Case 3:21-cv-09773-JD Document 39 Filed 08/05/22 Page 1 of 14
`
`
`PERKINS COIE LLP
`Sarah Fowler (Bar No. 264838)
`Moeka Takagi (Bar No. 333226)
`3150 Porter Drive
`Palo Alto, CA 94304-1212
`Phone: 650.838.4300
`SFowler@perkinscoie.com
`MTakagi@perkinscoie.com
`
`PERKINS COIE LLP
`Gene W. Lee (pro hac vice)
`Thomas Matthew (pro hac vice)
`1155 Avenue of the Americas, 22nd floor
`New York, NY 10112-0015
`212.262.6900
`GLee@perkinscoie.com
`TMatthew@perkinscoie.com
`
`Attorneys for Plaintiff
`Twitter, Inc.
`
`Lewis E. Hudnell, III (CASBN 218736)
`lewis@hudnelllaw.com
`Nicolas S. Gikkas (CASBN 189425)
`nick@hudnelllaw.com
`HUDNELL LAW GROUP P.C.
`800 W. El Camino Real Suite 180
`Mountain View, California 94040
`Telephone: 650.564.3698
`Facsimile: 347.772.3034
`
`Attorneys for Defendant
`VOIP-PAL.COM, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`Case No. 3:21-cv-9773-JD
`
`
`PROPOSED SCHEDULE
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`TWITTER, INC.,
`
`Plaintiff,
`
`v.
`
`VOIP-PAL.COM, INC.,
`
`Defendant.
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`PROPOSED SCHEDULE
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`Case 3:21-cv-09773-JD Document 39 Filed 08/05/22 Page 2 of 14
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`In accordance with the Court’s July 22, 2022 Order (ECF No. 38), Plaintiff Twitter, Inc.
`(“Twitter”), and Defendant VoIP-Pal.com, Inc. (“VoIP-Pal”) (collectively, the “parties”) submit this
`Proposed Schedule. For the convenience of the Court, this Proposed Schedule is presented, along
`with other relevant information, in a similar format to a Joint Case Management Statement.
`
`1.
`Jurisdiction and Service
`This Court has held that personal jurisdiction and subject matter jurisdiction are proper. ECF
`No. 38. No parties remain to be served.
`2.
`Facts
`The parties refer the Court to the briefing concerning VoIP-Pal’s Motion to Dismiss (ECF
`Nos. 25, 30, 33) for a recitation of the relevant facts.
`3.
`Legal Issues
`The parties currently believe that the principal legal issues are:
` The proper construction of any disputed claim terms; and
` Whether Twitter’s products and services do not infringe any claims of U.S. Patent
`Nos. 8,630,234 and 10,880,721 (collectively, the “Mobile Gateway Patents”), either
`directly under 35 U.S.C. § 271(a), indirectly under 35 U.S.C. § 271(b) or (c), or
`through foreign activity under 35 U.S.C. § 271(f).
`The parties reserve the right to raise additional factual or legal issues that may arise through
`the course of this action.
`Twitter’s additional statement: Twitter intends to amend the Complaint to add claims for
`invalidity. Twitter believes an additional principal legal issue is whether all the claims of the Mobile
`Gateway Patents are invalid under one or more of 35 U.S.C. §§ 101, 102, 103, and/or 112.
`4.
`Motions
`a.
`Pending Motions
`There are no pending motions.
`b.
`Anticipated Motions
`If VoIP-Pal does not counterclaim for infringement, Twitter anticipates filing a motion for
`leave to amend the complaint to add claims for declaratory judgment of invalidity under 35 U.S.C.
`§§ 101, 102, 103, and 112.
`PROPOSED SCHEDULE
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`5.
`Amendment of Pleadings, Addition of Parties
`As described above, if VoIP-Pal does not counterclaim for infringement, Twitter anticipates
`filing a motion for leave to amend the complaint to add claims for declaratory judgment of invalidity
`under 35 U.S.C. §§ 101, 102, 103, and 112.
`The parties agree that the deadlines for joining parties and amending the pleadings should be
`in accordance with the proposed schedule set forth in Appendix A.
`6.
`Evidence Preservation
`The parties have reviewed the Northern District of California’s Guidelines for Discovery of
`Electronically Stored Information (“ESI”) and Checklist for Fed. R. Civ. P. 26(f) Meet and Confer
`Regarding ESI, including those portions related to evidence preservation. Each party has
`implemented a litigation hold with respect to materials believed to be relevant to this action.
`7.
