Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4258 Page 1 of 14
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`Mieke K. Malmberg
`(SBN 209992)
`SKIERMONT DERBY LLP
`800 Wilshire Blvd., Ste. 1450
`Los Angeles, CA 90017
`Phone: (213) 788-4500
`Fax: (213)788-4545
`mmalmberg@skiermontderby.com
`Paul J. Skiermont
`(TX Bar No. 24033073)
`SKIERMONT DERBY LLP
`1601 Elm St., Ste. 4400
`Dallas, TX 75201
`Phone: (214) 978-6600
`Fax: (214) 978-6601
`pskiermont@skiermontderby.com
`(Additional counsel identified on
`signature page)
`Attorneys for Plaintiff
`BELL NORTHERN RESEARCH,
`LLC
`
`Joanna M. Fuller (SBN 266406)
`jfuller@fr.com
`FISH & RICHARDSON P.C.
`12390 El Camino Real
`San Diego, CA 92130
`Phone: (858) 678-5070
`Fax: (858) 678-5099
`Michael McKeon (DC Bar 459780)*
`mckeon@fr.com
`Christian Chu (SBN 218336)
`chu@fr.com
`Stephen A. Marshall (DC Bar 1012870)*
`smarshall@fr.com
`R. Andrew Schwentker (DC Bar 991792)*
`schwentker@fr.com
`FISH & RICHARDSON P.C.
`1000 Maine Avenue SW
`Washington, D.C. 20024
`Phone: (202) 783-5070
`Fax: (202) 783-2331
`*(pro hac vice granted)
`Attorneys for Defendants
`LG ELECS. INC., LG ELECS. U.S.A., INC.,
`and LG ELECS. MOBILE RES. U.S.A., LLC
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
`Case No. 3:18-CV-2864-CAB-BLM
`JOINT MOTION TO EXTEND THE
`CASE MANAGEMENT ORDER
`Judge: Hon. Cathy Bencivengo
`Magistrate Judge: Hon. Barbara Lynn Major
`
`BELL NORTHERN RESEARCH,
`LLC,
`
`Plaintiff,
`
`v.
`LG ELECTRONICS INC., LG
`ELECTRONICS U.S.A., INC., and
`LG ELECTRONICS MOBILE
`RESEARCH U.S.A., LLC,
`
`Defendants.
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`LG 1034
`LG v BNR
`IPR2020-00108
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`

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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4259 Page 2 of 14
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`Plaintiff Bell Northern Research, LLC (“BNR”) and Defendants LG
`Electronics Inc., LG Electronics U.S.A., Inc., and LG Electronics Mobile
`Research U.S.A., LLC (collectively, “LG”) (together with BNR, the “Parties”)
`submit this Joint Motion to Extend Deadlines in the Case Management Order.
`As the Southern District of California has recognized, Coronavirus Disease
`(COVID-19) has become an increasing concern. As of the date of this filing, the
`World Heath Organization has declared the Disease a global pandemic, a
`National Emergency has been declared in the United States, many corporations
`and other organizations have instituted remote work policies, and partial
`lockdowns and curfews have been instituted in many parts of the United States,
`including in New Jersey where LG Electronics USA, Inc. is located.
`In addition, numerous travel restrictions are in place. For example, the
`Centers for Disease Control has issued a Warning Level 3 for travel to South
`Korea (where LG Electronics Inc. is based), recommending that travelers avoid
`all nonessential travel to the country. Airlines are also substantially reducing air
`travel, such as American Airlines, which announced that it is reducing
`international air travel by 75%. And in a sign of the risks of domestic travel, the
`Department of Defense has banned all domestic travel with very narrow
`exceptions, and the Office of Management and Budget has issued guidance to all
`Executive Departments and Agencies recommending only “mission-critical
`travel,” such as “for activities essential to national security.”
`Prior to the global outbreak, the Parties had scheduled numerous fact
`depositions of both Parties during the period of March 23 through April 15, 2020.
`Many of the depositions of LG witnesses were to take place in Seoul, South
`Korea. Other depositions of both Parties were to take place in various locations
`around the United States that in most instances require travel by the witnesses,
`and in all instances require travel by counsel for one or both Parties, including to
`
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4260 Page 3 of 14
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`New York, New York; Dallas, Texas; and Overland Park, Kansas. These
`depositions are of witnesses that are highly relevant to the Parties’ current claims
`and defenses. As a result of the pandemic and travel concerns and restrictions,1 as
`well as the now unavailability of court reporters and translators in South Korea
`due to COVID-19 concerns, the Parties wish to postpone all depositions until a
`safer time. However, the fact discovery deadline is currently April 17, 2020.
