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Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 1 of 18
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE WESTERN DISTRICT OF TEXAS
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`WACO DIVISION
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`SYNKLOUD TECHNOLOGIES, LLC
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`VS.
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`ADOBE, INC.
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`May 19, 2020
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`*
`*
`* CIVIL ACTION NO. W-19-CV-527
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`*
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`BEFORE THE HONORABLE ALAN D ALBRIGHT, JUDGE PRESIDING
`TELEPHONIC DISCOVERY HEARING
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`APPEARANCES:
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`For the Plaintiff:
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`For Defendant Adobe:
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`Court Reporter:
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`Kevin James Terrazas, Esq.
`Cleveland Terrazas PLLC
`4611 Bee Cave Rd., #306 B
`Austin, TX 78746
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`Deepali A. Brahmbhatt, Esq.
`One LLP, 4000 MacArthur Blvd.
`East Tower, Suite 500
`Newport Beach, CA 92660
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`Deron R. Dacus, Esq.
`The Dacus Firm, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, TX 75701
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`Eugene Y. Mar, Esq.
`Winston Liaw, Esq.
`Farella Braun & Martel, LLP
`Sushila Chanana, Esq.
`235 Montgomery Street, 17th Floor
`San Francisco, CA 94104
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`Kristie M. Davis
`United States District Court
`PO Box 20994
`Waco, Texas 76702-0994
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`Proceedings recorded by mechanical stenography, transcript
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`produced by computer-aided transcription.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 2 of 18
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`(May 19, 2020, 1:59 p.m.)
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`MS. MILES: Telephonic discovery hearing in Civil Action
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`6:19-CV-527, styled SynKloud Technologies, LLC, versus Adobe,
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`Incorporated.
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`THE COURT: Good afternoon, everyone. If I could hear
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`from the plaintiff's counsel first, whoever will be speaking
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`today, and then if I could hear from defense counsel, and then
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`we'll take up whatever issues you have.
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`MR. TERRAZAS: Your Honor, this is Kevin Terrazas, and
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`with me is Deepali Brahmbhatt. And I will be speaking today on
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`behalf of plaintiff.
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`THE COURT: Okay. Thank you, sir.
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`MR. DACUS: Your Honor, this is Deron Dacus, and also on
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`the phone is Eugene Mar, Winston Liaw and Sushila Chanana on
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`behalf of Adobe, Your Honor, and we're ready to proceed.
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`THE COURT: And, Mr. Dacus, who'll be speaking on behalf
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`of defendant?
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`MR. DACUS: I'm sorry, Your Honor. I will. At least
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`until the point where I can't speak anymore. I plan to speak.
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`THE COURT: Very good. Okay. So what brings you all to
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`the Court?
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`MR. DACUS: Your Honor, this is Deron Dacus. I think
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`we've got two issues today.
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`THE COURT: Okay.
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`MR. DACUS: One is a complaint by Adobe, the defendant,
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 3 of 18
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`and then we have a complaint by the plaintiff.
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`At least from my perspective, Adobe's complaint should be
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`fairly short. Just to give the Court some background, earlier
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`in this case we at Adobe reached out to the inventor of the
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`patents-in-suit, and we had a discussion with him. He was not
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`represented by counsel.
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`As a result of that discussion, Adobe had some concerns
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`about retrieving and collecting and being able to produce
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`documents to us from the inventor in the case. We reached out
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`to the Court, you know, cognizant of the Court's rule that you
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`don't allow discovery until after Markman, we reached out to
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`the Court, expressed to the Court with the plaintiff on the
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`line what our concerns were and asked the Court for permission
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`to issue a subpoena to the inventor and require him to produce
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`documents.
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`The Court granted us that permission, and the way the
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`Court did that, Your Honor, is Dr. Yi sent an e-mail, and I
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`will -- I know the Court probably doesn't -- the Court knows --
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`well, I know the Court does not have this in front of it, so
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`I'll read this so the Court has the benefit of it.
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`This is an e-mail that Dr. Yi sent to all the lawyers on
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`December 3rd, 2019. And it says: To follow up on today's
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`call, I talked to Judge Albright about the possibility of early
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`discovery, specifically in regards to subpoenaing the inventor
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`of the patents-in-suit. He said that he would permit that in
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 4 of 18
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`this case. He also said that the inventor could be deposed
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`now, and if so, that will be the only deposition of the
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`inventor for this case. In other words, the inventor cannot be
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`deposed now and again during fact discovery.
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`So based on that order from the Court, we issued a
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`subpoena to the plaintiff. The plaintiff then produced -- not
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`to the plaintiff -- to the inventor. The plaintiff's counsel,
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`SynKloud's counsel, at some point in time began representing
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`the inventor, and so they responded to the subpoena, but they
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`only partially responded to the subpoena.
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`I think by their own admission they only partially
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`responded to it. They produced some documents, but they have
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`withheld other documents. And so what we're here asking the
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`Court to do today is to request, or require, that the plaintiff
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`comply with the Court's order, produce all the documents that
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`were requested pursuant to the subpoena, and in addition, I
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`think it's necessary, at a minimum, to produce a privilege log,
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`although we don't think the documents are privileged, but the
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`inventor's counsel, who's also the plaintiff's counsel,
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`contends that some of the documents are privileged.
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`If that's an issue, I do think we probably want to address
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`that today, but at a minimum I think we need an order from the
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`Court requiring them to produce all the documents that they
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`have not and to provide a privilege log.
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`So I can answer any questions, Judge, if any of that's
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 5 of 18
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`confusing.
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`THE COURT: No. It's not.
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`I'll hear from the plaintiff's counsel.
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`MR. TERRAZAS: Thank you, Your Honor. So, Your Honor, in
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`your order requiring the -- or allowing for a subpoena, the
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`ultimate issue there was whether or not the inventor was going
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`to destroy any documents. There's no question, and that's been
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`resolved because all those documents have gone to plaintiff's
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`counsel.
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`Plaintiff's counsel has since produced 716 pages from the
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`inventor plus two versions of source code. The only type of
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`documents that have not been produced are negotiations that are
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`related to Federal Rule of Evidence 408, that what counsel has
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`explained to the defendant is that we will make those available
