Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 1 of 21 PagelD #: 2157
`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 1 of 21 PageID #: 2157
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`NOKIA TECHNOLOGIESOY,
`
`Plaintiff / Counterclaim Defendant,
`
`V.
`
`HP,Inc.,
`
`Defendant / Counterclaim Plaintiff
`
`
`C.A. No. 23-cv-1237-GBW
`
`This
`
`SCHEDULING ORDER [PATENT, NON-ANDA|
`
`__\ say of JyNe 202 the Court having conducted an
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`initial Rule 16(b) scheduling conference pursuant to Local Rule 16.1(b), and the
`
`parties having determined after discussion that the matter cannot be resolved at
`
`this juncture by settlement, voluntary mediation, or binding arbitration;
`
`IT IS HEREBY ORDEREDthat:
`
`1.
`
`Rule 26(a)(1) Initial Disclosures and E-Discovery Default Standard.
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`Unless otherwise agreed to by the parties, the parties shall make their
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`initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(1) within
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`five (5) days of the date the Court enters this Order. If they have not already
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`done so, the parties are to review the Court's Default Standard for Discovery,
`
`Including Discovery of Electronically Stored Information ("ESI"), which is
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`posted at http://www.ded.uscourts.gov (see Other Resources, Default Standard
`
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`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 1 of 21 PageID #: 2157
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`NOKIA TECHNOLOGIESOY,
`
`Plaintiff / Counterclaim Defendant,
`
`V.
`
`HP,Inc.,
`
`Defendant / Counterclaim Plaintiff
`
`
`C.A. No. 23-cv-1237-GBW
`
`This
`
`SCHEDULING ORDER [PATENT, NON-ANDA|
`
`__\ say of JyNe 202 the Court having conducted an
`
`initial Rule 16(b) scheduling conference pursuant to Local Rule 16.1(b), and the
`
`parties having determined after discussion that the matter cannot be resolved at
`
`this juncture by settlement, voluntary mediation, or binding arbitration;
`
`IT IS HEREBY ORDEREDthat:
`
`1.
`
`Rule 26(a)(1) Initial Disclosures and E-Discovery Default Standard.
`
`Unless otherwise agreed to by the parties, the parties shall make their
`
`initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(1) within
`
`five (5) days of the date the Court enters this Order. If they have not already
`
`done so, the parties are to review the Court's Default Standard for Discovery,
`
`Including Discovery of Electronically Stored Information ("ESI"), which is
`
`posted at http://www.ded.uscourts.gov (see Other Resources, Default Standard
`
`
`
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`for Discovery) and is incorporated herein by reference.
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`2.
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` Joinder of Other Parties and Amendmentof Pleadings. All motions
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`to.join other parties, and to amend or supplement the pleadings, shall be filed on
`
`or before December 2, 2024. Unless otherwise ordered by the Court, any
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`motion to join a party or motion to amend the pleadings shall be made pursuant
`
`to the procedures set forth in Paragraphs 4(g) and 5.
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`3.
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`Disclosures. Absent agreement amongthe parties, and approval of
`
`the Court:
`
`(a)
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`By July 26, 2024,Plaintiff shall identify the accused
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`product(s), including accused methods and systems, and its damages model, as
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`well as the asserted patent(s) that the accused product(s) allegedly infringe(s).
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`Plaintiff shall also produce the file history for each asserted patent.
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`(b) By September 6, 2024, Defendant shall produce core
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`technical documentsrelated to the accused product(s), sufficient to show how
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`the accused product(s) work(s), including but not limited to non-publicly
`
`available operation manuals, productliterature, schematics, and specifications.
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`Defendant shall also producesales figures for the accused product(s).
`
`(c)
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`By October 15, 2024, Plaintiff shall produce an initial claim
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`chart relating each known accused productto the asserted claims each such
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`product allegedly infringes.
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`
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`(d)
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`By December 2, 2024, Defendant shall produce its initial
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`invalidity contentions for each asserted claim, as well as the known related
`
`.
