`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`GENTEX CORPORATION and INDIGO
`TECHNOLOGIES, LLC,
`
`
`Plaintiffs,
`
`THALES VISIONIX, INC.,
`
`
`Involuntary Plaintiff,
`
`
`v.
`
`
`FACEBOOK, INC. and FACEBOOK
`TECHNOLOGIES, LLC,
`
`
`Case No. 6:21-cv-00755-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`Defendants.
`
`
`
`
`
`UNOPPOSED MOTION FOR ENTRY OF AGREED
`AMENDED SCHEDULING ORDER
`
`Defendants Meta Platforms, Inc.1 and Facebook Technologies, LLC (collectively, “Meta”
`
`or “Defendants”) move for entry of the Agreed Amended Scheduling Order (the “Agreed Order”)
`
`detailed below. Plaintiffs Gentex Corporation and Indigo Technologies, LLC (collectively,
`
`“Gentex” or “Plaintiffs”) do not oppose this motion. The requested and agreed upon changes to
`
`the existing Scheduling Order are, as follows:
`
`The Agreed Order modifies the date for the opening brief and shifts the deadline for the
`
`ensuing submissions, as follows: (a) providing a six-day extension for the Opening Claim
`
`Construction brief; (b) shifting the deadline for each ensuing brief by one-week, and (c) providing
`
`a five-day extension for the Parties to submit the Joint Claim Construction Statement. The Parties
`
`
`1
`Effective October 28, 2021, Facebook, Inc. changed its name to Meta Platforms, Inc. Dkt.
`26.
`
`
`
`
`Case 6:21-cv-00755-ADA Document 37 Filed 02/17/22 Page 2 of 3
`
`have agreed that neither Defendants nor Plaintiffs will submit a technical tutorial. The
`
`modifications do not impact the Markman hearing set for April 25, 2022.
`
`For these reasons, Defendants request the Court enter the Agreed Amended Scheduling
`
`Order shown below:
`
`Deadline
`
`Defendants file Opening claim
`construction
`brief,
`including
`indefinite terms.
`
`Plaintiffs file Responsive claim
`construction brief.
`
`Current
`
`Amended Schedule
`
`Tuesday, Feb. 22 Monday, Feb. 28
`
`Monday, Mar. 14 Monday, Mar. 21
`
`file Reply
`Defendants
`construction brief.
`
`claim
`
`Monday, Mar. 28 Monday, Apr. 4
`
`Plaintiffs file a Sur-Reply claim
`construction brief.
`
`Joint Claim
`submit
`Parties
`Construction Statement
`
`Parties submit optional technical
`tutorials to the Court and technical
`adviser (if appointed).
`
`Monday, Apr. 11 Monday, Apr. 18
`
`Thursday, Apr. 14 Tuesday, Apr. 19
`
`Monday, Apr. 18 Parties agree to no
`technical tutorials
`
`Markman Hearing
`
`Monday, Apr. 25 No change
`
`
`
`
`
`
`Dated: February 17, 2022
`
`AGREED:
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Paige Arnette Amstutz
`Paige Arnette Amstutz
`Texas State Bar No. 00796136
`SCOTT, DOUGLASS & MCCONNICO, LLP
`303 Colorado Street, Suite 2400
`Austin, TX 78701
`Tel: (512) 495-6300
`Fax: (512) 495-6399
`pamstutz@scottdoug.com
`
`
`
`Case 6:21-cv-00755-ADA Document 37 Filed 02/17/22 Page 3 of 3
`
`
`
`Jeannie Heffernan (admitted)
`Bailey Morgan Watkins (TX Bar No. 24102244)
`KIRKLAND & ELLIS LLP
`401 Congress Avenue
`Austin, TX 78701
`Tel: (512) 678-9100
`Fax: (512) 678-9101
`jeannie.heffernan@kirkland.com
`bailey.watkins@kirkland.com
`
`Ellisen Shelton Turner (pro hac vice)
`Joshua Glucoft (admitted)
`KIRKLAND & ELLIS LLP
`2049 Century Park East, Suite 3700
`Los Angeles, CA 90067
`Tel: (310) 552-4200
`Fax: (310) 552-5900
`ellisen.turner@kirkland.com
`josh.glucoft@kirkland.com
`
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Tel: (415) 439-1400
`Fax: (415) 439-1500
`akshay.deoras@kirkland.com
`
`Counsel for Defendants Meta Platforms, Inc. and
`Facebook Technologies, LLC
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to the Federal Rules of Civil Procedure, I hereby certify that, on February 17,
`
`2022, all counsel of record who have appeared in this case are being served with a copy of the
`
`foregoing via the Court’s CM/ECF system.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Paige Arnette Amstutz
`Paige Arnette Amstutz
`
`
`
`
`
`
`
`
`
`
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