Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 1 of 15 PageID #: 155
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`TERRACON CONSULT ANTS, INC.,
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`V.
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`NV5, INC.,
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`Plaintiff,
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`Defendant.
`
`)
`)
`)
`)
`) C.A. No. 21-100 (LPS)
`)
`)
`)
`)
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`PROPOSED PATENT SCHEDULING ORDER
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`This),.~ day of June, 2021, the parties having determined after discussion that the
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`matter cannot be resolved at this juncture by settlement, voluntary mediation, or binding
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`arbitration;
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`IT IS HEREBY ORDERED that:
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`1.
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`Rule 26(a)(l) Initial Disclosures and E-Discovery Default Standard. Plaintiff
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`previously served its initial disclosures on January 26, 2021. Unless otherwise agreed to by the
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`parties, the Defendant shall make its initial disclosures pursuant to Federal Rule of Civil
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`Procedure 26(a)(l) within five (5) days of the date of this Order. If they have not already done
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`so, the parties are to review the Court's Default Standard for Discovery, Including Discovery of
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`Electronically Stored Information ("ESI") (which is posted at http://www.ded.uscourts.gov; see
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`Other Resources, Default Standards for Discovery, and is incorporated herein by reference).
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`Exhibit - 1015
`NV5, Inc. v. Terracon Consultants, Inc.
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`2.
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`Joinder of Other Parties and Amendment of Pleadings. All motions to join other
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`parties, and to amend or supplement the pleadings, shall be filed on or before November 25,
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`2021.
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`3.
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`Application to Court for Protective Order. The parties previously entered into an
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`Agreed Protective Order, which was entered by the District Court for the Southern District of
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`Texas on January 15, 2021. Doc. No. 37. The protective order includes in part the following
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`paragraph:
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`Other Proceedings. By entering this Protective Order and limiting
`the disclosure of information in this case, the presiding judge does
`not intend to preclude another court from finding that information
`may be relevant and subject to disclosure in another case. Any
`person or party subject to this Protective Order who may be subject
`to a motion to disclose another party's information designated
`"Confidential" or "Highly Confidential" pursuant to this Protective
`Order must promptly notify that party of the motion so that the
`party may have an opportunity to appear and be heard on whether
`that information should be disclosed.
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`4.
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`Papers Filed Under Seal. In accordance with section G of the Administrative
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`Procedures Governing Filing and Service by Electronic Means, a redacted version of any sealed
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`document shall be filed electronically within seven (7) days of the filing of the sealed document.
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`Should any party intend to request to seal or redact all or any portion of a transcript of a
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`court proceeding (including a teleconference), such party should expressly note that intent at the
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`start of the court proceeding. Should the party subsequently choose to make a request for sealing
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`or redaction, it must, promptly after the completion of the transcript, file with the Court a motion
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`for sealing/redaction, and include as attachments (1) a copy of the complete transcript
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`highlighted so the Court can easily identify and read the text proposed to be sealed/redacted, and
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`(2) a copy of the proposed redacted/sealed transcript. With their request, the party seeking
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`redactions must demonstrate why there is good cause for the redactions and why disclosure of
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`the redacted material would work a clearly defined and serious injury to the party seeking
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`redaction.
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`5.
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`Courtesy Copies. Other than with respect to "discovery matters," which are
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`governed by paragraph 8(g), and the final pretrial order, which is governed by paragraph 20, the
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`parties shall provide to the Court two (2) courtesy copies of all briefs and one (1) courtesy copy
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`of any other document filed in support of any briefs (i.e., appendices, exhibits, declarations,
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`affidavits etc.). This provision also applies to papers filed under seal.
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`6.
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`ADR Process. This matter is referred to a magistrate judge to explore the
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`possibility of alternative dispute resolution.
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`7.
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`Disclosures. Absent agreement among the parties, and approval of the Court:
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`a.
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`Plaintiff previously identified the accused product(s), including accused
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`methods and systems, as well as the asserted patent(s) that the accused product(s) allegedly
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`infringe(s) in infringement contentions and claim charts previously served on January 8, 2021
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`and in Plaintiffs initial disclosures previously served on January 26, 2021. Plaintiff also
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`previously produced the file history for each asserted patent on January 8, 2021.
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`b.
