Case 6:20-cv-00636-ADA Document 228 Filed 09/27/22 Page 1 of 5
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`DEMARAY LLC,
`
`
`Plaintiff,
`
`
`v.
`
`INTEL CORPORATION,
`
`Defendant
`
`
`DEMARAY LLC,
`
`
`Plaintiff,
`
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., et
`al.,
`
`
`CASE NO. 6:20-cv-00634-ADA
`
`JURY TRIAL DEMANDED
`
`
`CASE NO. 6:20-cv-00636-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`Defendants.
`
`
`
`
`
`
`
`
`JOINT MOTION TO AMEND SCHEDULE
`
`Plaintiff Demaray LLC (“Demaray”), Defendant Intel Corporation (“Intel”), and
`
`Defendants Samsung Electronics Co., Ltd., (a Korean Company), Samsung Austin Semiconductor,
`
`LLC, Samsung Electronics America, Inc., and Samsung Semiconductor, Inc. (collectively
`
`“Samsung”) (collectively “the Parties”), by and through their undersigned counsel, and subject to
`
`the approval of the Court, hereby jointly move the Court to amend the case deadlines in the two
`
`above-captioned matters to the below agreed-to deadlines.
`
`On September 12, 2022, Demaray filed motions to extend the discovery deadlines in the
`
`respective cases. See Dkt. 230 (6:20-cv-00634); Dkt. 218 (6:20-cv-00636). Thereafter, the Parties
`
`further met and conferred regarding alternative trial dates and determined that a trial date of
`
`

`

`Case 6:20-cv-00636-ADA Document 228 Filed 09/27/22 Page 2 of 5
`
`September 11, 2023 did not pose conflicts and would allow for an extension of discovery and other
`
`deadlines. On September 14, 2022, during discovery hearings, the Parties informed the Court of
`
`the proposed trial date of September 11, 2023 and that they would further meet and confer to align
`
`the remaining deadlines in the cases to that trial date. See Dkt 235 at 4-5 (6:20-cv-00634); see
`
`also Dkt. 222 (6:20-cv-00636). The Court stated that a trial date of September 11, 2023 was
`
`acceptable. Id. The Parties having reached agreement on the remaining deadlines in the cases,
`
`Demaray withdraws its motions to extend the discovery deadlines, and the Parties respectfully
`
`request that the Court grant their joint motion to amend the schedule with the following deadlines:
`
`Date
`
`11/04/2022
`
`2/09/2023
`3/16/2023
`4/27/2023
`5/31/2023
`
`6/05/2023
`
`6/15/2023
`6/29/2023
`
`7/17/2023
`7/20/2023
`7/27/2023
`7/27/2023
`
`Deadline
`
`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.
`Close of Fact Discovery
`Opening Expert Reports
`Rebuttal Expert Reports
`Close of Expert Discovery
`
`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.
`
`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
`Serve objections to rebuttal disclosures
`
`
`
`
`2
`
`

`

`Case 6:20-cv-00636-ADA Document 228 Filed 09/27/22 Page 3 of 5
`
`Date
`
`8/03/2023
`
`8/07/2023
`
`8/18/2023
`
`8/21/2023
`9/11/2023
`
`
`Deadline
`
`File Joint Pretrial Order and Pretrial Submissions (jury instructions, exhibits
`lists, witness lists, designations); file oppositions to motions in limine
`
`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.
`
`Deadline to meet and confer regarding remaining objections and disputes on
`motions in limine
`File joint notice identifying remaining objections to pretrial disclosures and
`disputes on motions in limine
`Final Pretrial Conference
`Jury Selection/Trial
`
`The Parties, by and through their undersigned counsel of record, in the interests of judicial
`
`
`
`
`
`economy, agree and stipulate, and respectfully request that the Court grant this motion and enter
`
`this revised schedule. A proposed order consistent with the above is attached as Exhibit A.
`
`
`
`
`
`
`
`
`3
`
`

`

`Case 6:20-cv-00636-ADA Document 228 Filed 09/27/22 Page 4 of 5
`
`
`
`Dated: September 27, 2022
`
`
`
`Dated: September 27, 2022
`
`
`
`Dated: September 27, 2022
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`KIRKLAND & ELLIS, LLP
`
`
`
`
`/s/ Kat Li
` Kat Li
`
`Attorneys for Defendants, Samsung Electronics
`et al.
`
`Respectfully submitted,
`
`WILMER CUTLER PICKERING HALE &
`DORR, LLP
`
`
`
`/s/ Mary V. Sooter
` Mary V. Sooter
`
`Attorneys for Defendant Intel Corporation
`
`Respectfully submitted,
`
`FOLIO LAW GROUP PLLC
`
`
`
`
`
`
`/s/ C. Maclain Wells
` C. Maclain Wells
`
`Attorneys for Plaintiff Demaray LLC
`
`
`
`4
`
`

`

`Case 6:20-cv-00636-ADA Document 228 Filed 09/27/22 Page 5 of 5
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that counsel of record who are deemed to have consented to electronic
`
`service are being served on September 27, 2022 with a copy of this document via the Court’s
`
`CM/ECF system per Local Rule CV-5(a)(3).
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Kat Li
` Kat Li
`
`5
`
`