Case 6:22-cv-00466-ADA-DTG Document 87 Filed 10/26/23 Page 1 of 4
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Advanced Silicon Technologies LLC,
`
`v.
`
`Plaintiff,
`
`NXP Semiconductors N.V.,
`NXP B.V., and
`NXP USA, Inc.,
`
`
`Civil Action No. 6:22-cv-00466-ADA-DTG
`
`
`
`
`Jury Trial Demanded
`
`
`
`Defendants.
`
`
`Joint Motion to Amend First Amended Scheduling Order (ECF No. 79)
`
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`Plaintiff Advanced Silicon Technologies LLC and Defendant NXP USA, Inc. have
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`conferred and jointly move to amend the First Amended Scheduling Order (ECF No. 79) to extend
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`the remaining deadlines in the Scheduling Order as outlined below.
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`The parties request this extension to allow for the completion of domestic and third-party
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`discovery and corresponding amendments to the parties' infringement and invalidity contentions
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`without the risk of requiring supplemental expert reports. The parties also request this additional
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`time to continue discussions aimed at streamlining the issues to be decided here and reducing the
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`overall number of remaining documents to be produced and witnesses to be produced, thereby
`
`making discovery more efficient overall.
`
`The proposed extensions are as follows:
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`
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`1
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Advanced Silicon Technologies LLC,
`
`v.
`
`Plaintiff,
`
`NXP Semiconductors N.V.,
`NXP B.V., and
`NXP USA, Inc.,
`
`
`Civil Action No. 6:22-cv-00466-ADA-DTG
`
`
`
`
`Jury Trial Demanded
`
`
`
`Defendants.
`
`
`Joint Motion to Amend First Amended Scheduling Order (ECF No. 79)
`
`
`Plaintiff Advanced Silicon Technologies LLC and Defendant NXP USA, Inc. have
`
`conferred and jointly move to amend the First Amended Scheduling Order (ECF No. 79) to extend
`
`the remaining deadlines in the Scheduling Order as outlined below.
`
`The parties request this extension to allow for the completion of domestic 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.
`
`The proposed extensions are as follows:
`
`
`
`1
`
`
`
`Case 6:22-cv-00466-ADA-DTG Document 87 Filed 10/26/23 Page 2 of 4
`
`Event
`
`Current Date
`
`New Proposed
`Date
`January 26, 2024
`October 27, 2023
`Close of fact discovery
`February 8, 2024
`November 9, 2023
`Opening expert reports
`March 8, 2024
`December 8, 2023
`Rebuttal expert reports
`December 22, 2023 March 22, 2024
`Close of expert discovery
`Second case narrowing meet and confer deadline December 29, 2023 March 29, 2024
`Dispositive and Daubert motion deadline
`January 12, 2024
`April 12, 2024
`Oppositions to dispositive and Daubert motions
`January 26, 2024
`April 26, 2024
`Serve pretrial disclosures
`January 26, 2024
`April 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
`File joint pretrial order, pretrial submissions, and
`oppositions to motions in limine
`File notice of request for daily transcript
`or real time reporting;
`Deadline to file replies to motions in limine
`File joint notice identifying remaining objections
`to pretrial disclosures and motions in limine
`Final pretrial conference
`Jury selection/trial
`
`February 2, 2024
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`May 3, 2024
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`February 9, 2024
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`May 10, 2024
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`February 9, 2024
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`May 10, 2024
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`February 16, 2024
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`May 17, 2024
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`February 23, 2024
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`May 24, 2024
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`March 8, 2024
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`June 7, 2024
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`March 15, 2024
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`June 14, 2024
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`March 28, 2024
`April 8, 2024
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`June 27, 2024
`July 8, 2024
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`2
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`Case 6:22-cv-00466-ADA-DTG Document 87 Filed 10/26/23 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/ Eric C. Green
`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: October 26, 2023
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`
`
`
`
`
`
`By: /s/ Patrick A. Fitch
`
`Brian A. Carpenter (State Bar No. 3840600)
`
`carpenter@caglaw.com
`Carstens, Allen & Gourley, LLP
`7500 Dallas Parkway, Suite 300
`Plano, Texas 75024
`(972) 367-2001 (Telephone)
`
`
`Robert R. Brunelli (admitted pro hac vice)
`
`rbrunelli@sheridanross.com
`Patrick A. Fitch (admitted pro hac vice)
`
`pfitch@sheridanross.com
`Paul S. Cha (admitted pro hac vice)
`
`pscha@sheridanross.com
`Brian S. Boerman (admitted pro hac vice)
`
`bboerman@sheridanross.com
`Bart A. Starr (admitted pro hac vice)
`
`bstarr@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 87 Filed 10/26/23 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on October 26, 2023, I electronically filed the foregoing with the Clerk
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`of Court using the CM/ECF system which will send notification of such filing to all counsel of
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`record in the above-referenced matter.
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`/s/ Lori R. Brown
`Lori R. Brown
`Paralegal
`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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