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`By June 28, 2021, Defendant shall produce core technical documents
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`related to the accused product(s), sufficient to show how the accused product(s) work(s),
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`including but not limited to non-publicly available operation manuals, product literature,
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`schematics, and specifications. Defendant shall also produce sales figures for the accused
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`product(s).
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`c.
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`By July 28, 2021 , Plaintiff shall produce an amended claim chart relating
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`each known accused product to the asserted claims each such product allegedly infringes.
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`d.
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`By September 1, 2021, Defendant shall produce its initial invalidity
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`contentions for each asserted claim, as well as the known related invalidating references.
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`e.
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`By 30 days after the Markman order, Plaintiff shall provide final
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`infringement contentions.
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`f.
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`By 14 days after Plaintiff provides final infringement contentions,
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`Defendant shall provide final invalidity contentions.
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`8.
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`Discovery. Unless otherwise ordered by the Court, the limitations on discovery
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`set forth in Local Rule 26.1 shall be strictly observed.
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`a.
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`Discovery Cut Off. All fact discovery in this case shall be initiated so that
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`it will be completed on or before February 21, 2022. All expert discovery in this case shall be
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`initiated so that it will be completed on or before July 9, 2022.
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`b.
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`Document Production. Document production shall be substantially
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`complete by November 20, 2021.
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`C.
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`Requests for Admission. A maximum of 50 requests for admission are
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`permitted for each side, except with respect to requests related to admissibility or authenticity
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`(subject to a claim of undue burden).
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`d.
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`Interrogatories.
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`1.
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`A maximum of 25
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`interrogatories,
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`including contention
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`interrogatories, are permitted for each side.
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`11.
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`The Court encourages the parties to serve and respond to
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`contention interrogatories early in the case. In the absence of agreement among the parties,
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`contention interrogatories, if filed, shall first be addressed by the party with the burden of proof.
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`The adequacy of all interrogatory answers shall be judged by the level of detail each party
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`provides; i.e., the more detail a party provides, the more detail a party shall receive.
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`e.
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`Depositions.
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`l.
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`Limitation on Hours for Deposition Discovery. Each side is limited
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`to a total of70 hours of taking testimony by deposition upon oral examination.
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`11.
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`Location of Depositions. Any party or representative ( officer,
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`director, or managing agent) of a party filing a civil action in this district court must ordinarily be
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`required, upon request, to submit to a deposition at a place designated within this district.
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`Exceptions to this general rule may be made by order of the Court. A defendant who
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`becomes a counterclaimant, cross-claimant, or third-party plaintiff shall be considered as having
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`filed an action in this Court for the purpose of this provision.
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`f.
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`Disclosure of Expert Testimony.
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`1.
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`Expert Reports. For the party who has the initial burden of proof
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`on the subject matter, the initial Federal Rule 26(a)(2) disclosure of expert testimony is due on or
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`before April 5, 2022. The supplemental disclosure to contradict or rebut evidence on the same
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`matter identified by another party is due on or before May 13, 2022. Reply expert reports from
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`the party with the initial burden of proof are due on or before June 3, 2022. No other expert
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`reports will be permitted without either the consent of all parties or leave of the Court. Along
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`with the submissions of the expert reports, the parties shall advise of the dates and times of their
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`experts' availability for deposition.
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`11.
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`Expert Report Supplementation. The parties agree they will permit
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`expert declarations to be filed in connection with motions briefing (including case-dispositive
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`motions), within the scope of their expert disclosures.
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`iii.
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`Objections to Expert Testimony. To the extent any objection to
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`expert testimony is made pursuant to the principles announced in Daubert v. Merrell Dow
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`Pharm., Inc., 509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it shall be
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`made by motion no later than the deadline for dispositive motions set forth herein, unless
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`otherwise ordered by the Court. Briefing on such motions is subject to the page limits set out in
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`connection with briefing of case dispositive motions.
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`g.
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`Discovery Matters and Disputes Relating to Protective Orders.
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`1.
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`Any discovery motion filed without first complying with the
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`following procedures will be denied without prejudice to renew pursuant to these procedures.
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`11.
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`Should counsel find, after good faith efforts -
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`including verbal
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`communication among Delaware and Lead Counsel for all parties to the dispute -
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`that they are
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`unable to resolve a discovery matter or a dispute relating to a protective order, the parties
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`involved in the discovery matter or protective order dispute shall submit a joint letter in
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`substantially the following form:
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`Dear Judge Stark:
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`The parties in the above- referenced matter write to request the
`scheduling of a discovery teleconference.