`The Parties agree that the current situation with respect to COVID-19
`necessitates an extension of the fact discovery deadline, and the Parties believe
`good cause exists because the extension is required to protect the health and
`safety of witnesses, court reporters and associated personnel, as well as counsel.
`In addition, a fact discovery deadline extension is further justified because LG
`and third party Qualcomm are both unable to continue to make their source code
`available for BNR’s review at the current time due to remote work policies
`instituted as a result of the COVID-19 situation.
`The Parties also agree that the current situation with respect to COVID-19
`may necessitate postponing the Mandatory Settlement Conference before
`Magistrate Judge Major currently scheduled for April 28, 2020 (with confidential
`statements due to chambers by April 17, 2020). Because the Scheduling Order
`requires that each party bring to the conference a representative “having full and
`complete authority to enter into a binding settlement,” (Dkt. No. 103 at ¶ 8(a)),
`LG intends to have a client representative from South Korea attend the conference.
`However, the Southern District of California has implemented visitor restrictions
`prohibiting entry into a courthouse in this District by any persons who have traveled
`to certain countries, including South Korea, within the last fourteen days. See Order
`of the Chief Judge No. 17: Visitor Restrictions (S.D. Cal. Mar. 13, 2020).
`
`1 For example, one BNR witness resides in Canada and the Canadian government has
`issued an advisory to residents that they avoid all non-essential travel outside of
`Canada. See https://travel.gc.ca/destinations/united-states (as of March 19, 2020).
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4261 Page 4 of 14
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`Accordingly, as long as that restriction is in place, it is not feasible for LG to
`participate in the Mandatory Settlement Conference in the manner required by the
`Scheduling Order. If that restriction is still in place on April 7, 2020, the Parties will
`jointly call Judge Major’s chambers to request a later date.
`While the Parties agree on the above, the Parties differ in their proposals
`for the length of an extension of the fact discovery deadline and its effect on the
`remainder of the schedule. Therefore, the Parties submit their proposals in the
`following chart:
`
`
`Event
`Fact Discovery Closes
`Disclosure of Experts
`Due
`Supplementary Expert
`Disclosure Due
`Opening Expert
`Reports Due
`Rebuttal Expert
`Reports Due
`Close of Expert
`Discovery
`Dispositive/ Daubert
`Motions Due
`Oppositions to
`Disposition/ Daubert
`Motions Due
`Replies to Disposition/
`Daubert Motions Due
`Exchange Rule
`26(a)(3) Pretrial
`Disclosures
`
`Current Date
`April 17, 2020
`
`BNR Proposal
`June 8, 2020
`
`LG Proposal
`June 17, 2020
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`April 17, 2020
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`June 8, 2020
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`June 17, 2020
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`May 8, 2020
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`June 29, 2020
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`July 8, 2020
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`May 22, 2020
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`July 6, 2020
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`July 22, 2020
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`July 2, 2020
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`Aug. 17, 2020
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`Sept. 2, 2020
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`July 31, 2020
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`Sep. 21, 2020
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`Sept. 30, 2020
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`Aug. 28, 2020
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`Oct. 5, 2020
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`Oct. 28, 2020
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`Sep. 17, 2020
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`Oct. 26, 2020
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`Nov. 17, 2020
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`Sep. 25, 2020
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`Nov. 2, 2020
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`Nov. 25, 2020
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`Nov. 2, 2020
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`No change
`
`Jan. 4, 2021
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`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4262 Page 5 of 14
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`Current Date
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`Nov. 9, 2020
`
`Nov. 16, 2020
`Nov. 16, 2020
`
`Event
`Deadline to Meet and
`Confer on Pretrial
`Disclosures
`Plaintiff Serves Draft
`Proposed Pretrial
`Order
`Motions in limine Due
`Proposed Pretrial
`Order Due to the Court Nov. 23, 2020
`Oppositions to Motions
`in limine Due
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`Nov. 23, 2020
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`BNR Proposal
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`LG Proposal
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`No change
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`Jan. 11, 2021
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`No change
`No change
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`Jan. 19, 2021
`Jan. 19, 2021
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`No change
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`Jan. 26, 2021
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`No change
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`No change
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`No change
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`Jan. 26, 2021
`Feb. 2, 2021 or
`subject to the
`Court’s availability
`Subject to the
`Court’s availability
`
`Pretrial Conference
`
`Nov. 30, 2020 at
`9 a.m.