`Initial Disclosures
`The parties agree that the deadline for initial disclosures under Fed. R. Civ. P. 26 should be
`in accordance with the proposed schedule set forth in Appendix A.
`8.
`Discovery
`a.
`Protective Order
`The parties agree that a protective order will be necessary in this case in light of the sensitive
`and proprietary information that will be exchanged during discovery. The parties will submit a
`proposed order in accordance with the due dates set forth in Appendix A. In the meantime, the
`Court’s form protective order governs this action pursuant to Patent Local Rule 2-2.
`b.
`Limits to Discovery Requests and Depositions
`Currently, the parties do not anticipate a need to limit or modify the limits set by the Federal
`Rules of Civil Procedure.
`c.
`Electronically Stored Information (ESI)
`The parties will submit a proposed order regarding the discovery of electronically stored
`information to the Court.
`d.
`Electronic Service
`The parties agree to accept service by email. Each counsel will establish an email distribution
`list accessible through a single external email address. Service by email will be treated as service by
`2
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`hand delivery. The parties agree that service by email by 11:59 p.m. Pacific time on a given day will
`be treated as service by personal delivery that day.
`The parties further agree that documents filed publicly through the Court’s ECF system need
`not be separately served by email or otherwise and that ECF filing constitutes personal service as of
`the date and time such document was filed. The parties agree that documents filed under seal or
`manually must be served by email or other electronic means including FTP transfer immediately
`following a related ECF filing, and that the email service of such documents shall relate back to the
`time of the related ECF filing.
`e.
`Privilege Logs
`The parties agree that privileged communications and documents covered by work product
`protection that are dated on or after October 6, 2016, need not be included in any privilege log. This
`exclusion applies only to communications and documents prepared and/or exchanged by or at the
`direction of counsel in anticipation of litigation or for trial; and to communications and documents
`exchanged between the parties and/or their counsel (outside counsel or in-house counsel). In
`addition, nothing herein precludes any party from arguing any alleged waiver of the attorney-client
`privilege by the other party.
`The parties further agree that Pursuant to Fed. R. Evid. 502(d), the production of a privileged
`or work-product-protected document, whether inadvertent or otherwise, is not a waiver of privilege
`or protection from discovery in this case or in any other federal or state proceeding. For example,
`the mere production of privileged or work-product-protected documents in this case as part of a mass
`production is not itself a waiver in this case or in any other federal or state proceeding.
`f.
`Expert Discovery
`The parties agree that the protections provided in Fed. R. Civ. P. 26(b)(4)(B) and (C) will
`apply equally to expert declarations as they do to expert reports, including both drafts of declarations
`and communications related to declarations. In accordance with Fed. R. Civ. P. 26(b)(4), draft expert
`reports, notes, outlines, and any other writings leading up to an expert’s final report(s) are exempt
`from discovery. In addition, all communications with and all materials generated by an expert with
`respect to his or her work on this action are exempt from discovery unless considered by the expert
`in forming his or her opinions. If an expert produces a report, the expert must produce his or her final
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`report and all materials which he or she considered (other than documents produced in discovery).
`9.
`Class Actions
`This litigation is not a class action.
`10.
`Related Cases
`
`a.
`Mobile Gateway Cases
`The following related cases concerning the Mobile Gateway Patents are currently pending
`in this District and before other tribunals:
`In this District:
` Voip-Pal.com, Inc. v. Google, Inc., Case No. 3:22-cv-03199-JD (transferred from
`W.D. Tex. on June 1, 2022)
` VOIP-PAL.COM, INC. v. Meta Platforms, Inc. et al., Case No. 3:22-cv-03202-JD
`(transferred from W.D. Tex. on June 1, 2022)
` Cellco Partnership et al v. Voip-Pal.com, Inc., Case No. 3:21-cv-05275-JD (N.D.
`Cal.) (case stayed)
`In the Western District of Texas:
` VOIP-PAL.COM, INC. v. AMAZON.COM, INC. et al., Case No. 6:21-cv-00668-
`ADA
` VOIP-PAL.COM, INC. v. Verizon Communications, Inc. et al., Case No. 6:21-cv-
`00672-ADA
` VOIP-PAL.COM, INC. v. T-Mobile US, Inc. et al., Case No. 6:21-cv-00674-ADA
` VOIP-PAL.com.Inc. v. Samsung Electronics Co., Ltd et al., Case No. 6:21-cv-01246-
`ADA-DTG
` VOIP-PAL.COM, INC. v. Huawei Technologies Co., LTD et al., Case No. 6:21-cv-
`01247-ADA-DTG
`
`b.
