`
`!
`
`Brian Ledahl
`bledahl@raklaw.com
`
`June 28, 2022
`
`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
`
`12424
`Wilshire Boulevard
`12th Floor
`Los Angeles
`California
`90025
`
`Tel 310.826.7474
`Fax 310.826.6991
`www.raklaw.com
`
`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:
`Plaintiff Network-1 Technologies, Inc. (“Network-1”) writes to respectfully
`request a status conference in this matter. Defendants have indicated that they do not
`oppose this request. The parties have addressed certain discovery issues, consistent with
`the stipulation entered by the Court (Case No. 2396, Dkt. # 256). The parties have also
`discussed anticipated supplemental expert reports. Network-1 anticipates that a status
`would be helpful to finalize the scheduling for such matters and to address remaining
`pretrial scheduling in these matters. The parties could conduct either a telephonic or in-
`person status conference with the Court.
`
`Memo Endorsed: The parties will submit a joint letter
`by July 7, 2022 setting forth their respective positions
`as to whether the stipulated supplemental discovery
`authorized by Judge Netburn's May 7, 2021 order
`(Case No. 2396, Dkt. No. 256; Case No. 9558, Dkt.
`No. 191), including any supplemental expert reports,
`has any impact on the parties' pending cross-motions
`for summary judgment.
`
`Respectfully submitted,
`
`Russ, August & Kabat
`
`/s/ Brian D. Ledahl
`
`Brian D. Ledahl
`
`SO ORDERED.
`
`_______________________
`Paul G. Gardephe
`United States District Judge
`Dated: June 30, 2022
`
`