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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`DEMARAY LLC,
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`Plaintiff,
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`v.
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`INTEL CORPORATION,
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`Defendant
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`DEMARAY LLC,
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD., et
`al.,
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`Defendants.
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`CASE NO. 6:20-cv-00634-ADA
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`JURY TRIAL DEMANDED
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`CASE NO. 6:20-cv-00636-ADA
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`JURY TRIAL DEMANDED
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`JOINT STIPULATION TO AMEND SCHEDULE
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`Plaintiff Demaray LLC (“Demaray”), Defendant Intel Corporation (“Intel”), and
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`Defendants Samsung Electronics Co., Ltd., (a Korean Company), Samsung Austin Semiconductor,
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`LLC, Samsung Electronics America, Inc., and Samsung Semiconductor, Inc. (collectively
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`“Samsung”) (collectively “the Parties”), by and through their undersigned counsel, and subject to
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`the approval of the Court, hereby stipulate and agree as follows to amend the case deadlines in the
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`two above-captioned matters.
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`On September 12, 2022, Demaray filed motions to extend the discovery deadlines in the
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`respective cases. See Dkt. 230 (6:20-cv-00634); Dkt. 218 (6:20-cv-00636). Thereafter, the Parties
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`further met and conferred regarding alternative trial dates and determined that a trial date of
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`Case 6:20-cv-00636-ADA Document 226 Filed 09/26/22 Page 2 of 5
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`September 11, 2023 did not pose conflicts and would allow for an extension of discovery and other
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`deadlines. On September 14, 2022, during discovery hearings, the Parties informed the Court of
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`the proposed trial date of September 11, 2023 and that they would further meet and confer to align
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`the remaining deadlines in the cases to that trial date. See Dkt 235 at 4-5 (6:20-cv-00634); see
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`also Dkt. 222 (6:20-cv-00636). The Court stated that a trial date of September 11, 2023 was
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`acceptable. Id. The Parties having reached agreement on the remaining deadlines in the cases,
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`Demaray withdraws its motions to extend the discovery deadlines, and the Parties respectfully
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`request that the Court enter their joint stipulation to amend the schedule with the following
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`deadlines:
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`Date
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`11/04/2022
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`Deadline
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`Deadline for the first of two meet and confers to discuss significantly
`narrowing the number of claims asserted and prior art references at issue.
`Unless the parties agree to the narrowing, they are ordered to contact the
`Court’s Law Clerk to arrange a teleconference with the Court to resolve the
`disputed issues.
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`2/09/2023
`3/16/2023
`4/27/2023
`5/31/2023
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`Close of Fact Discovery
`Opening Expert Reports
`Rebuttal Expert Reports
`Close of Expert Discovery
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`6/05/2023
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`Deadline for the second of two meet and confer to discuss narrowing the
`number of claims asserted and prior art references at issue to triable limits.
`To the extent it helps the parties determine these limits, the parties are
`encouraged to contact the Court’s Law Clerk for an estimate of the amount
`of trial time anticipated per side. The parties shall file a Joint Report within 5
`business days regarding the results of the meet and confer.
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`6/15/2023
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`6/29/2023
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`7/17/2023
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`7/20/2023
`7/27/2023
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`Dispositive motion deadline and Daubert motion deadline
`Serve Pretrial Disclosures (jury instructions, exhibits lists, witness lists,
`designations)
`Parties to jointly email the Court’s law clerk to confirm their pretrial
`conference and trial dates.
`Serve objections to pretrial disclosures/rebuttal disclosures
`File Motions in limine
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`2
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`Case 6:20-cv-00636-ADA Document 226 Filed 09/26/22 Page 3 of 5
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`Date
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`Deadline
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`7/27/2023
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`Serve objections to rebuttal disclosures
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`8/03/2023
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`File Joint Pretrial Order and Pretrial Submissions (jury instructions, exhibits
`lists, witness lists, designations); file oppositions to motions in limine
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`File Notice of Request for Daily Transcript or Real Time Reporting. If a
`daily transcript or real time reporting of court proceedings is requested for
`trial, the party or parties making said request shall file a notice with the
`Court and e-mail the Court Reporter, Kristie Davis at kmdaviscsr@yahoo.
`com.
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`Deadline to meet and confer regarding remaining objections and disputes on
`motions in limine
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`File joint notice identifying remaining objections to pretrial disclosures and
`disputes on motions in limine
`Final Pretrial Conference
`Jury Selection/Trial
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`8/07/2023
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`8/18/2023
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`8/21/2023
`9/11/2023
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`The Parties, by and through their undersigned counsel of record, in the interests of judicial
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`economy, agree and stipulate, and respectfully request that the Court enter this revised schedule.
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`A proposed order consistent with the above is attached as Exhibit A.
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`3
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`Case 6:20-cv-00636-ADA Document 226 Filed 09/26/22 Page 4 of 5
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`
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`Dated: September 26, 2022
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`Dated: September 26, 2022
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`Dated: September 26, 2022
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`Respectfully submitted,
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`KIRKLAND & ELLIS, LLP
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`/s/ Kat Li
` Kat Li
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`Attorneys for Defendants, Samsung Electronics
`et al.
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`Respectfully submitted,
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`WILMER CUTLER PICKERING HALE &
`DORR, LLP
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`/s/ Mary V. Sooter
` Mary V. Sooter
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`Attorneys for Defendant Intel Corporation
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`Respectfully submitted,
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`FOLIO LAW GROUP PLLC
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`/s/ C. Maclain Wells
` C. Maclain Wells
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`Attorneys for Plaintiff Demaray LLC
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`4
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`Case 6:20-cv-00636-ADA Document 226 Filed 09/26/22 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`I hereby certify that counsel of record who are deemed to have consented to electronic
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`service are being served on September 26, 2022 with a copy of this document via the Court’s
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`CM/ECF system per Local Rule CV-5(a)(3).
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` /s/ Kat Li
` Kat Li
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`5
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