`
`PAUL ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRAMER LEVIN NAFTALIS
` & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`EDWARD G. POPLAWSKI (SBN 113590)
`epoplawski@wsgr.com
`OLIVIA M. KIM (SBN 228382)
`okim@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Telephone: (323) 210-2901
`Facsimile: (866) 974-7329
`
`RYAN R. SMITH (SBN 229323)
`rsmith@wsgr.com
`CHRISTOPHER D. MAYS (SBN 266510)
`cmays@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`Facsimile: (650) 493-6811
`
`Attorneys for Defendant
`QUALYS INC.
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`OAKLAND DIVISION
`
`FINJAN, INC.,
`
`Plaintiff,
`
`v.
`
`QUALYS INC.,
`
`Defendant.
`
`Case No.: 4:18-cv-07229-YGR
`
`[PROPOSED] ORDER
`
`Date Complaint Filed: November 29, 2018
`
`Trial Date: None Set
`
`1 2 3 4 5 6 7 8 9
`
`10
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`
`[PROPOSED] ORDER
`
`CASE NO: 4:18-cv-07229-YGR
`
`
`
`Case 4:18-cv-07229-YGR Document 39 Filed 07/16/19 Page 2 of 3
`
`Event
`
`Finjan to file charts regarding prior and co-pending
`litigation involving Finjan’s patents and prior claim
`constructions
`Submit Protective Order and ESI Order
`Initial Disclosures
`Disclosure of Asserted Claims and Infringement
`Contentions; Document Production Accompanying
`Disclosure
`Last day to join parties or amend the pleadings without
`leave of Court
`Invalidity Contentions; Document Production
`Accompanying Invalidity Contentions
`Exchange of Proposed Terms for Construction
`Exchange of Preliminary Claim Constructions and
`Extrinsic Evidence
`Damages Contentions
`Joint Claim Construction and Prehearing Statement
`Responsive Damages Contentions
`Completion of Claim Construction Discovery
`Claim Construction Briefs – opening brief
`Claim Construction Briefs – responsive brief
`Claim Construction Briefs – reply brief
`Claim Construction Tutorial
`
`Claim Construction Hearing
`
`Close of fact discovery
`
`Opening expert reports
`
`Agreed Proposed
`Date/Deadline
`Complete
`
`Complete
`Complete
`Complete
`
`Complete
`
`Complete
`
`10/2/19
`10/23/19
`
`10/30/19
`12/4/19
`12/18/19
`1/15/20
`2/10/20
`3/16/20
`4/6/20
`5/6/20
`at 2pm
`(subject to the Court’s
`availability)
`5/20/20
`(subject to the Court’s
`availability)
`2 months after the
`claim construction
`order
`2 months after the
`close of fact discovery
`
`[PROPOSED] ORDER
`
`1
`
`CASE NO: 4:18-cv-07229-YGR
`
`1 2 3 4 5 6 7 8 9
`
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`
`5/1/2020 at 10:00 a.m.
`
`4/22/2020
`
`
`
`Case 4:18-cv-07229-YGR Document 39 Filed 07/16/19 Page 3 of 3
`
`Event
`
`Rebuttal expert reports
`
`Close of expert discovery
`
`Last day for a pre-filing conference on summary judgment
`motions
`
`Plaintiff’s opening summary judgment briefs
`
`Defendant’s opposition summary judgment briefs and
`cross motion for summary judgment
`
`Plaintiff’s reply summary judgment briefs and opposition
`to Defendant’s cross motion for summary judgment
`
`Defendant’s reply for its cross motion for summary
`judgment
`
`Summary judgment hearing
`
`Final Pretrial Conference
`
`Trial
`
`July 16, 2019
`
`Agreed Proposed
`Date/Deadline
`6 weeks after service
`of opening expert
`reports (subject to
`adjustment for
`holidays)
`1 month after the
`service of rebuttal
`expert reports
`three weeks after the
`close of expert
`discovery
`three weeks after the
`pre-filing conference
`on summary judgment
`motions
`three weeks after
`Plaintiff’s opening
`summary judgment
`brief
`three weeks after
`Defendant’s
`opposition summary
`judgment brief
`three weeks after
`Plaintiff’s opposition
`summary judgment
`brief
`Subject to the Court’s
`availability
`Subject to the Court’s
`availability
`Subject to the Court’s
`availability
`
`[PROPOSED] ORDER
`
`2
`
`CASE NO: 4:18-cv-07229-YGR
`
`1 2 3 4 5 6 7 8 9
`
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`
`IT IS SO ORDERED.
`
`Date:
`
`__________________________
`
`Yvonne Gonzalez Rogers
`
`U.S. District Court Judge
`
`
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