`
`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
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`
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`
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`CIVIL ACTION NO. 13-cv-11567
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`ZOND, LLC,
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`v.
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`Plaintiff,
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`THE GILLETTE COMPANY and THE
`PROCTER AND GAMBLE COMPANY,
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`Defendants.
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`
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`JOINT MOTION TO MODIFY THE COURT’S SCHEDULING ORDER (D.I. 23)
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`Plaintiff Zond, LLC (“Zond”) and Defendants The Gillette Company and The Procter
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`& Gamble Company (“Gillette”) hereby submit this joint motion to modify the Court’s
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`Scheduling Order (D.I. 23) by extending the deadlines in the case preceding the Markman
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`hearing by 60 days.
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`The parties have been working together to narrow and potentially completely resolve
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`the issues in this case. In particular, to narrow the issues in the case, on May 6, 2014, the
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`parties filed a stipulation dismissing claims concerning Gillette’s Commercial Razor Blades,
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`based on Gillette’s representations regarding those products. (D.I. 77). The parties are now
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`seeking a 60-day extension of the deadlines in the case preceding the Markman hearing, as set
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`forth below, in order to engage in a good faith effort to resolve the remaining issues in the
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`case and to avoid incurring further expense. This motion for extension does not affect the
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`date of the Markman hearing, which is scheduled for October 21, 2014.
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`Case 1:13-cv-11567-DJC Document 94 Filed 05/27/14 Page 2 of 3
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`Event
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`Current Date
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`Requested Date
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`Exchange of Proposed Claim Constructions
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`May 28, 2014
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`July 28, 2014
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`Amendment/Supplementation of Preliminary
`Infringement and Invalidity Contentions By
`Amendment/Supplementation of Preliminary
`Invalidity Contentions By (if Plaintiff serves
`amended infringement contentions on August 5,
`2014)
`Exchange of Claim Construction Opening Briefs
`and Evidence
`Joint Claim Construction and Prehearing
`Statement
`Exchange of Tutorials
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`June 4, 2014
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`August 5, 2014
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`June 11, 2014
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`August 12, 2014
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`June 18, 2014
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`August 18, 2014
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`July 16, 2014
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`September 1, 2014
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`August 7, 2014
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`October 6, 2014
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`Claim Construction Hearing
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`October 21, 2014
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`
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`Respectfully submitted,
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`ZOND, LLC
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`By its counsel,
`
`/s/ Daniel Kesack
`
`David S. Godkin (BBO#196530)
`Andrew A. Caffrey III (BBO#660481)
`Birnbaum & Godkin, LLP
`280 Summer Street
`Boston, MA 02210
`617-307-6100
`godkin@birnbaumgodkin.com
`caffrey@birnbaumgodkin.com
`
`David C. Radulescu, Ph.D.
`Tigran Vardanian
`Etai Lahav
`Gregory S. Maskel
`Daniel Kesack
`RADULESCU LLP
`136 Madison Ave, 6th Floor
`New York, NY 10016
`646-502-5950
`david@radulescullp.com
`
`2
`
`Dated: May 27, 2014
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`
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`
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`Case 1:13-cv-11567-DJC Document 94 Filed 05/27/14 Page 3 of 3
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`
`
`tigran@radulescullp.com
`etai@radulescullp.com
`greg@radulescullp.com
`daniel@radulescullp.com
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`
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`
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`Dated: May 27, 2014
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`Respectfully submitted,
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`THE GILLETTE COMPANY and THE
`PROCTER
`& GAMBLE COMPANY
`By their counsel,
`/s/ _Chris Noyes________________
`Mark G. Matuschak, BBO # 543873
`Larissa Bifano Park, BBO # 663105
`Wilmer Cutler Pickering Hale and Dorr LLP
`60 State Street
`Boston, MA 02109
`Christopher R. Noyes, BBO # 654324
`Wilmer Cutler Pickering Hale and Dorr LLP
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007
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`CERTIFICATE OF SERVICE
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`I hereby certify that this document filed through the ECF system will be sent
`electronically to the registered participants as identified on the Notice of Electronic Filing
`(NEF) and paper copies will be sent to those indicated as non-registered participants on the
`above date.
`
`
`/s/ Daniel Kesack
`Daniel Kesack
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`3
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