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`invalidating references.
`
`(e)
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`By June 5, 2025, Plaintiff shall provide final infringement
`
`contentions.
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`contentions.
`
`(f)
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`By June 26, 2025, Defendant shall provide final invalidity
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`4.
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`Discovery. Unless otherwise ordered by the Court or agreed to by
`
`parties, the limitations on discovery set forth in the Federal Rules of Civil
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`Procedure shall be strictly observed.
`
`(a)
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`Fact Discovery: Cut Off. All fact discovery in this case shall
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`be initiated so that it will be completed on or before July 25, 2025.
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`(b) Document Production, Document production shall be
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`substantially complete by April 25, 2025.
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`(c)
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`Requests for Admission. A maximum of 50 requests for
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`admission are permitted for eachside.
`
`(d)
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` Interrogatories.
`
`1.
`
`A maximum of30 interrogatories, including
`
`contention interrogatories, are permitted for each side.
`
`ii.
`
`The Court encourages the parties to serve and respond
`
`
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`to contention interrogatories early in the case. In the absence of agreement
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`among the parties, contention interrogatories, if filed, shall first be addressed by
`
`the party with the burden ofproof. The adequacy ofall interrogatory answers
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`shall be judged by the level of detail each party provides(i.e., the more detail a
`
`party provides, the more detail a party shall receive).
`
`(e) Depositions.
`
`i.
`
`Limitation on Hours for Deposition Discovery. Each .
`
`side is limited to a total of 70 hours of taking testimony of fact witnesses by
`
`deposition upon oral examination.
`
`il.
`
`Location of Depositions. Any party or representative
`
`(officer, director, or managing agent) of a party filing a civil action in this
`
`district court must ordinarily be required, upon request, to submit to a
`
`deposition at a place designated within this district. Exceptions to this general
`
`rule may be madeby order of the Court. A defendant who becomes a
`
`counterclaimant, cross-claimant, or third-party plaintiff shall be considered as
`
`having filed an action in this Court for the purpose of this provision.
`
`(f)
`
`Disclosure of Expert Testimony.
`
`i.
`
`Expert Reports. For the party who hastheinitial
`
`burden ofproof on the subject matter, the initial Federal Rule of Civil
`
`Procedure 26(a)(2) disclosure of expert testimony is due on or before August
`
`
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`26, 2025. The supplemental disclosure to contradict or rebut evidence on the
`
`same matter identified by another party is due on or before September 26, 2025.
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`Reply expert reports from the party with the initial burden ofproof are due on
`
`or before October 15, 2025. No other expert reports will be permitted without
`
`either the consentofall parties or leave of the Court. Along with the
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`submissions of the expert reports, the parties shall advise of the dates and times
`
`of their experts’ availability for deposition.
`
`ii.
`
`Objections to Expert Testimony. To the extent any
`
`objection to expert testimony is made pursuant to the principles announcedin
`
`Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), as
`
`incorporated in Federal Rule of Evidence 702,it shall be made by motion no
`
`later than the deadline for dispositive motions set forth herein, unless otherwise
`
`ordered by the Court. Briefing on such motions is subject to the page limits set
`
`out in connection with briefing of case dispositive motions.
`
`iil.
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`Expert Discovery Cut-Off, All expert discovery in this
`
`case shall be initiated so that it will be completed on or before November14,
`
`2025.
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`(g) Discovery Matters and Disputes Relating to Protective Orders.
`
`i.
`
`Any discovery motion filed without first complying
`
`with the following procedures will be denied without prejudice to renew
`
`
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`pursuant to these procedures.
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`Should counselfind, after good faith efforts -
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`including verbal communications among Delaware and Lead Counselforall.
`
`parties to the dispute - that they are unable to resolve a discovery matter or a
`
`disputerelating to a protective order, the parties involved in the discovery
`
`matter or protective order dispute shall submit a joint letter in substantially the
`
`following form:
`
`Dear Judge Williams:
`
`The parties in the above-referenced
`matter write to request the scheduling of a
`discovery teleconference.
