`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`ROBOCAST, INC., a Delaware corporation
`
`
`Plaintiff,
`
`
`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 limited liability
`company
`
`
`Defendant and Counterclaim Plaintiff.
`
`
`
`
`C.A. No. 1:22-cv-00304-JLH
`
`JURY TRIAL DEMANDED
`
`C.A. No. 1:22-cv-00305-JLH
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF ROBOCAST, INC.’S MOTION TO MODIFY
`JOINT SCHEDULING ORDER
`
`Pursuant to Federal Rule of Civil Procedure 16(b)(4), Plaintiff Robocast, Inc.
`
`(“Robocast”) respectfully submits this Motion to Modify Joint Scheduling Order (the “Motion”).
`
`The grounds for the Motion are set forth in Robocast’s Opening Brief that is being filed
`
`concurrently with the Motion. Robocast’s Proposed Modification to the Court’s Joint
`
`Scheduling Order is attached as Exhibit A to the Declaration of Samuel L. Moore in Support of
`
`Plaintiff Robocast’s Motion to Modify Joint Scheduling Order, which is also being filed
`
`concurrently herewith the Motion. A Proposed form of Order is attached to the Motion for the
`
`Court’s approval.
`
`
`
`1
`
`
`
`Case 1:22-cv-00305-JLH Document 205 Filed 03/12/24 Page 2 of 3 PageID #: 9943
`
`
`
`
`
`
`
`Dated: March 12, 2024
`
`Of Counsel
`
`Cantor Colburn LLP
`Marc N. Henschke (pro hac vice)
`Steven M. Coyle (pro hac vice)
`Andrew C. Ryan (pro hac vice)
`Nicholas A. Geiger (pro hac vice)
`Katherine M. Tassmer (pro hac vice)
`Sara T. Colburn (pro hac vice)
`20 Church Street
`22nd Floor
`Hartford, CT 06103
`Tel.: (860) 286-2929
`Fax: (860) 286-0115
`mhenschke@cantorcolburn.com
`scoyle@cantorcolburn.com
`aryan@cantorcolburn.com
`ngeiger@cantorcolburn.com
`ktassmer@cantorcolburn.com
`scolburn@cantorcolburn.com
`
`MCKOOL SMITH, P.C.
`
`Steven Rizzi (pro hac vice)
`Mariel Talmage (pro hac vice)
`1301 6th Avenue, 32nd floor
`New York, NY 10019
`Telephone: (212) 402-9400
`Fax: (212) 402-9444
`srizzi@McKoolSmith.com
`mtalmage@McKoolSmith.com
`
`Ramy E. Hanna (DE Bar Id# 5494)
`600 Travis Street
`Suite 7000
`Houston, Texas 77002
`Tel: (713) 485-7344
`rhanna@McKoolSmith.com
`
`Casey L. Shomaker (pro hac vice)
`Samuel L. Moore (pro hac vice)
`300 Crescent Court Suite 1500
`Dallas, Texas 75201
`Tel: (214) 978-4000
`
`BAYARD, P.A.
`
`/s/ Stephen B. Brauerman
`Stephen B. Brauerman (#4952)
`Ronald P. Golden III (#6254)
`600 N. King Street, Suite 400
`Wilmington, DE 19801
`Tel.: (302) 655-5000
`Fax: (302) 658-6395
`sbrauerman@bayardlaw.com
`rgolden@bayardlaw.com
`
`Attorneys for Plaintiff
`Robocast, Inc.
`
`
`
`2
`
`
`
`Case 1:22-cv-00305-JLH Document 205 Filed 03/12/24 Page 3 of 3 PageID #: 9944
`
`Fax: (214) 978-4044
`cshomaker@mckoolsmith.com
`smoore@mckoolsmith.com
`
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`3
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