Case 4:21-cv-03220-HSG Document 30 Filed 08/03/21 Page 1 of 12
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`[All Counsel in signature block below]
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
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`GOOGLE LLC,
`Plaintiff/Counterclaim Defendant,
`v.
`ECOFACTOR, INC.,
`Defendant/Counterclaim Plaintiff.
`
`Case No. 4:21-cv-3220-HSG
`JOINT CASE MANAGEMENT
`STATEMENT
`Date: August 10, 2021
`Time: 2:00 P.M.
`Courtroom: 2
`Judge: Haywood S. Gilliam, Jr.
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`AMERICAS 108361430
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`JOINT CASE MANAGEMENT STATEMENT
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`ATTORNEYS AT LAW
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`GOOGLE V. ECOFACTOR
`IPR2022-00538
`Exhibit 2002
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`Case 4:21-cv-03220-HSG Document 30 Filed 08/03/21 Page 2 of 12
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`INTRODUCTION
`Pursuant to this Court’s May 11, 2021 Notice (ECF No. 15), the Standing Order for All
`Judges of the Northern District of California, and Civil Local Rule 16-9, Plaintiff/Counterclaim
`Defendant Google LLC (“Google”) and Defendant/Counterclaim Plaintiff EcoFactor, Inc.
`(“EcoFactor”) submit this Joint Case Management Statement.
`1.
`JURISDICTION & SERVICE
`Google filed this action on April 30, 2021. ECF No. 1. This is a declaratory judgment
`action for non-infringement under the Declaratory Judgment Act, 28 U.S.C. § 2201, and under
`the patent laws of the United States, 35 U.S.C. §§ 1-390. The Court has subject matter jurisdiction
`over this action pursuant to 28 U.S.C. §§ 1331, 1338(a) and 2201(a). Venue is proper in this
`judicial district pursuant 28 U.S.C § 1400(b). EcoFactor has been served. Neither jurisdiction
`nor venue has been disputed.
`2.
`FACTS
`Google seeks a finding that its smart thermostat systems, including the Nest Thermostat
`and the Nest Third Generation Learning Thermostat (collectively, “Google Accused Products”)
`do not infringe United States Patent Nos. 8,740,100 (“the ’100 patent”); 8,751,186 (“the ’186
`patent”); 9,194,597 (“the ’597 Patent”); and 10,584,890 (“the ’890 Patent”) (collectively, the
`“Asserted Patents”). EcoFactor has asserted both defenses and counterclaims, and EcoFactor’s
`counterclaims seek a finding that the Google Accused Products infringe the Asserted Patents, and
`remedies for Google’s infringement, including injunctive relief, damages, a finding that this is an
`exceptional case under 35 U.S.C. § 285, and other relief the Court may deem proper under the
`circumstances.
`3.
`DISPUTED LEGAL ISSUES
`THE PARTIES HAVE IDENTIFIED THE FOLLOWING PRINCIPAL ISSUES
`CURRENTLY IN DISPUTE:
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`4.
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`1. Whether the Google Accused Products directly infringe one or more claims of
`each Asserted Patent under 35 U.S.C. § 271(a), and/or indirectly infringe one or
`more claims of each Asserted Patent under 35 U.S.C. §§271(b) or (c);
`2. Whether this case is exceptional under 35 U.S.C. § 285, entitling the prevailing
`party to attorneys’ fees.
`MOTIONS
`1. Anticipated Motions: Google and EcoFactor anticipate moving for summary
`judgment and may file other dispositive and non-dispositive motions as the case progresses. The
`parties anticipate filing a joint motion for a protective order governing the confidentiality of
`information and the review of source code in this matter, as well as a joint motion for an order
`governing the treatment of electronically stored information (ESI) in discovery.
`5.
`AMENDMENT OF PLEADINGS
`The parties agree that they may amend their pleadings, including the parties, claims, or
`defenses, consistent with the Federal Rules of Civil Procedure or with leave of the Court upon a
`showing of good cause.
