`
`
`
`Brian D. Ledahl
`bledahl@raklaw.com
`
`
`June 26, 2020
`
`
`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., Nos. 1:14-cv-2396-
`PGG-SN & 1:14-cv-9558-PGG-SN
`
`
`Dear Judge Gardephe:
`
`12424
`
`Wilshire Boulevard
`
`12th Floor
`
`Los Angeles
`
`California
`
`90025
`
`
`
`Tel 310.826.7474
`
`Fax 310.826.6991
`
`www.raklaw.com
`
`
`
`
`
`
`
`Plaintiff Network-1 Technologies, Inc. (“Network-1”) and Defendants Google LLC
`
`and YouTube, LLC respectfully submit this joint letter pursuant to the Court’s request regarding
`the need for further in-person claim construction proceedings. The parties have conferred and are
`in agreement that the matter may be submitted on the current record (including the briefs (Dkt. #s
`148, 151, 152, 153, 158, 163, and 164)1, prior hearing, post-hearing letter briefs from the parties
`(Dkt. #s 201, and 202)2, and the demonstrative slides that both parties provided to the Court in
`connection with the prior hearing3). The parties also advise the Court that since the various prior
`submissions, the Federal Circuit issued its decision in Nevro Corp. v. Boston Sci. Corp., 955 F.3d
`35 (Fed. Cir. 2020), which relates to issues of indefiniteness.
`
`Of course, should the Court find further argument, live expert witness testimony,
`
`or other presentation helpful, the parties remain willing to coordinate an appropriate hearing with
`the Court, including through telephonic or video conference if needed.
`
`
`
`
`
`
`
`
`1 All Dkt. numbers are from Case No. 1:14-cv-2396-PGG-SN.
`2 The parties withdraw any objection to these letters being considered by the Court.
`3 The parties’ respective demonstrative slides were not filed through the ECF system. The parties request that the
`Court advise them if it would prefer that those slides be filed.
`
`
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 218 Filed 06/26/20 Page 2 of 2
`
`Hon. Paul G. Gardephe
`June 26, 2020
`Page 2
`
`Respectfully submitted,
`
`
`RUSS, AUGUST & KABAT
`
`BY: /s/ Brian D. Ledahl
`
`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)
`Jacob R. Buczko (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
`jbuczko@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
`
`Thomas H. L. Selby (pro hac vice)
`Samuel Bryant Davidoff
`Andrew V. Trask
`Melissa Collins (pro hac vice)
`Graham W. Safty (pro hac vice)
`Sumeet P. Dang (pro hac vice)
`725 Twelfth Street, NW
`Washington, DC 20005
`Phone: (202) 434-5000
`Fax: (202) 434-5029
`tselby@wc.com
`sdavidoff@wc.com
`atrask@wc.com
`mcollins@wc.com
`gsafty@wc.com
`sdang@wc.com
`
`For Matters in New York:
`WILLIAMS & CONNOLLY LLP
`650 Fifth Avenue, Suite 1500
`New York, NY 10022
`
`Kevin Hardy (pro hac vice)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`1300 I Street, NW, Suite 900
`Washington, DC 20005
`Phone: (202) 538-8000
`Fax: (202) 538-8100
`kevinhardy@quinnemanuel.com
`
`Attorneys for Google LLC and
`YouTube, LLC
`
`
`
`
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