Case 8:19-cv-01150-JLS-ADS Document 34-1 Filed 10/25/19 Page 1 of 3 Page ID #:352
`
`EXHIBIT B
`PROPOSED SCHEDULE OF PRETRIAL AND TRIAL DATES IN UTILITY PATENT
`CASES ASSIGNED TO THE HON. JOSEPHINE L. STATON
`
`
`CASE NAME:
`
`CASE NO:
`
`
`
`
`
`UNILOC 2017 LLC v. INFOR, INC.
`
`8:19-cv-01150-JLS-ADS
`
`Matter
`
`Deadline
`
`Plaintiff(s)
`Request1
`
`11/22/19
`
`Scheduling Conference Date
`plus fourteen (14) days (N.D.
`Patent L.R. 3-1 and 3-2).
`
`Disclosure of Asserted
`Claims and Infringement
`Contentions and Document
`Production Accompanying
`Disclosure (N.D. Patent L.R.
`3-1(a)-(h) to 3-2(a)-(e)).
`
`Last Day to File Motions to
`Add Parties and Amend
`Pleadings without leave
`
`Disclosure of Invalidity
`Contentions and Production
`Accompanying Invalidity
`Contentions (N.D. Patent L.R.
`3- 3(a)-(d) to 3-4(a)-(b)).
`
`Exchange of Proposed Terms
`for Construction (N.D. Patent
`L.R. 4- 1(a)-(b)).
`
`Exchange of Preliminary
`Claim Constructions and
`Extrinsic Evidence (N.D.
`Patent L.R. 4- 2(a)-(c).
`
`Joint Status Report Regarding
`Technology Tutorial
`
`Completion of Claim
`
`Construction Discovery
`
` (N.D. Patent L.R. 4-4.)
`
`Defendant(s)
`Request2
`
`
`
`
`
`Scheduling Conference Date
`plus sixty (60) days.
`
`1/21/20
`
`
`
`Deadline for Infringement
`Contentions Disclosure plus
`forty-nine (49) days (adapted
`from N.D. Patent L.R. 3-3).
`
`Deadline for Invalidity
`Contentions Disclosure plus
`fourteen (14) days (N.D.
`Patent L.R. 4-1).
`
`Exchange of Proposed Terms
`for Construction plus
`fourteen (14) days (adapted
`from N.R. Patent L.R. 4-2).
`
`Sixty (60) days in advance of
`the Claim Construction
`Hearing (Order Setting
`Scheduling Conference).
`
`Exchange of Preliminary
`Claim Constructions and
`Extrinsic Evidence plus
`twenty-eight (28) days.
`
`1/10/20
`
`2/14/20
`
`1/31/20
`
`2/28/20
`
`2/7/20
`
`03/06/20
`
`2/28/20
`
`3/25/20
`
`3/6/20
`
`4/3/20
`
`
`1 Uniloc 2017 does not agree with Infor’s arguments, and prefers to go with the dates the Court has suggested.
`2 As Infor explained in the joint report, Infor will be promptly filing a renewed motion to dismiss, and a motion to
`stay discovery pending that motion, by October 31, 2019. Infor requests that the Court order the parties to propose a
`schedule after consideration of these motions. To the extent the Court is inclined to enter a schedule now, Infor
`proposes that the Court push its presumptive dates out a sufficient time to take into the account the fact that Uniloc,
`in its Amended Complaint, dropped the originally accused product and for the first time accused a new and different
`product. Infor also proposes that the Court build in time for expert discovery to be completed prior to the deadline
`for dispositive motions, for the reasons explained in the joint report.
`
`
`
`1
`
`

