Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 1 of 17
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`THE HONORABLE JAMES L. ROBART
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF WASHINGTON
`SEATTLE DIVISION
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` CASE NO. 2:17-cv-00932-JLR
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`JOINT STATUS REPORT AND
`DISCOVERY PLAN
`
`JURY TRIAL DEMANDED
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`CYWEE GROUP LTD.,
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` Plaintiff,
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`HTC CORPORATION
`and
`HTC AMERICA, INC.,
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` Defendants.
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 1
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

`

`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 2 of 17
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`Pursuant to Federal Rule of Civil Procedure 26(f), Local Civil Rules 16 and 26(f), this
`Court’s Order regarding Initial Disclosures, Joint Status Report and Early Settlement dated
`September 18, 2017 and extended by Order entered September 26, 2017, and pursuant to Local
`Patent Rule (“LPR”) 110, the following Joint Status Report and Discovery Plan is submitted by
`Plaintiff CyWee Group Ltd. (“CyWee” or “Plaintiff”) and Defendants HTC Corporation and
`HTC America, Inc. (collectively, “HTC” or “Defendants”).
`1. NATURE AND COMPLEXITY OF THE CASE
`CyWee accused HTC of infringing U.S. Patent Nos. 8,441,438 (“the ’438 Patent”) and
`8,552,978 (“the ’978 Patent”) (collectively, the “Asserted Patents.”). The claims of the patents-
`in-suit require, inter alia, sensor fusion in which information is combined from different sensors.
`More specifically, the ’438 Patent requires an accelerometer and gyroscope, while the ’978
`Patent additionally requires a magnetometer. CyWee accuses several HTC smartphones
`incorporating such sensors of infringing the patents-in-suit, including the HTC One M9, HTC
`One A9, HTC 10, HTC Bolt, and HTC U Ultra. CyWee accused HTC of directly infringing the
`patents-in-suit and also of inducing infringement of those patents. HTC filed a motion to dismiss
`(Dkt. 35), in which it seeks to dismiss CyWee’s allegations of induced infringement.
`HTC has not yet filed its answer to the complaint. Among other defense, HTC believes
`that to the extent the accused products incorporate devices that allegedly practice one or more of
`the Asserted Patents, those devices were sold to HTC by CyWee’s licensees, ST Microelectronic.
`HTC further believes that the authorized sale of these devices with CyWee’s technology and
`software that allegedly embody the Asserted Patents by CyWee’s licensee to HTC exhausts
`CyWee’s patent rights in those products.
`2. PROPOSED DEADLINE FOR JOINING ADDITIONAL PARTIES
`The parties propose a deadline for joining additional parties to be set at 75 days after the
`filing of Defendants’ answer to the complaint.
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 2
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 3 of 17
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`3. CONSENT TO MAGISTRATE
`The parties have not consented to have this case heard by a Magistrate Judge.
`4. DISCOVERY PLAN
`A. Initial Disclosures
`The Rule 26(f) conference was conducted on November 1, 2017. The Rule 26(a) initial
`disclosures were made on November 16, 2016.
`B. Subjects, Timing and Potential Phasing of Discovery
`The parties do not believe phasing of discovery is necessary, beyond the restrictions the
`Local Patent Rules impose. See LPR. 112.
