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Case 1:14-cv-02396-PGG-MHD Document 156-1 Filed 07/16/19 Page 1 of 3
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`
`
`
`
`
`
`14 Civ. 2396 (PGG)
`
`14 Civ. 9558 (PGG)
`
`
`
`NETWORK-1 TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC and YOUTUBE, LLC,
`
`Defendants.
`
`
`
`
`
`
`
`
`
`
`
`
`
`JOINT STIPULATION TO MODIFY THE PAGE LIMITS FOR
`CLAIM CONSTRUCTION BRIEFING
`
`Plaintiff Network-1 Technologies, Inc. and Defendants Google LLC and YouTube, LLC,
`
`through their undersigned counsel, hereby stipulate, subject to approval by this Court, to modify
`
`the page limits for two briefs.
`WHEREAS, Plaintiff Network-1 served and filed its opening claim constriction brief
`on May 30, 2019;
`WHEREAS, Defendants served and filed their response claim construction brief on
`June 28, 2019;
`WHEREAS, Network-1’s reply claim construction brief is currently due for service
`and filing on July 19, 2019;
`WHEREAS, Defendants’ sur-reply claim construction brief is currently due for service
`and filing on August 9, 2019;
`WHEREAS, this Court’s Individual Rules of Practice for Civil Cases, Section IV.B
`sets the page limit for Network-1’s reply and Defendants’ sur-reply claim construction briefs
`
`
`
`

`

`Case 1:14-cv-02396-PGG-MHD Document 156-1 Filed 07/16/19 Page 2 of 3
`
`
`
`at 10 pages;
`WHEREAS, the parties agree there are numerous issues to be addressed in these briefs,
`such that 5 additional pages per brief would be beneficial so that the parties may more fully
`explain their positions to the Court;
`
`NOW THEREFORE, the parties hereby stipulate and agree as follows:
`
`Network-1 may serve and file a reply claim construction brief solely rebutting
`1.
`Defendants’ response brief by July 19, 2019 that is no more than 15 pages in length; and
`2.
`Defendants may serve and file a sur-reply claim construction brief solely in
`response to new arguments raised in Network-1’s reply brief by August 9, 2019 that is no
`more than 15 pages in length.
`
`
`
`
`
`
`
`
`
`2
`
`

`

`Case 1:14-cv-02396-PGG-MHD Document 156-1 Filed 07/16/19 Page 3 of 3
`
`
`
`SO STIPULATED.
`Dated: July 16, 2019
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`
`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.
`
`
`
`
`WILLIAMS & CONNOLLY LLP
`
`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
`Christopher A. Suarez (pro hac vice)
`725 Twelfth St., N.W.
`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
`
`
`
`
`
`
`SO ORDERED.
`
`_________________________________
`Paul G. Gardephe
`United States District Judge
`
`
`
`
`3
`
`

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