Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 1 of 13 PageID #: 2338
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`TQDELTA, LLC,
`
`Plaintiff,
`
`v.
`
`2WIRE, INC.,
`
`Defendant.
`TQ DEL TA, LLC,
`
`Plaintiff,
`
`v.
`
`ZHONE TECHNOLOGIES, INC.,
`
`Defendant.
`TQ DEL TA, LLC,
`
`Plaintiff,
`
`v.
`
`ZYXEL COMMUNICATIONS, INC.
`and
`ZYXEL COMMUNICATIONS
`CORPORATION,
`
`Defendants.
`TQ DEL TA, LLC,
`
`Plaintiff,
`
`v.
`
`ADTRAN, INC.,
`
`Defendant.
`
`ADTRAN, INC.,
`
`Plaintiff,
`
`v.
`
`TQ DELTA, LLC,
`
`Defendant.
`
`C.A. No. l 3-cv-1835-RGA
`
`C.A. No. l 3-cv-1836-RGA
`
`C.A. No. 13-cv-2013-RGA
`
`C.A. No. 14-cv-954-RGA
`
`C.A. No. 15-cv-121-RGA
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 1 of 13
`
`

`

`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 2 of 13 PageID #: 2339
`
`THIRD AND FINAL SCHEDULING ORDER
`
`....
`This JQ_ day of April, 2017, the Court having conducted an initial Rule l 6(b)
`
`scheduling conference pursuant to Local Rule 16.1 (b ), and the parties having determined after
`
`discussion that the matter cannot be resolved at this juncture by settlement, voluntary mediation,
`
`or binding arbitration;
`
`IT IS ORDERED that:
`
`1.
`
`Rule 26(a)( 1) Initial Disclosures. The parties have produced their initial
`
`disclosures pursuant to Federal Rule of Civil Procedure 26(a)(l).
`
`2.
`
`Discovery Coordination.
`
`a.
`
`The parties propose to coordinate discovery in the above-captioned cases
`
`where practicable. Although proposing to coordinate discovery in these four cases where
`
`practicable, the defendants expressly reserve, and do not waive, the right to separate trials on any
`
`and all issues to be resolved at trial.
`
`b.
`
`Any submissions to the Court shall be filed in the specific case(s) to which
`
`they are believed in good faith to pertain.
`
`c.
`
`For purposes of counting discovery requests and deposition hours, the
`
`related defendants named in each case count as a single defendant.
`
`d.
`
`Except as modified herein, or by subsequent Court order, the Default
`
`Standard shall apply to each of the above-captioned cases.
`
`3.
`
`Joinder of Other Parties and Amendment of Pleadings. All motions to join other
`
`parties, and to amend or supplement the pleadings, shall be filed on or before August 31, 2017.
`
`2
`
`I f
`l I
`I
`I
`' i
`I t
`r • I
`I
`
`f
`t
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`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 2 of 13
`
`

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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 3 of 13 PageID #: 2340
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`4.
`
`Initial Discovery. 1
`
`The parties have served their Default Standard Paragraph 4.a., b., c., and d.
`
`disclosures.
`
`5. Discovery.
`
`a.
`
`Discovery Cut Off. All discovery in this case shall be initiated so that it
`
`will be completed on or before the following dates, which apply to both TQ Delta and the
`
`identified defendant:
`
`Defendant
`2Wire
`Zhone
`ZvXEL
`ADTRAN
`
`Discovery Cutoff
`Dec. 5, 2017
`Feb. 16,2018
`April 4, 2018
`May 11, 2018
`
`b.
`
`Document Production. Document production shall be substantially
`
`completed 60 days prior to the discovery cutoff above.
`
`c.
`
`Requests for Admission. A maximum of 40 requests for admission are
`
`permitted for plaintiff as to each defendant. The defendants may collectively serve 30 joint
`
`requests for admission on plaintiff and each defendant may individually serve 20 requests for
`
`admission on plaintiff. Notwithstanding the foregoing, there is no limitation on the number of
`
`requests for admission that a document is authentic and/or a business record.
`
`d.
`
`Interrogatories. A maximum of 25 interrogatories, including contention
`
`interrogatories, are permitted for plaintiff as to each defendant. The defendants may collectively
`
`serve 15 joint interrogatories on plaintiff. Each defendant may individually serve 20 additional
`
`defendant-specific interrogatories on plaintiff.
`
`e.
`
`Depositions.
`
`1 As these disclosures are "initial," each party shall be permitted to timely supplement.
`
`3
`
`f I l
`J I I I
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 3 of 13
`
`

