Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 1 of 14
`
`JRG3,JURY,PATENT/TRADEMARK,PROTECTIVE−ORDER
`U.S. District Court
`Eastern District of TEXAS [LIVE] (Marshall)
`CIVIL DOCKET FOR CASE #: 2:19−cv−00414−JRG
`
`Bright Data Ltd. v. Tefincom S.A.
`Assigned to: District Judge Rodney Gilstrap
`Related Cases: 2:19−cv−00395−JRG
`2:19−cv−00396−JRG
`2:20−cv−00188−JRG−RSP
`2:21−cv−00225−JRG−RSP
`2:21−cv−00224
`Cause: 35:271 Patent Infringement
`Plaintiff
`Bright Data Ltd.
`
`Date Filed: 12/31/2019
`Jury Demand: Plaintiff
`Nature of Suit: 830 Patent
`Jurisdiction: Federal Question
`
`represented by Colby Alexander Davis
`RuyakCherian LLP
`1901 L Street NW
`Suite 700
`Washington, DC 20006
`202−760−5171
`Fax: 202−478−1715
`Email: colbyd@ruyakcherian.com
`ATTORNEY TO BE NOTICED
`Gregory Blake Thompson
`Mann Tindel & Thompson
`201 E. Howard Street
`Henderson, TX 75654
`903/657−8540
`Fax: 903−657−6003
`Email: Blake@TheMannFirm.com
`ATTORNEY TO BE NOTICED
`James Mark Mann
`Mann Tindel & Thompson
`201 E. Howard Street
`Henderson, TX 75654
`903/657−8540
`Fax: 903−657−6003
`Email: Mark@TheMannFirm.com
`ATTORNEY TO BE NOTICED
`Joshua C Benson
`RuyakCherian LLP − Berkley
`1936 University Avenue
`Suite 350
`Berkeley, CA 94704
`510−613−4960
`Fax: 202−478−1715
`Email: joshuab@ruyakcherian.com
`ATTORNEY TO BE NOTICED
`Robert M Harkins , Jr
`RuyakCherian LLP − Berkley
`1936 University Avenue
`Suite 350
`Berkeley, CA 94704
`510−944−0187
`Fax: 202−478−1715
`Email: bobh@ruyakcherian.com
`ATTORNEY TO BE NOTICED
`Data Co Exhibit 1065
`Data Co v. Bright Data
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 2 of 14
`
`Ronald Wielkopolski
`RuyakCherian LLP
`1700 K St NW, Suite 810
`Washington, DC 20006
`202.838.1568
`Fax: 202−478−1715
`Email: ronw@ruyakcherian.com
`ATTORNEY TO BE NOTICED
`Sidney Calvin Capshaw , III
`Capshaw DeRieux LLP
`114 E Commerce Avenue
`Gladewater, TX 75647
`903−845−5770
`Email: ccapshaw@capshawlaw.com
`ATTORNEY TO BE NOTICED
`Thomas M Dunham
`RuyakCherian LLP
`1901 L Street NW
`Suite 700
`Washington, DC 20006
`(202) 838−1567
`Fax: (202) 478−1715
`Email: tomd@ruyakcherian.com
`ATTORNEY TO BE NOTICED
`Korula T Cherian
`RuyakCherian LLP − Berkley
`1936 University Avenue
`Suite 350
`Berkeley, CA 94704
`510.944.0185
`Email: sunnyc@ruyakcherian.com
`ATTORNEY TO BE NOTICED
`
`represented by Brett Christopher Govett
`Norton Rose Fulbright US LLP
`2200 Ross Avenue
`Suite 3600
`Dallas, TX 75201
`214/855−8118
`Fax: 12148558200
`Email: brett.govett@nortonrosefulbright.com
`LEAD ATTORNEY
`ATTORNEY TO BE NOTICED
`Steven Chase Callahan
`Charhon, Callahan, Robson & Garza PLLC
`3333 Lee Parkway
`Ste 460
`Dallas, TX 75219
`214−521−6400
`Fax: 214−764−8392
`Email: scallahan@ccrglaw.com
`LEAD ATTORNEY
`ATTORNEY TO BE NOTICED
`Arthur P Licygiewicz
`Norton Rose Fulbright US LLP − Dallas
`
`V.
`Defendant
`Tefincom S.A.