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`The following attorneys, including at least one Delaware Counsel
`and at least one Lead Counsel per party, participated in a verbal
`meet-and-confer (in person and/or by telephone) on the following
`date(s):
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`Delaware Counsel: ________ _
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`Lead Counsel: _____________ _
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`The disputes requiring judicial attention are listed below:
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`[provide here a non-argumentative list of disputes requiring
`judicial attention]
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`111.
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`On a date to be set by separate order, generally not less than forty-
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`eight ( 48) hours prior to the conference, the party seeking relief shall file with the Court a letter,
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`not to exceed three (3) pages, outlining the issues in dispute and its position on those issues. On a
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`date to be set by separate order, but generally not less than twenty-four (24) hours prior to the
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`conference, any party opposing the application for relief may file a letter, not to exceed three (3)
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`pages, outlining that party's reasons for its opposition.
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`iv.
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`Each party shall submit two (2) courtesy copies of its discovery
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`letter and any attachments.
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`v.
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`Should the Court find further briefing necessary upon conclusion
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`of the telephone conference, the Court will order it. Alternatively, the Court may choose to
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`resolve the dispute prior to the telephone conference and will, in that event, cancel the
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`conference.
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`9.
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`Motions to Amend.
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`a.
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`Any motion to amend (including a motion for leave to amend) a pleading
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`shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not
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`to exceed three (3) pages, describing the basis for the requested relief, and shall attach the
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`proposed amended pleading as well as a "blackline" comparison to the prior pleading.
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`b.
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`Within seven (7) days after the filing of a motion in compliance with this
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`Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5)
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`pages.
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`c.
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`Within three (3) days thereafter, the moving party may file a reply letter,
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`not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a
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`teleconference to address the motion to amend.
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`10. Motions to Strike.
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`a.
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`Any motion to strike any pleading or other document shall NOT be
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`accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed
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`three (3) pages, describing the basis for the requested relief, and shall attach the document to be
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`stricken.
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`b.
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`Within seven (7) days after the filing of a motion in compliance with this
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`Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5)
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`pages.
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`c.
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`Within three (3) days thereafter, the moving party may file a reply letter,
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`not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a
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`teleconference to address the motion to strike.
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`11.
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`Tutorial Describing the Technology and Matters in Issue. Unless otherwise
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`ordered by the Court, the parties shall provide the Court, no later than the date on which their
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`opening claim construction briefs are due, a tutorial on the technology at issue. In that regard, the
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`parties may separately or jointly submit a DVD of not more than thirty (30) minutes. The tutorial
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`should focus on the technology in issue and should not be used for argument. The parties may
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`choose to file their tutorial(s) under seal, subject to any protective order in effect. Each party may
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`comment, in writing (in no more than five (5) pages) on the opposing party's tutorial. Any such
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`comment shall be filed no later than the date on which the answering claim construction briefs
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`are due. As to the format selected, the parties should confirm the Court's technical abilities to
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`access the information contained in the tutorial ( currently best are "mpeg" or "quicktime").
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`12.
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`Claim Construction Issue Identification. On September 28, 2021, the parties shall
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`exchange a list of those claim term(s)/phrase(s) that they believe need construction and their
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`proposed claim construction of those term(s)/phrase(s). This document will not be filed with the
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`Court. On October 5, 2021, the parties shall exchange their proposed claim construction of
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`those term(s)/phrase(s). Subsequent to exchanging that list, the parties will meet and confer to
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`prepare a Joint Claim Construction Chart to be submitted on October 12, 2021. The parties'
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`Joint Claim Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s)
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`in issue, and should include each party's proposed construction of the disputed claim language
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`with citation(s) only to the
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`intrinsic evidence in support of their respective proposed
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`constructions. A copy of the patent(s) in issue as well as those portions of the intrinsic record
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`relied upon shall be submitted with this Joint Claim Construction Chart. In this joint submission,
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`the parties shall not provide argument.
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`13.