`The Parties’ Joint Position: The parties do not believe discovery should be bifurcated or
`phased, except as described herein. The parties submit the following agreed-upon proposed
`schedule, which deviates slightly from the deadlines contained in the Court’s Standing Rules for
`Patent Cases, due to the length of time before trial and the needs of the parties:
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 3
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 4 of 17
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`Deadline
`Preliminary Infringement Contentions
`and Disclosure of Asserted Claims (LPR
`120)
`Preliminary Non-Infringement and
`Invalidity Contentions (LPR 121)
`Proposed Terms and Claim Elements for
`Construction (LPR 130(a))
`Preliminary Claim Constructions and
`Extrinsic Evidence (LPR 131(a), (b))
`Expert Witness Report on Markman (if
`necessary)
`Rebuttal Expert Witness Report on
`Markman (if necessary)
`Joint Claim Construction Chart and
`Prehearing Statement (LPR 132(a))
`Completion of Claim Construction
`Discovery
`Opening Markman Briefs
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`Response Markman Briefs
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`Markman Hearing
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`Close of Fact Discovery
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`Parties Serve Opening Expert Reports
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`Parties Serve Rebuttal Expert Reports
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`Close of Expert Discovery
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`Last Day to File Dispositive Motions
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`Motions in Limine
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`Agreed Pretrial Order
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`Trial briefs, proposed voir dire questions,
`proposed jury instruction
`Pretrial Conference
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`Trial (Parties propose 7-8 Jury Days)
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`Proposed Schedule
`Tuesday, January 9, 2018
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`Tuesday, January 30, 2018
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`Monday, February 26, 2018
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`Monday, March 26, 2018
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`Thursday, April 26, 2018
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`Thursday, May 24, 2017
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`Thursday, June 7, 2018
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`Thursday, June 14, 2018
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`Thursday, June 21, 2018
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`Tuesday, July 17, 2018
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`At Court’s convenience on or
`after Thursday, August 2, 2018
`Thursday, September 6, 2018
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`Thursday, October 4, 2018
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`Thursday, October 25, 2018
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`Monday, December 3, 2018
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`Friday, December 14, 2018
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`Friday, January 11, 2019
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`Monday, January 21, 2019
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`Thursday, January 31, 2019
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`Thursday, February 14, 2019
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`Monday, March 4, 2019
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 4
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 5 of 17
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`C. Electronically Stored Information
`The parties intend to adopt modified versions of the Court’s Model Agreement Regarding
`Discovery of Electronically Stored Information and of the Court’s Model Stipulated Protective
`Order.
`
`D. Privilege Issues
`The parties consent to the claw back agreement provided in the Court’s Model
`Agreement Regarding Discovery of Electronically Stored Information and Model Stipulated
`Protective Order.
`E. Proposed Limitations on Discovery
`The parties do not believe that there should be any limitations to discovery other than
`those set forth in the Federal Rules of Civil Procedure, the Local Rules, the Patent Local Rules,
`and the Orders of this Court except as noted below:
`The parties agree that the limits on depositions set forth in the Federal Rules of Civil
`Procedure shall govern depositions, except that, for each expert report served by an expert
`witness, the parties will be permitted one (1) day of seven (7) hours to depose said expert
`witness. By way of example, if a party designates a single expert to testify on the separate issues
`of infringement and invalidity, the opposing party will be permitted to depose that expert for one
`day of seven hours on each respective issue. The parties will negotiate in good faith regarding
`additional deposition time should any party reasonably believe that a specific need for additional
`time exists.
`A non-translated deposition will not go longer than seven (7) hours per day on the record
`on any given day, unless agreed to by the party being deposed, who shall not unreasonably
`withhold consent to allow additional time if needed to fairly examine the deponent and such
`additional time is no more than sixty (60) minutes. This seven-hour per day limitation does not
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 5
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 6 of 17
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`mean that a corporate representative who is designated on more than one topic will be limited to
`seven hours total time for his/her deposition.
`The parties agree that for depositions using an interpreter, time will be measured using a
`1.5x multiplier. For example, the seven-hour time limit will be increased to ten-and-a-half (10.5)
`hours for depositions with an interpreter, but will only count for seven (7) hours against the
`parties’ limitations on depositions.
`A party who serves a subpoena in this matter on a non-party shall, prior to or at the same
`time as serving on that non-party, provide a copy of the subpoena and all attachments thereto to
`the other party. A party who receives documents from a third party pursuant to a subpoena will
`reproduce those documents to the other party within five (5) business days. Where reproduction
`of documents within five (5) business days is not possible, the party who received the documents
`will provide prompt notice to the other party and will work in good faith to resolve the issue on a
`case-by-case basis. A party scheduling the deposition of a third party shall promptly notify the
`parties of the date and location of the deposition and make all best efforts to schedule any
`deposition of the third party no earlier than five (5) business days after the party scheduling the
`deposition provides the copies of any documents received from that third party, provided,
`however, the scheduling party shall not be obligated to reschedule a deposition if the third party
`produces documents within five (5) business days before the deposition.
