Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 1 of 7
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`IRONBURG INVENTIONS LTD.,
`
`Plaintiff,
`
`v.
`
`VALVE CORPORATION,
`
`Defendant.
`
`Civil Action No.
`1:15-cv-04219-TWT
`
`
`
`STIPULATION AND SCHEDULING ORDER TO EXTEND TIME
`
`In light of the Order granting the parties’ stipulation for Plaintiff to file a
`
`new complaint adding a patent that was not previously asserted (D.I. 43), and in
`
`light of Plaintiff filing the new complaint (D.I. 44), Plaintiff and Defendant, by and
`
`through their respective attorneys, and subject to the approval of the Court, hereby
`
`stipulate that the scheduling order (D.I. 24, 19) is amended as follows:
`
`DEADLINE OR EVENT
`
`Disclosure of Asserted
`Claims and Preliminary
`Infringement Contentions
`for U.S. Patent No.
`9,352,229
`
`CURRENT DATES
`[D.I. 19, 24]
`
`NEW DATES
`
`N/A
`
`August 19, 2016
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`IRONBURG INVENTIONS LTD.,
`
`Plaintiff,
`
`v.
`
`VALVE CORPORATION,
`
`Defendant.
`
`Civil Action No.
`1:15-cv-04219-TWT
`
`
`
`STIPULATION AND SCHEDULING ORDER TO EXTEND TIME
`
`In light of the Order granting the parties’ stipulation for Plaintiff to file a
`
`new complaint adding a patent that was not previously asserted (D.I. 43), and in
`
`light of Plaintiff filing the new complaint (D.I. 44), Plaintiff and Defendant, by and
`
`through their respective attorneys, and subject to the approval of the Court, hereby
`
`stipulate that the scheduling order (D.I. 24, 19) is amended as follows:
`
`DEADLINE OR EVENT
`
`Disclosure of Asserted
`Claims and Preliminary
`Infringement Contentions
`for U.S. Patent No.
`9,352,229
`
`CURRENT DATES
`[D.I. 19, 24]
`
`NEW DATES
`
`N/A
`
`August 19, 2016
`
`
`
`Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 2 of 7
`
`DEADLINE OR EVENT
`
`Disclosure of Preliminary
`Non- Infringement and
`Invalidity Contentions for
`U.S. Patent No. 9,352,229
`(pursuant to LPR 4.4(b))
`Exchange of Proposed
`Terms and Claim Elements
`for Construction (pursuant
`to LPR 6.1)
`Exchange of Preliminary
`Claim Constructions and
`Extrinsic Evidence
`(pursuant to LPR 6.2)
`Joint Claim Construction
`Statement (pursuant to LPR
`6.3)
`
`Claim Construction
`Discovery Concludes
`(pursuant to LPR 6.4)
`
`Opening Claim
`Construction Briefs
`(pursuant to LPR 6.5)
`
`Response Claim
`Construction Briefs
`(pursuant to LPR 6.5)
`Claim Construction
`Hearing (pursuant to LPR
`6.6)
`
`CURRENT DATES
`[D.I. 19, 24]
`
`NEW DATES
`
`N/A
`
`September 19, 2016
`
`Pursuant to LPR, on or
`about August 30, 2016
`
`October 11, 2016
`
`Pursuant to LPR, on or
`about September 19,
`2016
`Pursuant to LPR, on or
`about October 11,
`2016
`
`Pursuant to LPR, on or
`about October 26,
`2016
`
`Pursuant to LPR, on or
`about November 10,
`2016
`
`Pursuant to LPR, on or
`about November 30,
`2016
`
`October 31, 2016
`
`November 22, 2016
`
`December 7, 2016
`
`December 22, 2016
`
`January 11, 2017
`
`pursuant to LPR, at the
`Court's convenience
`
`At the Court’s
`convenience
`
`2
`
`
`
`Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 3 of 7
`
`DEADLINE OR EVENT
`
`Claim Construction Order
`
`Final Infringement
`Contentions (pursuant to
`LPR 4.5(c))
`
`Final Invalidity
`Contentions (pursuant to
`LPR 4.5(c))
`
`Final Non-Infringement
`Contentions (pursuant to
`LPR 4.5(c))
`
`Fact Discovery Deadline
`(pursuant to LR Appendix F)
`Disclosure of Expert
`Reports on Issues Where
`the Party Bears the Burden
`of Proof (pursuant to LPR
`7.1(b))
`Disclosure of Expert
`Reports on Issues Where
`the Opposing Party Bears
`the
`Burden of Proof (pursuant
`to LPR 7.1(c))
`
`CURRENT DATES
`[D.I. 19, 24]
`pursuant to LPR, to be
`determined by the
`Court
`pursuant to LPR, no
`later than 30 days after
`Court issuing Claim
`Construction Order
`
`pursuant to LPR, no
`later than 30 days after
`Court issuing Claim
`Construction Order
`
`pursuant to LPR, no
`later than 30 days after
`service of Final
`Infringement
`Contentions
`
`pursuant to Dkt. 19,
`February 27, 2017
`
`pursuant to LPR, no
`later than 30 days after
`the close of fact
`discovery
`
`pursuant to LPR, no
`later than 30 days after
`Reports on issues
`where the Party bears
`the burden