`agent of
`NordVPN
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 3 of 14
`
`2200 Ross Avenue, Suite 3600
`Dallas, TX 75201−7932
`214−855−8256
`Fax: 214−855−8200
`Email: art.licygiewicz@nortonrosefulbright.com
`ATTORNEY TO BE NOTICED
`Brandy Shannell Nolan
`Norton Rose Fulbright US LLP − Dallas
`2200 Ross Avenue, Suite 3600
`Dallas, TX 75201−7932
`214−855−8183
`Fax: 214−855−8200
`Email: brandy.nolan@nortonrosefulbright.com
`ATTORNEY TO BE NOTICED
`Brett Ashley McKean
`Norton Rose Fulbright US LLP − Houston
`1301 McKinney, Suite 5100
`Houston, TX 77010−3095
`713−651−5417
`Fax: 713−651−5246
`Email: bmckean@fulbright.com
`ATTORNEY TO BE NOTICED
`Craig N Tolliver
`Charhon, Callahan, Robson & Garza PLLC
`3333 Lee Parkway
`Ste 460
`Dallas, TX 75219
`469−587−7263
`Fax: 214−764−8392
`Email: ctolliver@ccrglaw.com
`ATTORNEY TO BE NOTICED
`Daniel S Leventhal
`Norton Rose Fulbright US LLP − Houston
`1301 McKinney, Suite 5100
`Houston, TX 77010−3095
`713−651−5151
`Fax: 713−651−5246
`Email: daniel.leventhal@nortonrosefulbright.com
`ATTORNEY TO BE NOTICED
`David H Ben−Meir
`Norton Rose Fulbright US LLP − Los
`Angeles
`555 South Flower sreet
`Suite 4100
`Los Angeles, CA 90071
`215−892−9200
`Fax: 215−892−9494
`Email: david.ben−meir@nortonrosefulbright.com
`ATTORNEY TO BE NOTICED
`George T Scott
`Charhon, Callahan, Robson & Garza PLLC
`3333 Lee Parkway
`Ste 460
`Dallas, TX 75219
`469−587−7264
`Fax: 214−764−8392
`Email: jscott@ccrglaw.com
`ATTORNEY TO BE NOTICED
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 4 of 14
`
`John Charles Heuton
`Charhon, Callahan, Robson & Garza PLLC
`3333 Lee Parkway
`Ste 460
`Dallas, TX 75219
`214−521−6400
`Fax: 214−764−8392
`Email: jheuton@ccrglaw.com
`ATTORNEY TO BE NOTICED
`Michael Charles Smith
`Scheef & Stone, LLP − Marshall
`P O Box 1556
`Marshall, TX 75671−1556
`903−938−8900
`Email: michael.smith@solidcounsel.com
`ATTORNEY TO BE NOTICED
`Mitchell Reed Sibley
`Charhon, Callahan, Robson & Garza PLLC
`3333 Lee Parkway
`Ste 460
`Dallas, TX 75219
`469−587−7265
`Fax: 214−521−6400
`Email: msibley@ccrglaw.com
`ATTORNEY TO BE NOTICED
`
`Date Filed
`12/31/2019
`
`12/31/2019
`
`12/31/2019
`
`12/31/2019
`
`12/31/2019
`
`12/31/2019
`
`01/02/2020
`01/02/2020
`
`01/06/2020
`
`# Docket Text
`1 COMPLAINT for Patent Infringement against Tefincom S.A. ( Filing fee $ 400
`receipt number 0540−7590718.), filed by Luminati Networks Ltd.. (Attachments: # 1
`Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7
`Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Civil Cover Sheet)(Cherian, Korula)
`(Entered: 12/31/2019)
`2 CORPORATE DISCLOSURE STATEMENT filed by Luminati Networks Ltd.
`identifying Corporate Parent IPPN Group Ltd. for Luminati Networks Ltd.. (Cherian,
`Korula) (Entered: 12/31/2019)
`3 DEMAND for Trial by Jury by Luminati Networks Ltd.. (Cherian, Korula) (Entered:
`12/31/2019)
`4 Notice of Filing of Patent/Trademark Form (AO 120). AO 120 mailed to the Director
`of the U.S. Patent and Trademark Office. (Cherian, Korula) (Entered: 12/31/2019)
`5 NOTICE of Designation of Attorney in Charge to Korula T Cherian on behalf of
`Luminati Networks Ltd. (Cherian, Korula) (Entered: 12/31/2019)
`6 NOTICE of Attorney Appearance by Sidney Calvin Capshaw, III on behalf of
`Luminati Networks Ltd. (Capshaw, Sidney) (Entered: 12/31/2019)
`Case assigned to District Judge Rodney Gilstrap. (ch, ) (Entered: 01/02/2020)
`In accordance with the provisions of 28 USC Section 636(c), you are hereby notified
`that a U.S. Magistrate Judge of this district court is available to conduct any or all
`proceedings in this case including a jury or non−jury trial and to order the entry of a
`final judgment. The form Consent to Proceed Before Magistrate Judge is available on
`our website. All signed consent forms, excluding pro se parties, should be filed
`electronically using the event Notice Regarding Consent to Proceed Before Magistrate
`Judge. (ch, ) (Entered: 01/02/2020)
`7 NOTICE of Attorney Appearance by Robert M Harkins, Jr on behalf of Luminati
`Networks Ltd. (Harkins, Robert) (Entered: 01/06/2020)
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 5 of 14
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`01/09/2020
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`01/15/2020
`03/23/2020
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`03/27/2020
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`10/28/2020
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`10/28/2020
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`10/28/2020
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`10/28/2020
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`10/28/2020
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`10/28/2020
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`10/29/2020
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`11/02/2020
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`11/09/2020
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`11/12/2020
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`11/12/2020
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`11/20/2020
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`11/27/2020
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`12/07/2020
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`12/11/2020
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`12/22/2020
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`01/07/2021
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`01/20/2021
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`8 NOTICE of Attorney Appearance by Ronald Wielkopolski on behalf of Luminati
`Networks Ltd. (Wielkopolski, Ronald) (Entered: 01/09/2020)
`9 SUMMONS Issued as to Tefincom S.A.. (nkl, ) (Entered: 01/15/2020)
`10 NOTICE of Attorney Appearance by James Mark Mann on behalf of Luminati
`Networks Ltd. (Mann, James) (Entered: 03/23/2020)
`11 NOTICE of Attorney Appearance by Gregory Blake Thompson on behalf of Luminati
`Networks Ltd. (Thompson, Gregory) (Entered: 03/27/2020)
`12 MOTION to Dismiss by Tefincom S.A.. (Attachments: # 1 Text of Proposed
`Order)(Callahan, Steven) (Entered: 10/28/2020)
`13 CORPORATE DISCLOSURE STATEMENT filed by Tefincom S.A. (Callahan,
`Steven) (Entered: 10/28/2020)
`14 NOTICE of Designation of Attorney in Charge to Steven Chase Callahan on behalf of
`Tefincom S.A. (Callahan, Steven) (Entered: 10/28/2020)
`15 NOTICE of Attorney Appearance by George T Scott on behalf of Tefincom S.A.