`

`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 4 of 13 PageID #: 2341
`
`i.
`
`Limitation on Hours for Deposition Discovery. Plaintiff may take
`
`up to {Plaintiff's PPop6sak 75; Ddencta11ts' .Proposal-:- 4~ hours of fact deposition of each
`
`defendant (i.e., no more than.fPlaitttiff's Vrup988': 75; Defendants' P1sp9sale-49~ hours of
`
`deposition time collectively for the defendant in each case and its past or current officers,
`
`employees, and agents) and up to 100 hours of third party depositions. Defendants may
`
`collectively take up to 100 hours of fact deposition of plaintiff and up to 100 hours of third party
`
`depositions fDefemlanis' Prsps:mk excluding named inventors on each asserted patent each
`
`of whom may be deposed without regard for the party and third party time limits.]
`~· l'ropMW.: Defendants may collectively depose an inventor for up to Y\ hours
`10
`
`per patent family for which the witness is a named inventor, but no single defendant shall
`
`be permitted more than 7 hours of deposition time per inventor for each patent family.]
`
`Plaintiff may take a second deposition of an individual witness where the first deposition took
`
`place prior to the opening of general discovery; however, the total deposition time for the two
`
`depositions shall be limited to no more than 8 hours, subject to extension for good cause. For
`
`any depositions taken in a language other than English, each deposition hour will be counted as
`
`only one-half hour for purposes of any deposition hour limit. The foregoing limitations do not
`
`apply to the deposition of experts pursuant to Fed. R. Civ. P. 26(b)(4)(A). These time limitations
`
`may be amended by agreement of the parties or further order of the Court.
`
`ii.
`
`Location of Depositions. Any party or representative (officer,
`
`director, or managing agent) of a party filing a civil action in this district court must ordinarily be
`
`required, upon request, to submit to a deposition at a place designated within this district.
`
`Exceptions to this general rule may be made by order of the Court or by agreement of the parties.
`
`A defendant who becomes a counterclaimant, cross-claimant, or third-party plaintiff shall be
`
`4
`
`I
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 4 of 13
`
`

`

`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 5 of 13 PageID #: 2342
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`considered as having filed an action in this Court for the purpose of this provision. The parties
`
`agree that in these cases the depositions of party witnesses shall occur in the situs where the
`
`witness' business office is located2 or at a mutually agreeable location.
`
`iii.
`
`Expert Depositions. The parties agree to meet and confer with
`
`regard to time limitations for expert depositions by no later than 14 days after the conclusion of
`
`fact discovery.
`
`f.
`
`The parties are not required to prepare privilege logs or otherwise identify
`
`documents withheld from production to the extent that they: (i) relate to activities undertaken in
`
`compliance with the duty to preserve information under Fed. R. Civ. P. 26(b)(3)(A) and (B) or
`
`similar requirements; or (ii) are withheld from production on the basis of privilege, work
`
`product, and/or any other exemption or immunity from production and are generated after the
`
`filing of the initial complaint in the lawsuit. All other withheld documents must be logged in
`
`compliance with Fed. R. Civ. P. 26(b)(5)(A), absent agreement of the parties or further order of
`
`the Court.
`
`g.
`
`Discovery Matters and Disputes Relating to Protective Orders. The Court
`
`has assigned the parties to a Special Master for purposes of resolving discovery matters. D.I.
`
`273. The parties will follow the procedures set out in this Court's orders with respect to the
`
`Special Master. See D.I. 275.
`
`If a discovery-related motion is filed without leave of the Court, it will be denied
`
`without prejudice to the moving party's right to bring the dispute to the Court through the
`
`discovery matters procedures set forth in this Order.
`
`2 If in the United States.
`
`5
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 5 of 13
`
`