`
`The following attorneys, including at
`least one Delaware Counsel andat least one
`Lead Counsel per party, participated in a verbal
`meet- and-confer (in person and/or by
`telephone) on the following date(s):
`
`Delaware Counsel:
`Lead Counsel:
`
`The disputes requiring judicial attention
`are listed below:
`
`[provide here a non-argumentativelist of
`disputes requiring judicial attention]
`
`On a date to be set by separate order, generally not
`
`less than forty-eight (48) hours prior to the conference, the party seeking relief
`
`shall file with the Courtaletter, not to exceed three (3) pages, outlining the
`
`
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`issues in dispute and its position on those issues. On a date to be set by separate
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`order, but generally not less than twenty-four (24) hours prior to the conference,
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`any. party opposing the application for relief may file a letter, not to exceed
`
`three (3) pages, outlining that party's reasons forits opposition.
`
`iv.
`
`Eachparty shall submit two (2) courtesy copiesofits
`
`discovery letter and any attachments.
`
`v.
`
`Should the Court find further briefing necessary upon
`
`conclusion of the telephone conference, the Court will order it. Alternatively,
`
`the Court may chooseto resolve the dispute prior to the telephone conference
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`and will, in that event, cancel the conference.
`
`
`
`5.MotionstoAmend.
`
`(a) Any motion to amend (including a motion for leave to
`
`amend)a pleading shall NOT be accompanied by an openingbrief butshall,
`
`instead, be accompaniedbya letter, not to exceed three (3) pages, describing
`
`the basis for the requested relief, and shall attach the proposed amended
`
`pleading as well as a "blackline" comparison to the prior pleading.
`
`(b) Within seven (7) days after the filing of a motion in
`
`compliance with this Order, any party opposing such a motion shall file a
`
`responsiveletter, not to exceed five (5) pages.
`
`(c) Within three (3) days thereafter, the moving party mayfile a
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`
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`reply letter, not to exceed two (2) pages, and, by this same date, the parties shall
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`file a letter requesting a teleconference to address the motion to amend.
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`6.
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`Motions to Strike.
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`(a) Any motiontostrike any pleading or other documentshall
`
`NOTbe accompanied by an opening brief butshall, instead, be accompanied by
`
`a letter, not to exceed three (3) pages, describing the basis for the requested
`
`relief, and shall attach the documentto be stricken.
`
`(b) Within seven (7) days after the filing of a motion in
`
`compliance with this Order, any party opposing such a motion shall file a
`
`responsiveletter, not to exceed five (5) pages.
`
`(c) Within three (3) days thereafter, the moving party may file a
`
`reply letter, not to exceed two (2) pages, and, by this same date, the parties shall
`
`file a letter requesting a teleconference to address the motiontostrike.
`
`7.
`
`Technology Tutorials. Unless otherwise ordered by the Court, the
`
`parties jointly shall provide the Court, no later than the date on which the Joint
`
`Claim Construction Chart is due, a tutorial on the technology at issue. In that
`
`regard, the parties shall jointly submit to the Court an electronic tutorial ofnot
`
`more than thirty (30) minutes. The tutorial should focus on the technology in
`
`issue and educate the Court about the same and should not be used for
`
`argument. As to the format selected, the parties should confirm the Court's
`
`
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`technical abilities to access the information containedin the tutorial ("mpeg",
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`"quicktime", etc.). The parties may choose to file their tutorial under seal,
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`subject to any protective orderin effect..
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`8.
`
`Claim Construction Issue Identification. On or before December
`
`16, 2024, the parties shall exchangea list of those claim term(s)/phrase(s) that
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`they believe need construction and their proposed claim construction of those
`
`term(s)/phrase(s). On or before December 23, 2024, the parties shall respond to .
