Case 2:18-cv-08962-JLL-CLW Document 38 Filed 10/09/18 Page 1 of 14 PageID: 951
`
`James E. Cecchi
`Caroline F. Bartlett
`CARELLA, BYRNE, CECCHI,
`OLSTEIN, BRODY & AGNELLO, P.C.
`5 Becker Farm Road
`Roseland, NJ 07068
`Tel: 973-994-1700
`Fax: 973-994-1744
`
`Gregory J. Myers, MN #0287398
`LOCKRIDGE GRINDAL NAUEN
`P.L.L.P.
`100 Washington Avenue South, Suite 2200
`Minneapolis, MN 55401
`Tel: 612-339-6900
`Fax: 612-339-0981
`gjmyers@locklaw.com
`kgmarttila@locklaw.com
`
`Counsel for Plaintiff
`SIPCO, LLC
`
`Steven Pepe (pro hac vice)
`Cassandra B. Roth
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Tel: 212-596-9000
`
`James R. Batchelder (pro hac vice)
`James L. Davis, Jr. (pro hac vice)
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`Tel: 650-617-4000
`
`Scott McKeown (pro hac vice)
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, NW
`Washington, DC 20006-6807
`Tel: 202-508-4600
`
`Counsel for Defendant
`RAB Lighting Inc.
`
`
`
`SIPCO, LLC,
`
`Plaintiff,
`
`v.
`
`RAB LIGHTING INC.,
`
`Defendant.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`CIVIL ACTION FILE NUMBER:
`
`2:18-cv-08962-JLL-CLW
`
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`JOINT PROPOSED DISCOVERY PLAN
`
`Plaintiff SIPCO, LLC (“SIPCO”) and Defendant RAB Lighting Inc. (“RAB”)
`
`(collectively, “the Parties”) have conferred regarding the matters listed under Local Rules 9.3
`
`and 16.1, and respectfully submit this Joint Statement pursuant to the Court’s Order (Dkt. No.
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`

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`Case 2:18-cv-08962-JLL-CLW Document 38 Filed 10/09/18 Page 2 of 14 PageID: 952
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`32) and Civil Case Management Order. This case currently involves six SIPCO patents, United
`
`States Patents Nos. 7,103,511 (the “’511 Patent”), 7,468,661 (the “’661 Patent”), 6,914,893 (the
`
`“’893 Patent”), 7,263,073 (the “’073 Patent”), 6,836,737 (the “’737 Patent”), and 8,924,587 (the
`
`“’587 Patent”) (collectively, the “Patents-in-Suit”). There are three main issues currently in this
`
`case: (1) whether or not RAB’s products infringe any of the asserted claims of the Patents-in-
`
`Suit; (2) whether these claims are valid under the U.S. patent laws (35 U.S.C. §§ 101 et seq.); (3)
`
`whether SIPCO breached the Parties’ December 14, 2015 confidentiality agreement (the
`
`“Confidentiality Agreement”).
`
`I.
`
`THE PARTIES
`
`The attorneys currently appearing in this case on behalf of each party are as follows;
`
`SIPCO, LLC
`
`James E. Cecchi
`Caroline F. Bartlett
`CARELLA, BYRNE, CECCHI, OLSTEIN,
`BRODY & AGNELLO, P.C.
`5 Becker Farm Road
`Roseland, NJ 07068
`Tel: 973-994-1700
`Fax: 973-994-1744
`
`Gregory J. Myers, MN #0287398
`LOCKRIDGE GRINDAL NAUEN P.L.L.P.
`100 Washington Avenue South, Suite 2200
`Minneapolis, MN 55401
`Tel: 612-339-6900
`Fax: 612-339-0981
`gjmyers@locklaw.com
`kgmarttila@locklaw.com
`
`
` RAB LIGHTING INC.
`
` Steven Pepe (pro hac vice)
`Cassandra B. Roth
`
`
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Tel: 212-596-9000
`
`James R. Batchelder (pro hac vice)
`James L. Davis, Jr. (pro hac vice)
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`Tel: 650-617-4000
`
`Scott McKeown (pro hac vice)
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, NW
`Washington, DC 20006-6807
`Tel: 202-508-4600
`
`
`II.