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`after the fact discovery period opens.
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`As the Court -- I remember in one of our previous hearings
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`the Court said that it would not allow SynKloud to get
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`licensing and other negotiation documents from the defendants
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`in cases because that's restricted to after claim construction,
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`after the Markman, and the open discovery period there.
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`We're simply asking for the same here involving the
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`inventor because, again, the underlying issue of why the
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`subpoena was even issued has been resolved in that all the
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`documents are at least in plaintiff's counsel's possession and
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`the vast majority of them are also in defendant's possession.
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 6 of 18
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`Same thing with the privilege log, Your Honor, is that it
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`would be unduly burdensome right now to issue a privilege log
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`before we even get into fact discovery, and defendants haven't
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`shown why at this stage before claim construction, before the
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`Markman, why they need both the licensing negotiations as well
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`as a privilege log and how that would bear on any issues before
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`full fact discovery opens.
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`THE COURT: Mr. Dacus?
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`MR. DACUS: Yes, Your Honor. So a couple of points.
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`One is, when counsel says the only documents remaining are
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`negotiation documents, I'm not sure exactly the scope and the
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`breadth of -- that he's talking about because at least our
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`impression, the defendant's impression, from having discussions
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`in meet and confers before we bothered the Court were that
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`there were also communications between the plaintiff SynKloud
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`and the inventor from whom the plaintiff purchased the patent.
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`So we believe there are communications that are relevant to the
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`case that fall into that category.
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`So the way I see this, Your Honor, maybe I see it wrong, I
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`mean, we have an order from the Court that says we have the
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`right to issue a subpoena and get whatever documents we believe
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`the inventor has. We've -- we've issued that subpoena. By the
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`plaintiff's own admission, I think here, they've not fully
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`responded to that subpoena. And as the Court heard from the
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`Court's order, the Court also gave us the right, not the
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 7 of 18
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`obligation, but the right to go ahead and take the inventor's
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`deposition now. We certainly haven't decided if we want to do
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`that, but we certainly cannot do that and do not want to do
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`that before we have a complete production of documents.
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`THE COURT: What is -- I remember -- I actually remember
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`this hearing, but what is the purpose of taking the inventor
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`now? I know there are times when you want to take the
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`inventor. Frankly, I don't remember an inventor deposition I
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`ever attended that was worth taking at all. But if we -- if we
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`continue the fiction that it is worth taking, and certainly you
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`have the right to do it, what is -- why does the defendant want
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`to take the inventor now and what -- does it have anything to
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`do with -- with the Markman?
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`MR. DACUS: Your Honor, it does not have anything to do
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`with the Markman. But to answer the Court's question directly,
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`there are potential on-sale bar and other invalidity issues
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`about disclosure of the alleged patent information before the
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`critical dates that potentially bear on invalidity issues. In
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`addition, of course, there are -- there is potential
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`documentation, and I believe the plaintiff has admitted there's
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`documentation related to the purchase agreement between the
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`inventor and the plaintiff SynKloud in this case.
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`So that's at least two reasons that we would want to talk
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`to the inventor.
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`THE COURT: Well, it's not very often that I -- as I
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 8 of 18
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`recall, I could be wrong, as I recall, part of the fear that
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`the defendant had was that the -- there was going to be some
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`destruction of documents, not, you know, not intentional, but
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`just some, you know, let's get them -- let's get them secured
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`and subpoenaed, and you have them now. And it's not my
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`practice, generally speaking, to allow discovery that's
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`non-Markman related. So I'm not -- unless you can explain to
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`me some reason why you think the defendant would be prejudiced
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`by waiting until after the Markman to depose the plaintiff, I'm
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`not sure why I would allow that, given the counsel for
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`plaintiff's representation that all the documents that we were
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`worried about have been -- have been secured.
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`MR. DACUS: I certainly understand what the Court's
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`saying. I guess my only response to that is we have a court
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`order that said we are allowed to subpoena those documents and
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`to retrieve them, and so we're acting under the Court's order
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`to do that.
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`THE COURT: Well, you -- let me try one more time. Let me
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`just make sure we're on the record -- let me just make sure,
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`and I'm not questioning plaintiff's counsel's credibility at
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`all. I just want to make sure, Mr. Terrazas, that -- or
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`Mr. Terrazas that -- Mr. Terrazas, I'll get this right -- I'm
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`not challenging your credibility at all. I just want to make
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`sure I fully understand what you're saying.
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`The plaintiff's position is -- to the Court is that you
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 9 of 18
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`are now representing the inventor. You have gone to the
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`inventor and secured all of the relevant -- all of the
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`documents that were in existence when you engaged with the
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`inventor, and those are secured and in your possession. Is
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`that fair?
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`MR. TERRAZAS: Yes, sir. That is correct.
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`THE COURT: Okay. So -- and obviously those aren't going
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`anywhere. And so, again, I'll turn it back to Mr. Dacus. I
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`think my -- I think the Court's major concern here has been
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`alleviated by the fact that the inventor is now, for lack of a
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`better word, cooperating may be a better word -- is just
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`represented.
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`I have much more comfort when a lawyer comes in and says
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`I'm -- the inventor is -- I'm representing the inventor. We
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`have all the documents, there's no possibility of destruction,
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`than I am when there's just an inventor who is unrepresented.
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`So, Mr. Dacus, when do we have the -- when is the Markman
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`set for this case?
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`MR. DACUS: I believe it's in September. Mr. Mar can