`Dec. 15, 2020 at
`8:45 a.m.
`
`Trial
`
`The Parties submit the following statements in support of their respective
`proposals:
`BNR’s Statement
`The COVID-19 situation poses considerable obstacles to the administration
`of justice and the court system as a whole. Courts, faced with the uncertainty of
`what will happen with respect to the public health crisis, are having to balance the
`rights of litigants to a speedy resolution of their cases with safety concerns. As
`the Southern District of California has recognized on its website2 and as this
`Court acknowledged by declaring a mistrial in the Finjan, Inc. v. ESET, LLC case,
`there is an indisputable need to suspend court activities through at least April 16,
`2020. See Case No.: 3:17-cv-0183-CAB-(BGS), Dkt. No. 783 (Minute Order entered
`
`
`2 https://www.casd.uscourts.gov/_assets/pdf/rules/Order%20of%20the%20Chief%20
`Judge%2018.pdf (as of March 20, 2020).
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4263 Page 6 of 14
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`on Mar. 16, 2020). In view of these exigent circumstances, the Parties agree that an
`discovery extension until early June is necessary and prudent.
`However, it is premature to move all other dates in the schedule when such
`movement is not necessary. BNR’s proposal reflects the amount of time between
`dates that the Court ordered in the related, consolidated cases involving the ZTE
`and Coolpad defendants (C.A. Nos. 3.18-cv-1783 and 3.18-cv-1786). Therefore,
`this proposed schedule has proven to be reasonable and manageable and allows
`the parties sufficient time to complete fact discovery based on current predictions,
`while maintaining the Court’s trial date. While previously the Parties had agreed
`to more time between the deadlines, that additional time is not strictly necessary.
`In order to avoid affecting the Court’s schedule for trial and undue prejudice to
`BNR, BNR believes its proposal should be accepted.
`LG has provided no authority for prematurely extending all dates in the
`schedule. In fact, as of the date of this filing, BNR is not aware of any federal
`court that issued a general order continuing hearings and/or trials beyond June 1.3
`LG has not identified any specific concerns backed by restrictions that would
`prevent the Parties from meeting furture deadlines beyond early June. See Saint
`Lawrence Comm. LLC v. Amazon.com, Inc. et al., C.A. No. 2:19-cv-00027-JRG,
`Dkt. No. 79 (E.D.T.X. March 12, 2020) (“striving to balance its decision between
`the competing parameters of prudence and panic”). And if such specific concerns
`arise, the Parties and the Court are free to revisit the schedule. But it is simply
`premature to do so at this point.
`This Court has previously set a schedule in the related consolidated case
`that was commensurate with the deadlines BNR proposes here, and no party ever
`asked for an extension of that schedule. While the Parties in this case previously
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`3 https://www.paulhastings.com/about-us/advice-for-businesses-in-dealing-with-the-
`expanding-coronavirus-events/u.s.-court-closings-cancellations-and-restrictions-due-
`to-covid-19 (collecting orders).
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4264 Page 7 of 14
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`agreed upon a schedule that built in some additional time, one reason for that
`agreement on BNR’s part is that it would allow flexibility in exigent
`circumstances. While no one anticipated COVID-19, the pandemic does not yet
`necessitate pushing off a trial scheduled for December at this point. As explained
`previously, there is sufficient time in the schedule to permit the parties to
`accomplish what they need to accomplish without moving the trial date. For
`example, the parties do not need nearly two months after rebuttal expert reports
`are due to prepare their summary judgment and Daubert motions – a month and a
`half should be sufficient. LG need not wait until the last day of expert discovery
`to begin work on its motions.
`Finally, LG’s assertion that “BNR’s proposed schedule assumes that the
`current public health emergency will not have any impact on later dates in this case
`or other cases in this District” is simply false. BNR assumes no such thing.. The
`situation is uncertain, and BNR does not guarantee that there will be no reason for
`the parties or the Court to revisit the schedule due to continued COVID-19 issues.
`But LG’s proposal does not address that scenario any more than BNR’s does,
`because the trajectory of this pandemic is uncertain. Nor is there any evidence
`that LG’s proposed two months’ extension of the trial date reflects some
`forecasted turning point for COVID-19. LG dismissively ignores the prejudice
`BNR will suffer as a result of lost time and delay of resolution of this matter if the
`schedule is unnecessarily extended. Thus, BNR submits that the most reasonable
`course of action is for the Court to extend deadlines that are reasonably necessary
`to extend at the current and anticipated stage of events, and not to needlessly and
`prematurely disrupt its schedule on speculation and conjecture.
