Courtroom 9D, in the above-entitled Court, located at 350
`West 1st Street, Los Angeles, CA, 90012, the Honorable George H. Wu presiding,
`Defendants Bank of America Corporation and Bank of America, N.A. (together
`“Defendants” or “Bank of America”) hereby move this Court to strike portions of the
`Expert Report of Dr. Dan Schonfeld Regarding the Infringement of the Asserted Claims
`of U.S. Patent Nos. 9,031,278, 7,881,529, 7,899,252, 9,324,004, and 8,478,036 (the
`“Schonfeld Report,” and the motion, “Schonfeld Motion to Strike”), pursuant to Rule
`16 of the Federal Rules of Civil Procedure.
`This Schonfeld Motion to Strike is based on the Notice of Motion, the
`Memorandum of Points and Authorities and supporting declarations, all pleadings,
`papers, and records filed in this action, and any further evidence that the Court may
`wish to consider at the hearing on this Schonfeld Motion to Strike.
`This Schonfeld Motion to Strike is made following the conference of counsel
`pursuant to L.R. 7-3 which took place on March 5, 2024.
`
`
`
`Dated: March 26, 2024
`Respectfully submitted,
`
`WINSTON & STRAWN LLP
`
`By: /s/ Dustin J. Edwards
`
` George C. Lombardi
` E. Danielle T. Williams
` Dustin J. Edwards
`
`Attorneys for Defendants
`BANK OF AMERICA CORPORATION and
`BANK OF AMERICA, N.A.
`
`
`
`
`
`
`
`DEFENDANTS’ MOTION TO STRIKE THE EXPERT REPORT OF DR. DAN SCHONFELD
`CASE NO. 2:20-CV-07872-GW-PVC
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