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`correct me, but I believe it's the first week in September.
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`THE COURT: Okay. Is there --
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`MR. MAR: I think it's actually on the 11th of September.
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`THE COURT: Okay. So as of the -- as of September 11th,
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`discovery will begin. Either -- can you -- I think you've
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`answered they don't relate to the Markman. I think you can
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 10 of 18
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`explain with respect to the possibility of on-sale bar what
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`you -- or invalidity, what you might want them for. Can you
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`articulate, Mr. Dacus, any prejudice, not just disadvantage,
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`but prejudice that would -- the defendant would suffer if I
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`don't allow you to have those documents in advance of the
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`Markman?
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`MR. DACUS: To be honest with you, Judge, I cannot. You
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`know, the primary thing we do not want to do is waive our
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`opportunity to get these documents since we have a court order
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`that told us we could and should go get them.
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`If Mr. Mar has some prejudice that I'm overlooking, I'd
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`certainly invite him to chime up, but I honestly could not
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`articulate anything for the Court.
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`THE COURT: Yeah. I'll tell you that, you know, my -- you
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`know, we spent a lot of time, not that you all care that it
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`should be the end all, be all, but, you know, we spent a lot of
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`time coming up with -- and, Mr. Dacus, I think you may have
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`participated in coming up with the way we schedule. And part
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`of the -- part of my entire way of doing things is to free up
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`the parties from the burden of non-Markman related duties. And
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`then the exchange I think I give to the parties, not to sound
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`defensive, but is you know that the day after the Markman
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`discovery can commence on a substantive issue, and you won't be
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`sitting around waiting additional time to get discovery. And
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`so it -- I don't -- absent prejudice, I don't like to -- I
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 11 of 18
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`don't like to change up the way I do things, and with the
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`plaintiff's counsel's representation that the documents are not
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`at peril of being lost or destroyed, I'm comfortable that him
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`producing them to you after the Markman will be okay. So
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`that's one issue.
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`What is the -- did the plaintiff also have an issue to
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`take up?
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`MR. TERRAZAS: Yes, Your Honor.
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`THE COURT: Okay.
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`MR. TERRAZAS: Our issue is related to your scheduling
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`order, and there's a requirement by March 13th for the
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`production of documents by the defendants that's sufficient to
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`show the operation of the accused products. And here we've got
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`accused products and services, and so both would be involved in
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`that. And, Your Honor, there's been 380 documents that have
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`been produced by defendants. Only 39 of those involve any sort
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`of technical documents. And, Your Honor, of those, they don't
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`show what we need to see, which is server side functionality.
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`And so it doesn't show how the servers function. It doesn't
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`provide any desktop or mobile applications and how they operate
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`with the servers.
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`And, Your Honor, we've gone back and forth, and I think
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`some of the concern here is that defendants have tried to parse
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`and characterize the accused products and services how they
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`want to as opposed to how they're claimed and how they've been
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 12 of 18
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`presented in the preliminary infringement contentions.
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`And so what they've said is is that they may start
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`producing documents -- producing more documents on May 22nd.
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`And, Your Honor, we need a set deadline of when they need to
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`have this production complete because part of the issues here
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`is that in order to understand the operation of the accused
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`products and to be able to prepare for the final infringement
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`contentions that are due a month after the Markman, we need to
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`have these documents in our hands and to be able to analyze
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`them ahead of time.
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`In addition, it helps to inform the Court for the tutorial
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`for the Markman as to what's really at issue. The Federal
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`Circuit back in 2006 in the Wilson Sporting Goods versus
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`Hillerich case, Judge Rader explained that knowing at least
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`what the products might encompass and the scope can be helpful
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`even for claim construction.
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`And so having these documents ahead of time is important
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`for us, and for them not to produce them by the Court's
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`deadline of March 13th, all the documents they're supposed to,
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`is causing great prejudice to plaintiff.
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`THE COURT: Mr. Dacus?
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`MR. DACUS: Yes, Your Honor. I'm going to address this at
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`a high level, Your Honor, and I hope that it's sufficient. If
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`not, then there are others on the phone. If we need to get
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`down in the weeds, we certainly can, but let me attempt to
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 13 of 18
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`address it at a high level, and I hope that will resolve the
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`issue.
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`So let me start out by saying that our document production
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`under the Court's requirements was absolutely fulsome and
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`absolutely complete. About a month ago, however, the plaintiff
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`came to us and said that they believe there was a deficiency.
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`And as counsel said, what has come to light, at least from our
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`part, is there's definitely a disagreement on the scope of
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`these claims between the two parties, and not just a mild
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`agreement, a very large disagreement on what these claims say
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`and what they relate to.
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`Having said that, however, we've had several meet and
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`confers with the plaintiff to try to fully understand what it
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`is additionally that they -- they want documentation-wise.
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`None of that conversation that we've had with the plaintiff has
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`convinced us that our original production was not fulsome and
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`complete because we believe it was.
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`But what we've told them was to identify in writing what
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`it is they want. They've done that. We've now told them that
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`we would begin producing the documents that they've requested
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`this Friday, May 22nd, as counsel noted, and the thing I want
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`to say to the Court is and I want to be clear, we do not
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`believe in any way that these documents are required by the
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`Court's order. We believe we've complied with it. But we also
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`don't believe this is a fight worth having, and we don't
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`