`
`BRIEF DESCRIPTION OF THE CASE
`
`SIPCO accuses RAB of directly and indirectly infringing certain claims of the Patents-in-
`
`Suit by making, having had made, using, offering for sale, and selling Lightcloud networked
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`
`
`-2-
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`

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`Case 2:18-cv-08962-JLL-CLW Document 38 Filed 10/09/18 Page 3 of 14 PageID: 953
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`lighting control system (“Lightcloud”) products. RAB maintains in part that SIPCO has failed to
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`state a claim on which relief can be granted, that there that that there is no infringement, that one or
`
`more claims of the Asserted Patents are invalid under 35 U.S.C. §§ 101, 102, 103, and/or 112,
`
`and that SIPCO is not entitled to damages or injunctive relief. RAB counterclaims that SIPCO
`
`breached the Confidentiality Agreement, and has suffered and will continue to suffer harm as a
`
`result of SIPCO’s breach of the Confidentiality Agreement.
`
`III.
`
`SETTLEMENT
`
`The parties have engaged in settlement discussions but have not been able to reach
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`agreement.
`
`IV.
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`INITIAL CONFERENCE
`
`The parties have met and conferred pursuant to Fed R. Civ. P. 26(f).
`
`V.
`
`INITIAL DISCLOSURES
`
`The parties will exchange initial disclosures pursuant to Fed R. Civ. P. 26(a)(1) on
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`October 26, 2018.
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`VI. DISCOVERY ALREADY CONDUCTED
`
`None.
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`VII. PROPOSED JOINT DISCOVERY PLAN
`
`A.
`
`Subjects for Discovery
`
`The Parties agree that discovery may be needed on at least the following issues:
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`• The construction of disputed terms in the asserted claims of the Patents-in-Suit;
`
`• Whether RAB infringes, directly or indirectly, any claim of the Patents-in-Suit;
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`• Whether the asserted claims of the Patents-in-Suit are invalid;
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`• Whether SIPCO’s rights in the Patents-in-Suit have been exhausted;
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`
`
`-3-
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`• Whether the asserted claims of the Patents-in-Suit are invalid for obviousness-
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`type double patenting;
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`• The development, design, and operation of RAB’s Lightcloud products;
`
`• Whether SIPCO has failed to state a claim upon which relief can be granted;
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`• Whether SIPCO has standing to maintain the Complaint;
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`• SIPCO’s acquisition and alleged ownership of the Patents-in-Suit;
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`• Whether SIPCO’s infringement claims are barred by the doctrine of prosecution
`
`history estoppel and/or disclaimer;
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`• Whether SIPCO’s infringement claims are barred by the doctrine of prosecution
`
`history laches;
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`• Whether SIPCO’s request for relief is barred by the doctrines of patent exhaustion
`
`and/or license;
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`• Whether SIPCO’s claims are barred by waiver, laches, acquiescence and/or
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`estoppel;
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`• What, if any, damages are appropriate, if infringement is found and the patents are
`
`not found invalid, including whether damages are limited by the doctrine of
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`intervening rights;
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`• Whether SIPCO is entitled to injunctive relief;
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`• Whether SIPCO breached the Confidentiality Agreement;
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`• What damages are appropriate, if breach of the Confidentiality Agreement is
`
`found; and
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`• Whether RAB is entitled to injunctive relief.
`
`B.
`
`Proposed Schedule And Limitations
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`
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`-4-
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`

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`1.
`
`Schedule
`
`The parties expect that the case calendar will generally follow the Court’s Patent Rules.