`
`and provide their proposed construction for any term(s)/phrase(s) presented by
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`the other side for which the party did not initially provide a construction. These
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`documents will not be filed with the Court. Subsequent to exchangingthatlist,
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`the parties will meet and confer to prepare a Joint Claim Construction Chart to
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`be filed no later than January 7, 2025. The Joint Claim Construction Chart, in
`
`Word format, shall be e-mailed simultaneously with filing to
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`gbw_civil@ded.uscourts.gov. The parties' Joint Claim Construction Chart
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`should identify for the Court the term(s)/phrase(s) ofthe claim(s) in issue, and
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`should include each party's proposed construction of the disputed claim
`
`language with citation(s) only to the intrinsic evidence in support oftheir
`
`respective proposed constructions. A copy of the patent(s) in issue as well as
`
`those portions ofthe intrinsic record relied upon shall be submitted with this
`
`Joint Claim Construction Chart. In this joint submission, the parties shall not
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`
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`provide argument.
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`9.
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`Claim Construction Briefing. Plaintiff shall serve, but not file, its
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`openingbrief, not to exceed 5,000 words, on January 17, 2025. Defendant shall
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`serve, but notfile, its answering brief not to exceed 7,500 words, on February
`
`22, 2025. Plaintiff shall serve, but notfile, its reply brief, not to exceed 5,000
`
`words, on March 7, 2025. Defendantshall serve, butnotfile its sur-reply brief,
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`not to exceed 2,500 words, on March 21, 2025. No later than March 28, 2025
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`the parties shall file a Joint Claim Construction Brief. The parties shall copy and
`
`paste their untiled briefs into one brief, with their positions on each claim term
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`in sequential order, in substantially the form below.
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`JOINT CLAIM CONSTRUCTION BRIEF
`
`1.
`
`2.
`
`Agreed-Upon Constructions
`
`Disputed Constructions
`
`[TERM 1]
`
`(a)
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`Plaintiffs Opening Position
`
`(b) Defendant's Answering Position
`
`(c)
`
`Plaintiffs Reply Position
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`(d) Defendant's Sur-Reply Position
`
`[TERM 2]
`
`1.
`
`Plaintiffs Opening Position
`
`10
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`
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`2.
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`3.
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`4.
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`Defendant's Answering Position
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`Plaintiffs Reply Position
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`Defendant's.Sur-Reply Position
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`If there are any materials that would be submitted in an index,the parties
`
`shall submit them in a Joint Appendix.
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`10. Hearing on Claim Construction, Beginning at 1:00 p.m. on April
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`21, 2025, the Court will hear argument on claim construction. Theparties shall
`
`notify the Court, by joint letter submission, no later than the date on whichtheir
`
`answering claim construction briefs are due: (i) whether they request leaveto
`
`present testimony at the hearing; and(ii) the amount of time they are requesting
`
`be allocated to them for the hearing.
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`Provided that the parties comply with all portions of this Scheduling
`
`Order, and any other orders of the Court, the parties should anticipate that the
`
`Court will issue its claim construction order within sixty (60) days of the
`
`conclusion of the claim construction hearing. If the Court is unable to meetthis
`
`goal, it will advise the parties no later than sixty (60) days after the conclusion
`
`of the claim construction hearing.
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`11.
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`Interim Status Report, On June 18, 2025, counsel shall submit a
`
`joint letter to the Court with an interim report of the matters in issue and the
`
`progress of discovery to date. Thereafter, if the Court deems it necessary,it will
`
`11
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`
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`schedule a status conference.
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`12.
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`Supplementation. Absent agreement amongthe parties, and
`
`approval of the Court,
`
`(a)
`
`nolater than June 5, 2025 the patentee mustfinally
`
`supplementthe identification of all accused products and servefinal
`
`infringement contentions; and
`
`(b)
`
`nolater than June 26, 2025 the accused infringers must
`
`finally supplement the identification ofall invalidity references andservefinal
`
`invalidity contentions.