`

`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 6 of 13 PageID #: 2343
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`6.
`
`Application to Court for Protective Order. A protective order has been entered in
`
`these actions.
`
`7.
`
`Papers Filed Under Seal. When filing papers under seal, counsel shall deliver to
`
`the Clerk an original and one copy of the papers. A redacted version of any sealed document
`
`shall be filed electronically within seven days of the filing of the sealed document.
`
`8.
`
`Courtesy Copies. The parties shall provide to the Court two courtesy copies of all
`
`briefs and one courtesy copy of any other document filed in support of any briefs (i.e.,
`
`appendices, exhibits, declarations, affidavits etc.). This provision also applies to papers filed
`
`under seal.
`
`9.
`
`Claim Construction Issue Identification. On or before (see chart below section
`
`11), the parties shall exchange a list of those claim term(s)/phrase(s) that they believe need
`
`construction and their proposed claim construction of those term(s)/phrase(s). This document
`
`will not be filed with the Court. Subsequent to exchanging that list, each party shall have the
`
`right to propose a construction for a term proposed by the other party, and the parties will meet
`
`and confer to prepare a Joint Claim Construction Chart to be filed no later than (see chart below
`
`section 11). The Joint Claim Construction Chart, in Word or WordPerfect format, shall bee-
`
`mailed simultaneously with filing to rga_civil@ded.uscourts.gov. The parties' Joint Claim
`
`Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s) in issue,
`
`and should include each party's proposed construction of the disputed claim language with
`
`citation(s) only to the intrinsic evidence in support of their respective proposed constructions. A
`
`copy of the patent(s) in issue as well as those portions of the intrinsic record relied upon shall be
`
`submitted with this Joint Claim Construction Chart. In this joint submission, the parties shall not
`
`provide argument.
`
`6
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`I i I f
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`r
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`I
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`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 6 of 13
`
`

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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 7 of 13 PageID #: 2344
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`10.
`
`Claim Construction Briefing. The Plaintiff shall serve, but not file, its opening
`
`brief, on (see chart below section 11). The defendants shall serve, but not file, a joint answering
`
`brief on (see chart below section 11 ). The plaintiff shall serve, but not file, its reply brief on
`
`(see chart below section 11). The defendant shall serve, but not file, a joint sur-reply brief on
`
`(see chart below section 11). No later than (see chart below section 11), the parties shall file a
`
`Joint Claim Construction Brief. The parties shall copy and paste their untiled briefs into one
`
`brief, with their positions on each claim term in sequential order, in substantially the form below.
`
`JOINT CLAIM CONSTRUCTION BRIEF
`
`I.
`
`II.
`
`Agreed-upon Constructions
`
`Disputed Constructions
`
`A.
`
`[TERM I]
`
`1.
`2.
`3.
`4.
`
`Plaintiffs Opening Position
`Defendant's Answering Position
`Plaintiffs Reply Position
`Defendants' Sur-Reply Position
`
`B.
`
`[TERM2]
`
`1.
`2.
`3.
`4.
`
`Plaintiffs Opening Position
`Defendants' Answering Position
`Plaintiffs Reply Position
`Defendants' Sur-Reply Position
`
`Etc. The parties need not include any general summaries of the law relating to claim
`
`construction. If there are any materials that would be submitted in an appendix, the parties shall
`
`submit them in a Joint Appendix.
`
`11.
`
`Hearing on Claim Construction. Beginning at (see chart below), the Court will
`
`hear argument on claim construction. Absent prior approval of the Court (which, if it is sought,
`
`must be done so by joint letter submission no later than the date on which sur-reply construction
`
`7
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 7 of 13
`
`

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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 8 of 13 PageID #: 2345
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`briefs are due), the parties shall not present testimony at the argument, and the argument shall not
`
`exceed a total of three hours.
`
`Family
`
`IA&
`lB
`
`Terms
`Joint
`cc
`and
`Construct Chart
`ions
`4/18/17
`
`519117
`
`Opening Responsiv
`Brief
`e Brief
`
`Reply
`Brief
`
`Sur-
`Reply
`Brief
`
`Joint CC Hearing
`Brief
`
`616117
`
`7/10/17
`
`7/31/17
`
`8/14/17
`
`8/22/17
`
`9/5/17 at
`t):oo l\M
`
`9/13/17
`at
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`3
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`5
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`6
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`7
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`8
`
`4/26/17
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`5/17/17
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`6/14/17
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`7/12/17
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`8/2/17
`
`8/16/17
`
`8/30/17
`
`5/3/17
`
`5/24/17
`
`6121117
`
`7/19/17
`
`8/9/17
`
`8/23117
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`9/6/17
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`5111117
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`6/1/17
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`6/29/17
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`7/27/17
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`8/17/17
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`8/31/17
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`9/14/17
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`5/18/17
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`6/8/17
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`7/6/17
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`8/3/17
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`8/24/17
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`9/7/17
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`9/21117
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`8/2/17
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`8/23/17
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`9/20/17
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`10/18/17
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`1118/17
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`11/22/17
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`12/6/17
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`8/23/17
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`9/13/17
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`10/11117
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`1118/17
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`11129/17
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`12/13/17
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`12/27/17
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`9/1/17
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`9/22/17
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`10/20/17
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`11117/17
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`12/8/17
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`12/22/17
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`1/5/18
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`9A&
`9B
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`9/6/17
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`9/27/17
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`10/25/17
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`11122/17
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`12/13/17
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`12/27117
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`1110/18
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`10
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`9/14/17
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`10/6/17
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`11/3/17
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`12/1/17
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`12/22/17
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`1/9/18
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`1/18/18
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`12.
`
`Disclosure of Expert Testimony.
`
`a.
`
`Expert Reports. For the party who has the initial burden of proof on the
`
`subject matter, the initial Federal Rule 26(a)(2) disclosure of expert testimony is due on or before
`
`(see chart below). The supplemental disclosure to contradict or rebut evidence on the same
`
`matter identified by another party is due on or before (see chart below). Reply expert reports
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`8
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`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 8 of 13
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`