`
`The parties propose the following schedule in this case:
`
`Event
`Parties submit proposed Joint Discovery Plan and
`Pretrial Scheduling Order
`Initial scheduling conference
`Initial Disclosures
`Parties submit proposed Discovery Confidentiality
`Order
`(L. Pat. R. 2.2)
`Deadline to file motion to amend pleadings or to add
`new parties, whether by amended or third-party
`complaint
`Plaintiff serves “Disclosure of Asserted Claims and
`Infringement Contentions” along with accompanying
`document production
`(L. Pat. R. 3.1 and 3.2)
`Defendant serves non-infringement and invalidity
`contentions of asserted claims along with accompanying
`document production
`(L. Pat. R. 3.2A, 3.3, and 3.4)
`Plaintiff serves response to invalidity contentions
`(L. Pat. R. 3.4A)
`Parties exchange proposed terms for construction and
`thereafter meet and confer to narrow issues
`(L. Pat. R. 4.1)
`Parties exchange preliminary proposed constructions
`and identifications of intrinsic and extrinsic evidence
`and thereafter meet and confer to narrow issues
`(L. Pat. R. 4.2(a) and (b))
`Parties exchange evidence opposing proposed claim
`constructions
`(L. Pat. R. 4.2(c))
`Parties file Joint Claim Construction and Prehearing
`Statement
`(L. Pat. R. 4.3)
`Parties complete fact discovery related to claim
`construction
`(L. Pat. R. 4.4)
`Parties file opening Markman papers, and serve
`supporting evidence, including any expert declarations
`(L. Pat. R. 4.5(a))
`
`
`
`-5-
`
`Proposed Date
`October 9, 2018
`October 12, 2018
`October 26, 2018
`
`October 26, 2018
`
`November 16, 2018
`
`November 9, 2018
`
`January 9, 2019
`
`January 30, 2019
`
`February 13, 2019
`
`March 8, 2019
`
`March 22, 2019
`
`April 22, 2019
`
`May 22, 2019
`
`July 15, 2019
`
`

`

`Case 2:18-cv-08962-JLL-CLW Document 38 Filed 10/09/18 Page 6 of 14 PageID: 956
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`Event
`Completion of claim construction discovery of any
`expert witness who submitted a claim construction
`declaration with opening Markman briefs
`(L. Pat. R. 4.5(b))
`Parties file responsive Markman papers and serve
`supporting evidence
`(L. Pat. R. 4.5(c))
`Parties propose schedule to the Court for claim
`construction hearing
`(L. Pat. R. 4.6)
`Tutorial and Claim construction hearing
`Parties file for Post-Markman amendments
`(L. Pat. R. 3.7)
`Disclosure of Opinion of Counsel Defenses
`(L. Pat. R. 3.8)
`Close of fact discovery
`Opening expert reports on issues for which the party
`bears the burden of proof
`Rebuttal expert report
`Reply expert reports
`Close of expert discovery
`Deadline for dispositive motions
`
`Responses to dispositive motions
`
`Replies in support of dispositive motions
`
`Pretrial disclosures required by Fed. R. Civ. P. 26(a)(3)
`– witness lists, deposition designations and exhibit lists
`(L.R. 16.5(c))
`Motions in Limine; Plaintiff provides draft of proposed
`jury instructions, proposed voir dire, and proposed
`verdict form.
`Parties exchange objections to pretrial disclosures
`(witness lists, deposition designations, exhibit lists)
`
`Proposed Date
`
`August 15, 2019
`
`September 16, 2019
`
`September 30, 2019 (including
`parties’ proposals regarding the
`format of a Tutorial and the Claim
`Construction Hearing)
`At the Court’s convenience
`21 days after Markman order
`
`30 days after Markman order
`60 days after Markman order
`30 days after close of fact discovery
`30 days after opening expert reports
`21 days after rebuttal expert reports
`30 days after reply expert reports
`30 days after close of expert discovery
`21 days after deadline for dispositive
`motions
`14 days after deadline for responses to
`dispositive motions
`
`28 days before Pretrial Conference
`
`21 days before Pretrial Conference
`
`21 days before Pretrial Conference
`
`Parties meet and confer regarding pretrial memorandum 14 days before Pretrial Conference
`
`Oppositions to Motions in Limine; Defendant provides
`edits to Proposed Jury Instructions, Proposed Voir Dire,
`and Proposed Verdict form
`Objections to Proposed Jury Instructions, Proposed Voir
`Dire, and Proposed Verdict form
`
`14 days before Pretrial Conference
`
`7 days before pretrial conference
`
`
`
`-6-
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`

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`Event
`
`Proposed Date
`
`Joint Pretrial Memorandum
`
`7 days before pretrial conference
`
`Final Pretrial Conference
`
`Jury selection/trial date
`
`At such time as ordered by the Court
`
`At such time as ordered by the Court
`
`
`
`2.
`
`Limitations On Discovery
`
`The Parties agree that Local Rule 26.1(c) and the Federal Rules of Civil Procedure shall
`
`control the limits of discovery, with the following additional limitations:
`
`1.
`
`Interrogatories: A Party may serve on any other Party no more than 25
`
`interrogatories. An interrogatory shall not be deemed to have multiple subparts simply because it
`
`calls for a response involving more than one patent, patent claim, accused product, or prior art
`
`reference. A party may serve interrogatories 30 days before the close of fact discovery.
`
`2.