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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 14 of 18
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`believe it's a fight that we need to be in front of the Court
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`on.
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`So we have agreed to produce the documents that the
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`plaintiff has requested, and we've agreed to start that
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`production on Friday. So from our perspective, we don't think
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`there's a dispute here. We don't -- a dispute in front of the
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`Court, but if there's something additional that the plaintiff
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`wants, you know, we certainly want to address it.
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`THE COURT: So if I understand what Mr. Dacus --
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`Mr. Dacus, I understand what you're saying, the plaintiff will
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`know Friday whether or not there's still something we need to
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`take up?
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`MR. DACUS: I don't think the plaintiff will know that,
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`Your Honor, because we will not complete our production on
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`Friday. We will begin that production.
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`THE COURT: Okay.
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`MR. DACUS: And it's certainly going to take several weeks
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`to complete it, given the breadth of what the plaintiff is
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`requesting, at least from our perspective, the breadth of the
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`documents that the plaintiff is requesting goes far, far beyond
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`what the Court's initial requirement is for the sufficient to
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`show.
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`But, again, I think this case is likely to go the long
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`haul, so it's really not a fight worth having, so we're willing
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`to produce these documents. But it's going to take us some
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`

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`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 15 of 18
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`time to do it.
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`THE COURT: Okay. So here is, as a practical matter,
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`where the Court is at. I don't know that, you know, I can -- I
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`can do whatever I want, but I don't know that I can effectively
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`do anything more, it sounds like, than order the defendant to
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`be producing the documents they're producing. It sounds like
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`they have agreed to do it. The plaintiff may be unhappy about
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`the pace at which they receive these. I really don't know that
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`I can help with that either.
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`So here's where we're at: The defendant has -- defense
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`counsel has represented they are going to continue to produce
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`documents. If -- Mr. Dacus, when you have finished producing
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`the documents that you are going to produce, please inform
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`plaintiff's counsel of that.
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`Plaintiff's counsel, if you at that time feel like there
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`are additional documents you have not yet received that you
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`need, contact the Court, and we'll jump on this immediately.
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`Number two, if -- as a result of the timing of your
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`receipt of the documents from the defendant, if you feel like
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`dates need to be jiggered in terms of allowing you to do
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`whatever you need to do in terms of your burdens under the
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`scheduling order, again, obviously contact Mr. Dacus and team,
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`see if you can work it out. If you can't work it out, again,
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`immediately contact the Court.
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`It's tough when there are issues that blow up in March and
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`