`Therefore, BNR respectfully requests that the Court adopt BNR’s proposal.
`
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`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4265 Page 8 of 14
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`LG’s Statement
`As the Parties negotiated dates and locations for depositions in recent weeks,
`LG remained willing and able to move forward with the depositions of its witnesses
`within the current fact discovery period, even if it required that the subset of LG’s
`counsel who attended the depositions scheduled to take place in South Korea in early
`April would need to self-quarantine away from their families upon return to the
`United States. However, on Wednesday, March 11, 2020, BNR informed LG that
`personnel necessary to conduct the depositions in South Korea (e.g., court reporters,
`interpreters) are no longer available due to COVID-19 concerns. Likewise, the
`Parties have now agreed to postpone the depositions of BNR’s witnesses, who reside
`in Canada and may face travel restrictions.
`Given these restrictions and the dire circumstances created by the spread of the
`coronavirus in this country and abroad, BNR initially proposed a one-month
`extension of fact discovery, without modifying any other dates in the procedural
`schedule. While LG agreed that an extension of the schedule was necessary in light
`of COVID-19, LG proposed a two-month extension of all case deadlines instead of
`just an extension of the fact discovery cut-off. After further consideration, BNR
`proposed a procedural schedule that extends the fact discovery and expert disclosures
`deadlines by 52 days, pushes out the expert report due dates by about 45 days, and
`delays the dispositive motion deadlines by about 38 days. But BNR’s proposal
`keeps all of the remaining dates—including all of the dates for pretrial exchanges,
`motions in limine, and trial—unchanged.
`In contrast, LG proposes that all dates in the procedural schedule, including
`the pretrial and trial dates, should be uniformly extended by two months for at least
`three reasons. First, LG’s requested extension of all deadlines is consistent with the
`across-the-board extensions of two to three months that many courts around the
`country have been granting in light of the coronavirus concerns. E.g., In the Matter
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`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4266 Page 9 of 14
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`of Certain Pouch-Type Battery Cells, Battery Modules, and Battery Pack , Inv. No.
`337-TA-1179, Order No. 21 (U.S.I.T.C. Mar. 10, 2020) (extending all deadlines of
`ITC investigation involving LG Chem, Ltd. by two to three months due to COVID-
`19 concerns). Some courts have extended all deadlines in civil cases. For example,
`the the Northern District of Illinois issued an Amended General Order on March 16
`providing that “[i]n all civil cases, all deadlines, whether set by the court or by the
`Rules of Civil Procedure or Local Rules, are hereby extended by 21 days from the
`current deadline set.”4 And other courts have simply vacated all deadlines until
`further notice. E.g., Sheaffer v. Sup. Tank Lines N.W. Div. LLC, No. 2:19-cv-190,
`Dkt. No. 53 (W.D. Wash. Mar. 13, 2020) (“Given the uncertainty over when the
`Western District of Washington will resume holding civil trials in light of the recent
`General Order regarding COVID-19, the Court will hereby vacate the currently
`pending deadlines in this matter, including motions in limine, joint pretrial statement,
`pretrial conference, and the trial date.”). In fact, just a few days ago, Judge
`Bencivengo adopted this approach in the middle of trial by vacating all pending
`dates:
`The Court suspended jury trial proceedings and excused the jury for
`the day. With the agreement of counsel, the Court deems a Mistrial
`based upon the current state of extraordinary circumstances due to the
`Coronavirus/COVID-19 Pandemic. The Court will contact counsel
`upon the conclusion of the national state of emergency for further
`scheduling of court proceedings. All previously pending dates of trial
`are hereby vacated.
`
`Finjan, Inc. v. ESET, LLC, Case No.: 3:17-cv-0183-CAB-(BGS), Dkt. No. 783
`(Minute Order entered on Mar. 16, 2020) (emphasis added).
`Second, the parties negotiated the current schedule—including the time
`intervals between deadlines—specifically to provide the parties and the Court with
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`4 https://content.govdelivery.com/attachments/USFEDCOURTS/2020/03/16/file_
`attachments/1402402/AmendedGeneralOrder20-0012.pdf
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`sufficient time for the orderly conduct of all of the events that must take place
`between now and trial. See Dkt. No. 101 (Jt. Notice of Prop. Sched. Order).