`

`Case 8:19-cv-01150-JLS-ADS Document 34-1 Filed 10/25/19 Page 2 of 3 Page ID #:353
`
`EXHIBIT B
`PROPOSED SCHEDULE OF PRETRIAL AND TRIAL DATES IN UTILITY PATENT
`CASES ASSIGNED TO THE HON. JOSEPHINE L. STATON
`
`
`CASE NAME:
`
`CASE NO:
`
`
`
`
`UNILOC 2017 LLC v. INFOR, INC.
`
`8:19-cv-01150-JLS-ADS
`
`Matter
`
`Deadline
`
`Joint Claim Construction and
`Prehearing Statement (N.D.
`Patent L.R. 4-3(a)-(e)).
`
`Completion of Claim
`Construction Discovery plus
`seven (7) days.
`
`Opening Claim Construction
`Briefs
`
`Responsive Claim
`Construction Briefs
`
`Claim Construction Hearing
`
`Claim Construction Ruling
`Date
`
`Production Related to
`Reliance Upon Advice of
`Counsel (N.D. Patent L.R. 3-
`7(a)-(c).)
`
`Fact Discovery Cut-Off
`
`Last Day to Serve Initial
`Expert Reports (unrelated to
`claim construction).
`
`Last Day to File Motions
`(Except Daubert and all other
`Motions in Limine).
`
`Last Day to Serve Rebuttal
`Expert Reports (unrelated to
`claim construction).
`
`Deadline for filing of Joint
`Claim Construction and
`Prehearing Statement plus
`seven (7) days.
`
`Deadline for filing of
`Opening Claim Construction
`Briefs plus fourteen (14)
`days.
`
`Twenty-five (25) days after
`the Responsive Brief
`Deadline (set for Tuesday at
`9:00 a.m.).
`
`Projected as 94 days
`(approximately three months)
`after the hearing. The actual
`date is likely to vary and may
`be earlier or later.
`
`Thirty-two (32) days after the
`projected Claim Construction
`Ruling Date (adapted from
`N.D. Patent L.R. 3-7).
`
`Approximately one (1) month
`after the deadline for the
`Production Related to
`Reliance on Advice of
`Counsel and 18 weeks before
`the Final Pretrial Conference
`(“FPTC”).
`
`16 weeks before the FPTC.
`
`16 weeks before the FPTC.
`
`12 weeks before the FPTC.
`
`
`
`2
`
`Plaintiff(s)
`Request1
`
`3/13/20
`
`Defendant(s)
`Request2
`
`4/10/20
`
`3/20/20
`
`4/17/20
`
`4/3/20
`
`5/01/20
`
`4/28/20
`
`5/26/20
`
`7/30/20
`
`~09/04/20
`
`8/31/20
`
`10/6/20
`
`10/1/20
`
`11/6/20
`(26 weeks
`before FPTC)
`
`16 weeks
`before the
`FPTC.
`
`16 weeks
`before the
`FPTC.
`
`12 weeks
`before the
`FPTC
`
`24 weeks
`before FPTC
`
`16 weeks
`before FPTC
`
`20 weeks
`before FPTC
`
`

`

`Case 8:19-cv-01150-JLS-ADS Document 34-1 Filed 10/25/19 Page 3 of 3 Page ID #:354
`
`EXHIBIT B
`PROPOSED SCHEDULE OF PRETRIAL AND TRIAL DATES IN UTILITY PATENT
`CASES ASSIGNED TO THE HON. JOSEPHINE L. STATON
`
`
`CASE NAME:
`
`CASE NO:
`
`
`
`
`UNILOC 2017 LLC v. INFOR, INC.
`
`8:19-cv-01150-JLS-ADS
`
`Matter
`
`Deadline
`
`Last Day to Conduct
`Settlement Proceedings.
`
`9 weeks before the FPTC.
`
`Expert Discovery Cut-Off.
`
`8 weeks before the FPTC.
`
`Last Day to File Daubert
`Motions.
`
`Last Day to File Motions in
`Limine (excluding Daubert
`Motions).
`
`Final Pre-Trial Conference
`(Friday at 10:30 a.m.).
`
`Revised: July 31, 2019
`
`7 weeks before the FPTC.
`
`4 weeks before the FPTC.
`
`
`
`
`
`Plaintiff(s)
`Request1
`
`Defendant(s)
`Request2
`
`9 weeks before
`the FPTC.
`
`9 weeks before
`FPTC
`
`8 weeks before
`the FPTC.
`
`18 weeks
`before FPTC
`
`7 weeks before
`the FPTC
`
`7 weeks before
`FPTC
`
`4 weeks before
`the FPTC.
`
`4 weeks before
`FPTC
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`