`The parties do not currently intend to amend the operative pleadings but reserve the right to
`request leave of the Court to do so should the Court determine that either party needs to provide
`additional information.
`6.
`EVIDENCE PRESERVATION
`Each party has reviewed the ESI Guidelines and each party believes that it has taken
`appropriate and reasonable measures to preserve evidence relevant to each party’s claims and
`defenses in this matter.
`7.
`DISCLOSURES
`The Parties served initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1)(A) on August 3,
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`2021.
`8.
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`DISCOVERY
`The parties have not served any discovery yet.
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`A. Changes to the timing, form, or requirement for disclosure (Fed. R. Civ. P.
`26(f)(3)(A))
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`The parties served initial disclosures on August 3, 2021 and do not propose any change to
`the form or requirement for such disclosures.
`B. The subjects on which discovery may be needed (Fed. R. Civ. 26(f)(3)(B))
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`The parties anticipate that the scope of discovery will encompass the factual and legal
`issues identified in Sections 2 and 3 above, and the requested relief discussed in Section 9 below,
`including related and subsidiary factual and legal issues and matters. The parties reserve the right
`to amend subjects for discovery that may be sought pending further discovery.
`C. Any issues about disclosure, discovery, or preservation of electronically stored
`information, including the form or form in which it should be produced (Fed.
`R. Civ. P. 26(f)(3)(C)
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`The Parties anticipate presenting an ESI order to Court to govern the discovery of
`electronically stored information. The parties will exchange draft proposed ESI orders and will
`present agreed-on terms to the Court, along with any points of disagreement requiring the Court’s
`guidance.
`D. Any issues about claims of privilege or of protection as trial-preparation
`materials (Fed. R. Civ. P. 26(f)(3)(D))
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`The parties agree that absent a specific showing of need, documents created on or after
`April 30, 2021 that are subject to a claim of attorney-client privilege, work product immunity, or
`any other privilege or immunity do not need to be included in the parties’ privilege logs. Subject
`to the foregoing, the parties agree that issues of privilege or work product shall be addressed as
`provided in the Federal Rules of Civil Procedure, Federal Rule of Evidence 502, and the
`Protective Order and/or ESI Order to be entered in this action.
`E. Changes that should be made to the limitations on discovery (Fed. R. Civ. P.
`26(f)(3)(E))
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`To the extent not limited below, and unless otherwise agreed to by the parties, the parties
`agree that discovery is subject to the limitation set forth in the Federal Rules of Civil Procedure,
`Local Rules of the Court, and the ESI Order and Protective Order to be entered in this action. If
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`a party requests discovery that exceeds any of the limitation set forth below, the parties agree to
`meet and confer in good faith to attempt to resolve the issue without intervention of the Court. If
`the parties are unable to reach agreement, a party may seek leave from the Court for the additional
`discovery.
`The Parties agree to serve interrogatories, document requests, deposition notices, requests
`for admission, and responses thereto, on each other via email. The parties further agree that the
`service of a complete copy of these documents via email on or before midnight Pacific time shall
`count as same-day service.
` Interrogatories to Parties
`The parties agree that the limitations of Federal Rule of Civil Procedure 33 apply.
` Requests for Admission
`The parties agree that each side may serve up to 30 Requests for Admission. Requests for
`Admission related to the authentication of documents and public availability of prior art are
`exempt from this limitation.
` Depositions
`The parties agree that each party is limited to 70 hours in its deposition of fact witnesses
`in this litigation, including individual and 30(b)(6) witnesses, and excluding expert depositions,
`Furthermore, either party may request additional hours for good cause. All other requirements of
`Federal Rule of Civil Procedure 30 apply.
`F. Any other orders that the court should issue under Rule 26(c) or under Rule
`16(b) and (c)
`
`The parties anticipate presenting a stipulated protective order governing the discovery of
`confidential information, including source code, to the Court.
