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`August 19, 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 jointly regarding the claim construction hearing scheduled for October 25, 2019
`at 10:00 a.m. See Case No. 14 Civ. 2396 (PGG), Dkt. No. 165 (Aug. 14, 2019).
`
`First, the parties understand that at the beginning of the October 25 hearing, the Court would like
`a tutorial about the case, including the patents-in-suit. See Dkt. No. 139 at 8:7-15. As such, the
`parties propose that each side’s attorneys present a non-argumentative tutorial no longer than
`thirty minutes per side at the outset of the hearing.
`
`Second, the parties envision that the remainder of the claim construction hearing, excluding the
`tutorial, can be completed in approximately two hours. The parties also suggest that the Court
`conduct the claim construction hearing on a term-by-term basis, i.e., both sides would present
`their arguments on the first claim term before the second claim term is addressed, etc. In the
`parties’ view, a term-by-term approach will be more streamlined and will aid the Court in better
`understanding the parties’ claim construction positions.
`
`Finally, the parties do not intend to present expert testimony as part of the tutorial or at the
`remainder of the hearing.
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`If the Court would like to discuss these proposals or other claim construction hearing logistics,
`the parties would welcome a telephonic conference with the Court.
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`Case 1:14-cv-02396-PGG-MHD Document 169 Filed 08/19/19 Page 2 of 2
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`!
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`Hon. Paul G. Gardephe
`August 19, 2019
`Page 2
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`Dated: August 19, 2019
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`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/ Andrew V. Trask
`
`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)
`Graham W. Safty (pro hac vice)
`Sumeet P. Dang (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
`gsafty@wc.com
`sdang@wc.com
`
`Attorneys for Google LLC and
`YouTube, LLC
`
`
`
`
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