Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 1 of 8 PageID# 15328
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`
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`Exhibit B
`
`Parties’ Proposed Pre-Trial Schedule (All Claims)
`
`
`
`
`
`
`
`
`
`Exhibit B
`
`Parties’ Proposed Pre-Trial Schedule (All Claims)
`
`
`
`
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`
`
`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 2 of 8 PageID# 15329
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`
`
`
`Event
`
`Dates for 8
`Samsung Patents
`
`File Protective Order
`
`Deadline to Provide Initial
`Infringement Contentions
`
`April 21, 2015
`
`Dates for 4 NVIDIA Patents
`NVIDIA’s
`Samsung’s
`Proposed Dates
`Proposed Dates
`April 20, 2015
`
`April 21, 2015
`
`June 4, 2015
`
`48 total claims, no
`limit per patent
`
`32 total claims,
`limit 10 per patent
`
`Rule 26(a)(1) Initial
`Disclosures
`
`Deadline to produce
`documents sufficient to
`show the operation of the
`accused instrumentalities
`(to the extent such
`documents are in
`Defendants’ possession,
`custody, or control)
`
`Deadline to Provide
`Invalidity Contentions
`
`Exchange List of Proposed
`Claim Terms for
`Construction
`
`First Asserted Claim
`Selection
`
`
`
`Exchange Revised List of
`Proposed Claim Terms for
`Construction
`
`Deadline for Parties to
`Discuss Settlement and
`Report to Court regarding
`Same
`
`April 24, 2015
`
`April 24, 2015
`
`May 28, 2015
`
`May 13, 2015
`
`May 28, 2015
`
`June 24, 2015
`
`May 8, 2015
`
`May 22, 2015
`
`July 1, 2015
`
`May 15, 2015
`
`May 29, 2015
`
`July 8, 2015
`
`May 20, 2015
`
`48 total claims, 10
`claims per patent
`
`
`April 21, 2015
`
`June 4, 2015
`
`48 total claims, no
`limit per patent
`
`32 total claims,
`limit 10 per patent
`
`May 22, 2015
`
`June 5, 2015
`
`July 15, 2015
`
`May 27, 2015
`
`
`
`
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`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 3 of 8 PageID# 15330
`
`
`Event
`
`Exchange proposed
`constructions for claim
`terms on the revised lists of
`claim terms for
`construction and supporting
`evidence for those
`constructions
`
`First Invalidity Reference
`Selection
`
`
`
`Exchange and File Final
`Constructions
`
`Tutorial
`
`Opening Claim
`Construction Brief
`
`Responsive Claim
`Construction Brief
`
`Markman Hearing
`
`Dates for 8
`Samsung Patents
`
`Dates for 4 NVIDIA Patents
`NVIDIA’s
`Samsung’s
`Proposed Dates
`Proposed Dates
`
`May 25, 2015
`
`June 8, 2015
`
`July 22, 2015
`
`May 27, 2015
`
`June 10, 2015
`
`July 29, 2015
`
`60 total references,
`limit 12 per patent
`
`60 total references,
`limit 12 per patent
`
`40 total references,
`limit 12 per patent
`
`May 29, 2015
`
`June 12, 2015
`
`August 3, 2015
`
`June 3, 2015 at
`10:00 AM
`
`On or about June
`17, 2015
`
`On or about
`August 5, 2015
`
`June 5, 2015
`
`June 19, 2015
`
`August 12, 2015
`
`June 12, 2015
`
`June 26, 2015
`
`August 19, 2015
`
`June 22, 2015 at
`10:00 AM
`
`On or about July 6,
`2015
`
`On or about
`August 26, 2015
`
`Second Asserted Claim
`Selection and Amended
`Infringement Contentions
`
`24 total claims, limit 5 per
`patent
`
`7 days after the
`Court issues its
`Claim
`Construction Order
`
`7 days after the
`Court issues its
`Claim
`Construction Order
`on Counterclaim
`Patents
`
`7 days after the
`Court issues its
`Claim
`Construction Order
`on Counterclaim
`Patents
`
`24 total claims,
`limit 5 per patent
`
`16 total claims,
`limit 5 per patent
`
`2
`
`
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`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 4 of 8 PageID# 15331
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`
`Event
`
`Dates for 8
`Samsung Patents
`
`Second Invalidity
`Reference Selection
`
`30 total references, limit 6
`per patent
`
`7 days after
`Samsung’s Second
`Election of
`Asserted Claims
`
`Dates for 4 NVIDIA Patents
`NVIDIA’s
`Samsung’s
`Proposed Dates
`Proposed Dates
`7 days after
`7 days after
`NVIDIA’s Second
`NVIDIA’s Second
`Election of
`Election of
`Asserted Claims
`Asserted Claims
`
`30 total references,
`limit 6 per patent
`
`20 total references,
`limit 6 per patent
`
`Exchange initial expert
`reports
`
`September 18,
`2015
`
`September 18,
`2015
`
`October 9, 2015
`
