Case 6:21-cv-00331-ADA Document 96 Filed 08/18/22 Page 1 of 6
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`IGT and IGT CANADA SOLUTIONS ULC,
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`ZYNGA INC.,
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`Defendant.
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`Plaintiffs,
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`
`
`v.
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`C.A. No. 6:21-CV-00331-ADA
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`Judge: Honorable Alan D. Albright
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`JOINT MOTION TO RESET PRETRIAL DEADLINES,
`PRETRIAL CONFERENCE DATE, AND TRIAL DATE
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`Plaintiffs IGT and IGT Canada Solutions ULC (“IGT”) and Defendant Zynga Inc.
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`(“Zynga”) jointly move to extend the remaining case schedule, pursuant to the Court’s Standing
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`Order Regarding Joint or Unopposed Request to Change Deadline. In support of this Motion, the
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`parties state as follows:
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`1.
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`On March 2, 2022, this Court issued an order granting Plaintiff’s motion to compel
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`Defendant to produce technical documents and source code sufficient to show the operation of the
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`accused products. Dkt. 61. Since that time, the parties have worked diligently to repeatedly meet
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`and confer to place the accused products in multiple representative buckets.
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`2.
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`On June 30, 2022, this Court granted an extension of all case deadlines by three
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`weeks pursuant to the parties’ joint motion.
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`3.
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` Since that time, the parties have diligently pursued discovery. However, given the
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`scope of the case, and despite having taken eighteen depositions since July, at least thirteen more
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`depositions remain to be taken prior to fact discovery closing.
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`4.
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`In order to accommodate these depositions, the parties have agreed to keep the
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`existing August 24 deadline for written discovery intact, but have agreed to extend the discovery
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`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`IGT and IGT CANADA SOLUTIONS ULC,
`
`
`
`
`
`ZYNGA INC.,
`
`
`
`
`
`Defendant.
`
`Plaintiffs,
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`
`C.A. No. 6:21-CV-00331-ADA
`
`Judge: Honorable Alan D. Albright
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`JOINT MOTION TO RESET PRETRIAL DEADLINES,
`PRETRIAL CONFERENCE DATE, AND TRIAL DATE
`
`Plaintiffs IGT and IGT Canada Solutions ULC (“IGT”) and Defendant Zynga Inc.
`
`(“Zynga”) jointly move to extend the remaining case schedule, pursuant to the Court’s Standing
`
`Order Regarding Joint or Unopposed Request to Change Deadline. In support of this Motion, the
`
`parties state as follows:
`
`1.
`
`On March 2, 2022, this Court issued an order granting Plaintiff’s motion to compel
`
`Defendant to produce technical documents and source code sufficient to show the operation of the
`
`accused products. Dkt. 61. Since that time, the parties have worked diligently to repeatedly meet
`
`and confer to place the accused products in multiple representative buckets.
`
`2.
`
`On June 30, 2022, this Court granted an extension of all case deadlines by three
`
`weeks pursuant to the parties’ joint motion.
`
`3.
`
` Since that time, the parties have diligently pursued discovery. However, given the
`
`scope of the case, and despite having taken eighteen depositions since July, at least thirteen more
`
`depositions remain to be taken prior to fact discovery closing.
`
`4.
`
`In order to accommodate these depositions, the parties have agreed to keep the
`
`existing August 24 deadline for written discovery intact, but have agreed to extend the discovery
`
`
`
`
`
`Case 6:21-cv-00331-ADA Document 96 Filed 08/18/22 Page 2 of 6
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`period for depositions by two weeks. The parties have adjusted the schedule to extend the time
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`that would otherwise be permitted for the filing of responses and replies to dispositive motions and
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`Daubert motions. Finally, additional modifications to the new schedule were made to account for
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`counsels’ various scheduling conflicts. Of course, these extensions are all proposed subject to this
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`Court’s schedule and availability.
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`5.
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`This motion for an extension is not sought to delay proceedings but is sought in
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`order to more fully address discovery, including depositions and expert reports. The parties still
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`have to complete over a dozen depositions and the week remaining in fact discovery is insufficient.
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`6.