`G. Production of ESI
`
`The parties anticipate presenting a stipulated protocol for ESI production to the Court.
`CLASS ACTIONS
`This matter is not a class action matter.
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`9.
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`10.
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`RELATED CASES
`The Asserted Patents are also at issue in EcoFactor, Inc. v. ecobee, Inc., No. 6:21-00428
`(W.D. Tex. Apr. 28, 2021).
`11.
`RELIEF
`Google’s Position: Google requests that the Court grant:
` Judgment in Google’s favor against EcoFactor on all causes of action alleged in
`Google’s Complaint (ECF No. 1);
` Judgment that this is an exceptional case under 35 U.S.C. § 285;
` Judgment that EcoFactor take nothing from its Counterclaims, including no
`injunctive relief;
` Attorneys’ fees and costs; and
` Such other and further relief as the Court may deem to be just and proper.
`EcoFactor’s Position:
` Judgment in favor of EcoFactor on all causes of action alleged in EcoFactor’s
`counterclaims in EcoFactor’s Answer (ECF No. 17), including judgment that Google
`has infringed, either literally and/or under the doctrine of equivalents, the ’100
`Patent, the ’186 Patent, the ’597 Patent, and the ’890 Patent;
` Permanent injunction prohibiting Google from further acts of infringement of the
`’100 Patent, the ’186 Patent, the ’597 Patent, and the ’890 Patent;
` Attorneys’ fees and costs;
` Judgment and order requiring Google to provide accountings and to pay
`supplemental damages to Plaintiff, including without limitation, pre-judgment and
`post-judgment interest;
` Judgment that this is an exceptional case within the meaning of 35 U.S.C. § 285; and
` Any and all other relief as the Court may deem appropriate and just under the
`circumstances.
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`12.
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`SETTLEMENT AND ADR
`The parties conferred regarding Alternative Dispute Resolution options under ADR Local
`Rule 3-5 and agreed to mediation with a court-appointed mediator at an appropriate time. The
`parties are separately submitting their ADR Certification by Parties and Counsel.
`13.
`CONSENT TO MAGISTRATE JUDGE FOR ALL PURPOSES
`The parties do not consent to disposition of this case by a Magistrate Judge.
`14. OTHER REFERENCES
`The parties do not believe that this case is suitable for reference to binding arbitration, a
`special master, or the Judicial Panel on Multidistrict Litigation.
`15.
`NARROWING OF ISSUES
`The parties will continue to meet and confer on ways to potentially narrow the number of
`issues in dispute.
`16.
`EXPEDITED TRIAL PROCEDURE
`This matter is not the type of case that can be handled under the Expedited Trial Procedure
`of General Order No. 64 Attachment A.
`17.
`SCHEDULING
`The Parties agree on the application of the Patent Local Rules (“PLR”) at this time as
`well as their proposed case schedules.
`
`
`Event
`Deadline for Parties to exchange Rule 26
`initial disclosures
`Pat. L.R. 3-1 & 3-2. Disclosure of
`Asserted Claims and Infringement
`Contentions and Accompanying
`Document Production by EcoFactor
`Pat. L.R. 3-3 & 3-4. Invalidity
`Contentions and Accompanying
`Document Production by Google
`Pat. L.R. 4-1. Exchange of Proposed
`Terms for Claim Construction
`Pat. L.R. 4-2. Exchange of Preliminary
`Constructions and Extrinsic Evidence
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`Agreed Proposed Deadlines
`August 3, 2021
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`August 24, 2021
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`October 8, 2021
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`October 22, 2021
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`November 12, 2021
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`Pat. L.R. 3-8. Damages Contentions by
`EcoFactor.
`Pat. L.R. 4-3. Joint Claim Construction
`and Pre-Hearing Statement.