`
`Requests for Production of Documents and Things: A Party may serve on
`
`any other Party no more than 25 requests for the production of documents and things (“RFPs”).
`
`An RFP shall not be deemed to have multiple subparts simply because it requires the production
`
`of documents and things related to more than one patent, patent claim, accused product, or prior
`
`art reference. A party may serve requests for production 30 days before the close of fact
`
`discovery.
`
`3.
`
`Requests for Admission: A maximum of 15 requests for admission are
`
`permitted for each party, except that there shall be no limit on requests for admission used solely
`
`to establish the authenticity of a document. The parties shall work in good faith to avoid
`
`unnecessary depositions to establish the authenticity of documents. A party may serve requests
`
`for admissions 30 days before the close of fact discovery.
`
`
`
`-7-
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`

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`4.
`
`Privileged Communications and Privilege Logs: Consistent with Fed. R.
`
`Civ. P. 26(b)(5)(A) of the Federal Rules of Civil Procedure, a party withholding or redacting any
`
`responsive document on the grounds of any privilege, immunity, or similar claim shall provide to
`
`the other party a Privilege Log (covering all documents already identified) on a rolling basis as
`
`discovery progresses, and must be served no later than 30 days prior to the close of fact
`
`discovery (except to the extent material is identified and withheld after that time, in which case a
`
`supplemental log shall be produced by the close of fact discovery). The parties need not log
`
`privileged or otherwise protected documents that were created on or after December 16, 2015, as
`
`doing so would be unduly burdensome. In addition, privileged or otherwise protected documents
`
`created by or on behalf of litigation counsel or exchanged with litigation counsel, regardless of
`
`their date, do not need to be included on any privilege log. If a Party seeks additional logging as
`
`an exception to this general rule, it shall file a separate motion and demonstrate good cause.
`
`Under no circumstances does this provision exempt from discovery any post-complaint, non-
`
`privileged communications or documents, including communications or documents over which
`
`privilege has been waived.
`
`5.
`
`Fact Depositions of Parties and Third Parties:
`
`a) Employees of the Parties may be served with deposition notices through the
`
`party’s counsel, rather than being served by a subpoena. Counsel for the Parties
`
`agree to make best efforts that affiliates of the Parties may be served with
`
`deposition notices through the party’s counsel, rather than being served by a
`
`subpoena.
`
`b) Except as otherwise authorized by the Court, each side is limited to a total of six
`
`(6) depositions upon oral examination of fact witnesses, including Rule 30(b)(6)
`
`
`
`-8-
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`

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`witnesses, but excluding non-party depositions and expert witnesses. Each
`
`deposition is limited to a maximum of seven (7) hours, except as otherwise
`
`authorized by the Court or agreed to by the parties. Notwithstanding the
`
`preceding sentence, the parties shall confer in good faith regarding the limitation
`
`on hours for each deposition taken pursuant to Rule 30(b)(6).
`
`6.
`
`Expert Depositions:
`
`a) Each expert disclosed by a Party may be deposed by the other Party for up to
`
`seven hours, which may be increased upon agreement of the Parties. If any
`
`Party requests more than seven hours for an expert deposition, the Parties will
`
`confer in good faith and attempt to reach agreement without intervention by the
`
`Court.
`
`7.
`
`Service: The parties consent to service by e-mail, in accordance with
`
`Rule 5(b)(2)(E) of the Federal Rules of Civil Procedure. The parties further agree that, for the
`
`purpose of computing deadlines for responses to pleadings or discovery requests when such
`
`deadlines are triggered by service of a document, service by e-mail will be considered as service
`
`by hand delivery on the same day, unless the e-mail is sent after midnight Eastern or on a
`
`Saturday, Sunday, or Federal Holiday, in which case it will be considered as service by hand
`
`delivery on the next business day. Documents shall be served upon Plaintiff at ____________,
`
`or any other service e-mail later provided by Plaintiff. Documents shall be served upon
`
`Defendant at RAB-SIPCO@Ropesgray.com, or any other service e-mail later provided by
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`Defendant.
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`8.
`
`Discovery Disputes
`
`a) Discovery disputes will be governed by L. Civ. R. 37.1 (“Discovery Motions”).
`
`
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`-9-
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`

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`VIII. ANTICIPATED SPECIAL DISCOVERY NEEDS
`
`The Parties do not anticipate any special discovery needs at this time.
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`IX.