`’606 Cases
`The following cases concerning VoIP-Pal’s U.S. Patent No. 10,218,606 are currently
`pending in this District and before other tribunals:
`In this District:
` VOIP-PAL.COM, INC. v. Meta Platforms, Inc. et al., Case No. 3:22-cv-04279-AGT
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`(transferred from W.D. Tex. on July 25, 2022)
`In the Western District of Texas (subject to motions to transfer to N.D. Cal.):
` VOIP-PAL.COM, INC. v. Google LLC, Case No. 6:20-cv-00269-ADA (stayed
`pending resolution of motion to transfer)
` VOIP-PAL.COM, INC. v. Amazon.Com, Inc. et al., Case No. 6:20-cv-00272-ADA
`(stayed pending resolution of motion to transfer)
`VoIP-Pal’s additional statement: VoIP-Pal disputes that cases concerning the ’606 patent are
`related to cases concerning the Mobile Gateway patents because they concern different VoIP-Pal
`patents from a different patent family. Indeed, on August 25, 2021, Judge Koh denied AT&T’s and
`Apple’s motions to relate case concerning the ’606 patent family to cases concerning the Mobile
`Gateway patents. See Case No. 5:20-cv-2460-LHK, Dkt. 95; Case No. 5:20-cv-2995-LHK, Dkt.
`No. 96. On August 26, 2021, Judge Koh issued an order denying that Case No. 5:21-cv-5275-BLF
`and Case No. 5:20-cv-3092-LHK are related. See Case No. 5:20-cv-3092-LHK, Dkt. No. 78.
`11.
`Relief
`Twitter seeks a declaration that Twitter’s products and services do not infringe any claims of
`the Mobile Gateway Patents.
`VoIP-Pal responded to Twitter’s Complaint by filing a Motion To Dismiss (ECF No. 25),
`which was denied (ECF No. 38). VoIP-Pal has not yet answered the Complaint.
`12.
`Settlement and ADR
`As required by ADR L.R. 3-5, the Parties have reviewed the Court’s ADR handbook,
`discussed the available ADR procedures and considered whether this case would benefit from an
`ADR procedure. The parties have filed their ADR Certification By Parties And Counsel (ECF Nos.
`28, 29).
`13.
`Consent to Magistrate Judge for All Purposes
`The parties do not consent to have a magistrate judge conduct all further proceedings
`including trial and entry of judgment.
`14. Other References
`The parties agree that currently this case is not suitable for reference to binding arbitration, a
`special master, or the Judicial Panel on Multidistrict Litigation.
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`15.
`Narrowing of Issues
`This case currently involves two claims, whether Twitter infringes the two Mobile Gateway
`Patents. VoIP-Pal has not yet answered Twitter’s Complaint and has therefore raised no additional
`issues. The parties do not currently see an opportunity to further narrow the issues in this case.
`16.
`Expedited Trial Procedure
`The parties do not propose that this case proceed under the Expedited Trial Procedure of
`General Order 64.
`17.
`Scheduling
`The parties’ joint scheduling proposal is set forth in the chart attached hereto as Appendix A.
`VoIP-Pal’s additional statement: VoIP-Pal, however, maintains that the schedule in this
`case should be aligned with the schedule in the related cases involving the Mobile Gateway patents
`as noted in paragraph 10 above. The Court has not entered a schedule in any of those cases and each
`of those cases is awaiting an initial Case Management Conference. VoIP-Pal also maintains that the
`Court should conduct claim construction before considering any motion under 35 U.S.C. § 101.
`18.
`Trial
`Twitter has not yet requested a jury trial. VoIP-Pal has not yet answered and therefore has
`not yet made a request.
`19.
`Disclosure of Non-Party Interested Entities or Persons
`Twitter has filed its Certification of Interested Entities or Persons as required by Civil Local
`Rule 3-15. The undersigned certifies that as of this date, other than the named parties, there is no
`such interest to report.
`VoIP-Pal has filed its Certification of Interested Entities or Persons as required by Civil Local
`Rule 3-15. The undersigned certifies that as of this date, other than the named parties, there is no
`such interest to report.
`20.
`Professional Conduct
`The parties have confirmed that all attorneys of record for the parties have reviewed the
`Guidelines for Professional Conduct for the Northern District of California.
`21. Other Matters
`Pursuant to Patent Local Rule 2-1, the parties have also met and conferred regarding the
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`following additional matters:
`
`a.
`
`Proposed modification of the obligations or deadlines set forth in the
`Patent Local Rules
`The Parties propose the deadlines set forth in the attached proposed case schedule in
`Appendix A.