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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 9 of 13 PageID #: 2346
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`from the party with the initial burden of proof are due on or before (see chart below). No other
`
`expert reports will be permitted without either the consent of all parties or leave of the Court.
`
`Along with the submissions of the expert reports, the parties shall advise of the dates and times
`
`of their experts' availability for deposition. Depositions of experts shall be completed on or
`
`before (see chart below).
`
`Family
`
`IA & IB
`
`Opening Expert
`Reports
`(as to the parties
`designated for trial
`only)
`Dec. 7,2017
`
`Rebuttal Expert
`Reports
`(as to the parties
`designated for
`trial only)
`Jan. 4, 2018
`
`Reply Expert
`Reports
`(as to the parties
`designated for trial
`only)
`Jan.25,2018
`
`Completion of Expert
`Depositions
`(as to the parties
`designated for trial
`only)
`Feb. 15,2018
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`Dec.22,2017
`
`Jan. 19, 2018
`
`Feb. 9,2018
`
`Mar. 2, 2018
`
`Jan. 12, 2018
`
`Feb.9,2018
`
`Mar. 2, 2018
`
`Mar. 23, 2018
`
`Mar. 2, 2018
`
`Mar. 30, 2018
`
`Apr. 20, 2018
`
`May 11, 2018
`
`Mar. 30, 2018
`
`Apr. 27, 2018
`
`May 18, 2018
`
`June 8, 2018
`
`Apr. 20, 2018
`
`May18,2018
`
`June 8, 2018
`
`June 29, 2018
`
`May.4,2018
`
`June 1, 2018
`
`June 22, 2018
`
`July 13, 2018
`
`June 1,2018
`
`June 29, 2018
`
`July 20, 2018
`
`Aug. 10, 2018
`
`9A&9B
`
`June 15, 2018
`
`July 13, 2018
`
`Aug. 3, 2018
`
`Aug. 24, 2018
`
`10
`
`July 13, 2018
`
`Aug. 10, 2018
`
`Aug. 31, 2018
`
`Sept. 21, 2018
`
`b.
`
`Objections to Expert Testimony. To the extent any objection to expert
`
`testimony is made pursuant to the principles announced in Daubert v. Merrell Dow Pharm., Inc.,
`
`509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it shall be made by
`
`motion no later than the deadline for dispositive motions set forth herein, unless otherwise
`
`ordered by the Court.
`
`9
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`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 9 of 13
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`

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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 10 of 13 PageID #: 2347
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`13.
`
`Case Dispositive Motions. All case dispositive motions, an opening brief, and
`
`affidavits, if any, in support of the motion shall be served and filed on or before (see chart
`
`below). No case dispositive motion under Rule 56 may be filed more than ten days before the
`
`above date without leave of the Court.
`
`Family
`
`IA & 1B
`
`Case Dispositive and Daubert Motions
`(as to the parties designated for trial only)
`Mar. 8, 2018
`
`2
`
`..,
`
`.)
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9A&9B
`
`10
`
`Mar. 23, 2018
`
`Apr. 13, 2018
`
`June l, 2018
`
`June 29, 2018
`
`July 20, 2018
`
`Aug. 3, 2018
`
`Aug. 31, 2018
`
`Sept. 14, 2018
`
`Oct. 12, 2018
`
`14.
`
`Applications by Motion. Except as otherwise specified herein, any application to
`
`the Court shall be by written motion. Any non-dispositive motion should contain the statement
`
`required by Local Rule 7 .1.1.
`
`15.
`
`Pretrial Conference. On (see chart below), the Court will hold a Rule 16(e) final
`
`pretrial conference in Court with counsel beginning at (see chart below). The parties shall file a
`
`joint proposed final pretrial order in compliance with Local Rule 16.3(c) no later than 5 p.m. on
`
`(see chart below). Unless otherwise ordered by the Court, the parties shall comply with the
`
`10
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`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 10 of 13
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`

