`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`ROBOCAST, INC., a Delaware corporation,
`
`
`
`v.
`
`YOUTUBE, LLC, a Delaware limited liability
`company; and GOOGLE LLC, a Delaware limited
`liability company,
`
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendants.
`
`
`
`C.A. No. 22-304-JLH
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`STIPULATION AND [PROPOSED] ORDER
`MODIFYING SCHEDULING ORDER
`
`WHEREAS, the Court recently set the Markman hearing in this matter for September 5,
`
`2024 (D.I. 219);
`
`WHEREAS, the current deadline for Opening Expert Reports in this matter is also
`
`September 5, 2024 (D.I. 161);
`
`WHEREAS, the Parties have met and conferred to address that scheduling overlap as well
`
`allow for the scheduling of remaining depositions in fact discovery, which the Parties continue to
`
`diligently work on completing;
`
`WHEREAS, the Parties need additional time to complete the remaining depositions in fact
`
`discovery in light of counsel and witness availability;
`
`WHEREAS, the Parties are not requesting any adjustments to hearing dates for the Court;
`
`IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto, and
`
`subject to the approval of the Court, that:
`
`1.
`
`The Scheduling Order (D.I. 161) is modified as follows:
`
`
`
`
`
`
`Case 1:22-cv-00304-JLH Document 244 Filed 07/24/24 Page 2 of 3 PageID #: 10003
`
`
`
`Event
`
`Markman Hearing
`
`Fact Discovery Cut Off
`
`
`Original Date
`
`New Date
`
`September 5, 2024
`
`September 5, 20241
`
`July 26, 2024
`
`September 30, 2024
`
`(No additional deposition
`notices may be served
`based on this modification,
`and this does not modify
`the elapsed deadline to
`serve written discovery)
`60 days after the Court’s
`Markman ruling
`30 days after Opening
`Expert Reports
`
`Four weeks after Rebuttal
`Expert Reports
`
`Four weeks after Reply
`Expert Reports
`
`One week after
`Completion of Expert
`Depositions
`
`One week after Reducing
`Asserted Claims
`
`Ten days after Reducing
`Prior Art
`
`30 days after Opening
`Briefs for Case Dispositive
`Motions
`
`30 days after Answering
`Briefs for Case Dispositive
`Motions
`
`
`Opening Expert Reports
`
`Rebuttal Expert Reports
`
`
`Reply Expert Reports
`
`
`September 5, 2024
`
`October 7, 2024
`
`November 1, 2024
`
`Completion of Expert Depositions
`
`
`November 27, 2024
`
`Reducing Asserted Claims
`
`
`December 4, 2024
`
`Reducing Prior Art
`
`
`Opening Briefs for Case
`Dispositive Motions
`
`Answering Briefs for Case
`Dispositive Motions
`
`
`December 11, 2024
`
`December 20, 2024
`
`January 17, 2025
`
`Reply Briefs for Case Dispositive
`Motions
`
`
`February 14, 2025
`
`
`1 This date remains unchanged and is the only date shared with the co-pending case filed by
`Robocast, Robocast, Inc. v. Netflix, Inc., C.A. No. 22-304-JLH. No date coordinated with the
`Netflix matter is impacted by this stipulation.
`
`2
`
`
`
`Case 1:22-cv-00304-JLH Document 244 Filed 07/24/24 Page 3 of 3 PageID #: 10004
`
`2.
`
`Pursuant to the Court’s prior Order (D.I. 161 ¶ 2), the deadlines relating to motions
`
`in limine, and the dates for the pretrial conference and trial shall be scheduled after the Court issues
`
`its rulings on case dispositive motions.
`
`/s/ Stephen B. Brauerman
`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.
`
`Dated: July 19, 2024
`
`/s/ Frederick L. Cottrell, III
`Frederick L. Cottrell, III (#2555)
`Christine D. Haynes (#4697)
`Richards, Layton & Finger, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`haynes@rlf.com
`
`Attorneys for Defendants YouTube, LLC and
`Google LLC
`
`24th
`July
`SO ORDERED this _______day of ____________________, 2024.
`
`The Honorable Jennifer L. Hall
`United States District Judge
`
`3
`
`
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