`Pat. L.R. 4-4. Completion of Claim
`Construction Discovery
`Pat. L.R. 3-9. Responsive Damage
`Contentions by Google
`Pat. L.R. 4-5(a). Opening Claim
`Construction Brief by EcoFactor
`Pat. L.R 4.5(b). Responsive Claim
`Construction Brief by Google
`Pat. L.R. 4.5(c). Reply Claim
`Construction Brief by EcoFactor
`Technology Tutorial
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`November 29, 2021
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`December 7, 2021
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`January 6, 2022
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`December 29, 2021
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`January 21, 2022
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`February 4, 2022
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`February 11, 2022
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`Subject to the convenience of the
`Court’s calendar
`Subject to the convenience of the
`Court’s calendar
`14 days after the Court’s claim
`construction ruling
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`Pat. L.R. 4-6. Claim Construction Hearing
`(Markman)
`Parties to submit proposes schedule for
`fact discovery deadline, expert discovery,
`dispositive and Daubert motions, pretrial,
`and trial.
`The parties agree that it is not necessary to enter a schedule beyond the dates above at
`this early stage of the case. The parties instead request an opportunity to submit an agreed-on
`schedule, or competing scheduling proposals if an agreement cannot be reached, for the Court
`to consider within 14 days of the Court’s claim construction ruling.
`Notwithstanding that request, to the extent the Court intends to enter additional
`deadlines now, the parties submit the proposal below:
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`Event
`Proposed Date for Designation of Experts
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`Close of fact discovery
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`Deadline to file discovery motions relating
`to fact discovery
`Opening expert reports
`Rebuttal expert reports
`Close of expert discovery
`Opening summary judgment/ Daubert
`Briefs
`Responsive summary judgment/ Daubert
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`Agreed Proposed Deadlines
`Estimated 90 days after the Court’s claim
`construction ruling
`Estimated 150 days after the Court’s claim
`construction ruling
`7 days after the close of fact discovery
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`21 days after the close of fact discovery
`42 days after the opening expert reports
`28 days after the rebuttal expert reports
`28 days after close of expert discovery
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`14 days after Opening summary judgment/
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`JOINT CASE MANAGEMENT STATEMENT
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`Briefs
`Reply summary judgment/ Daubert Briefs
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`Hearing on summary judgment/ Daubert
`Briefs
`Pretrial Conference
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`Trial
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`Daubert Briefs
`7 days after Answering summary judgment/
`Daubert Briefs
`Subject to the convenience of the Court’s
`calendar
`Subject to the convenience of the Court’s
`calendar
`Subject to the convenience of the Court’s
`calendar
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`18.
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`TRIAL
`Both parties have requested trial by jury. The parties’ best estimate of the length of trial
`is approximately 5 Court days for this trial, assuming each trial day starts at 7:30 a.m. and ends
`at 1:00 p.m. as noted in the Court’s Guidelines for Trial and Final Pretrial Conference in Civil
`Jury Cases Before the Honorable Haywood Gilliam Jr.
`19.
`DISCLOSURE OF NON-PARTY INTERESTED ENTITIES OR PERSONS
`Each party has filed the Certification of Interested Entities or Persons required by Civil
`Local Rule 3-15.
`On April 30, 2021, Google filed its Certificate of Interested Parties and Entities pursuant
`to Civil Local Rule 3-15. ECF No. 3. Google stated, pursuant to Civil L.R. 3-15, that Google
`LLC, XXVI Holdings Inc. (holding company of Google LLC), and Alphabet Inc. (holding
`company of XXVI Holdings Inc.) either (i) have a financial interest in the subject matter in
`controversy or in a party to the proceeding, or (ii) have a non-financial interest in that subject
`matter or in a party that could be substantially affected by the outcome of this proceeding.
`On July 13, 2021, EcoFactor filed its Corporate Disclosure Statement. ECF No. 18.
`PROFESSIONAL CONDUCT
`All attorneys of record for the Parties have reviewed the Guidelines for Professional
`Conduct for the Northern District of California.