`VoIP-Pal’s additional statement: VoIP-Pal, however, maintains that the schedule in this
`case should be aligned with the schedule in the related cases involving the Mobile Gateway patents
`as noted in paragraph 10 above. The Court has not entered a schedule in any of those cases and
`each of those cases is awaiting an initial Case Management Conference. VoIP-Pal also maintains
`that the Court should conduct claim construction before considering any motion under 35 U.S.C. §
`101.
`
`b.
`Claim Construction Discovery
`The parties’ proposed schedule (Appendix A) addresses timing of fact discovery (including
`damages discovery), as well as the timing of claim construction discovery required under the Patent
`Local Rules.
`
`c.
`Format for Claim Construction Hearing
`With respect to the format of the Claim Construction Hearing, the parties reserve the right
`to provide live testimony from experts during the hearing.
`
`d.
`How the Parties Intend to Educate the Court on the Technology
`The parties recommend that the Court conduct a technology tutorial at the Claim
`Construction Hearing to allow the parties and potentially experts to educate the Court regarding the
`subject matter of the Patent-in-Suit.
`
`e.
`Damages Estimate
`Twitter seeks at least an award of attorneys’ fees, expenses, and costs associated with the
`present action under 35 U.S.C. § 285 and/or under the discretion of this Court. Such fees, costs, and
`expenses cannot be computed at the present time because they will accumulate over the course of
`the litigation.
`VoIP-Pal seeks at least an award of attorneys’ fees, expenses and costs under the Court’s
`equitable jurisdiction, or in the alternative, under 28 U.S.C. § 1927, for being forced to unnecessarily
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`Case 3:21-cv-09773-JD Document 39 Filed 08/05/22 Page 9 of 14
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`litigate the present declaratory judgment action. Such fees, costs, and expenses cannot be computed
`at the present time because they will accumulate over the course of the litigation.
`
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`PROPOSED SCHEDULE
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`Appendix A:
`Proposed Case Schedule
`
`
`
`
`
`Event
`
`
`Initial Case Management
`Conference
`
`
`Defendant’s Answer to the
`Complaint
`
`
`Proposed Joint Protective Order and
`Proposed Order for Discovery of
`Electronically Stored Information.
`
`
`Fed. R. Civ. P. 26(a)(1)
`Initial Disclosures
`
`
`Infringement Contentions &
`Accompanying Production
`
`
`
`Invalidity Contentions &
`Accompanying Production
`
`
`
`Exchange of Terms for Construction
`
`Pat. L.R. 4-1
`
`
`
`Exchange of Preliminary
`Constructions and Extrinsic
`Evidence
`
`Pat. L.R. 4-2
`
`
`
`
`
`Deadline
`
`At the convenience of the Court
`
`August 5, 2022
`
`
`Thirty (30) days after the pleadings are closed
`(including any Answer and Response to any
`Amended Complaint)
`
`
`
`If Defendant asserts a counterclaim for
`infringement: Fourteen (14) days from Proposed
`Joint Protective Order and Proposed Order for
`Discovery of Electronically Stored Information
`
`
`If Defendant asserts a counterclaim for
`infringement: Forty-five (45) days after service of
`Infringement Contentions (See Pat. L.R. 3-3)
`
`If Defendant does not assert a counterclaim for
`infringement: Twenty-four (24) days after Proposed
`Joint Protective Order and Proposed Order for
`Discovery of Electronically Stored Information
`
`
`If invalidity is at issue: Fourteen (14) days after
`service of Invalidity Contentions (See Pat. L.R. 4-1)
`
`If invalidity is not at issue: Forty-two (42) days after
`service of Infringement Contentions (See Pat. L.R. 4-
`1)
`
`
`Twenty-one (21) days after Exchange of
`Terms for Construction (See Pat. L.R. 4-2)
`
`PROPOSED SCHEDULE
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`
`
`Event
`
`
`VoIP-Pal’s Damages Contentions
`
`Pat. L.R. 3-8
`
`
`
`
`
`Deadline
`
`If Defendant asserts a counterclaim of
`infringement: Fifty (50) days after Invalidity
`Contentions
`
`If Defendant does not assert a counterclaim for
`infringement: n/a (damages not at issue)
`
`
`
`Joint Claim Construction &
`Prehearing Statement
`
`Pat. L.R. 4-3
`
`
`Defendants’ Responsive Damages
`Contentions
`
`Pat. L.R. 3-9
`
`
`
`Completion of Claim Construction
`Discovery
`
`Pat. L.R. 4-4
`
`
`Opening Claim Construction Brief
`
`Pat. L.R. 4-5(a)
`
`
`Deadline to Amend Pleadings
`Without Leave of Court
`
`FRCP 15(a)(1)(B)
`
`
`Responsive Claim Construction
`Briefs
`
`Pat. L.R. 4-5(b)
`
`
`Reply Claim Construction Brief
`
`Pat. L.R. 4-5(c)
`
`
`Sixty (60) days after service of Invalidity Contentions
`
`
`If Defendant asserts a counterclaim of
`infringement: Thirty (30) days after service of
`Damages Contentions (See Pat. L.R. 3-9)
`
`If Defendant does not assert a counterclaim for
`infringement: n/a (damages not at issue)
`
`
`Thirty (30) days after service and filing of the Joint
`Claim Construction & Prehearing Statement (See Pat.