`
`13.
`
`Case Dispositive Motions.
`
`(a) All case dispositive motions, an opening brief, and
`
`affidavits, if any, in support ofthe motion shall be served and filed on or before
`
`December 15, 2025. Briefing will be presented pursuantto the Court's Local
`
`Rules. No case dispositive motion under Rule 56 maybefiled more than ten
`
`(10) days before the above date without leave of the Court.
`
`(b)
`
`Concise Statement of Facts Requirement. Any motion for
`
`summary judgmentshall be accompanied by a separate concise statement, not
`
`to exceed six (6) pages, which details each material fact which the moving party
`
`contendsis essential for the Court's resolution of the summary judgment motion
`
`(not the entire case) and as to which the moving party contendsthere is no
`
`12
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`
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`genuine issue to be tried. Each fact shall be set forth in a separate numbered
`
`paragraph and shall be supported by specific citation(s) to the record.
`
`Anyparty opposing the motion shall include with its opposing
`
`papers a response to the movingparty's concise statement, not to exceed six (6)
`
`pages, which admits or disputes the facts set forth in the movingparty's concise
`
`statement on a paragraph-by-paragraphbasis. To the extent a fact is disputed,
`
`the basis of the dispute shall be supported by specific citation(s).to the record.
`
`Failure to respondto a fact presented in the moving party's concise statement of
`
`facts shall indicate that fact is not in dispute for purposes of summary judgment.
`
`The party opposing the motion mayalso include with its opposing papers a
`
`separate concise statement, not to exceed four (4) pages, which sets forth
`
`material facts as to which the opposing party contendsthere is a genuine issue
`
`to be tried. Each fact asserted by the opposing party shall also be set forth in a
`
`separate numbered paragraph andshall be supported by specific citation(s) to
`
`the record.
`
`The movingparty shall include with its reply papers a response to
`
`the opposing party's concise statementof facts, not to exceed four (4) pages, on
`
`a paragraph-by-paragraphbasis. Failure to respondto a fact presentedin the
`
`opposing party's concise statement of facts shall indicate that fact remains in
`
`dispute for purposes of summary judgment.
`
`13
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`
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`(c)
`Page limits combined with Daubert motion page limits. Each
`party is permitted to file as many case dispositive motions as desired provided,
`
`however, that each SIDE will be limited to a combinedtotal of 40 pages for all
`
`opening briefs, a combinedtotal of 40 pages for all answering briefs, and a
`
`combinedtotal of 20 pages for all reply briefs regardless of the number of case
`
`dispositive motionsthatare filed. In the eventthat a party files, in addition to a
`
`case dispositive motion, a Daubert motion to exclude or precludeall or any
`
`portion of an expert's testimony, the total amount of pages permitted for all case
`
`dispositive and Daubert motionsshall be increased to 50 pagesfor all opening
`
`briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs for
`
`each SIDE.!
`
`(d)
`
`Ranking of Summary Judgment Motions. Any party that
`
`files more than one summary judgment motion shall number each motion to
`
`indicate the order in which the party wishes the Court to review its pending
`
`motions. The first motion the party wishes the Court to consider shall be
`
`designated #1, the second motion shall be designated #2, and so on. The Court
`
`' The parties must work together to ensure that the Court receives no more than
`a total of 250 pages(i.e., 50 + 50 + 25 regarding oneside's motions, and 50 +
`50 + 25 regarding the other side's motions) of briefing on all case dispositive
`motions and Daubert motions that are covered by this scheduling order and any
`other scheduling order entered in any related case that is proceeding on a
`consolidated or coordinated pretrial schedule.
`
`14
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`
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`will review the party's summary judgment motions in the order designated by
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`the party. If the Court decides to deny a motionfiled by theparty, barring
`
`exceptional reasons determined sua sponte by the Court, the Court will not
`
`review any lower ranked summary judgment motionsfiled by the party.
