Case 1:16-cv-00290-MN Document 16 Filed 05/26/16 Page 1 of 5 PageID #: 757
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`GODO KAISHA IP BRIDGE 1,
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`Plaintiff,
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`v.
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`OMNIVISION TECHNOLOGIES, INC.,
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`Defendant.
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`§
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`CIVIL ACTION NO. 1:16-cv-00290-SLR
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`JURY TRIAL DEMANDED
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`STIPULATION AND ORDER FOR EXTENSION OF TIME AND VENUE DISCOVERY
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`WHEREAS on May 16, 2016, Defendant OmniVision Technologies, Inc. (“OmniVision”
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`or “Defendant”) filed a Motion to Transfer Venue to the Northern District of California [D.I. 10-
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`13] (“Motion to Transfer”);
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`WHEREAS Plaintiff Godo Kaisha IP Bridge 1’s (“IP Bridge” or “Plaintiff”) Opposition
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`to the Motion to Transfer is currently due on June 3, 2016. [D.I. 11];
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`WHEREAS OmniVision and IP Bridge (collectively “the parties”) have agreed to
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`conduct early discovery relating only to venue and OmniVision’s Motion to Transfer as follows:
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`1.
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`Within two business days of entry of the Court’s Scheduling Order, IP Bridge will
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`serve its venue discovery requests on OmniVision; and
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`2.
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`OmniVision will respond to IP Bridge’s venue discovery requests within fifteen
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`(15) days of being served with those requests;
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`WHEREAS the parties agree that all other discovery and initial disclosures (with the
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`exception of the disclosures required under Fed. R. Civ. Pro. 7.1) shall be stayed pending a
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`decision from the Court ruling on OmniVision’s Motion to Transfer;
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`STIPULATION AND ORDER FOR EXTENSION OF TIME
`AND VENUE DISCOVERY
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`1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`GODO KAISHA IP BRIDGE 1,
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`
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`Plaintiff,
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`
`
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`
`
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`v.
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`OMNIVISION TECHNOLOGIES, INC.,
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`
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`
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`Defendant.
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`§
`§
`§
`§
`§
`§
`§
`§
`§
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`CIVIL ACTION NO. 1:16-cv-00290-SLR
`
`JURY TRIAL DEMANDED
`
`
`
`STIPULATION AND ORDER FOR EXTENSION OF TIME AND VENUE DISCOVERY
`
`WHEREAS on May 16, 2016, Defendant OmniVision Technologies, Inc. (“OmniVision”
`
`or “Defendant”) filed a Motion to Transfer Venue to the Northern District of California [D.I. 10-
`
`13] (“Motion to Transfer”);
`
`WHEREAS Plaintiff Godo Kaisha IP Bridge 1’s (“IP Bridge” or “Plaintiff”) Opposition
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`to the Motion to Transfer is currently due on June 3, 2016. [D.I. 11];
`
`WHEREAS OmniVision and IP Bridge (collectively “the parties”) have agreed to
`
`conduct early discovery relating only to venue and OmniVision’s Motion to Transfer as follows:
`
`1.
`
`Within two business days of entry of the Court’s Scheduling Order, IP Bridge will
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`serve its venue discovery requests on OmniVision; and
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`2.
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`OmniVision will respond to IP Bridge’s venue discovery requests within fifteen
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`(15) days of being served with those requests;
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`WHEREAS the parties agree that all other discovery and initial disclosures (with the
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`exception of the disclosures required under Fed. R. Civ. Pro. 7.1) shall be stayed pending a
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`decision from the Court ruling on OmniVision’s Motion to Transfer;
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`STIPULATION AND ORDER FOR EXTENSION OF TIME
`AND VENUE DISCOVERY
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`1
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`Case 1:16-cv-00290-MN Document 16 Filed 05/26/16 Page 2 of 5 PageID #: 758
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`WHEREAS the parties further agree to stipulate to an extension of time for IP Bridge to
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`file its Opposition to OmniVision’s Motion to Transfer until fifteen (15) days after OmniVision
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`responds to IP Bridge’s venue discovery requests, if IP Bridge does not file a motion to compel
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`relating to the venue discovery by the 15th day after OmniVision provides its responses; and
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`WHEREAS OmniVision reserves the right to seek venue discovery upon receipt of IP
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`Bridge’s Opposition to OmniVision’s Motion to Transfer and to seek an extension of time to file
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`its reply until fifteen (15) days after IP Bridge responds to OmniVision’s venue discovery
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`requests;
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`WHEREAS the parties further agree that OmniVision’s reply on the Motion to Transfer
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`will be due within fifteen (15) days of IP Bridge’s Opposition, if OmniVision does not serve
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`venue discovery requests on IP Bridge.
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`IT IS HEREBY STIPULATED, by and between Plaintiff and Defendant in the above-
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`referenced actions, through their undersigned counsel and subject to the approval of the Court,
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`that:
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`1.