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`ELECTRONICALLY STORED INFORMATION (“ESI”) AND E-MAIL
`DISCOVERY
`
`The Parties do not anticipate any problems with e-discovery at this time. The parties’
`
`joint proposal for e-discovery is as follows:
`
`A.
`
`ESI
`
`1.
`
`General Document Image Format. The parties shall produce computer-
`
`based or digital information in the following format: single-page Group IV tiff images named
`
`according to the beginning production number; document level text files named according to the
`
`beginning production number of the document; tiff, text, and native files produced in different
`
`folders; and Summation or Concordance load files containing the fields BegBates, EndBates,
`
`BegAttach, EndAttach, Tiff FilePath, and Text FilePath, as well as other metadata as identified
`
`below. If a document is more than one page in length, the unitization of the document and any
`
`attachments and/or affixed notes shall be maintained as they existed in the original document. A
`
`party that receives a document that is not produced in color may make a reasonable request to
`
`receive the document in color, and upon receipt of such a request, the producing party shall
`
`produce the document in color.
`
`2.
`
`Text-Searchable Documents. +Each party has an obligation to make its
`
`production text-searchable.
`
`3.
`
`Footer. Except where a document is produced in native format, each
`
`document image shall contain a footer with a sequentially ascending production number.
`
`4.
`
`Production of ESI in Native Format. The parties agree to produce in
`
`native format any types of files (e.g. spreadsheets) that cannot be reasonably rendered in TIFF
`
`
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`-10-
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`

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`format. In addition, a party that receives a document produced in non-native form may make a
`
`reasonable request to receive the document in its native form, and upon receipt of such a request,
`
`the producing party shall produce the document in its native format.
`
`5.
`
`Metadata Fields. With respect to any non-email ESI produced, the parties
`
`are only obligated to provide the following metadata, to the extent such metadata exists:
`
`Custodian, Duplicate Custodian(s), Filename, Author, Date Created, MD5 Hash, File Size, File
`
`Extension, Control Number Begin, Control Number End, Attachment Range, Attachment Begin,
`
`and Attachment End (or the equivalent thereof). With respect to email, the parties do not
`
`anticipate the need for the production of email and will meet and confer to discuss appropriate
`
`scope of email production to the extent a party demonstrates substantial need for the production
`
`of email. The parties are not required to preserve metadata fields that are frequently updated in
`
`the ordinary course of business, for example, fields regarding last-opened dates.
`
`6.
`
`Scope. Nothing in this Order expands the scope of discovery provided for
`
`under Rule 26(b) of the Federal Rules of Civil Procedure or limits discovery unless expressly
`
`stated herein.
`
`7.
`
`No Backup Restoration Required. Absent a showing of good cause, no
`
`party need restore any form of media upon which backup data is maintained in a party’s normal
`
`or allowed processes, including but not limited to backup tapes, disks, SAN, and other forms of
`
`media, to comply with its discovery obligations in the present case unless necessary to the
`
`resolution of issues in this case.
`
`8.
`
`De-Duplication. To the extent identical copies of documents (i.e.,
`
`documents with identical hash values) appear in the files of a custodian or across custodians, the
`
`party producing such documents shall have the option of either: (1) producing all such copies; or
`
`
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`-11-
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`(2) producing only one such identical copy and also producing an overlay file that includes a
`
`metadata field entitled “Duplicate Custodian” containing the names of each custodian whose
`
`files contain such identical copies.
`
`9.
`
`Categories of Documents Deemed Not Reasonably Accessible. Absent a
`
`showing of good cause, the following categories of documents are deemed not reasonably
`
`accessible and need not be collected and preserved: (i) deleted, slack, fragmented or other data
`
`only accessible by forensics; (ii) random access memory (RAM), temporary files, or other
`
`ephemeral data that are difficult to preserve without disabling the operating system; (iii) on-line
`
`access data such as temporary internet files, history, cache, cookies, and the like; (iv) back-up
`
`data that are substantially duplicative of data that are more accessible elsewhere; (v) voice
`
`messages; (vi) instant messages or chats; (vii) electronic mail or pin-to-pin messages sent to or
`
`from mobile devices (e.g., iPhone and Blackberry devices); (viii) other electronic data stored on
`
`a mobile device, such as calendar or contact data or notes; (ix) logs of calls made from mobile
`
`devices; (x) server, system or network logs; (xi) electronic data temporarily stored by laboratory
`
`equipment or attached electronic equipment; (xii) data remaining from systems no longer in use
`
`that is unintelligible on the systems in use.