`The parties agree to serve documents by email to counsel of record, or if the documents
`are voluminous, by FTP, Dropbox, or other internet file service. The parties will use best efforts
`to serve documents filed under seal by email, or if too voluminous, by FTP or other internet file
`service within an hour of filing.
`The parties agree that communications with a party’s expert witness will not be subject to
`discovery, but any information relied upon by an expert witness in forming an opinion will be
`discoverable.
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 6
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 7 of 17
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`Any party may later move to modify these limitations for good cause.
`F. The Need for Any Discovery Related Orders
`The parties intend to adopt modified version of the Court’s Model Stipulated Protective
`Order and Model Agreement Regarding Discovery of Electronically Stored Information as
`described in paragraph 4(C), above.
`5. THE PARTIES’ VIEWS, PROPOSALS, AND AGREEMENTS REGARDING
`RULE 26(f)(1)
`A. Prompt Case Resolution
`HTC believes that a business-to-business settlement meeting between party
`representatives may lead to a speedy case resolution. In addition, HTC believes that an early
`determination of whether the authorized sales of ST Microelectronics’ devices with CyWee’s
`technology and software incorporated in HTC’s accused products exhausts CyWee’s patent
`rights will lead to a prompt case resolution.
`B. Alternative Dispute Resolution
`The parties agree to private mediation, and will work to identify a mediator agreeable to
`all parties within forty-five (45) days following the Court’s issuance of the claim construction
`order, or earlier, with the corresponding report due within fifteen (15) days after the mediation.
`C. Related Cases
`Currently, there are five federal actions pending that bring claims on the Patents-in-Suit:
`CyWee Group Ltd. v. Motorola Mobility LLC, No. 1:17-cv-00780-GMS (D. Del. June 16, 2017);
`CyWee Group Ltd. v. Huawei Technologies Co., Inc. et al., No. 2:17-cv-00495-RWS-RSP (E.D.
`Tex. June 9, 2017); CyWee Group Ltd. v. Samsung Electronics Co, Ltd. et al., No. 2:17-cv-
`00140-RWS-RSP (E.D. Tex. Feb. 17, 2017); CyWee Group Ltd. v. LG Electronics, Inc. et al.,
`No. 3:17-cv-01102-BEN-RBB (S.D. Cal. May 31, 2017); CyWee Group Ltd. v. ZTE Corporation
`et al., No. 3:17-cv-02130-BEN-RBB (S.D. Cal. Oct. 17, 2017).
`
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 7
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 8 of 17
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`D. Discovery Management
`The parties agree to abide by the limitations on discovery imposed under the Federal
`Rules of Civil Procedure and Local Civil Rules, share discovery information obtained from third
`parties, and coordinate the schedule for depositions in advance of setting such dates.
`E. Anticipated Discovery Sought
`The parties intend to conduct discovery on infringement, validity, and damages. In
`addition to discovery on noninfringement, invalidity, and damages, HTC also intends to conduct
`discovery relating to its defenses, which will be known after HTC has filed its answer to the
`complaint.
`
`F. Phasing Motions
`Except as described here or in the Local Patent Rules, the parties do not currently believe
`that phasing motions, except as provided herein, will facilitate early resolution of potentially
`dispositive issues.
`G. Preservation of Discoverable Information
`The parties have not identified any issues relating to the preservation of discoverable
`information and the scope of the preservation obligation.
`H. Inadvertent Production/Privilege
`The parties have adopted the claw back provisions provided in the Court’s Model
`Agreement Regarding Discovery of Electronically Stored Information and Model Stipulated
`Protective Order.
