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`July 16, 2019
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`Filed Via ECF
`
`Hon. Paul G. Gardephe
`United States District Court
`Southern District of New York
`40 Foley Square, Room 2204
`New York, New York 10007
`
`Re: Network-1 Technologies, Inc. v. Google LLC, et al.,
`
`Case Nos. 14 Civ. 2396 (PGG) & 14 Civ. 9558 (PGG)
`
`
`12424
`Wilshire Boulevard
`12th Floor
`Los Angeles
`California
`90025
`
`Tel 310.826.7474
`Fax 310.826.6991
`www.raklaw.com
`
`
`
`
`
`
`Dear Judge Gardephe:
`
`The parties write to jointly request additional pages for both Plaintiff Network-1’s reply and
`Defendants’ sur-reply claim construction briefs.
`
`In accordance with the parties’ prior stipulation, as entered by the Court, Network-1’s reply
`claim construction brief is due this Friday, July 19 and Defendants’ sur-reply is due August 9.
`Case No. 14 Civ. 2396 (PGG), Dkt. No. 155 at 2.
`
`Pursuant to Your Honor’s Individual Rules of Practice for Civil Cases, Section IV.B, the parties
`understand the default page limit for each of these briefs is 10 pages. For a number of reasons,
`Plaintiff and Defendants agree that a 15-page limit is appropriate for their respective briefs.
`There are four claim terms at issue across three patents, and Defendants assert that two of the
`terms render the claims in which they appear invalid as indefinite under 35 U.S.C. § 112. In
`addition, this litigation has a protracted procedural history, including administrative proceedings
`before the Patent Trial and Appeal Board of the United States Patent and Trademark Office and
`appeals to the United States Court of Appeals for the Federal Circuit, which addressed points
`related to those at issue in this briefing.
`
`For the foregoing reasons, the parties respectfully request that the joint stipulation and proposed
`order attached to this letter reflecting these page limit alterations be entered by the Court.
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`
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`Case 1:14-cv-02396-PGG-MHD Document 156 Filed 07/16/19 Page 2 of 2
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`!
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`Hon. Paul G. Gardephe
`July 16, 2019
`Page 2
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`Dated: July 16, 2019
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`Respectfully submitted,
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`RUSS, AUGUST & KABAT
`
`WILLIAMS & CONNOLLY LLP
`
`BY: /s/ Amy E. Hayden
`
`Marc A. Fenster (pro hac vice)
`Brian D. Ledahl (pro hac vice)
`Adam S. Hoffman (pro hac vice)
`Paul A. Kroeger (pro hac vice)
`Amy E. Hayden (pro hac vice)
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`mfenster@raklaw.com
`bledahl@raklaw.com
`ahoffman@raklaw.com
`pkroeger@raklaw.com
`ahayden@raklaw.com
`
`Charles R. Macedo
`AMSTER, ROTHSTEIN &
`EBENSTEIN LLP
`90 Park Avenue
`New York, NY 10016
`Phone: (212) 336-8074
`Fax: (212) 336-8001
`cmacedo@arelaw.com
`
`
`Attorneys for Network-1
`Technologies, Inc.
`
`BY: /s/ Samuel Bryant Davidoff
`
`Samuel Bryant Davidoff
`650 Fifth Avenue, Suite 1500
`New York, NY 10022
`212-688-9224
`sdavidoff@wc.com
`
`Bruce R. Genderson (pro hac vice)
`Kevin Hardy (pro hac vice)
`Daniel P. Shanahan (pro hac vice)
`Andrew V. Trask (pro hac vice)
`Christopher A. Suarez (pro hac vice)
`725 Twelfth St. NW
`Washington, DC 20005
`Phone: (202) 434-5000
`Fax: (202) 434-5029
`bgenderson@wc.com
`khardy@wc.com
`dshanahan@wc.com
`atrask@wc.com
`csuarez@wc.com
`
`Attorneys for Google LLC and
`YouTube, LLC
`
`
`
`
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