`21. OTHER ISSUES
`The Parties do not believe that any other issues are appropriate for inclusion in this Joint
`Management Statement.
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`20.
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`22.
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`ADDITIONAL INFORMATION PURSUANT TO PATENT LOCAL RULE 2-1(B)
`
`A. Local Rules
`The parties’ proposed schedule is set forth in Section 17 above.
`B. Scope and Timing of Any Claim Construction Discovery
`The parties’ proposed schedule set forth in Section 17, above, includes a proposed
`deadline for claim construction discovery.
`C. Format of the Claim Construction Hearing
`The Parties propose that the Claim Construction Hearing consist of a three-hour
`presentation, with 90 minutes allotted to Google and 90 minutes allotted to EcoFactor.
`D. How the Parties Intend to Educate the Court on the Technology at Issue.
`The Parties propose educating the Court on the technology at issue through a tutorial
`immediately preceding the Claim Construction Hearing. Google proposes that the Court allow
`Google to make a presentation no longer than 45 minutes, followed by a presentation by
`EcoFactor no longer than 45 minutes.
`
`Dated: August 3, 2021
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`Respectfully submitted,
`
`WHITE & CASE LLP
`
`By: /s/ Bijal V. Vakil ____________________
`
`Bijal V. Vakil
`
`Bijal V. Vakil (CA State Bar No. 192878)
`bvakil@whitecase.com
`Shamita D. Etienne-Cummings
`(CA State Bar No. 202090)
`setienne@whitecase.com
`Henry Y. Huang (CA State Bar No. 252832)
`henry.huang@whitecase.com
`WHITE & CASE LLP
`3000 El Camino Real
`Two Palo Alto Square, Suite 900
`Palo Alto, CA 94306-2109
`Telephone: 650.213.0300
`Facsimile: 650.213.8158
`
`Attorneys for Plaintiff and Counterclaim
`Defendant GOOGLE LLC
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`Dated: August 3, 2021
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`/s/ Reza Mirzaie
`Counsel for Defendant
`
`Marc A. Fenster, CA SBN 181067
`mfenster@raklaw.com
`Reza Mirzaie, CA SBN 246953
`rmirzaie@raklaw.com
`James N. Pickens, CA SBN 307474
`jpickens@raklaw.com
`Minna Y. Chan, CA SBN 305941
`mchan@raklaw.com
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Tele: 310/826-7474
`Fax: 310/826-6991
`
`Attorneys for Defendant/Counterclaim Plaintiff
`ECOFACTOR, INC.
`
`
`
`
`AMERICAS 108361430
`
`- 10 -
`
`
`
`
`JOINT CASE MANAGEMENT STATEMENT
`CASE NO: 4:21-cv-3220-HSG
`
`WHITE & CASE LLP
`
`ATTORNEYS AT LAW
`
`SILICON VALLEY
`
`
`
`GOOGLE V. ECOFACTOR
`IPR2022-00538
`Exhibit 2002
`Page 11
`
`

`

`Case 4:21-cv-03220-HSG Document 30 Filed 08/03/21 Page 12 of 12
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`CASE MANAGEMENT ORDER
`The above JOINT CASE MANAGEMENT STATEMENT & PROPOSED ORDER is
`approved as the Case Management Order for this case and all parties shall comply with its
`provisions.
`
`IT IS SO ORDERED.
`
`
`Dated:
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`
`
`
`
`Judge Haywood S Gilliam, Jr.
`UNITED STATES DISTRICT COURT JUDGE
`
`AMERICAS 108361430
`
`- 11 -
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`
`
`
`JOINT CASE MANAGEMENT STATEMENT
`CASE NO: 4:21-cv-3220-HSG
`
`
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`WHITE & CASE LLP
`
`ATTORNEYS AT LAW
`
`SILICON VALLEY
`
`
`
`GOOGLE V. ECOFACTOR
`IPR2022-00538
`Exhibit 2002
`Page 12
`
`