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`( I
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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 11 of 13 PageID #: 2348
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`timeframes set forth in Local Rule 16.3 ( d) for the preparation of the proposed joint final pretrial
`
`order.
`
`Family
`
`IA & IB
`
`Joint Submission of Proposed Final
`Pretrial Order, any motions in limine,
`voir dire, jury instructions, and
`special verdict forms
`(as to parties designated for trial only)
`May 18, 2018
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9A&9B
`
`10
`
`June 1,2018
`
`June 22, 2018
`
`Aug. 10, 2018
`
`Sept. 7, 2018
`
`Sept. 28, 2018
`
`Oct. 12, 2018
`
`Nov. 9, 2018
`
`Nov. 23, 2018
`
`Dec. 21, 2018
`
`Pretrial Conference
`(as to parties designated for trial
`only)
`
`May 25, 2018 at 8:30 a.m.
`
`June 8, 2018 at 8:30 a.m.
`
`June 29, 2018 at 8:30 a.m.
`
`Aug. 17, 2018 at 8:30 a.m.
`
`Sept. 14, 2018 at 8:30 a.m.
`
`Oct. 5, 2018 at 8:30 a.m.
`
`Oct. 19, 2018 at 8:30 a.m.
`
`Nov. 16, 2018 at 8:30 a.m.
`
`Nov. 30, 2018 at 8:30 a.m.
`
`Dec. 28, 2018 at 8:30 a.m.
`
`16. Motions in Limine. Motions in limine shall not be separately filed. All in limine
`
`requests and responses thereto shall be set forth in the proposed pretrial order. Each party shall
`
`be limited to three in limine requests, unless otherwise permitted by the Court. The in limine
`
`request and any response shall contain the authorities relied upon; each in limine request may be
`
`supported by a maximum of three pages of argument and may be opposed by a maximum of
`
`three pages of argument, and the party making the in limine request may add a maximum of one
`
`additional page in reply in support of its request. If more than one party is supporting or
`
`opposing an in limine request, such support or opposition shall be combined in a single three
`
`page submission (and, ifthe moving party, a single one page reply). No separate briefing shall be
`
`submitted on in limine requests, unless otherwise permitted by the Court.
`
`11
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`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 11 of 13
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`

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`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 12 of 13 PageID #: 2349
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`17.
`
`Jury Instructions, Voir Dire, and Special Verdict Forms. Pursuant to Local Rules
`
`47.1 ( a)(2) and 51.1, the parties should file (i) proposed voir dire, (ii) preliminary jury
`
`instructions, (iii) final jury instructions, and (iv) special verdict forms on (see chart below
`
`section 15). The parties shall submit simultaneously with filing each of the foregoing four
`
`documents in Word or WordPerfect format to rga_civil@ded.uscourts.gov.
`
`18.
`
`Trial. The first matter is scheduled for a 5 day jury trial beginning at 9:30 a.m. on
`
`(see chart below), with the subsequent trial days beginning at 9:30 a.m. Until the case is
`
`submitted to the jury for deliberations, the jury will be excused each day at 4:30 p.m. The trial
`
`will be timed, as counsel will be allocated a total number of hours in which to present their
`
`respective cases.
`
`19.
`
`Family
`
`IA& lB
`
`Defendant
`Designated for
`Trial
`2Wire
`
`Trial Date
`(as to parties designated for trial
`only)
`June 4, 2018
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9A&9B
`
`10
`
`June 18, 2018
`
`July 9, 2018
`
`Aug. 27, 2018
`
`Sept. 24, 2018
`
`Oct. 15, 2018
`
`Oct. 29, 2018
`
`Nov.26,2018
`
`Dec. 10, 2018
`
`Jan. 7, 2019
`
`2Wire
`
`2Wire
`
`Zhone
`
`Zhone
`
`Zhone
`
`ZyXEL
`
`ZyXEL
`
`ADTRAN
`
`AD TRAN
`
`12
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 12 of 13
`
`

`

`Case 1:15-cv-00121-RGA Document 117 Filed 04/10/17 Page 13 of 13 PageID #: 2350
`
`20.
`
`ADR Process. This matter is referred to a magistrate judge to explore the
`
`possibility of alternative dispute resolution.
`
`13
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1028
`Page 13 of 13
`
`