`(Scott, George) (Entered: 10/28/2020)
`16 NOTICE of Attorney Appearance by Mitchell Reed Sibley on behalf of Tefincom S.A.
`(Sibley, Mitchell) (Entered: 10/28/2020)
`17 NOTICE of Attorney Appearance by Craig N Tolliver on behalf of Tefincom S.A.
`(Tolliver, Craig) (Entered: 10/28/2020)
`18 NOTICE of Attorney Appearance by Michael Charles Smith on behalf of Tefincom
`S.A. (Smith, Michael) (Entered: 10/29/2020)
`19 NOTICE of Readiness for Scheduling Conference by Luminati Networks Ltd.
`(Cherian, Korula) (Entered: 11/02/2020)
`20 NOTICE by Tefincom S.A. of Filing of Alice Letter Brief (Attachments: # 1 Exhibit
`A)(Callahan, Steven) (Entered: 11/09/2020)
`21 RESPONSE in Opposition re 12 MOTION to Dismiss filed by Luminati Networks
`Ltd.. (Attachments: # 1 Text of Proposed Order)(Cherian, Korula) (Entered:
`11/12/2020)
`22 AMENDED COMPLAINT for Patent Infringement against Tefincom S.A., filed by
`Luminati Networks Ltd.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, #
`4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, #
`10 Exhibit J, # 11 Exhibit K)(Cherian, Korula) (Entered: 11/12/2020)
`23 RESPONSE in Support re 12 MOTION to Dismiss (Defendant's Reply in Support of
`Rule 12(b)(6) Motion to Dismiss) filed by Tefincom S.A.. (Callahan, Steven) (Entered:
`11/20/2020)
`24 MOTION to Dismiss Amended Complaint by Tefincom S.A.. (Attachments: # 1 Text
`of Proposed Order)(Callahan, Steven) (Entered: 11/27/2020)
`25 NOTICE by Tefincom S.A. re 24 MOTION to Dismiss Amended Complaint (Joint
`Alice Letter Brief) (Attachments: # 1 Exhibit A)(Callahan, Steven) (Entered:
`12/07/2020)
`26 RESPONSE in Opposition re 24 MOTION to Dismiss Amended Complaint filed by
`Luminati Networks Ltd.. (Attachments: # 1 Text of Proposed Order)(Cherian, Korula)
`(Entered: 12/11/2020)
`27 ORDER − Scheduling Conference set for 1/20/2021 09:00 AM before District Judge
`Rodney Gilstrap. Signed by District Judge Rodney Gilstrap on 12/22/2020. (nkl, )
`(Entered: 12/22/2020)
`28 NOTICE of Discovery Disclosure by Luminati Networks Ltd. re P.R. 3−1 and 3−2
`(Cherian, Korula) (Entered: 01/07/2021)
`Minute Entry for proceedings held before District Judge Rodney Gilstrap: Scheduling
`Conference held on 1/20/2021. Counsel for the parties appeared and were asked if they
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 6 of 14
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`02/03/2021
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`02/03/2021
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`02/09/2021
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`02/09/2021
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`02/10/2021
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`02/10/2021
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`02/10/2021
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`02/11/2021
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`03/03/2021
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`03/23/2021
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`03/23/2021
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`03/23/2021
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`03/23/2021
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`03/24/2021
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`03/24/2021
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`03/29/2021
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`03/31/2021
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`04/01/2021
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`consented to a trial before the United States Magistrate Judge. The Court then gave the
`parties Markman and Jury Selection dates. (Court Reporter Susan Zielie, RMR,
`FCRR.) (aeb) (Entered: 01/20/2021)
`29 Joint MOTION for Entry of Proposed Agreed Docket Control Order by Luminati
`Networks Ltd.. (Attachments: # 1 Text of Proposed Order)(Cherian, Korula) (Entered:
`02/03/2021)
`30 Joint MOTION for Entry of Proposed Agreed Discovery Order by Luminati Networks
`Ltd.. (Attachments: # 1 Text of Proposed Order)(Cherian, Korula) (Entered:
`02/03/2021)
`31 DOCKET CONTROL ORDER re 29 Joint MOTION for Entry of Proposed Agreed
`Docket Control Order filed by Luminati Networks Ltd.., Pretrial Conference set for
`11/29/2021 09:00 AM before District Judge Rodney Gilstrap., Amended Pleadings due
`by 5/12/2021., Jury Selection set for 1/3/2022 09:00AM before District Judge Rodney
`Gilstrap., Markman Hearing set for 7/28/2021 09:00 AM before District Judge Rodney
`Gilstrap., Motions in Limine due by 11/8/2021., Proposed Pretrial Order due by
`11/22/2021. Signed by District Judge Rodney Gilstrap on 2/8/2021. (nkl, ) (Entered:
`02/09/2021)
`32 DISCOVERY ORDER re 30 Motion for Entry of Proposed Agreed Discovery Order.