`October 9, 2015
`
`November 20,
`2015
`
`December 11,
`2015
`
`Exchange rebuttal expert
`reports
`
`Conclusion of all
`discovery, including expert
`discovery and expert
`depositions
`
`Deadline for filing
`Summary Judgment
`Motions
`
`Motions in Limine
`
`October 30, 2015
`
`October 30, 2015
`
`January 29, 2016
`
`November 5, 2015 November 5, 2015 February 4, 2016
`
`November 10,
`2015
`
`Opposition to Motions in
`Limine
`
`November 18,
`2015
`
`Written Stipulations of
`Uncontroverted Facts Meet
`and Confer
`
`List of All Discovery
`Materials to be Offered at
`Trial to be Served (Includes
`Deposition Designations
`and Summaries of Same)
`
`November 10,
`2015
`
`November 18,
`2015
`
`February 9, 2016
`
`February 22, 2016
`
`(24 days before pretrial)
`
`(21 days before pretrial)
`
`Replies in support of
`Motions in Limine
`
`November 25,
`2015
`
`November 25,
`2015
`
`February 29, 2016
`
`3
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 5 of 8 PageID# 15332
`
`
`Event
`
`Plaintiff’s Witness Call List
`to be Filed
`
`Plaintiff’s Proposed Exhibit
`List Due
`
`Plaintiff’s Exhibits to be
`Delivered to Opposing
`Counsel
`
`Defendants’ Witness Call
`List to be Filed
`
`Defendants’ Proposed
`Exhibit List Due
`
`Defendants’ Exhibits to be
`Delivered to Opposing
`Counsel
`
`Summary Judgment
`Hearing, if desired
`
`Rebuttal Designations and
`Amended Summaries to be
`Served
`
`Hearing on Motions in
`Limine (if desired)
`
`Objections to Exhibits to be
`Filed with Clerk
`
`Written stipulations of
`uncontroverted facts signed
`by Counsel and Filed with
`Clerk
`
`Any Objection to
`Designations Due
`
`Dates for 8
`Samsung Patents
`
`Dates for 4 NVIDIA Patents
`NVIDIA’s
`Samsung’s
`Proposed Dates
`Proposed Dates
`(18 days before pretrial)
`
`(18 days before pretrial)
`
`(18 days before pretrial)
`
`(16 days before pretrial)
`
`(16 days before pretrial)
`
`(16 days before pretrial)
`
`(15 days before pretrial)
`
`(14 days before pretrial)
`
`December 2, 2015 December 2, 2015 March 2, 2016
`
`(12 days before pretrial)
`
`(11 days before pretrial)
`
`(11 days before pretrial)
`
`4
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`
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`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 6 of 8 PageID# 15333
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`
`Dates for 8
`Samsung Patents
`
`Dates for 4 NVIDIA Patents
`NVIDIA’s
`Samsung’s
`Proposed Dates
`Proposed Dates
`
`(10 days before pretrial)
`
`(9 days before pretrial)
`
`(7 days before pretrial)
`
`(7 days before pretrial)
`
`(5 days before pretrial)
`
`(4 days before pretrial)
`
`(4 days before pretrial)
`
`(3 days before pretrial)
`
`(2 days before pretrial)
`
`(1 day before pretrial)
`
`December 15,
`2015 at 10:00 AM
`
`On or about March
`15, 2016
`
`Event
`
`Proposed Jury Instructions
`and Proposed Verdict Form
`Due to Clerk
`
`Confer to Resolve
`Objections to Discovery
`Designations
`
`Objections to Proposed
`Jury Instructions Due
`
`Proposed Voir Dire Due to
`Clerk and Delivered to
`Opposing Counsel
`
`Filing of Discovery
`Designations (Conformed
`Version) to Opposing
`Counsel, Clerk and the
`Court
`
`Consolidated and Agreed to
`Jury Instructions Due
`
`Set of Disputed Instructions
`with Brief Statement of
`Reasons of Dispute Due
`
`Objections to Voir Dire
`Filed
`
`Summaries of Deposition
`Testimony to which No
`Objection Has Been Made
`to Be Filed with Clerk
`
`Exhibits to Be Delivered to
`Clerk (Two Sets, Pre-
`Marked, Indexed)
`Final Pre-Trial Conference December 15,
`2015 at 10:00 AM
`
`5
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 7 of 8 PageID# 15334
`
`
`Event
`
`Jury Selection
`
`Trial
`
`Dates for 8
`Samsung Patents
`
`January 7, 2016 at
`9:30 AM
`
`Dates for 4 NVIDIA Patents
`NVIDIA’s
`Samsung’s
`Proposed Dates
`Proposed Dates
`January 7, 2016 at
`On or about April
`9:30 AM
`7, 2016
`
`January 11, 2016
`at 9:30 AM
`
`January 11, 2016
`at 9:30 AM
`
`On or about April
`11, 2016
`
`6
`
`
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`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 8 of 8 PageID# 15335
`Case 3:14-cv-00757-REP-DJN Document 96-2 Filed 04/21/15 Page 8 of 8 Page|D# 15335
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