`
`NEW DATES
`To be determined by the
`Court
`
`No later than 30 days
`after Court issuing
`Claim Construction
`Order
`
`No later than 30 days
`after Court issuing
`Claim Construction
`Order
`
`No later than 30 days
`after service of Final
`Infringement
`Contentions
`
`April 10, 2017
`
`May 10, 2017
`
`June 9, 2017
`
`3
`
`
`
`Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 4 of 7
`
`DEADLINE OR EVENT
`
`Rebuttal expert witness
`disclosures (pursuant to LPR
`7.1(d))
`
`Open of Expert Discovery
`(pursuant to LPR 7.2)
`
`Close of Expert Discovery
`(pursuant to LPR 7.2)
`
`Settlement Conference
`(pursuant to LR 16.3)
`
`Dispositive Motions
`(pursuant to LR 56.1(D))
`
`Opposition to Dispositive
`Motions (pursuant to LR
`7.1(B))
`
`Reply Briefs to Dispositive
`Motions (pursuant to LR
`7.1(C))
`
`CURRENT DATES
`[D.I. 19, 24]
`pursuant to LPR, no
`later than 10 days after
`Reports on Issues
`where the Opposing
`Party bears the burden
`
`pursuant to LPR, within
`7 days of the service of
`rebuttal reports
`
`pursuant to LPR, within
`30 days after the
`opening of expert
`discovery
`
`pursuant to LR, within
`14 days after the close
`of expert discovery
`
`pursuant to LR, no later
`than 30 days after the
`close of expert
`discovery
`
`pursuant to LR, no later
`than 21 days after
`service of dispositive
`motions
`
`pursuant to LR, no later
`than 14 days after
`service of oppositions
`
`NEW DATES
`
`June 19, 2017
`
`June 26, 2017
`
`July 26, 2017
`
`On or before August 9,
`2017
`
`August 25, 2017
`
`September 15, 2017
`
`September 29, 2017
`
`4
`
`
`
`Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 5 of 7
`
`DEADLINE OR EVENT
`Hearing on Dispositive
`Motions (pursuant to LR
`7.1(E))
`
`Pretrial Order (pursuant to
`LR 16.4(A))
`
`Daubert Motions (pursuant
`to LR 26.2(C))
`
`Pretrial Conference
`(pursuant to LR 16.4(A))
`
`Jury Trial (pursuant to LR
`16.4(A))
`
`CURRENT DATES
`[D.I. 19, 24]
`pursuant to LR, at the
`Court's convenience
`
`pursuant to LR, within
`30 days after close of
`discovery or Court's
`ruling on summary
`judgment, whichever is
`later
`
`pursuant to LR, no later
`than date Pretrial Order
`is submitted
`
`pursuant to LR, at the
`Court's discretion
`
`pursuant to LR, on or
`about
`October/November
`2017
`
`NEW DATES
`
`At the Court's
`convenience
`
`Within 30 days after
`close of discovery or
`Court's ruling on
`summary judgment,
`whichever is later
`
`No later than date
`Pretrial Order is
`submitted
`
`At the Court's discretion
`
`On or about December
`2017/January 2018
`
`IT IS SO STIPULATED AND AGREED.
`
`[signatures on following pages]
`
`5
`
`
`
`Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 6 of 7
`
`Dated: August 18, 2016
`
`Dated: August 18, 2016
`
`By: /s/ Robert D. Becker
`Robert D. Becker, pro hac vice
`CA Bar No. 160648
`MANATT, PHELPS & PHILLIPS LLP-CA
`1841 Page Mill Road, Suite 200
`Palo Alto, CA 94304
`Telephone: (650) 812-1300
`Facsimile: (650) 213-0260
`rbecker@manatt.com
`
`By: /s/ Cynthia R. Parks
`Cynthia R. Parks
`GA Bar No. 563929
`PARKS IP LAW LLC
`730 Peachtree St. NE, Suite 600
`Atlanta, GA 30308
`Telephone: (678) 365-4444
`Facsimile: (678) 365-4450
`cparks@cparksip.com
`
`Attorneys for Plaintiff
`IRONBURG INVENTIONS LTD.
`
`By: /s/ Patrick A. Lujin
`B. Trent Webb, pro hac vice
`MO Bar No. 40778
`Patrick A. Lujin, pro hac vice
`MO Bar No. 41392
`Mark D. Schafer, pro hac vice
`MO Bar No. 67197
`SHOOK, HARDY & BACON LLP
`2555 Grand Blvd
`Kansas City, MO 64108
`Telephone: (816) 474-6550
`
`6
`
`
`
`Case 1:15-cv-04219-TWT Document 47 Filed 08/22/16 Page 7 of 7
`
`Facsimile: (816) 421-5547
`bwebb@shb.com
`plujin@shb.com
`mschafer@shb.com
`
`By: /s/ Thomas W. Curvin
`Thomas W. Curvin
`GA Bar No. 202740
`SUTHERLAND ASBILL & BRENNAN LLP
`999 Peachtree , NE Suite 2300
`Atlanta, GA 30309-3996
`Telephone: (404) 853-8000
`Facsimile: (404) 853-8806
`tom.curvin@sutherland.com
`
`Attorneys for Defendant
`VALVE CORPORATION
`
` ORDER
`
`Upon review of the above stipulation, such stipulation is also hereby entered
`
`as an Order of this Court
`
`IT IS SO ORDERED, this 22nd day of August, 2016.
`
`/s/Thomas W. Thrash
`UNITED STATES DISTRICT JUDGE
`
`7
`
`
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