`Signed by District Judge Rodney Gilstrap on 2/8/2021. (nkl, ) (Entered: 02/09/2021)
`33 Joint MOTION for Protective Order by Luminati Networks Ltd.. (Attachments: # 1
`Text of Proposed Order)(Cherian, Korula) (Entered: 02/10/2021)
`34 NOTICE of Discovery Disclosure by Luminati Networks Ltd. re Initial and Additional
`Disclosures (Cherian, Korula) (Entered: 02/10/2021)
`35 NOTICE of Discovery Disclosure by Tefincom S.A. (Initial Disclosures) (Callahan,
`Steven) (Entered: 02/10/2021)
`36 PROTECTIVE ORDER granting 33 Joint MOTION for Protective Order. Signed by
`District Judge Rodney Gilstrap on 2/11/2021. (ch, ) (Entered: 02/11/2021)
`37 NOTICE of Discovery Disclosure by Tefincom S.A. (Invalidity Contentions and
`Subject Matter Eligibility Contentions) (Callahan, Steven) (Entered: 03/03/2021)
`38 NOTICE of Attorney Appearance by Brett Christopher Govett on behalf of Tefincom
`S.A. (Govett, Brett) (Entered: 03/23/2021)
`39 NOTICE of Attorney Appearance by Brandy Shannell Nolan on behalf of Tefincom
`S.A. (Nolan, Brandy) (Entered: 03/23/2021)
`40 NOTICE of Attorney Appearance by Brett Ashley McKean on behalf of Tefincom
`S.A. (McKean, Brett) (Entered: 03/23/2021)
`41 NOTICE of Attorney Appearance by Daniel S Leventhal on behalf of Tefincom S.A.
`(Leventhal, Daniel) (Entered: 03/23/2021)
`42 NOTICE of Discovery Disclosure by Luminati Networks Ltd. re P.R. 4−1 (Cherian,
`Korula) (Entered: 03/24/2021)
`43 NOTICE of Discovery Disclosure by Tefincom S.A. (Defendant's List of Claim Terms
`(P.R. 4−1)) (Callahan, Steven) (Entered: 03/24/2021)
`44 Unopposed MOTION TO CHANGE THE CASE CAPTION TO REFLECT
`PLAINTIFF'S NAME CHANGE by Luminati Networks Ltd.. (Attachments: # 1 Exhibit
`A, # 2 Exhibit B, # 3 Text of Proposed Order)(Wielkopolski, Ronald) (Entered:
`03/29/2021)
`45 ORDER granting 44 Motion to Change the Case Caption to Reflect Plaintiffs Name
`Change. Signed by District Judge Rodney Gilstrap on 03/30/2021. (nkl, ) (Entered:
`03/31/2021)
`46 Unopposed MOTION for Extension of Time to Amend P.R. 3−1 Disclosures to
`Address Software Limitations by Bright Data Ltd.. (Attachments: # 1 Text of Proposed
`Order)(Wielkopolski, Ronald) (Entered: 04/01/2021)
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 7 of 14
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`04/12/2021
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`04/14/2021
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`04/14/2021
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`04/15/2021
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`04/15/2021
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`04/19/2021
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`04/19/2021
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`04/26/2021
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`04/29/2021
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`05/05/2021
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`05/14/2021
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`05/18/2021
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`05/20/2021
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`06/01/2021
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`06/03/2021
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`06/08/2021
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`06/16/2021
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`06/30/2021
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`47 NOTICE of Attorney Appearance − Pro Hac Vice by John Charles Heuton on behalf
`of All Defendants. Filing fee $ 100, receipt number 0540−8351658. (Heuton, John)
`(Entered: 04/12/2021)
`48 NOTICE by Tefincom S.A. of Compliance regarding Patent Local Rule 4−2
`Disclosures (Leventhal, Daniel) (Entered: 04/14/2021)
`49 NOTICE of Discovery Disclosure by Bright Data Ltd. re P.R. 4−2 (Cherian, Korula)
`(Entered: 04/14/2021)
`50 Unopposed MOTION for Extension of Time to Complete Discovery (Second) TO
`AMEND P.R. 3−1 DISCLOSURES TO ADDRESS SOFTWARE LIMITATIONS by
`Bright Data Ltd.. (Attachments: # 1 Text of Proposed Order)(Cherian, Korula)
`(Entered: 04/15/2021)
`51 ORDER granting 46 Unopposed MOTION for Extension of Time to Amend P.R. 3−1
`Disclosures to Address Software Limitations. Signed by District Judge Rodney
`Gilstrap on 4/15/2021. (ch, ) (Entered: 04/16/2021)
`52 Joint MOTION FOR ENTRY OF E−DISCOVERY ORDER by Bright Data Ltd..