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`The parties respectfully request entry of the proposed amended and agreed
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`deadlines, subject to the Court’s availability:
`
`Agreed Deadline
`September 6, 2022
`
`September 20, 2022
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`Event Item(s)
`Close of Fact Discovery (Written fact discovery to close by August 24,
`2022)
`Opening Expert Reports
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`November 1, 2022
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`Rebuttal Expert Reports
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`November 22, 2022
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`Close of Expert Discovery
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`November 29, 2022
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`Deadline for the second of two meet and confers 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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`December 14, 2022
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`Dispositive Motion Deadline and Daubert Motion Deadline
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`January 11, 2023
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`Oppositions to Dispositive Motions; Oppositions to Daubert Motions
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`January 25, 2023
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`Replies in support of Dispositive Motions; Replies in support of
`Daubert Motions
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`2
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`Case 6:21-cv-00331-ADA Document 96 Filed 08/18/22 Page 3 of 6
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`February 1, 2023
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`Serve Pretrial Disclosures (jury instructions, exhibits lists, witness
`lists, discovery and deposition designations).
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`February 15, 2023
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`Serve objections to pretrial disclosures/rebuttal disclosures
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`March 1, 2023
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`Serve objections to rebuttal disclosures and file motions in limine
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`March 15, 2023
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`File Joint Pretrial Order and Pretrial Submission (jury instructions,
`exhibits lists, witness lists, discovery and deposition designations); file
`oppositions to motions in limine.
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`March 22, 2023
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`Deadline to meet and confer regarding remaining objections and
`disputes on motions in limine.
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`March 29, 2023
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`April 5, 2023
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`Deadline to file Notice of Request for Daily Transcript or Real Time
`Reporting
`identifying remaining objections
`File
`joint notice
`disclosures and disputes on motions in limine
`Final Pretrial Conference
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`to pretrial
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`April 17, 2023
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`Jury Selection/Trial
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`3
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`Case 6:21-cv-00331-ADA Document 96 Filed 08/18/22 Page 4 of 6
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`Dated: August 18, 2022
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`Respectfully submitted,
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`
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`By:
`
` /s/ Leif R. Sigmond Jr.
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`
`
`Deron R. Dacus
`State Bar No. 00790553
`The Dacus Firm, P.C.
`821 ESE Loop 323
`Suite 430
`Tyler, TX 75701
`Telephone: 903-705-1117
`Facsimile: 903-581-2543
`ddacus@dacusfirm.com
`
`Leif R. Sigmond Jr.
`Illinois State Registration No. 6204980
`Baker & Hostetler LLP
`One North Wacker Drive
`Suite 4500
`Chicago, IL 60606-2841
`Telephone: 312-416-6275
`Facsimile: 312-416-6201
`LSigmond@bakerlaw.com
`
`Attorneys for IGT and IGT Canada
`Solutions ULC
`
`By: /s/ Alyssa Caridis
`
`Mark D. Siegmund
`Texas Bar No. 24117055
`STECKLER WAYNE CHERRY &
`LOVE PLLC
`8416 Old McGregor Road
`Waco, Texas 76712
`mark@swclaw.com
`Telephone: +1 254 651 3690
`Facsimile: +1 254 651 3689
`
`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`Clement Seth Roberts, Bar No. 209203
`(Pro Hac Vice)
`croberts@orrick.com
`The Orrick Building
`405 Howard Street
`San Francisco, CA 94105
`Telephone: +1 415 773 5700
`Facsimile: +1 415 773 5799
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`Alyssa Caridis, Bar No. 260103 (Pro Hac
`Vice)
`acaridis@orrick.com
`777 South Figueroa Street
`Suite 3200
`Los Angeles, CA 90017
`Telephone: +1 213 629 2020
`Facsimile: +1 213 612 2499
`
`Sten Jensen, Bar No. 443300 (Pro Hac
`Vice)
`sjensen@orrick.com
`Chris Childers, Bar No. 1719610 (Pro Hac
`Vice)
`cchilders@orrick.com
`Columbia Center
`1152 15th St NW
`Washington, DC 20005
`Telephone: +1 202 339 8400
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`4
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`Case 6:21-cv-00331-ADA Document 96 Filed 08/18/22 Page 5 of 6
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`Facsimile: +1 202 339 8500
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`Attorneys for Defendant Zynga Inc.
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`5
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`Case 6:21-cv-00331-ADA Document 96 Filed 08/18/22 Page 6 of 6
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`CERTIFICATE OF SERVICE
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`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
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`that, on August 18, 2022, all counsel of record who have appeared in this case are being served
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`with a copy of the foregoing via the Court’s CM/ECF system.
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`
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`
` /s/ Leif R. Sigmond Jr.
`Leif R. Sigmond Jr.
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`6
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