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`IP Bridge may conduct early discovery relating only to venue and OmniVision’s
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`Motion to Transfer and that within two business days of entry of the Court’s
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`Scheduling Order, IP Bridge will serve its venue discovery requests on
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`OmniVision;
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`2.
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`OmniVision will respond to IP Bridge’s venue discovery requests within fifteen
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`(15) days of being served with those requests;
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`3.
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`All other discovery and initial disclosures (with the exception of the disclosures
`
`required under Fed. R. Civ. Pro. 7.1) shall be stayed pending a decision from the
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`Court ruling on OmniVision’s Motion to Transfer;
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`STIPULATION AND ORDER FOR EXTENSION OF TIME
`AND VENUE DISCOVERY
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`2
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`Case 1:16-cv-00290-MN Document 16 Filed 05/26/16 Page 3 of 5 PageID #: 759
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`4.
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`IP Bridge’s deadline to file its Opposition to OmniVision’s Motion to Transfer is
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`extended until fifteen (15) days after OmniVision responds to IP Bridge’s venue
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`discovery requests, if IP Bridge does not file a motion to compel relating to the
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`venue discovery by the 15th day after OmniVision provides its responses; and
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`5.
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`OmniVision shall have the right to seek venue discovery upon receipt of IP
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`Bridge’s Opposition to OmniVision’s Motion to Transfer and to seek an extension
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`of time to file its reply until fifteen (15) days after IP Bridge responds to
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`OmniVision’s venue discovery requests;
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`6.
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`OmniVision’s reply on the Motion to Transfer is due within fifteen (15) days of
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`IP Bridge’s Opposition, if OmniVision does not serve venue discovery requests
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`on IP Bridge.
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`STIPULATION AND ORDER FOR EXTENSION OF TIME
`AND VENUE DISCOVERY
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`3
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`Case 1:16-cv-00290-MN Document 16 Filed 05/26/16 Page 4 of 5 PageID #: 760
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`STAMOULIS & WEINBLATT LLC
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`By: /s/ Stamatios Stamoulis
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`Stamatios Stamoulis (#4606)
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`Richard C. Weinblatt (#5080)
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`Two Fox Point Centre
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`6 Denny Road, Suite 307
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`Wilmington, DE 19809
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`(302) 999-1540
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`Stamoulis@swdelaw.com
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`Weinblatt@swdelaw.com
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`Attorneys for Plaintiff Godo Kaisha
`IP Bridge 1
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`OF COUNSEL:
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`SHORE CHAN DEPUMPO LLP
`Michael W. Shore (pro hac vice)
`shore@shorechan.com
`Alfonso Garcia Chan (pro hac vice)
`achan@shorechan.com
`Joseph F. DePumpo (pro hac vice)
`jdepumpo@shorechan.com
`Jennifer M. Rynell (pro hac vice)
`jrynell@shorechan.com
`Russell J. DePalma (pro hac vice)
`rdepalma@shorechan.com
`Ari Rafilson (pro hac vice)
`arafilson@shorechan.com
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Telephone: (214) 593-9110
`Facsimile: (214) 593-9111
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`OHASHI & HORN LLP
`Hiromasa Ohashi (pro hac vice)
`ohashi@ohashiandhorn.com
`Jeff J. Horn Jr. (pro hac vice)
`horn@ohashiandhorn.com
`Cody A. Kachel (pro hac vice)
`ckachel@ohashiandhorn.com
`1120 Avenue of the Americas, 4th Floor
`New York, New York 10036
`Telephone: (214) 743-4170
`Facsimile: (214) 743-4179
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`POTTER ANDERSON & CORROON LLP
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`By: /s/ David E.Moore
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`David E.Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byrne (#4446)
`Hercules Plaza
`P.O. Box 951
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`Wilmington, DE 19899
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`(302) 984-6000
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`dmoore@potteranderson.com
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` bpalapura@potteranderson.com
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`Attorneys for Defendant OmniVision
`Technologies, Inc.
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`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
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`Edward G. Poplawski (pro hac vice)
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Tel: (323) 210-2901
`epoplawski@wsgr.com
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`James C. Yoon (pro hac vice)
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Tel: (650) 493-9300
`jyoon@wsgr.com
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`Jennifer J. Schmidt (pro hac vice)
`Madeleine E. Greene (pro hac vice)
`One Market Street
`Spear Tower, Suite 3300
`San Francisco, CA 94105-1126
`Tel: (415) 947-2000
`jschmidt@wsgr.com
`mgreene@wsgr.com
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`STIPULATION AND ORDER FOR EXTENSION OF TIME
`AND VENUE DISCOVERY
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`4
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`Case 1:16-cv-00290-MN Document 16 Filed 05/26/16 Page 5 of 5 PageID #: 761
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`SO ORDERED, this __________ day of _________________________, 2016.
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`_______________________________
`United States District Judge
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`STIPULATION AND ORDER FOR EXTENSION OF TIME
`AND VENUE DISCOVERY
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`5
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