`(Attachments: # 1 Text of Proposed Order)(Wielkopolski, Ronald) (Entered:
`04/19/2021)
`53 Joint MOTION TO AMEND DOCKET CONTROL ORDER by Bright Data Ltd..
`(Attachments: # 1 Text of Proposed Order)(Wielkopolski, Ronald) (Entered:
`04/19/2021)
`54 ORDER granting 53 Joint MOTION TO AMEND DOCKET CONTROL ORDER.
`Signed by District Judge Rodney Gilstrap on 4/26/2021. (ch, ) (Entered: 04/28/2021)
`55 ORDER REGARDING E−DISCOVERY IN PATENT CASES granting 52 Motion
`FOR ENTRY OF E−DISCOVERY ORDER. Signed by District Judge Rodney
`Gilstrap on 4/28/2021. (nkl, ) (Entered: 04/29/2021)
`56 P.R. 4−3 Joint Claim Construction and Prehearing Statement by Bright Data Ltd..
`(Attachments: # 1 Exhibit Chart)(Wielkopolski, Ronald) (Entered: 05/05/2021)
`57 Unopposed MOTION to Substitute Attorney (Lead Attorney) by Bright Data Ltd..
`(Harkins, Robert) (Additional attachment(s) added on 5/18/2021: # 1 Text of Proposed
`Order) (nkl, ). (Entered: 05/14/2021)
`58 SEALED PATENT MOTION TO COMPEL DEFENDANT TO PRODUCE
`COMPLETE SOURCE CODE by Bright Data Ltd.. (Attachments: # 1 Affidavit
`McKune, # 2 Exhibit A, # 3 Exhibit B, # 4 Text of Proposed Order)(Cherian, Korula)
`(Entered: 05/18/2021)
`59 REDACTION to 58 SEALED PATENT MOTION TO COMPEL DEFENDANT TO
`PRODUCE COMPLETE SOURCE CODE by Bright Data Ltd.. (Attachments: # 1
`Affidavit McKune, # 2 Exhibit A − Remains Under Seal, # 3 Exhibit B, # 4 Text of
`Proposed Order)(Cherian, Korula) (Entered: 05/20/2021)
`60 SEALED RESPONSE to Motion re 58 SEALED PATENT MOTION TO COMPEL
`DEFENDANT TO PRODUCE COMPLETE SOURCE CODE filed by Tefincom S.A..
`(Attachments: # 1 Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Text of Proposed
`Order)(Leventhal, Daniel) (Entered: 06/01/2021)
`61 REDACTION to 60 Sealed Response to Motion, by Tefincom S.A.. (Attachments: # 1
`Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Text of Proposed Order)(Leventhal,
`Daniel) (Entered: 06/03/2021)
`62 Joint MOTION TO ADOPT CLAIM CONSTRUCTION ORDERS IN LIEU OF
`HEARING by Bright Data Ltd.. (Attachments: # 1 Text of Proposed
`Order)(Wielkopolski, Ronald) (Entered: 06/08/2021)
`63 ORDER granting 62 Motion to Adopt Claim Construction Orders in Lieu of Hearing.
`Signed by District Judge Rodney Gilstrap on 6/15/2021. (nkl, ) (Entered: 06/16/2021)
`64 NOTICE of Attorney Appearance − Pro Hac Vice by Colby Davis on behalf of Bright
`Data Ltd.. Filing fee $ 100, receipt number 0540−8477010. (Davis, Colby) (Entered:
`06/30/2021)
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 8 of 14
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`07/21/2021
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`07/23/2021
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`08/03/2021
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`08/03/2021
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`08/09/2021
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`08/09/2021
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`08/11/2021
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`08/20/2021
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`08/20/2021
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`08/23/2021
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`09/02/2021
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`09/07/2021
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`09/08/2021
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`65 NOTICE of Attorney Appearance by Arthur P Licygiewicz on behalf of Tefincom
`S.A. (Licygiewicz, Arthur) (Entered: 07/21/2021)
`66 NOTICE of Attorney Appearance by Thomas M Dunham on behalf of Bright Data
`Ltd. (Dunham, Thomas) (Entered: 07/23/2021)
`68 REDACTION to 67 Sealed Motion by Tefincom S.A.. (Attachments: # 1 Exhibit A, #
`2 Exhibit B, # 3 Exhibit C, # 4 Text of Proposed Order)(Nolan, Brandy) (Entered:
`07/27/2021)
`69 NOTICE of Attorney Appearance − Pro Hac Vice by David H Ben−Meir on behalf of
`Tefincom S.A.. Filing fee $ 100, receipt number 0540−8516921. (Ben−Meir, David)
`(Entered: 07/30/2021)
`NOTICE of Hearing: Telephone Conference set for 8/3/2021 02:00 PM before
`Magistrate Judge Roy S. Payne. (bga) (Entered: 08/02/2021)
`70 HOTLINE ORDER. Signed by Magistrate Judge Roy S. Payne on 8/3/2021. (nkl, )
`(Entered: 08/04/2021)
`Minute Entry for proceedings held before Magistrate Judge Roy S. Payne: Telephone
`Conference held on 8/3/2021. (bga) (Entered: 08/05/2021)
`71 Sealed Response to 67 Defendant's Motion For Issuance of Letter Request for Derry
`Shribman's Deposition And to Amend the Docket Control Order to Complete The
`Deposition. (Attachments: # 1 Affidavit Wielkopolski, # 2 Exhibit A, # 3 Text of
`Proposed Order)(Wielkopolski, Ronald) (Entered: 08/09/2021)
`72 Joint MOTION (Second) To Amend Docket Control Order by Bright Data Ltd..
