`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., AMAZON.COM LLC,
`AMAZON WEB SERVICES, INC., A2Z
`DEVELOPMENT CENTER, INC. d/b/a LAB126,
`RAWLES LLC, AMZN MOBILE LLC, AMZN
`MOBILE 2 LLC, AMAZON.COM SERVICES, INC.
`f/k/a AMAZON FULFILLMENT SERVICES, INC.,
`and AMAZON DIGITAL SERVICES LLC,
`
`Defendants.
`
`C.A. No. 1:19-cv-01410-MN
`
`JOINT STIPULATION AND [PROPOSED] ORDER
`
`WHEREAS, on July 12, 2022, this Court entered an Order amending the Scheduling Order
`
`in this action (D.I. 172);
`
`WHEREAS, the parties are diligently working to finalize rebuttal expert reports;
`
`WHEREAS, Plaintiff’s technical expert requires additional time to complete his rebuttal
`
`to Defendants’ expert report concerning alleged patent invalidity;
`
`WHEREAS, the parties have conferred and Defendants have agreed to accommodate
`
`Plaintiff’s request by extending the deadline for the rebuttal and reply expert reports by one-week,
`
`subject to the Court’s approval; and
`
`WHEREAS, the requested extension will not impact the deadline for completing expert
`
`discovery or delay the filing of dispositive motions or any Daubert motions.
`
`IT IS HEREBY STIPULATED AND AGREED, subject to the approval and Order of the
`
`Court, that to allow the parties time to complete rebuttal expert reports, the deadlines in the Court’s
`
`July 12, 2022 Order (D.I 172) shall be amended as set forth in the below table. Except as noted in
`
`1
`
`
`
`Case 1:19-cv-01410-MN Document 175 Filed 09/14/22 Page 2 of 4 PageID #: 2633
`
`the below table, no other dates are to be changed at this stage absent the Court’s instruction or
`
`Order to the contrary.
`
`Existing
`Deadline
`9/15/2022
`10/7/2022
`11/11/2022
`12/9/2022
`1/20/2023
`2/10/2023
`
`TBD
`
`TBD
`TBD
`
`Proposed
`Deadline
`9/22/2022
`10/14/2022
`(Unchanged)
`(Unchanged)
`(Unchanged)
`(Unchanged)
`
`TBD
`
`TBD
`TBD
`
`Event / Deadline
`
`Rebuttal expert report
`Reply expert report
`Expert discovery closes
`Case-dispositive motions and Daubert motions
`Response to dispositive motions and Daubert motions
`Reply to dispositive motions and Daubert motions
`File (i) proposed voir dire, (ii) preliminary jury
`instructions, (iii) final jury instructions, (iv) special
`verdict forms
`Pretrial conference
`Jury Trial (7 days)
`
`2
`
`
`
`Case 1:19-cv-01410-MN Document 175 Filed 09/14/22 Page 3 of 4 PageID #: 2634
`
`WILSON SONSINI GOODRICH & ROSATI
`
` ASHBY & GEDDES
`
`/s/ Ian R. Liston
`Ian R. Liston (#5507)
`Jennifer A. Ward (#6476)
`222 Delaware Avenue, Suite 800
`Wilmington, DE 19801
`iliston@wsgr.com
`jward@wsgr.com
`Telephone: (302) 304-7600
`
`Of Counsel:
`Edward G. Poplawski, admitted pro hac vice
`Erik J. Carlson, admitted pro hac vice
`Ryan S. Benyamin, admitted pro hac vice
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071-2027
`epoplawski@wsgr.com
`ecarlson@wsgr.com
`rbenyamin@wsgr.com
`Telephone: (323) 210-2900
`Facsimile: (866) 974-7329
`James C. Yoon, admitted pro hac vice
`Ryan Smith, admitted pro hac vice
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`jyoon@wsgr.com
`rsmith@wsgr.com
`Telephone: (650) 493-9300
`Facsimile: (650) 493-6811
`Attorneys for VB Assets, LLC
`
`/s/ Steven J. Balick
` Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`Telephone: (302) 654-1888
`Of Counsel:
`J. David Hadden, CSB No. 176148
`Email: dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`Email: sshamilov@fenwick.com
`Ravi R. Ranganath, CSB No. 272981
`rranganath@fenwick.com
`Johnson Kuncheria, CSB No. 335765
`jkuncheria@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`Email: vsalmastlian@fenwick.com
`Sapna Mehta, CSB No. 288238
`Email: smehta@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.520
`Attorneys for Defendants Amazon.com, Inc.,
`Amazon.com LLC, Amazon Web Services, Inc., A2Z
`Development Center, Inc. d/b/a Lab126, Rawles LLC,
`AMZN Mobile LLC, AMZN Mobile 2 LLC,
`Amazon.com Services, Inc. f/k/a Amazon Fulfillment
`Services, Inc., and Amazon Digital Services LLC
`
`3
`
`
`
`Case 1:19-cv-01410-MN Document 175 Filed 09/14/22 Page 4 of 4 PageID #: 2635
`
`SO ORDERED this _____ day of September, 2022.
`
`________________________________
`UNITED STATES DISTRICT JUDGE
`
`4
`
`
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