`
`14. Applications by Motion. Except as otherwise specified herein, any
`
`application to the Court shall be by written motion. Any non-dispositive motion
`
`should contain the statement required by Local Rule 7.1.1.
`
`15. Application to Court for Protective Order, Should counsel find it
`
`will be necessary to apply to the Court for a protective order specifying terms
`
`and conditions for the disclosure of confidential information, counsel should
`
`confer and attempt to reach an agreement on a proposed form of order and
`
`submit it to the Court within ten (10) days from the date the Court enters this
`
`Order. Should counsel be unable to reach an agreement on a proposed form of
`
`order, counsel must follow the provisions of Paragraph 4(g) above.
`
`Any proposedprotective order must include the following paragraph:
`
`Other Proceedings. By entering this order and
`limiting the disclosure of informationin this case,
`the Court does not intend to preclude another court
`from finding that information may be relevant and
`subject to disclosure in another case. Any person or
`party subject to this order who becomessubject to a
`motion to disclose another party's information
`designated "confidential" [the parties shouldlist any
`other level of designation, such as "highly
`
`15
`
`
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`confidential," which may be providedfor in the
`protective order] pursuant to this order shall
`promptly notify that party of the motion so that the
`party may have an opportunity to appear and be
`heard on whetherthat information should be
`disclosed.
`
`16.
`
`Papers Filed Under Seal. In accordance with section G ofthe
`
`Revised Administrative Procedures Governing Filing and Service by Electronic
`
`Means, a redacted version of any sealed document shall be filed electronically
`
`within seven (7) daysofthefiling of the sealed document.
`
`17.
`
`Courtesy Copies. The parties shall provide to the Court two (2)
`
`courtesy copies offilings(i.e., briefs, appendices, exhibits, declarations,
`
`affidavits etc.). Courtesy copies of appendices and exhibits should include hard
`
`tabs. This provision also applies to papers filed underseal.
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`18. Motions in Limine, Motionsin limine shall not be separately filed.
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`All in limine requests and responsesthereto shall be set forth in the proposed
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`pretrial order. Each SIDE shall be limited to three (3) in limine requests, unless
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`otherwise permitted by the Court. The in /imine request and any response shall
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`contain the authorities relied upon; each in limine request may be supported by
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`a maximum ofthree (3) pages of argument, may be opposed by a maximum of
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`three (3) pages of argument, and the side making the in limine request may add
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`a maximum of one (1) additional page in reply in support ofits request. If more
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`16
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`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 17 of 21 PagelD #: 2173
`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 17 of 21 PageID #: 2173
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`than one party is supporting or opposing an in limine request, such support or
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`opposition shall be combined in a single three (3) page submission (and,if the
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`moving party, a single one (1) page reply), unless otherwise ordered by the.
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`Court. No separate briefing shall be submitted on in limine requests, unless
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`otherwise permitted by the Court.
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`19. Pretrial Conference. On June 2, 2026, the Court will holdapretrial
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`conference in Court with counsel beginning at 3:00 p.m. Unless otherwise
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`ordered by the Court, the parties should assumethatfiling the pretrial order
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`satisfies the pretrial disclosure requirement of Federal Rule of Civil Procedure
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`26(a)(3). The parties shall file with the Court the joint proposed final pretrial
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`order in compliance with Local Rule 16.3(c) and the Court's Preferences and
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`Procedures for Civil Cases not later than seven (7) days before the pretrial
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`conference. Unless otherwise ordered by the Court, the parties shall comply
`with the timeframesset forth in Local Rule 16.3(d)(1)-(3) for the preparation of |
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`the joint proposedfinal pretrial order.
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`The parties shall provide the Court two (2) courtesy copies of the joint
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`proposedfinal pretrial order and all attachments. The proposedfinal pretrial
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`order shall contain a table of contents and the paragraphs shall be numbered.
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`20.