`(Attachments: # 1 Text of Proposed Order)(Harkins, Robert) (Entered: 08/09/2021)
`73 REDACTION to 71 Sealed Document, by Bright Data Ltd.. (Attachments: # 1
`Affidavit Wielkopolski, # 2 Exhibit A, # 3 Text of Proposed Order)(Wielkopolski,
`Ronald) (Entered: 08/11/2021)
`74 ***DEFICIENT DOCUMENT***
`SEALED MOTION FOR LEAVE TO FILE SECOND AMENDED INFRINGEMENT
`CONTENTIONS by Bright Data Ltd.. (Attachments: # 1 Affidavit Wielkopolski, # 2
`Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8
`Text of Proposed Order)(Wielkopolski, Ronald) Modified on 8/20/2021 (ch, ).
`(Entered: 08/20/2021)
`NOTICE of Deficiency regarding the 74 submitted NO CERTIFICATE OF
`CONFERENCE. Correction should be made by ONE BUSINESS DAY (ch, )
`(Entered: 08/20/2021)
`75 Opposed SEALED MOTION FOR LEAVE TO FILE SECOND AMENDED
`INFRINGEMENT CONTENTIONS (Corrected) by Bright Data Ltd.. (Attachments: # 1
`Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6
`Exhibit E, # 7 Exhibit F, # 8 Text of Proposed Order)(Wielkopolski, Ronald) (Entered:
`08/20/2021)
`76 REDACTION to 75 Opposed SEALED MOTION FOR LEAVE TO FILE SECOND
`AMENDED INFRINGEMENT CONTENTIONS (Corrected) by Bright Data Ltd..
`(Attachments: # 1 Affidavit Wielkopolski, # 2 Exhibit A−F Remains Under Seal, # 3
`Text of Proposed Order)(Wielkopolski, Ronald) (Entered: 08/23/2021)
`77 SEALED RESPONSE to Motion re 75 Opposed SEALED MOTION FOR LEAVE TO
`FILE SECOND AMENDED INFRINGEMENT CONTENTIONS (Corrected) filed by
`Tefincom S.A.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit
`D, # 5 Text of Proposed Order)(Leventhal, Daniel) (Entered: 09/02/2021)
`78 REDACTION to 77 Sealed Response to Motion, by Tefincom S.A.. (Callahan, Steven)
`(Entered: 09/07/2021)
`79 Joint MOTION to Amend/Correct (Third Joint Motion to Amend Docket Control
`Order) by Tefincom S.A.. (Attachments: # 1 Text of Proposed Order)(Callahan,
`Steven) (Entered: 09/08/2021)
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 9 of 14
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`09/10/2021
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`09/13/2021
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`09/20/2021
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`09/22/2021
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`09/24/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`09/27/2021
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`80 SEALED REPLY to Response to Motion re 75 Opposed SEALED MOTION FOR
`LEAVE TO FILE SECOND AMENDED INFRINGEMENT CONTENTIONS
`(Corrected) filed by Bright Data Ltd.. (Wielkopolski, Ronald) (Entered: 09/10/2021)
`81 REDACTION to 80 Sealed Reply to Response to Motion by Bright Data Ltd..