`
`10.
`
`Production Media. Document images, load files, and metadata shall be
`
`produced on hard drives, CDs, DVDs, or other mutually agreeable media (“Production Media”).
`
`Each piece of Production Media shall include a unique identifying label corresponding to the
`
`identity of the party producing the documents, the date of the production of documents, and the
`
`Document Number ranges of the documents in that production. To the extent that the Production
`
`Media includes any information designated as confidential under the Local Rules or any
`
`Stipulated Protective Order filed with the Court, the label on such Production Media shall
`
`
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`-12-
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`indicate that the Production Media includes information so designated. Production Media shall
`
`include text referencing the case name and number. Further, any replacement Production Media
`
`shall cross-reference the original Production Media, clearly identify that it is a replacement, and
`
`cross-reference the Document Number range that it replaces.
`
`11.
`
`Cost Shifting. All costs associated with production of documents pursuant
`
`to this Order shall be borne by the producing party. However, costs will be shifted for
`
`disproportionate ESI production requests pursuant to Federal Rule of Civil Procedure 26.
`
`12.
`
`Good Faith. The parties shall negotiate in good faith regarding production
`
`of the requested ESI, such as in instances where production according to the protocols expressly
`
`set forth herein are impracticable, with the goal of avoiding any undue burden on the producing
`
`party while ensuring a reasonably usable production for the receiving party.
`
`13.
`
`No Waiver. Pursuant to Federal Rule of Evidence 502(d), the parties
`
`hereby agree that the inadvertent or mistaken production of a privileged or work product
`
`protected ESI is not a waiver in the pending case or in any other federal or state proceeding. The
`
`mere production or electronic screening of ESI in a litigation as part of a mass production shall
`
`not itself constitute a waiver for any purpose.
`
`X.
`
`PROTECTIVE ORDER AND CONFIDENTIALITY
`
`The Parties agree to follow Local Rule 5.2.10, 5.3(c) and Appendix U in filing under seal
`
`of any documents that contain confidential information. The Parties will submit a proposed
`
`confidentiality order by October 26, 2018.
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`XI. ADDITIONAL DISCOVERY ISSUES
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`The Parties do not anticipate any discovery issues beyond those listed above.
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`XII. VOLUNTARY ARBITRATION
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`The parties are willing to participate in voluntary arbitration.
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`-13-
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`Case 2:18-cv-08962-JLL-CLW Document 38 Filed 10/09/18 Page 14 of 14 PageID: 964
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`XIII. BIFURCATION
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`The parties agree that this case is not appropriate for bifurcation.
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`XIV. INTERIM STATUS CONFERENCE
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`The parties believe an interim status conference should be held two months after issuance
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`of the court’s claim construction order.
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`XV. MAGISTRATE JUDGE
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`The parties do not consent to the trial being conducted by a magistrate judge.
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`XVI. OTHER ISSUES
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`The parties do not have any other issues to raise at this time.
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`Dated: October 9, 2018
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`/s/ James E. Cecchi
`James E. Cecchi
`Caroline F. Bartlett
`CARELLA, BYRNE, CECCHI,
`OLSTEIN, BRODY & AGNELLO, P.C.
`5 Becker Farm Road
`Roseland, NJ 07068
`Tel: 973-994-1700
`Fax: 973-994-1744
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`Gregory J. Myers, MN #0287398
`LOCKRIDGE GRINDAL NAUEN
`P.L.L.P.
`100 Washington Avenue South, Suite 2200
`Minneapolis, MN 55401
`Tel: 612-339-6900
`Fax: 612-339-0981
`gjmyers@locklaw.com
`kgmarttila@locklaw.com
`
`Counsel for Plaintiff
`SIPCO, LLC
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`/s/ Cassandra B. Roth
`Steven Pepe (pro hac vice)
`Cassandra B. Roth
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Tel: 212-596-9000
`
`James R. Batchelder (pro hac vice)
`James L. Davis, Jr. (pro hac vice)
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`Tel: 650-617-4000
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`Scott McKeown (pro hac vice)
`ROPES & GRAY LLP
`2099 Pennsylvania Avenue, NW
`Washington, DC 20006-6807
`Tel: 202-508-4600
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`Counsel for Defendant
`RAB Lighting Inc.
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`-14-
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