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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF KANSAS
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`Case No. 6:17-cv-01217
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`LOGANTREE LP,
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` Plaintiff,
`vs.
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`GARMIN INTERNATIONAL, INC. and
`GARMIN USA, INC.,
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`Defendants.
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`DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTION TO EXTEND
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`There is no good cause to extend the July 5 deadline to serve opening expert reports because
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`LoganTree:
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`• Failed to timely conduct any discovery into Garmin’s source code despite the
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`schedule allotting for 20 months of fact discovery and even served its final
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`infringement contentions on March 15, 2021 before reviewing any source code;
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`• Waited until 12 days before the close of discovery to even review Garmin’s source
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`code despite it being available for inspection since 2019 (Ex. A, Garmin’s
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`Objections and Responses to LoganTree’s First Set of RFPs, at 7), and only
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`requested print outs a few days before the end of discovery;
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`• Failed to ask Garmin’s 30(b)(6) witness knowledgeable about the source code a
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`single question about the source code, including which portions were related to the
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`various accused products or even about where Garmin’s accused functionality
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`was in the code; and
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`• Never raised a request for extension of the expert report deadline at the June 8
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`discovery hearing or even in its out of time motion to print excessive pages.
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`Case 6:17-cv-01217-EFM-ADM Document 124 Filed 07/02/21 Page 2 of 3
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`Garmin requests LoganTree’s motion be denied for an utter lack of good cause.
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`Dated: July 2, 2021
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`Respectfully submitted,
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`ERISE IP, P.A.
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`/s/ Megan J. Redmond
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`Megan J. Redmond, KS Bar #21999
`Adam P. Seitz, KS Bar #21059
`Carrie A Bader, KS Bar #24436
`Clifford T. Brazen, KS Bar #27408
`ERISE IP, P.A.
`7015 College Blvd., Suite 700
`Overland Park, Kansas 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`adam.seitz@eriseip.com
`megan.redmond@eriseip.com
`carrie.bader@eriseip.com
`cliff.brazen@eriseip.com
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`Attorneys for Defendants Garmin
`International, Inc. and Garmin USA, Inc.
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`2
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`Case 6:17-cv-01217-EFM-ADM Document 124 Filed 07/02/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that, on July 2, 2021, the foregoing document was filed with the Clerk of
`the Court using CM/ECF and that all counsel of record who are deemed to have consented to
`electronic service are being served with a copy of this document via the Court’s CM/ECF system
`accordingly.
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`By: /s/ Megan J. Redmond
`Megan J. Redmond
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`3
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