`
`
`
`EXHIBIT A
`
`Note : This chart assumes that the Court grants Plaintiffs leave to file their Second Amended
`Complaint on April 23. All dates after the first date should be based upon when Plaintiffs
`actually file their Second Amended Complaint.
`
`
`Deadline
`
`Item
`
`April 23, 2021
`
`Plaintiffs file unopposed motion (“Motion”) for leave to file
`Second Amended Complaint
`
`Some time after April 23,
`2021
`
`Court grants Plaintiffs’ Motion and Plaintiff files Second
`Amended Complaint
`
`May 7, 2021 or two weeks
`after previous event
`
`Government files Answer or otherwise responds
`
`
`
`June 4, 2021
`
`Plaintiffs serve preliminary infringement contentions arising
`from the Second Amended Complaint including for added
`‘708 patent
`
`
`
`1
`
`
`
`Case 1:19-cv-00859-RTH Document 51-1 Filed 04/23/21 Page 2 of 3
`
`July 2, 2021
`
`Defendant serves preliminary invalidity contentions.
`
`
`
`July 16, 2021
`
`July 30, 2021
`
`August 6, 2021
`
`August 13, 2021
`
`August 20, 2021
`
`Parties exchange claim terms for construction.
`
`Parties exchange proposed claim constructions.
`
`Parties disclose extrinsic evidence. The parties shall disclose
`any extrinsic evidence, including the identity of any expert
`witness they may rely upon with respect to claim construction
`or indefiniteness. With respect to any expert identified, the
`parties shall identify the scope of the topics for the witness’s
`expected testimony. With respect to items of extrinsic
`evidence, the parties shall identify each such item by
`production number or produce a copy of any such item if not
`previously produced.
`Deadline to meet and confer to narrow terms in dispute and
`exchange revised list of terms/constructions.
`
`Plaintiffs file Opening claim construction brief, including any
`arguments that any claim terms are indefinite.
`
`September 10, 2021
`
`Defendant files Responsive claim construction brief.
`
`September 24, 2021
`
`Plaintiffs file Reply claim construction brief.
`
`September 27, 2021
`
`October 8, 2021
`
`October 15, 2021
`
`PLAINTIFFS’ PROPOSED DATE FOR COMPLETION
`OF GOVERNMENT’S LPR PRODUCTION
`Defendant files a Sur-Reply claim construction brief.
`
`
`
`Parties submit Joint Claim Construction Statement.
`
`See General Issues Note #8 regarding providing copies of the
`briefing to the Court and the technical adviser (if appointed).
`
`2
`
`
`
`
`
`
`
`Case 1:19-cv-00859-RTH Document 51-1 Filed 04/23/21 Page 3 of 3
`
`October 22, 2021
`
`October 29, 2021
`
`Parties submit optional technical tutorials to the Court and
`technical adviser (if appointed). Plaintiffs propose that the
`parties should provide at least one month’s notice to the
`other party if they expect to provide a technical tutorial.
`Markman Hearing at [9:00 a.m. or 1:30 p.m.]
`
`November 26, 2021(Day
`After
`Thanksgiving)/December
`3, 2021
`
`DATE PROPOSED BY GOVERNMENT FOR
`DOCUMENT PRODUCTION
`
`3
`
`
`
`
`
`
`
`
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