`I. Model Protocol for Discovery of ESI
`The parties intend to adopt a modified version of the Court’s Model Agreement
`Regarding Discovery of Electronically Stored Information.
`In addition, the parties agree as follows:
`
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 8
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 9 of 17
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`General Electronically Stored Information (“ESI”) production under Federal Rules of
`Civil Procedure 34 and 45 shall not include email and similar forms of electronic correspondence
`(collectively, “email”). To obtain email, parties must propound specific email production
`requests in accordance to an e-discovery order agreed upon by the parties.
`The parties agree to search non-custodial central repositories, including central databases,
`or relevant portions thereof, using the same search terms to the extent that the party reasonably
`anticipates they contain non-duplicative responsive documents.
`Regarding the production of ESI, the parties agree that they will produce such
`information in an organized manner on CD, DVD or the like, or by FTP, Dropbox, or other
`internet file service. Voluminous productions will be made on CD, DVD, or the like. Each
`piece of production media shall identify a production number corresponding to the production
`volume (e.g., “VOL001,” “VOL002”), as well as the volume of the material in that production
`(e.g., “-001,” “-002”). Each piece of production media shall also identify: (1) The producing
`party’s name, (2) the production date, and (3) the Bates number range of the materials contained
`on the production media.
`ESI shall be produced as single-page TIFFs with appropriate Concordance and/or
`Summation load files (i.e., .DAT, .OPT, and .LOG files). The parties agree that they will
`provide or make available certain documents natively upon reasonable requests by the receiving
`party.
`
`Responsive documents in TIFF format will be stamped with the appropriate
`confidentiality designations in accordance with the protective order(s) in this matter. Each TIFF
`file should be one page and named according to the corresponding Bates number associated with
`the document. To the extent feasible, each responsive document produced in native format will
`have its confidentiality designation identified in the filename of the native file. Additionally, all
`ESI produced in a TIFF format will include appropriate confidentiality designation as provided
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 9
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 10 of 17
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`under the protective order(s) in this matter. Source code will be produced in accordance with the
`protective order(s) in this matter. The parties agree that the search terms will not be applied to
`source code.
`A party is only required to produce a single copy of a responsive document and a party
`may de-duplicate responsive ESI (based on MD5 or SHA-1 hash values at the document level)
`across custodians.
`In addition, to the extent possible, text files should be provided along with the image files
`for each document. Any optical character recognition (“OCR”) or text files created for use by
`the producing party shall be provided to the receiving party. The text of native files should be
`extracted directly from the native file. If a document has been redacted, however, or does not
`contain extractable text, OCR of the redacted document will suffice in lieu of extracted text.
`The parties further agree that each party will use its best efforts to filter out common
`system files and application executable files by using a commercially reasonable hash
`identification process.
`The parties identify the following accessible and inaccessible ESI as to the parties:
`a. Accessible ESI: Reasonably accessible sources of ESI include
`electronic documents stored on computer networks, hard drives,
`shared network drives, workstation or laptop hard drives, and
`portable drives/media, including external hard drives, zip drives,
`CD-ROM and DVD-ROM disks, and USB flash drives/jump
`drives. Each party will conduct a reasonably diligent search of
`those reasonably accessible sources in which it has reason to
`believe relevant, non-duplicative ESI responsive to discovery
`requests will be found.
`
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 10
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 11 of 17
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`b. Inaccessible ESI: Contingent on each party’s compliance with the
`obligations set forth in Paragraph 3(a), above, the parties agree that
`the circumstances of this case do not warrant the preservation,
`review, or production of the following ESI that is not reasonably
`accessible because: (1) It is unlikely that significant relevant
`information would be located in those sources that is not otherwise
`available from reasonably accessible sources and (2) the remote
`possibility of locating significant relevant information is
`substantially outweighed by the burden and cost of preservation
`and/or review and production of ESI from these sources:
`
` Voicemail;
`
`Instant messaging and text messaging;
` Residual, fragmented, damaged, permanently deleted slack and unallocated data;
` Data residing on mobile telephones and handheld PDA-type devices; and
` Metadata.