`Extending fact and expert discovery but then squeezing the rest of the dates into the
`same timeframe—as BNR proposes—would unnecessarily compress the time for
`critically important and potentially case-dispositive events such as summary
`judgment motions and pre-trial submissions. For example, BNR’s proposal
`compresses the timeframe for preparing summary judgment and Daubert motions
`from the agreed-upon four weeks down to just two weeks, thus prejudicing LG’s
`ability to prepare these motions. While BNR dismisses these concerns by urging LG
`not to wait to prepare its dispositive motions, the reality is that much of the evidence
`likely needed to support these motions would come from expert depositions, and
`could not be prepared before the evidence is secured. As another example, BNR’s
`proposed schedule would have the reply briefs in support of dispositive motions and
`Daubert motions due just three weeks before the parties must submit to the Court the
`proposed final pretrial order. As a result, the Court would be left with little time to
`consider all of the issues and to rule on the pending motions. And by squeezing the
`time window for the Court to resolve the motions, the parties may not know what
`issues remain for trial until possibly days before the trial. This situation is simply
`unnecessary and unfair to the Court and to LG. Rather than compress the remaining
`schedule after expert discovery, LG respectfully submits that it would be much better
`to simply extend the entire case schedule by at least two months so that all events
`can take place in the orderly fashion that the parties contemplated when they
`negotiated the current joint procedural schedule.
`Third, BNR’s proposed schedule assumes that the current public health
`emergency will not have any impact on later dates in this case or other cases in this
`District. An orderly litigation process, however, involves events building on
`previous events. For example, the preparation of expert reports relies on evidence
`
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
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`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`from fact discovery, and dispositive motions are usually based on reports and
`depositions from experts. Once an event in the case is impacted, later events will
`also be impacted like falling dominos. Beyond this one case, the public health
`emergency has had drastic consequences on court calendars. Indeed, this District,
`along with many other district courts around the country, has continued civil and
`criminal trials scheduled to begin now through the middle to the end of April. See,
`e.g., Order of the Chief Judge No. 18: Suspension of Jury Trials and Other
`Proceedings during the COVID-19 Public Emergency (S.D. Cal. Mar. 17, 2020);5
`General Order No. 72 In re Coronavirus Disease Public Health Emergency (N.D.
`Cal. Mar. 16, 2020);6 In re Coronavirus/ COVID-19 Pandemic Standing Order
`(S.D.N.Y. Mar. 13, 2020);7 Order Regarding Court Operations Under the Exigent
`Circumstances Created by the COVID-19 Pandemic (W.D. Tex. Mar. 13, 2020).8
`Even if it were desirable to maintain the current trial date in this case, rescheduled
`trial dates in other civil cases and—more importantly—in criminal cases subject to
`the Speedy Trial Act will likely take priority and require moving the trial date in this
`case.
`Finally, the simple fact is that the timeframe for the situation we are all facing
`now continues to remain uncertain. For example, the quarantine imposed on January
`26, 2020 in the Hubei province of China where the virus was first reported in
`December 2019 remains in force nearly two months later, with only partial
`exceptions made in recent days. In Italy, the first COVID-19 case appeared on
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`5 https://www.casd.uscourts.gov/_assets/pdf/rules/Order%20of%20the%20Chief%
`20Judge%2018.pdf
`6 https://cand.uscourts.gov/wp-content/uploads/general-orders/GO_72_3-16-
`2020.pdf.
`7 https://nysd.uscourts.gov/sites/default/files/2020-03/20%20MISC%
`20154a%20(002)%20-%20In%20Re%20Coronavirus-COVID-19%20Pandemic.pdf
`8 https://www.txwd.uscourts.gov/wp-content/uploads/2020/03/Order-Re-COVID-
`19.pdf
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
`
`
`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4269 Page 12 of 14
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`January 31, 2020, and the first cluster of cases were detected in the Lombardy region
`on February 21, 2020. Even though the Italian government placed the entire country
`in quarantine on March 11, 2020, the death rate and spread of the virus in Italy
`continue unabated even today nearly a month and a half after the first case appeared.
