Case 3:14-cv-00757-REP-DJN Document 96-3 Filed 04/21/15 Page 1 of 6 PageID# 15336
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`Exhibit C
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`Parties’ Proposed Pre-Trial and Trial Schedule for
`NVIDIA’s Counterclaims against Samsung
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`Exhibit C
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`Parties’ Proposed Pre-Trial and Trial Schedule for
`NVIDIA’s Counterclaims against Samsung
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`Case 3:14-cv-00757-REP-DJN Document 96-3 Filed 04/21/15 Page 2 of 6 PageID# 15337
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`
`Event
`
`File Protective Order
`
`Deadline to Provide
`Initial Infringement
`Contentions
`
`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
`
`Dates for Counterclaims on Four NVIDIA Patents
`NVIDIA’s Proposed Dates
`Samsung’s 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
`
`April 24, 2015
`
`May 28, 2015
`
`May 28, 2015
`
`June 24, 2015
`
`May 22, 2015
`
`July 1, 2015
`
`May 29, 2015
`
`July 8, 2015
`
`April 21, 2015
`
`June 4, 2015
`
`48 total claims, no limit per
`patent
`
`32 total claims, limit 10 per
`patent
`
`June 5, 2015
`
`July 15, 2015
`
`May 27, 2015
`
`
`
`2
`
`
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`Case 3:14-cv-00757-REP-DJN Document 96-3 Filed 04/21/15 Page 3 of 6 PageID# 15338
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`
`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
`
`Dates for Counterclaims on Four NVIDIA Patents
`NVIDIA’s Proposed Dates
`Samsung’s Proposed
`Dates
`
`June 8, 2015
`
`July 22, 2015
`
`June 10, 2015
`
`July 29, 2015
`
`60 total references, limit 12
`per patent
`
`40 total references, limit 12
`per patent
`
`June 12, 2015
`
`August 3, 2015
`
`Tutorial
`
`On or about June 17, 2015
`
`On or about August 5, 2015
`
`Opening Claim
`Construction Brief
`
`Responsive Claim
`Construction Brief
`
`June 19, 2015
`
`August 12, 2015
`
`June 26, 2015
`
`August 19, 2015
`
`Markman Hearing
`
`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 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
`
`Second Invalidity
`Reference Selection
`
`30 total references, limit
`6 per patent
`
`7 days after NVIDIA’s
`Second Election of Asserted
`Claims
`
`7 days after NVIDIA’s
`Second Election of Asserted
`Claims
`
`30 total references, limit 6
`per patent
`
`20 total references, limit 6
`per patent
`
`
`
`3
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`
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`Case 3:14-cv-00757-REP-DJN Document 96-3 Filed 04/21/15 Page 4 of 6 PageID# 15339
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`
`Event
`
`Exchange initial expert
`reports
`
`Exchange rebuttal expert
`reports
`
`Conclusion of all
`discovery, including
`expert discovery and
`expert depositions
`
`Deadline for filing
`Summary Judgment
`Motions
`
`Dates for Counterclaims on Four NVIDIA Patents
`NVIDIA’s Proposed Dates
`Samsung’s Proposed
`Dates
`November 20, 2015
`
`September 18, 2015
`
`October 9, 2015
`
`December 11, 2015
`
`October 30, 2015
`
`January 29, 2016
`
`November 5, 2015
`
`February 4, 2016
`
`Motions in Limine
`
`November 10, 2015
`
`February 9, 2016
`
`Opposition to Motions in
`Limine
`
`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)
`
`Replies in support of
`Motions in Limine
`
`Plaintiff’s Witness Call
`List to be Filed
`
`Plaintiff’s Proposed
`Exhibit List Due
`
`Plaintiff’s Exhibits to be
`Delivered to Opposing
`Counsel
`
`November 18, 2015
`
`February 22, 2016
`
`(24 days before pretrial)
`
`(21 days before pretrial)
`
`November 25, 2015
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`February 29, 2016
`
`(18 days before pretrial)
`
`(18 days before pretrial)
`
`(18 days before pretrial)
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`
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`4
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`Case 3:14-cv-00757-REP-DJN Document 96-3 Filed 04/21/15 Page 5 of 6 PageID# 15340
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`
`Event
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`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
`
`Proposed Jury
`Instructions and
`Proposed Verdict Form
`Due to Clerk
`
`Confer to Resolve
`Objections to Discovery
`Designations
`
`Objections to Proposed
`Jury Instructions Due
`
`Dates for Counterclaims on Four NVIDIA Patents
`NVIDIA’s Proposed Dates
`Samsung’s Proposed
`Dates
`(16 days before pretrial)
`
`(16 days before pretrial)
`
`(16 days before pretrial)
`
`(15 days before pretrial)
`
`(14 days before pretrial)
`
`December 2, 2015
`
`March 2, 2016
`
`(12 days before pretrial)
`
`(11 days before pretrial)
`
`(11 days before pretrial)
`
`(10 days before pretrial)
`
`(9 days before pretrial)
`
`(7 days before pretrial)
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`
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`5
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`Case 3:14-cv-00757-REP-DJN Document 96-3 Filed 04/21/15 Page 6 of 6 PageID# 15341
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`
`Event
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`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
`
`Jury Selection
`
`Trial
`
`Dates for Counterclaims on Four NVIDIA Patents
`NVIDIA’s Proposed Dates
`Samsung’s Proposed
`Dates
`
`(7 days before pretrial)
`
`(5 days before pretrial)
`
`(4 days before pretrial)
`
`(4 days before pretrial)
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`(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
`
`January 7, 2016 at 9:30 AM On or about April 7, 2016
`
`January 11, 2016 at 9:30
`AM
`
`On or about April 11, 2016
`
`
`
`
`
`6
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