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`Claim Construction Briefing. The Plaintiff shall serve, but not file, its opening
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`brief, not to exceed 20 pages, on October 26, 2021. The Defendant shall serve, but not file, its
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`answering brief, not to exceed 30 pages, on November 23, 2021. The Plaintiff shall serve, but
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`not file, its reply brief, not to exceed 20 pages, on December 17, 2021. The Defendant shall
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`serve, but not file, its sur-reply brief, not to exceed 10 pages, on January 12, 2022. No later than
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`January 19, 2022, the parties shall file a Joint Claim Construction Brief. The parties shall copy
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`and paste their untitled briefs into one brief, with their positions on each claim term in sequential
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`order, in substantially the form below:
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`JOINT CLAIM CONSTRUCTION BRIEF
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`I. Representative Claims
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`II. Agreed-upon Constructions
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`III. Disputed Constructions
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`A.
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`[TERM 1]
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`1. Plaintiffs Opening Position
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`2. Defendant' s Answering Position
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`3. Plaintiffs Reply Position
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`4. Defendant's Sur-Reply Position
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`B.
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`[TERM 2]
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`1. Plaintiffs Opening Position
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`2. Defendant' s Answering Position
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`3. Plaintiffs Reply Position
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`4. Defendant's Sur-Reply Position
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`The parties need not include any general summaries of the law relating to claim
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`construction. If there are any materials that would be submitted in an index, the parties shall
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`submit them in a Joint Appendix.
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`14.
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`Hearing on Claim Construction. Beginning at 9:00 a.m. on February 7, 2022, the
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`Court will hear argument on claim construction. The parties shall notify the Court, by joint letter
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`submission, no later than the date on which their answering claim construction briefs are due:
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`(i) whether they request leave to present testimony at the hearing; and (ii) the amount of time
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`they are requesting be allocated to them for the hearing.
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`Provided that the parties comply with all portions of this Scheduling Order, and any other
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`orders of the Court, the parties should anticipate that the Court will issue its claim construction
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`order within sixty (60) days of the conclusion of the claim construction hearing. If the Court is
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`unable to meet this goal, it will advise the parties no later than sixty (60) days after the
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`conclusion of the claim construction hearing.
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`15.
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`Interim Status Report. On February 7, 2022, counsel shall submit a joint letter to
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`the Court with an interim report on the nature of the matters in issue and the progress of
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`discovery to date. Thereafter, if the Court deems it necessary, it will schedule a status
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`conference.
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`16.
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`Supplementation. Absent agreement among the parties, and approval of the Court,
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`no later than the dates set for final infringement and invalidity contentions, the parties must
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`finally supplement, inter alia, the identification of all accused products and of all invalidity
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`references.
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`17.
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`Case Dispositive Motions. All case dispositive motions, an opening brief, and
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`affidavits, if any, in support of the motion shall be served and filed on or before August 3,
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`2022. Briefing will be presented pursuant to the Court' s Local Rules, as modified by this
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`Order.
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`a.
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`No early motions without leave. No case dispositive motion under Rule 56
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`may be filed more than ten (10) days before the above date without leave of the Court.
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`b.
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`Page limits combined with Daubert motion page limits. Each party is
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`permitted to file as many case dispositive motions as desired; provided, however, that each SIDE
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`will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40
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`pages for all answering briefs, and a combined total of 20 pages for all reply briefs regardless of
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`the number of case dispositive motions that are filed. In the event that a party files , in addition to
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`a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an
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`expert's testimony, the total amount of pages permitted for all case dispositive and Daubert
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`motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs,
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`and 25 pages for all reply briefs for each SIDE. 1
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`C.
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`Hearing. The Court will hear argument on all pending case dispositive and
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`Daubert motions on November 1, 2022 beginning at 9:00 a.m.
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`Subject to further order of the Court, each side will be allocated a total of forty-five ( 45)
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`minutes to present its argument on all pending motions.
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`18.
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`Applications by Motion. Except as otherwise specified herein, any application to
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`the Court shall be by written motion filed with the Clerk. Any non-dispositive motion should
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`contain the statement required by Local Rule 7.1.1.
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`19.
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`Pretrial Conference. On January 27, 2023, the Court will hold a pretrial
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`conference m Court with counsel beginning at 2:00 p.m. Unless otherwise ordered by the
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`Court, the parties should assume that filing the pretrial order satisfies the pretrial disclosure
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`requirement of Federal Rule of Civil Procedure 26(a)(3). The parties shall file with the Court the
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`joint proposed final pretrial order with the information required by the form of Revised Final
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`Pretrial Order -- Patent, which can be found on the Court's website (www.ded.uscourts.gov), on or
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`before January 17, 2023 . Unless otherwise ordered by the Court, the parties shall comply with
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`the
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`timeframes set forth
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`in Local Rule 16.3( d)(l )-(3) for the preparation of the joint
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`proposed final pretrial order.