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`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a
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`caseis to betried to a jury, pursuant to Local Rules 47.l(a)(2) and 51.1 the
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`17
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`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 18 of 21 PagelD #: 2174
`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 18 of 21 PageID #: 2174
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`parties should file (i) proposedvoir dire,(ii) preliminary jury instructions,(iii)
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`final jury instructions, and (iv) special verdict forms seven (7) business days
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`before the final pretrial conference. This submission shall be accompanied by a
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`courtesy copy containing electronic files of these documents,in Microsoft
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`Word format, which may be submitted by e-mail to
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`gbw_civil@ded.uscourts.gov.
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`21.
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`Trial. This matter is scheduled for a five day jury trial beginningat
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`9:30 a.m. on June 8, 2026 with the subsequenttrial days beginning at 9:30
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`a.m. Until the case is submitted to the jury for deliberations, the jury will be
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`excused each day at 5:30 p.m. Thetrial will be timed, as counsel will be
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`allocated a total number of hours in which to present their respective cases.
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`22.
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`Judgment on Verdict and Post-Trial Status Report. Within seven
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`(7) days after a jury returns a verdict in any portion of a jury trial, the parties
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`shall jointly submit a form of order to enter judgment on the verdict. At the
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`same time, the parties shall submit a joint status report, indicating among other
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`things how the case should proceed andlisting any post-trial motions each party
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`intendsto file.
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`23.
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` Post-Trial Motions. Unless otherwise ordered by the Court, all
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`SIDESare limited to a maximum of 20 pages of opening briefs, 20 pages of
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`answering briefs, and 10 pages ofreply briefs relating to any post-trial motions
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`18
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`
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`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 19 of 21 PagelD #: 2175
`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 19 of 21 PageID #: 2175
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`filed by that side, no matter how many such motionsarefiled.
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`24.
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`ADRProcess. This matteris referred to a magistrate judge to
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`
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`The Honorable Gregory B. Williams
`United States District Judge
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`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 20 of 21 PagelD #: 2176
`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 20 of 21 PageID #: 2176
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`Counsel Shall Provide a Chart of All Relevant Deadlines
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` Plaintiff shall identify asserted patent(s), the accused
`product(s), and damages model. Plaintiff shall also
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`producethe file history for each asserted patent
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`
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`Defendant shall produce core technical documents and|September 6, 2024
`sales figures for the accused product(s).
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`October 15, 2024
`Initial Infringement Contentions
`Joinder of Other Parties and Amendment of Pleadings|December 2, 2024
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`Initial Invalidity Contentions -|December2, 2024 --
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`December 16, 2024,
`Theparties shall exchangea list of those claim
`term(s)/phrase(s) that they believe need construction
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`and their proposed claim construction of those
`term(s)/phrase(s).
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`
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`Theparties shall respond to and provide their proposed|December 23, 2024
`construction for any term(s)/phrase(s) presented by the
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`other side for which the party did notinitially provide a
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`construction.
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`July 26, 2024
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`csit|
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`Tutorials
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`January 7, 2025
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`February 22, 2025
`March 7, 2025
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`March 21, 2025
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`April 28, 2025
`June 5, 2025
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`June 18, 2025
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`June 26, 2025
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`July 25, 2025
`August 26, 2025
`September 26, 2025
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`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 21 of 21 PagelD #: 2177
`Case 1:23-cv-01237-GBW Document 33 Filed 06/17/24 Page 21 of 21 PageID #: 2177
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`Responsesto Case Dispositive Motions and Daubert ~|January 21,2026 -
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`October 15, 2025
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`November 14, 2025
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`Reply Expert Reports
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`Expert Discovery Cut-Off
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`December 15, 2025
`Case Dispositive Motions and Daubert Motions
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`Motions
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`Replies in Support of Case Dispositive Motions and
`Daubert Motions
`Final Pretrial Conference
`Jury Selection/Trial
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`February 3, 2026
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`June 2, 2026,at 3:00 p.m.
`June 8, 2026, at 9:30 a.m.
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