`(Wielkopolski, Ronald) (Entered: 09/13/2021)
`82 SEALED SUR−REPLY to Reply to Response to Motion re 75 Opposed SEALED
`MOTION FOR LEAVE TO FILE SECOND AMENDED INFRINGEMENT
`CONTENTIONS (Corrected) filed by Tefincom S.A.. (Leventhal, Daniel) (Entered:
`09/20/2021)
`83 REDACTION to 82 Sealed Sur−Reply to Reply to Response to Motion by Tefincom
`S.A.. (Callahan, Steven) (Entered: 09/22/2021)
`84 ORDER denying 24 MOTION to Dismiss Amended Complaint. Signed by District
`Judge Rodney Gilstrap on 9/24/21. (ch, ) (Entered: 09/24/2021)
`85 Opposed SEALED MOTION TO EXCLUDE EXPERT TESTIMONY OF KEITH
`UGONE, PH.D. by Bright Data Ltd.. (Attachments: # 1 Affidavit Wielkopolski, # 2
`Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Text of Proposed Order)(Wielkopolski,
`Ronald) (Entered: 09/27/2021)
`86 Opposed SEALED MOTION TO STRIKE CERTAIN NON−INFRINGEMENT
`OPINIONS OF EXPERT DR. KEVIN ALMEROTH by Bright Data Ltd.. (Attachments:
`# 1 Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D,
`# 6 Exhibit E, # 7 Exhibit F, # 8 Text of Proposed Order)(Wielkopolski, Ronald)
`(Entered: 09/27/2021)
`87 SEALED MOTION Defendant's Motion for Summary Judgment of Invalidity of the
`'319, '510 and '511 Patents by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit
`2, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit
`F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14
`Exhibit L, # 15 Exhibit M, # 16 Exhibit N, # 17 Exhibit O, # 18 Exhibit P, # 19 Text of
`Proposed Order)(Leventhal, Daniel) (Entered: 09/27/2021)
`88 SEALED MOTION to Exclude Opinions and Testimony of Dr. Stephen Becker by
`Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit
`A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10
`Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Text of Proposed
`Order)(Leventhal, Daniel) (Entered: 09/27/2021)
`89 Opposed SEALED MOTION TO STRIKE CERTAIN INVALIDITY OPINIONS OF
`DR. FREEDMAN by Bright Data Ltd.. (Attachments: # 1 Affidavit Wielkopolski, # 2
`Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8
`Text of Proposed Order)(Wielkopolski, Ronald) (Entered: 09/27/2021)
`90 SEALED MOTION to Exclude Opinions and Testimony of Dr. Vernon Thomas Rhyne,
`III by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit A, # 4
`Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, #
`10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Text of Proposed
`Order)(Leventhal, Daniel) (Entered: 09/27/2021)
`91 SEALED MOTION for Partial Summary Judgment of Non−Infringement for the '511
`Patent by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4
`Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, #
`10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15
`Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Text of Proposed Order)(Leventhal,
`Daniel) (Entered: 09/27/2021)
`92 SEALED MOTION FOR PARTIAL SUMMARY JUDGMENT ON CERTAIN
`INVALIDITY GROUNDS by Bright Data Ltd.. (Attachments: # 1 Affidavit
`Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Text of
`Proposed Order)(Wielkopolski, Ronald) (Entered: 09/27/2021)
`93 SEALED MOTION for Summary Judgment of Non−Infringement of the '319, '510 and
`614 Patents by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit
`A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 10 of 14
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`09/29/2021
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`10/01/2021
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`10/01/2021
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`G, # 10 Exhibit H, # 11 Text of Proposed Order)(Leventhal, Daniel) (Entered:
`09/27/2021)
`94 REDACTION to 85 Opposed SEALED MOTION TO EXCLUDE EXPERT
`TESTIMONY OF KEITH UGONE, PH.D. by Bright Data Ltd.. (Attachments: # 1
`Affidavit Wielkopolski, # 2 Exhibit A−C Remains Under Seal, # 3 Text of Proposed
`Order)(Wielkopolski, Ronald) (Entered: 09/29/2021)
`95 REDACTION to 86 Opposed SEALED MOTION TO STRIKE CERTAIN
`NON−INFRINGEMENT OPINIONS OF EXPERT DR. KEVIN ALMEROTH by Bright
`Data Ltd.. (Attachments: # 1 Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4
`Exhibit C, # 5 Exhibit D−F Remains Under Seal, # 6 Text of Proposed
`Order)(Wielkopolski, Ronald) (Entered: 09/29/2021)
`96 REDACTION to 89 Opposed SEALED MOTION TO STRIKE CERTAIN
`INVALIDITY OPINIONS OF DR. FREEDMAN by Bright Data Ltd.. (Attachments: # 1
`Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B Remains Under Seal, # 4 Exhibit
`C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Text of Proposed
`Order)(Wielkopolski, Ronald) (Entered: 09/29/2021)
`97 REDACTION to 92 SEALED MOTION FOR PARTIAL SUMMARY JUDGMENT ON
`CERTAIN INVALIDITY GROUNDS by Bright Data Ltd.. (Attachments: # 1 Affidavit
`Wielkopolski, # 2 Exhibit A Remains Under Seal, # 3 Exhibit B, # 4 Exhibit C, # 5
`Exhibit D, # 6 Text of Proposed Order)(Wielkopolski, Ronald) (Entered: 09/29/2021)
`98 REDACTION to 90 SEALED MOTION to Exclude Opinions and Testimony of Dr.
`Vernon Thomas Rhyne, III by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit
`2, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit
`F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14
`Text of Proposed Order)(Leventhal, Daniel) (Entered: 09/29/2021)
`99 REDACTION to 87 SEALED MOTION Defendant's Motion for Summary Judgment
`of Invalidity of the '319, '510 and '511 Patents by Tefincom S.A.. (Attachments: # 1
`Exhibit 1, # 2 Exhibit 2, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7
`Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J,
`# 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M, # 16 Exhibit N, # 17 Exhibit O, # 18
`Exhibit P, # 19 Text of Proposed Order)(Leventhal, Daniel) (Entered: 09/29/2021)
`100 REDACTION to 88 SEALED MOTION to Exclude Opinions and Testimony of Dr.
