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`September 9, 2019
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`VIA E-FILING
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`The Honorable Leonard P. Stark
`J. Caleb Boggs Federal Building
`844 N. King Street, Unit 26, Room 6124
`Wilmington, Delaware 19801-3556
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`RE: Elm 3DS Innovations, LLC v. Samsung Electronics Co., Ltd., et al.,
`(C.A. No. 14-cv-1430-LPS)
`Elm 3DS Innovations, LLC v. Micron Technology, Inc., et al.,
`(C.A. No. 14-cv-1431-LPS)
`Elm 3DS Innovations, LLC v. SK Hynix Inc., et al.,
`(C.A. No. 14-cv-1432-LPS)
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`Dear Chief Judge Stark:
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`Pursuant to D.I. 221, the parties are currently scheduled to exchange revised opening claim
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`construction briefs on Monday, September 9 in anticipation of a Markman Hearing on November
`15. Elm’s counsel has a conflicting trial scheduled in November and has consulted with each
`Defendant. The Defendants have indicated that they do not oppose rescheduling the Markman
`Hearing until January or at the Court’s convenience thereafter. Elm thus requests the Court
`continue the Markman to early January (or at the Court’s convenience thereafter).
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`Additionally, the parties are finalizing the disputed claim construction issues and, therefore,
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`request additional time to exchange revised opening claim construction briefs. The parties met and
`conferred, and have agreed-upon the following schedule which the parties respectfully request that
`the Court enter:
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`Current Date New Date
`Deadline
`Revised Opening Briefs Exchanged Sept. 9
`Oct. 7
`Answering Briefs Exchanged
`Oct. 7
`Nov. 4
`File Joint Brief and Related Material Oct. 14
`Nov. 11
`Markman Hearing
`Nov. 15
`Early January (or at the Court’s
`convenience thereafter)
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`
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`Attached for the Court’s consideration is a proposed Order embodying the above proposed
`schedule. We are available at the Court’s convenience should Your Honor have any questions.
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`Respectfully submitted,
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`/s/ Brian E. Farnan
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`cc: Counsel of Record (Via E-Filing)
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`Brian E. Farnan
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`9 1 9 N . M A R K E T S T R E E T , 1 2 T H F L O O R , W I L M I N G T O N , D E 1 9 8 0 1
`P H O N E : ( 3 0 2 ) 7 7 7 – 0 3 0 0 · F A X : ( 3 0 2 ) 7 7 7 – 0 3 0 1 · W W W . F A R N A N L A W . C O M
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