`L.R. 4-4)
`
`Forty-five (45) days after service and filing of the
`Joint Claim Construction & Prehearing Statement
`(See Pat. L.R. 4-5(a))
`
`As provided under the Federal Rules of Civil
`Procedure or the Local Rules of this Court.
`
`Fourteen (14) days after service of the Opening Claim
`Construction Brief (See Pat. L.R. 4-5(b))
`
`Seven (7) days after service of the Responsive Claim
`Construction Brief (See Pat. L.R. 4-5(c))
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`
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`Event
`
`
`Claim Construction Hearing
`
`Pat. L.R. 4-6
`
`
`Advice of Counsel Production
`
`Pat. L.R. 3-7
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`
`Close of Fact Discovery
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`
`
`Opening Expert Reports
`
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`Rebuttal Expert Reports
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`Close of Expert Discovery
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`Opening Summary Judgment Briefs
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`Responsive Summary Judgment
`Briefs
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`Reply Summary Judgment Briefs
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`
`Summary Judgment Hearing
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`
`Pretrial Conference
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`
`Trial
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`
`
`
`Dated: August 5, 2022
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`PROPOSED SCHEDULE
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`Deadline
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`Two (2) weeks after submission of the Reply Claim
`Construction Brief (See Pat. L.R. 4-6), subject to the
`Court’s schedule
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`30 days after service of the Court’s
`claim construction ruling
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`60 days after service of the Court’s
`claim construction ruling
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`45 days after close of fact discovery
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`30 days after opening expert reports
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`30 days after rebuttal expert reports
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`45 days after close of expert discovery
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`21 days after opening summary judgment briefs
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`14 days after opening summary judgment briefs
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`At the convenience of the Court
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`At the convenience of the Court
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`At the convenience of the Court
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`
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`PERKINS COIE LLP
`
` /s/Sarah Fowler
`
`Sarah Fowler (Bar No. 264838)
`Moeka Takagi (Bar No. 333226)
`3150 Porter Drive
`Palo Alto, CA 94304-1212
`Phone: 650.838.4300
`SFowler@perkinscoie.com
`11
`Case No. 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 39 Filed 08/05/22 Page 13 of 14
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`MTakagi@perkinscoie.com
`Gene W. Lee (pro hac vice)
`Thomas Matthew (pro hac vice)
`1155 Avenue of the Americas, 22nd floor
`New York, NY 10112-0015
`212.262.6900
`GLee@perkinscoie.com
`TMatthew@perkinscoie.com
`Attorneys for Plaintiff
`Twitter, Inc.
`
`HUDNELL LAW GROUP P.C.
`
`
`
`
`/s/Lewis E. Hudnell
`Lewis E. Hudnell, III (CASBN 218736)
`lewis@hudnelllaw.com
`Nicolas S. Gikkas (CASBN 189425)
`nick@hudnelllaw.com
`HUDNELL LAW GROUP P.C.
`800 W. El Camino Real Suite 180
`Mountain View, California 94040
`Telephone: 650.564.3698
`Facsimile: 347.772.3034
`
`Attorneys for Defendant
`VOIP-PAL.COM, INC.
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`PROPOSED SCHEDULE
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`Case No. 3:21-cv-9773-JD
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`Case 3:21-cv-09773-JD Document 39 Filed 08/05/22 Page 14 of 14
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`/s/Sarah Fowler
`Sarah Fowler
`
`
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`ATTESTATION
`Pursuant to Civil Local Rule 5-1(i)(3), I hereby attest that all signatories to this document
`concur in its filing.
`
`Dated: August 5, 2022
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`Case No. 3:21-cv-9773-JD
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