`
`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
`
`Plaintiffs,
`
`
`
`v.
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`C.A. No. 19-859-RTH
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`E-NUMERATE SOLUTIONS, INC. and
`E-NUMERATE, LLC,
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`
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`THE UNITED STATES OF AMERICA,
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`Defendant.
`
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`JOINT MOTION TO EXTEND CERTAIN DEADLINES
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`
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`Plaintiffs e-Numerate Solutions, Inc. and e-Numerate, LLC (collectively “e-Numerate”)
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`and Defendant United States (“the Government”) jointly move this Court to extend the deadlines
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`for submitting the Protective Order in this matter and several dates relating to the initial disclosures
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`set forth in the Court of Federal Claims Patent Rules. Specifically, the parties respectfully request
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`that the Court extend the deadlines as follows:
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`Event
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`Current Deadline
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`Proposed Deadline
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`14 December 2020
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`21 December 2020
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`14 December 2020
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`15 December 2020
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`14 December 2020
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`18 December 2020
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`16 February 2021
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`17 February 2021
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`16 February 2021
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`19 February 2021
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`Parties Submit Joint
`Protective Order Along With
`Disputed Provisions
`Plaintiffs Serve Preliminary
`Infringement Contentions
`Plaintiffs Serve Documents
`Related To Preliminary
`Infringement Contentions
`Government Serves
`Preliminary Invalidity
`Contentions
`Government Serves
`Documents Related to
`Preliminary Invalidity
`Contentions
`
`
`
`
`1
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`
`
`Case 1:19-cv-00859-RTH Document 37 Filed 12/14/20 Page 2 of 4
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`
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`The parties request the extension of these dates for the following reasons. With regard to
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`the Protective Order deadline, the parties have made significant progress on the negotiation of the
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`Order and have agreed to use this Court’s Protective Order in Wanker v. United States, Case No.
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`18-1660C- RTH as the template for the parties’ additional discussions. The extension of the
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`deadline for the service of the preliminary infringement contentions is to accommodate a
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`scheduling conflict Plaintiffs’ attorneys have in an unrelated matter. The extension of the deadline
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`for the document production accompanying the infringement contentions is to allow for the
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`processing of the documents. The extension of the deadline for the service of preliminary
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`invalidity contentions is to account for the extension granted to Plaintiffs. The extension on the
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`document production deadline accompanying the invalidity contentions is also to account for the
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`extension granted to Plaintiffs. These extensions are not sought for purposes of delay.
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`
`
`2
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`
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`Case 1:19-cv-00859-RTH Document 37 Filed 12/14/20 Page 3 of 4
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`
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`Dated: December 14, 2020
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`
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`Respectfully submitted,
`
`O’KELLY & ERNST, LLC
`
`/s/ Sean T. O’Kelly
`Sean T. O’Kelly
`824 N. Market Street, Suite 1001A
`Wilmington, Delaware 19801
`Tel.: (302) 778-4000
`Fax: (302) 295-2873
`sokelly@oelegal.com
`
`and
`
`O’ROURKE LAW OFFICE, LLC
`Gerard M. O'Rourke
`1201 N. Orange Street
`Suite 7260
`Wilmington, DE 19801-1186
`(484) 770-8046
`gorourke@orourkefirm.com
`
`Attorneys for Plaintiffs e-Numerate
`Solutions, Inc. and e-Numerate LLC
`
`
`
`3
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`
`
`Case 1:19-cv-00859-RTH Document 37 Filed 12/14/20 Page 4 of 4
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`
`
`Of Counsel:
`SCOTT BOLDEN
`Department of Justice
`
`RICHARD M. HUMES
`Associate General Counsel
`GEORGE C. BROWN
`Assistant General Counsel
`Office of the General Counsel
`U.S. Securities and Exchange
`Commission
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`Respectfully submitted,
`
`
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`JEFFREY BOSSERT CLARK
`Acting Assistant Attorney General
`
`GARY L. HAUSKEN
`Director
`
`/s/ Shahar Harel
`SHAHAR HAREL
`Commercial Litigation Branch
`Civil Division
`Department of Justice
`Washington, DC 20530
`Shahar.Harel@udsoj.gov
`Email:
`Telephone:
`(202) 305-3075
`Facsimile:
`(202) 307-0345
`
`COUNSEL FOR THE UNITED STATES OF
`AMERICA
`
`4
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`
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