`

`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 16 of 18
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`I don't -- and I don't hear about them until May. I know
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`that's probably the fault that you all in front of an infinite
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`number of judges who have beat me about the head saying, you
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`guys need to work this out. Don't bother me.
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`I am willing to -- I'm going to try to do just the
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`opposite. In anything going forward in this case, if you all
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`can't reach a resolution with each other, there's no obligation
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`to spend weeks and weeks. You know, just contact the Court. I
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`would rather have a -- this has taken 23 minutes. I would
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`1 2 3 4 5 6 7 8 9
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`rather take 23 minutes to get it resolved now than to have to
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`do stuff in the future.
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`So -- so that's what we're going to do, but the burden I'm
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`going to place on the plaintiff is at any time if you feel that
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`you have been prejudiced by -- and I'm not saying by prejudice
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`I mean that the defendant did anything wrong. I'm just saying
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`if you wind up being prejudiced under your deadlines by when
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`you get information you believe you need, contact Mr. Dacus.
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`If that doesn't work, immediately contact me, and we will get
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`this all resolved.
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`Is there anything else I can take up?
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`MR. TERRAZAS: Not from plaintiffs. Thank you, Your
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`Honor.
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`MR. DACUS: Nothing from defendants. Thank you, Your
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`Honor.
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`THE COURT: And let me be clear, I'm really not chastising
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`

`

`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 17 of 18
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`anyone. I know that -- I know that we've all existed in a
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`world where you basically had to -- you know, it had to be
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`almost a death sentence before you went -- you go in front of
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`some judges and ask them for help. And I just -- that's a -- I
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`understand that's a different method than I have, and so I'm
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`just -- I encourage you to get to me as quickly as possible.
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`And --
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`MR. DACUS: Understood, Your Honor.
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`THE COURT: -- we'll get this stuff resolved. Okay?
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`MR. DACUS: We appreciate that method.
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`THE COURT: Anything else, Mr. Dacus?
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`MR. DACUS: No, sir.
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`THE COURT: Okie dokie. The Court is always available,
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`and so come to me as soon as you need help.
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`Other than that, be safe out there and have a great
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`afternoon. Take care.
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`(Hearing adjourned at 2:25 p.m.)
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
`
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
`
`

`

`Case 6:19-cv-00527-ADA Document 37 Filed 06/02/20 Page 18 of 18
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`UNITED STATES DISTRICT COURT )
`
`WESTERN DISTRICT OF TEXAS
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`)
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`I, Kristie M. Davis, Official Court Reporter for the
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`United States District Court, Western District of Texas, do
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`certify that the foregoing is a correct transcript from the
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`record of proceedings in the above-entitled matter.
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`I certify that the transcript fees and format comply
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`with those prescribed by the Court and Judicial Conference of
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`the United States.
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`Certified to by me this 2nd day of June 2020.
`
`/s/ Kristie M. Davis
`KRISTIE M. DAVIS
`Official Court Reporter
`800 Franklin Avenue
`Waco, Texas 76701
`(254) 340-6114
`kmdaviscsr@yahoo.com
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`KRISTIE M. DAVIS, OFFICIAL COURT REPORTER
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`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (WACO)
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`

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