`Stephen Becker by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3
`Exhibit 3, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9
`Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Text of
`Proposed Order)(Leventhal, Daniel) (Entered: 09/29/2021)
`101 REDACTION to 91 SEALED MOTION for Partial Summary Judgment of
`Non−Infringement for the '511 Patent by Tefincom S.A.. (Attachments: # 1 Exhibit 1,
`# 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D,
`# 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13
`Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Text of
`Proposed Order)(Leventhal, Daniel) (Entered: 09/29/2021)
`102 ***FILED IN ERROR***
`REDACTION to 93 SEALED MOTION for Summary Judgment of Non−Infringement
`of the '319, '510 and 614 Patents by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2
`Exhibit 2, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8
`Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Text of Proposed Order)(Leventhal,
`Daniel) Modified on 10/1/2021 (ch, ). (Entered: 09/29/2021)
`***FILED IN ERROR. PER ATTORNEY Document # 102, REDACTION.
`PLEASE IGNORE.***
`(ch, ) (Entered: 10/01/2021)
`103 REDACTION to 93 SEALED MOTION for Summary Judgment of Non−Infringement
`of the '319, '510 and 614 Patents by Tefincom S.A.. (Attachments: # 1 Exhibit 1, # 2
`Exhibit 2, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8
`
`

`

`Case: 2:19-cv-414 As of: 11/02/2021 09:28 AM CDT 11 of 14
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`10/08/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/12/2021
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`10/14/2021
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`Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Text of Proposed Order)(Leventhal,
`Daniel) (Entered: 10/01/2021)
`104 Unopposed MOTION for Extension of Time to File Answer re 22 Amended
`Complaint, by Tefincom S.A.. (Attachments: # 1 Text of Proposed Order)(Callahan,
`Steven) (Entered: 10/08/2021)
`105 SEALED RESPONSE to Motion re 88 SEALED MOTION to Exclude Opinions and
`Testimony of Dr. Stephen Becker filed by Bright Data Ltd.. (Attachments: # 1
`Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6
`Exhibit E, # 7 Exhibit F, # 8 Text of Proposed Order)(Wielkopolski, Ronald) (Entered:
`10/12/2021)
`106 SEALED RESPONSE to Motion re 91 SEALED MOTION for Partial Summary
`Judgment of Non−Infringement for the '511 Patent filed by Bright Data Ltd..
`(Attachments: # 1 Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C,
`# 5 Exhibit D, # 6 Exhibit E, # 7 Text of Proposed Order)(Wielkopolski, Ronald)
`(Entered: 10/12/2021)
`107 SEALED RESPONSE to Motion re 90 SEALED MOTION to Exclude Opinions and
`Testimony of Dr. Vernon Thomas Rhyne, III filed by Bright Data Ltd.. (Attachments: #
`1 Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, #
`6 Exhibit E, # 7 Exhibit F, # 8 Text of Proposed Order)(Wielkopolski, Ronald)
`(Entered: 10/12/2021)
`108 SEALED RESPONSE to Motion re 92 SEALED MOTION FOR PARTIAL
`SUMMARY JUDGMENT ON CERTAIN INVALIDITY GROUNDS filed by Tefincom
`S.A.. (Attachments: # 1 Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5
`Exhibit D, # 6 Exhibit E, # 7 Text of Proposed Order)(Leventhal, Daniel) (Additional
`attachment(s) added on 10/13/2021: # 8 Revised Proposed Order) (nkl, ). (Entered:
`10/12/2021)
`109 SEALED RESPONSE to Motion re 85 Opposed SEALED MOTION TO EXCLUDE
`EXPERT TESTIMONY OF KEITH UGONE, PH.D. filed by Tefincom S.A..
`(Attachments: # 1 Affidavit Declaration, # 2 Exhibit Ex. A, # 3 Exhibit Ex.
`B)(Licygiewicz, Arthur) (Additional attachment(s) added on 10/13/2021: # 4 Text of
`Proposed Order) (nkl, ). (Entered: 10/12/2021)
`110 SEALED RESPONSE to Motion re 86 Opposed SEALED MOTION TO STRIKE
`CERTAIN NON−INFRINGEMENT OPINIONS OF EXPERT DR. KEVIN
`ALMEROTH filed by Tefincom S.A.. (Attachments: # 1 Affidavit, # 2 Exhibit A, # 3
`Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9
`Text of Proposed Order)(Leventhal, Daniel) (Entered: 10/12/2021)
`111 SEALED RESPONSE to Motion re 89 Opposed SEALED MOTION TO STRIKE
`CERTAIN INVALIDITY OPINIONS OF DR. FREEDMAN filed by Tefincom S.A..
`(Attachments: # 1 Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D,
`# 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Text of Proposed
`Order)(Leventhal, Daniel) (Entered: 10/12/2021)
`112 SEALED RESPONSE to Motion re 87 SEALED MOTION Defendant's Motion for
`Summary Judgment of Invalidity of the '319, '510 and '511 Patents filed by Bright
`Data Ltd.. (Attachments: # 1 Affidavit Wielkopolski, # 2 Exhibit A, # 3 Exhibit B, # 4
`Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, #
`10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Text of Proposed
`Order)(Wielkopolski, Ronald) (Entered: 10/12/2021)
`113 SEALED RESPONSE to Motion re 93 SEALED MOTION for Summary Judgment of
`Non−Infringement of the '319, '510 and 6