`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`ROBOCAST, INC., a Delaware corporation
`
`
`Plaintiff,
`
`
`C.A. No. 1:22-cv-00304-JLH
`
`JURY TRIAL DEMANDED
`
`C.A. No. 1:22-cv-00305-JLH
`
`JURY TRIAL DEMANDED
`
`v.
`
`YOUTUBE, LLC, a Delaware limited liability
`company; and GOOGLE LLC, a Delaware
`limited liability company,
`
`
`Defendants.
`
`
`
`ROBOCAST, INC., a Delaware corporation
`
`
`Plaintiff and Counterclaim Defendant,
`
`
`v.
`
`NETFLIX, INC., a Delaware corporation
`
`
`Defendant and Counterclaim Plaintiff.
`
`
`
`
`MOTION FOR TELECONFERENCE TO
`RESOLVE SCHEDULING DISPUTE
`
`Plaintiff Robocast, Inc. (“Robocast”), Defendants YouTube, LLC and Google LLC
`
`(collectively “YouTube”), and Defendant Netflix, Inc. (“Netflix”) respectfully move this Court to
`
`schedule a teleconference to address Robocast’s Motion to Modify Joint Scheduling Order.
`
`The following attorneys, including at least one Delaware Counsel and at least one Lead
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`Counsel per party, participated in a verbal meet-and-confer by telephone on the following date:
`
`February 14, 2024.
`
`Delaware Counsel: Stephen B. Brauerman, Ronald P. Golden III (for Robocast);
`
`Frederick L. Cottrell, III, Griffin A. Schoenbaum (for YouTube); and Kelly E. Farnan, Sara M.
`
`Metzler (for Netflix).
`
`
`
`1
`
`
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`Case 1:22-cv-00304-JLH Document 143 Filed 03/14/24 Page 2 of 3 PageID #: 7819
`
`
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`Lead Counsel: Steven Rizzi, Marc Henschke, William D. Ellerman, Ari Rafilson, Casey
`
`L. Shomaker (for Robocast); Jordan F. Jaffe (for YouTube); and Tara D. Elliott, Rachel Weiner
`
`Cohen, Ashley M. Fry, Kimberly Q. Li (for Netflix).
`
`The parties are available for a teleconference on the following dates, or at the Court’s
`
`convenience:
`
` Robocast is available on March 28, 29 and April 5, 8, 9 at a time of day convenient
`
`for the Court.
`
` Netflix is available on March 19 (after 3pm ET), March 22, and April 5.
`
` YouTube is available for the dates proposed by both Netflix and Robocast except
`
`for April 8 and April 9.
`
`Robocast proposes that Robocast may file a six (6) page letter brief in support of its Motion
`
`to Amend the Scheduling Order; YouTube may file a three (3) page responsive letter brief; and
`
`Netflix may file a three (3) page responsive letter brief in accordance with a briefing schedule set
`
`by the Court in advance of a telephone conference. Netflix and YouTube believe the Court’s
`
`standard limit for letter briefs is appropriate here, with each party’s letter brief not exceeding three
`
`(3) pages.
`
`Dated: March 14, 2024
`
`/s/ Ronald P. Golden III
`Stephen B. Brauerman (#4952)
`Ronald P. Golden III (#6254)
`Bayard, P.A.
`600 North King Street, Suite 400
`Wilmington, DE 19801
`(302) 655-5000
`sbrauerman@bayardlaw.com
`rgolden@bayardlaw.com
`
`Attorneys for Plaintiff Robocast, Inc.
`
`
`
`
`
`
`
`
`
`
`
`/s/ Sara M. Metzer
`Kelly E. Farnan (#4395)
`Sara M. Metzer (#6509)
`Richards, Layton & Finger, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`farnan@rlf.com
`metzler@rlf.com
`
`Attorneys for Defendant Netflix, Inc.
`
`
`
`2
`
`
`
`Case 1:22-cv-00304-JLH Document 143 Filed 03/14/24 Page 3 of 3 PageID #: 7820
`
`
`
`
`/s/ Frederick L. Cottrell, III
`Frederick L. Cottrell, III (#2555)
`Griffin A. Schoenbaum (#6915)
`Richards, Layton & Finger, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`schoenbaum@rlf.com
`
`Attorneys for Defendants YouTube, LLC and
`Google LLC
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`3
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