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`The parties must work together to ensure that the Court receives no more than a total of
`250 pages (i.e., 50 + 50 + 25 regarding one side's motions, and 50 + 50 + 25 regarding the
`other side's motions) of briefing on all case dispositive motions and Daubert motions that
`are covered by this scheduling order and any other scheduling order entered in any related
`case that is proceeding on a consolidated or coordinated pretrial schedule.
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`The parties shall provide the Court two (2) courtesy copies of the joint proposed final
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`pretrial order and all attachments.
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`As noted in the Revised Final Pretrial Order - Patent, the parties shall include in their
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`joint proposed final pretrial order, among other things:
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`a.
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`a request for a specific number of hours for their trial presentations, as
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`well as a requested number of days, based on the assumption that in a typical jury trial day (in
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`which there is not jury selection, jury instruction, or deliberations), there will be 5 ½ to 6 ½
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`hours of trial time, and in a typical bench trial day there will be 6 to 7 hours of trial time;
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`b.
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`their position as to whether the Court should allow objections to efforts to
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`impeach a witness with prior testimony, including objections based on lack of completeness
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`and/or lack of inconsistency;
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`C.
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`their position as to whether the Court should rule at trial on objections to
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`expert testimony as beyond the scope of prior expert disclosures, taking time from the parties'
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`trial presentation to argue and decide such objections, or defer ruling on all such objections
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`unless renewed in writing following trial, subject to the proviso that a party prevailing on such a
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`post-trial objection will be entitled to have all of its costs associated with a new trial paid for by
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`the party that elicited the improper expert testimony at the earlier trial; and
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`d.
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`their position as to how to make motions for judgment as a matter of law,
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`whether it be immediately at the appropriate point during trial or at a subsequent break, whether
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`the jury should be in or out of the courtroom, and whether such motions may be supplemented in
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`writing.
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`20. Motions in Limine. Motions in limine shall not be separately filed. All in /imine
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`requests and responses thereto shall be set forth in the proposed pretrial order. Each SIDE shall
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`be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine
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`request and any response shall contain the authorities relied upon; each in limine request may be
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`supported by a maximum of three (3) pages of argument and may be opposed by a maximum of
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`three (3) pages of argument, and the side making the in limine request may add a maximum of
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`one (I) additional page in reply in support of its request. If more than one party is supporting or
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`opposing an in limine request, such support or opposition shall be combined in a single three (3)
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`page submission (and, if the moving party, a single one (1) page reply), unless otherwise ordered
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`by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise
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`permitted by the Court.
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`21.
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`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a case is to be
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`tried to a jury, pursuant to Local Rules 4 7 and 51 the parties should file (i) proposed voir dire,
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`(ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict forms
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`three (3) business days before the final pretrial conference. This submission shall be
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`accompanied by a courtesy copy containing electronic
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`files of these documents, m
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`WordPerfect or Microsoft Word format, which may be submitted by e-mail to Judge Stark' s
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`staff.
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`22.
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`Trial. This matter is scheduled for a seven (7) day jury trial beginning at 9:30 a.m.
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`on February 6, 2023, with the subsequent trial days beginning at 9:00 a.m. Until the case
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`is submitted to the jury for deliberations, the jury will be excused each day at 4:30 p.m. The
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`trial will be timed, as counsel will be allocated a total number of hours in which to present
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`their respective cases.
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`23.
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`Judgment on Verdict and Post-Trial Status Report. Within seven (7) days after
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`a jury returns a verdict in any portion of a jury trial, the parties shall jointly submit a form of
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`order to enter judgment on the verdict. At the same time, the parties shall submit a joint status
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`report, indicating among other things how the case should proceed and listing any post-trial
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`motions each party intends to file.
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`24.
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`Post-Trial Motions. Unless otherwise ordered by the Court, all SIDES are limited
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`to a maximum of 20 pages of opening briefs, 20 pages of answering briefs, and 10 pages of reply
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`briefs relating to any post-trial motions filed by that side, no matter how many such motions are
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`filed.
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`- 15 -
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`