`The coronavirus crisis in the United States is only at its initial stage, with travel and
`movement restrictions likely to expand. For example, the government issued a
`“shelter in place” order in Northern California that directs everyone in six counties in
`the Bay Area to stay inside their homes and away from each other for at least three
`weeks.9 As another example, the U.S. State Department issued a “Level 4: Do Not
`Travel” advisory on March 19, 2020, citing other countries’ “mandatory quarantines,
`closing borders, and prohibiting non-citizens from entry with little advance notice.”10
`With each passing day in this public health emergency, the obstacles to an orderly
`litigation process continue to mount. Continuing all of the dates in this case by at
`least 60 days will allow time for the crisis to crescendo and the parties to proceed
`with the litigation in an orderly manner despite the challenges of the present
`situation.
`LG therefore respectfully requests that the Court adopt LG’s proposed
`schedule.
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`9 https://www.sfchronicle.com/local-politics/article/Bay-Area-must-shelter-in-place-
`Only-15135014.php
`10 https://travel.state.gov/content/travel/en/traveladvisories/ea/travel-advisory-alert-
`global-level-4-health-advisory-issue.html
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
`
`
`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4270 Page 13 of 14
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`Dated: March 20, 2020
`
`
`/s/ Sadaf R. Abdullah
`Mieke K. Malmberg
`(SBN 209992)
`SKIERMONT DERBY LLP
`800 Wilshire Blvd., Ste. 1450
`Los Angeles, CA 90017
`Phone: (213) 788-4500
`Fax: (213) 788-4545
`mmalmberg@skiermontderby.com
`
`Paul J. Skiermont (pro hac vice)
`Sadaf R. Abdullah (pro hac vice)
`Steven W. Hartsell (pro hac vice)
`Alexander E. Gasser (pro hac vice)
`Jaime K. Olin
`(SBN 243139)
`Steven J. Udick (pro hac vice)
`Joseph M Ramirez (pro hac vice)
`SKIERMONT DERBY LLP
`1601 Elm St., Ste. 4400
`Dallas, TX 75201
`Phone: (214) 978-6600
`Fax: (214) 978-6601
`pskiermont@skiermontderby.com
`sabdullah@skiermontderby.com
`shartsell@skiermontderby.com
`agasser@skiermontderby.com
`jolin@skiermontderby.com
`sudick@skiermontderby.com
`jramirez@skiermontderby.com
`
`Attorneys for Plaintiff
`Bell Northern Research, LLC
`
`
`
` Respectfully submitted,
`
`/s/ R. Andrew Schwentker
`Joanna M. Fuller (SBN 266406)
`jfuller@fr.com
`FISH & RICHARDSON P.C.
`12390 El Camino Real
`San Diego, CA 92130
`Phone: (858) 678-5070
`Fax: (858) 678-5099
`
`Michael McKeon (DC Bar No. 459780;
`admitted pro hac vice)
`mckeon@fr.com
`Christian Chu (SBN 218336)
`chu@fr.com
`Stephen A. Marshall (DC Bar No.
`1012870; admitted pro hac vice)
`smarshall@fr.com
`R. Andrew Schwentker (DC Bar No.
`991792; admitted pro hac vice)
`schwentker@fr.com
`FISH & RICHARDSON P.C.
`1000 Maine Avenue SW
`Washington, D.C. 20024
`Phone: (202) 783-5070
`Fax: (202) 783-2331
`
`Attorneys for Defendants
`LG Electronics Inc., LG Electronics
`U.S.A., Inc., and LG Electronics Mobile
`Research U.S.A., LLC
`
`
`
`
`
`
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
`
`
`(CASE NO. 3:18-CV-2864-CAB-BLM)
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`Case 3:18-cv-02864-CAB-BLM Document 115 Filed 03/20/20 PageID.4271 Page 14 of 14
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`SIGNATURE CERTIFICATION
`Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies
`and Procedures Manual, I hereby certify that the content of this document is
`acceptable to Andy Schwentker, counsel for the LG Defendants, and that I have
`obtained his/her authorization to affix his/her electronic signature to this document.
`
`
`/s/ Sadaf R. Abdullah
`
`CERTIFICATE OF SERVICE
`I hereby certify that a true and correct copy of the above and foregoing
`
`document has been served on March 20, 2020 to all counsel of record who are deemed
`to have consented to electronic service via the Court’s CM/ECF System. Pursuant to
`Local Rule 5.4(c), any other counsel of record will be served by electronic mail,
`facsimile or overnight delivery.
`
`
`/s/ Sadaf R. Abdullah
`
`JOINT MOTION TO EXTEND CASE MANAGEMENT ORDER
`
`
`(CASE NO. 3:18-CV-2864-CAB-BLM)
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