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Case 3:22-cv-02956-TLT Document 42 Filed 11/16/22 Page 1 of 4
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`SHOOK, HARDY & BACON L.L.P.
`Jason M. Richardson (SBN 250916)
`555 Mission Street, Suite 2300
`San Francisco, California 94105
`Telephone: 415.544.1900
`Facsimile: 415.391.0281
`
`Chian Chiu Li
`5773 Tan Oak Drive
`Fremont, CA 94555
`(408) 417-0455
`
`Pro Se Defendant
`
`Trent Webb (admitted pro hac vice)
`Ryan J. Schletzbaum (admitted pro hac vice)
`Mark D. Schafer (admitted pro hac vice)
`2555 Grand Boulevard
`Kansas City, MO 64108
`
`Attorneys for Apple Inc.
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF NORTHERN CALIFORNIA
`
`APPLE INC.,
`
`Plaintiff,
`
`vs.
`
`CHIAN CHIU LI,
`
`Defendant.
`
`Case No. 3:22-cv-02956-TLT
`
`STIPULATION AND [PROPOSED]
`ORDER AS MODIFIED TO EXTEND
`PATENT CASE SCHEDULE
`
`JUDGE: Trina L. Thompson
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`STIPULATION SETTING CASE SCHEDULE
`CASE NO. 3:22-CV-02956
`
`IPR2023-00560
`Apple EX1009 Page 1
`
`

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`Case 3:22-cv-02956-TLT Document 42 Filed 11/16/22 Page 2 of 4
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`Plaintiff Apple Inc. (“Apple”) and Defendant Chian Chiu Li (“Mr. Li”) (collectively
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`“Parties”) jointly submit this Stipulation and request for order to extend the remaining case
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`deadlines.
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`WHEREAS, on October 13, 2022, the Court issued a Scheduling Order (Dkt. No. 33) setting
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`forth the case schedule in this litigation;
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`WHEREAS, on October 27, 2022, Mr. Li filed an unopposed Motion to Extend Time of
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`Patent Case Schedule (“Motion for Extension”) (Dkt. No. 39) requesting a five-month extension to
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`each of the case deadlines;
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`WHEREAS, in Mr. Li’s Motion for Extension, he represented the extension was necessary
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`because he “needs more time to go through similar cases and collect supporting materials that are
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`available.” Dkt. No. 39 at 2.
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`WHEREAS, in Mr. Li’s Motion for Extension, he also represented that the Parties agree to
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`stay the case once Apple files its inter partes review (“IPR”) petition with the United States Patent
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`and Trademark Office. Id.
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`WHEREAS, the Parties remain in agreement that this case should be stayed upon Apple
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`filing its IPR petition and, once filed, the Parties intend to jointly move for a stay of this litigation
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`pending final disposition of Apple’s IPR petition.
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`WHEREAS, on November 1, 2022, the Court entered a Text Order (Dkt. No. 40) directing
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`the Parties to meet and confer and file a joint stipulation and proposed order setting a case schedule.
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`NOW THEREFORE IT IS HEREBY STIPULATED by and between Apple and Mr. Li
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`that the Court amend the current case schedule (Dkt. No. 33) to the proposed amended deadlines as
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`follows:
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`STIPULATION SETTING CASE SCHEDULE
`CASE NO. 3:22-CV-02956
`
`2
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`IPR2023-00560
`Apple EX1009 Page 2
`
`

`

`Case 3:22-cv-02956-TLT Document 42 Filed 11/16/22 Page 3 of 4
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`Event
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`Apple to serve invalidity contentions and accompanying
`document production [Pat. L.R. 3-3, 3-4]
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`Deadline
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`May 15, 2023
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`Exchange of list of claim terms [Pat. L.R. 4-1]
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`May 29, 2023
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`Exchange of proposed constructions and extrinsic evidence [Pat.
`L.R. 4-2]
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`July 19, 2023
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`Mr. Li to serve damages contentions [Pat. L.R. 3-8]
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`July 3, 2023
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`Joint claim construction prehearing statement [Pat. L.R. 4-3]
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`July 13, 2023
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`Joint Case Management Statement for Interim Conference
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`July 17, 2023
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`Apple to serve rebuttal damages contentions [Pat. L.R. 3-9]
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`August 7, 2023
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`Party intending to rely on expert witness testimony to support
`proposed construction to serve claim construction expert report
`[Pat. L.R. 4-3]
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`September 29, 2023
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`Close of claim construction discovery [Pat. L.R. 4-4]
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`August 15, 2023
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`Mr. Li to file opening claim construction brief [Pat. L.R. 4-5(a)]
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`Pre-recorded Case Tutorial
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`August 30, 2023
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`Apple to file responsive claim construction brief [Pat. L.R. 4-
`5(b)]
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`September 13, 2023
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`Mr. Li to file reply claim construction brief [Pat. L.R.4-5(c)]
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`Claim construction hearing and technology tutorial
`[Pat. L.R. 4-6]
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`Advice of Counsel
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`September 20, 2023
`10
`October 9, 2023
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`30 days after Claim
`Construction Order
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`STIPULATION SETTING CASE SCHEDULE
`CASE NO. 3:22-CV-02956
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`IPR2023-00560
`Apple EX1009 Page 3
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`

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`Case 3:22-cv-02956-TLT Document 42 Filed 11/16/22 Page 4 of 4
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`Dated: November 10, 2022
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`Respectfully Submitted
`
`SHOOK, HARDY & BACON L.L.P.
`
`By: /s/ Mark D. Schafer
`
`Attorney for Apple Inc.
`
`Dated: November 10, 2022
`
`CHIAN CHIU LI
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`By: /s/ Chian Chiu Li
`Pro Se
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`SIGNATURE ATTESTATION
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`Pursuant to N.D. Cal. L.R. 5-1(h)(3), I, Mark D. Schafer, attest that I have obtained
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`authorization from the above signatories to file the above-referenced document. I declare under
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`penalty of perjury under the laws of the United States of America that the foregoing is true and
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`correct.
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`Executed: November 10, 2022
`
`By: /s/ Mark D. Schafer
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`PURSUANT TO STIPULATION, IT IS SO ORDERED AS MODIFIED.
`
`November 15, 2022
`Dated:___________________________
`
`_________________________________
`The Honorable Trina L. Thompson
`United States District Judge
`
`STIPULATION SETTING CASE SCHEDULE
`CASE NO. 3:22-CV-02956
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`IPR2023-00560
`Apple EX1009 Page 4
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`

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