Case 6:22-cv-00466-ADA-DTG Document 78 Filed 07/31/23 Page 1 of 4
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`
`Case No. 6:22-cv-00466-ADA-DTG
`
`
`
`
`Jury Trial Demanded
`
`
`Advanced Silicon Technologies LLC,
`
`
`Plaintiff,
`
`v.
`
`NXP Semiconductors N.V.,
`NXP B.V., and
`NXP USA, Inc.,
`
`
`Defendants.
`
`
`
`
`Joint Motion to Amend Scheduling Order (ECF No. 45)
`
`Plaintiff Advanced Silicon Technologies LLC and Defendant NXP USA, Inc. have
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`conferred and jointly move to amend the Scheduling Order (ECF No. 45) to extend the remaining
`
`deadlines in the Scheduling Order by approximately 60 days, as outlined below.
`
`The parties request this extension to allow for the completion of domestic and foreign party
`
`and third-party discovery and corresponding amendments to the parties' infringement and
`
`invalidity contentions without the risk of requiring supplemental expert reports. The parties also
`
`request this additional time to continue discussions aimed at streamlining the issues to be decided
`
`here and reducing the overall number of remaining documents to be produced and witnesses to be
`
`produced, thereby making discovery more efficient overall.
`
`
`
`
`
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`1
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`
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Case No. 6:22-cv-00466-ADA-DTG
`
`
`
`
`Jury Trial Demanded
`
`
`Advanced Silicon Technologies LLC,
`
`
`Plaintiff,
`
`v.
`
`NXP Semiconductors N.V.,
`NXP B.V., and
`NXP USA, Inc.,
`
`
`Defendants.
`
`
`
`
`Joint Motion to Amend Scheduling Order (ECF No. 45)
`
`Plaintiff Advanced Silicon Technologies LLC and Defendant NXP USA, Inc. have
`
`conferred and jointly move to amend the Scheduling Order (ECF No. 45) to extend the remaining
`
`deadlines in the Scheduling Order by approximately 60 days, as outlined below.
`
`The parties request this extension to allow for the completion of domestic and foreign party
`
`and third-party discovery and corresponding amendments to the parties' infringement and
`
`invalidity contentions without the risk of requiring supplemental expert reports. The parties also
`
`request this additional time to continue discussions aimed at streamlining the issues to be decided
`
`here and reducing the overall number of remaining documents to be produced and witnesses to be
`
`produced, thereby making discovery more efficient overall.
`
`
`
`
`
`
`
`1
`
`
`
`Case 6:22-cv-00466-ADA-DTG Document 78 Filed 07/31/23 Page 2 of 4
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`The proposed extensions are as follows:
`
`Event
`
`Current Date
`
`New Date
`
`First case narrowing meet and confer deadline
`
`July 31, 2023
`
`September 29, 2023
`
`Close of fact discovery
`
`Opening expert reports
`
`Rebuttal expert reports
`
`August 28, 2023
`
`October 27, 2023
`
`September 11, 2023 November 9, 2023
`
`October 9, 2023
`
`December 8, 2023
`
`Close of expert discovery
`
`October 23, 2023 December 22, 2023
`
`Second case narrowing meet and confer deadline
`
`October 30, 2023 December 29, 2023
`
`Dispositive and Daubert motion deadline
`
`November 6, 2023
`
`January 12, 2024
`
`Oppositions to dispositive and Daubert motions November 20, 2023
`
`January 26, 2024
`
`Serve pretrial disclosures
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`November 20, 2023
`
`January 26, 2024
`
`File replies in support of dispositive
`and Daubert motions
`
`Serve objections to pretrial disclosures
`and rebuttal disclosures
`
`Parties jointly email law clerks to confirm
`pretrial conference and trial dates
`
`Serve objections to rebuttal disclosures;
`file motions in limine
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`November 27, 2023
`
`February 2, 2024
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`December 4, 2023
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`February 9, 2024
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`December 4, 2023
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`February 9, 2024
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`December 11, 2023
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`February 16, 2024
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`File joint pretrial order, pretrial submissions, and
`oppositions to motions in limine
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`December 18, 2023
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`February 23, 2024
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`File notice of request for daily transcript
`or real time reporting
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`December 29, 2023
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`March 8, 2024
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`File joint notice identifying remaining objections
`to pretrial disclosures and motions in limine
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`January 5, 2023
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`March 15, 2024
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`Final pretrial conference
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`January 8, 2024
`
`March 28, 2024
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`Jury selection/trial
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`January 29, 2024
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`April 8, 2024
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`2
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`Case 6:22-cv-00466-ADA-DTG Document 78 Filed 07/31/23 Page 3 of 4
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`For these reasons, the parties jointly request that the Court enter the above modifications
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`Respectfully submitted,
`
`By: /s/ Richard S. Zembek
`
`Richard S. Zembek (SBN 00797726)
`richard.zembek@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`Fulbright Tower
`1301 McKinney, Suite 5100
`Houston, Texas 77010-3095
`Tel: (713) 651-5151
`Fax: (713) 651-5246
`
`Eric C. Green (SBN 24069824)
`Eric.green@nortonrosefulbright.com
`Catherine Garza (SBN 24073318)
`Cat.garza@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`98 San Jacinto Boulevard, Suite 1100
`Austin, Texas 78701
`Tel: (512) 474-5201
`Fax: (512) 536-4598
`
`Counsel for Defendant NXP USA, Inc.
`
`to the Scheduling Order.
`
`Dated: July 31, 2023
`
`
`
`By: /s/ Patrick A. Fitch
`
`
`Brian A. Carpenter (State Bar No. 3840600)
`
`carpenter@caglaw.com
`Carstens, Allen & Gourley, LLP
`1105 Wooded Acres, Suite 415
`Waco, Texas 76701
`(254) 294-1854 (Telephone)
`
`
`Robert R. Brunelli (admitted pro hac vice)
`
`rbrunelli@sheridanross.com
`Patrick A. Fitch (admitted pro hac vice)
`
`pfitch@sheridanross.com
`Alex W. Ruge (admitted pro hac vice)
`
`aruge@sheridanross.com
`Brian Boerman (admitted pro hac vice)
`
`bboerman@sheridanross.com
`Angela J. Bubis (admitted pro hac vice)
`abubis@sheridanross.com
`Briana D. Long (admitted pro hac vice)
`blong@sheridanross.com
`Sheridan Ross P.C.
`1560 Broadway, Suite 1200
`Denver, Colorado 80202
`(303) 863-9700 (Telephone)
`(303) 863-0223 (Facsimile)
`litigation@sheridanross.com
`
`Attorneys for Plaintiff
`Advanced Silicon Technologies LLC
`
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`3
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`Case 6:22-cv-00466-ADA-DTG Document 78 Filed 07/31/23 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 31, 2023, I electronically filed the foregoing with the Clerk of
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`Court using the CM/ECF system which will send notification of such filing to all counsel of record
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`in the above-referenced matter.
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`/s/ Thomas J. Armento
`Thomas J. Armento
`Paralegal
`tarmento@sheridanross.com
`Sheridan Ross P.C.
`1560 Broadway, Suite 1200
`Denver, Colorado 80202
`(303) 863-9700 (Telephone)
`(303) 863-0223 (Facsimile)
`litigation@sheridanross.com
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`4
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