`The parties will meet and confer on whether the production of backup tapes, online
`archive, offline archive, and legacy data is warranted in this case due to the substantial burden
`associated with reviewing and locating significant relevant information in these sources.
`J. Alternatives to Model Protocol
`
`None.
`6. COMPLETION OF DISCOVERY
`The parties propose a deadline for completing discovery as set forth in Section 4.B,
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`above.
`7. BIFURCATION
`The parties do not believe that the case should be bifurcated.
`
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 11
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

`

`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 12 of 17
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`8. PRETRIAL STATEMENT
`The parties do not wish to dispense with pretrial statements or pretrial orders required by
`Local Civil Rules 16(e), (h), (i), and (k), and 16.1.
`9. INDIVIDUALIZED TRIAL PROGRAM
`The parties do not intend to utilize the Individualized Trial Program set forth in Local
`Civil Rule 39.2.
`10. OTHER SUGGESTIONS
`A. Service by Electronic Means
`The parties agree that courtesy copies of all documents, including motions, discovery
`requests and responses, shall be sent to one another via email (or FTP transfer), and that such
`transmission shall be accepted as service in accordance with Federal Rule of Civil Procedure
`5(b)(2)(E).
`11. TRIAL DATE
`The parties believe this case will be ready for trial on March 4, 2019.
`12. TRIAL BY JURY
`The parties have requested a jury trial.
`13. NUMBER OF TRIAL DAYS REQUIRED
`The parties believe that the duration of the trial will be seven (7) to eight (8) jury days.
`14. CONTACT INFORMATION FOR TRIAL COUNSEL
`Expected trial counsel for CyWee is:
`
`
`
`Carmen E. Bremer, WSBA 47,565
`carmen.bremer@bremerlawgroup.com
`BREMER LAW GROUP PLLC
`1700 Seventh Avenue, Suite 2100
`Seattle, WA 98101
`Tel: (206) 357-8442
`Fax: (206) 858-9730
`
`
`
`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 12
`
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`
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 13 of 17
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`
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`Michael W. Shore (pro hac vice)
`mshore@shorechan.com
`Alfonso G. Chan (pro hac vice)
`achan@shorechan.com
`Christopher Evans (pro hac vice)
`cevans@shorechan.com
`Ari B. Rafilson (pro hac vice)
`arafilson@shorechan.com
`William D. Ellerman (pro hac vice)
`wellerman@shorechan.com
`Paul T. Beeler (pro hac vice)
`pbeeler@shorechan.com
`SHORE CHAN DEPUMPO LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
`Expected trial counsel for HTC is:
`
`James C. Yoon, CA Bar #177155 (pro hac vice)
`Ryan R. Smith, CA Bar #229323 (pro hac vice)
`Albert Shih, CA Bar # 251726 (pro hac vice)
`Jamie Y. Otto, CA Bar # 295099 (pro hac vice)
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`Facsimile: (650) 565-5100
`Email: jyoon@wsgr.com
`
`rsmith@wsgr.com
`
`ashih@wsgr.com
`jotto@wsgr.com
`15. DATES ON WHICH TRIAL COUNSEL MAY HAVE COMPLICATIONS
`REGARDING THE TRIAL DATE
`Counsel for Plaintiff do not anticipate any complications at this time.
`Counsel for Defendants currently have trials scheduled for November 5, 2018 through
`November 9, 2018, and May 11, 2020 through May 15, 2020.
`16. CONFIRMATION OF SERVICE
`All parties have been served.
`
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 13
`
`
`
`
`
`
`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

`

`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 14 of 17
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`17. SCHEDULING CONFERENCE
`The parties do not request a scheduling conference at this time.
`18. DATE OF RULE 7.1 DISCLOSURE FILING
`Plaintiff filed its corporate disclosure statement on June 16, 2017 and Defendants filed
`their disclosure statements on October 26, 2017.
`19. INFORMATION REQUIRED PURSUANT TO LOCAL PATENT RULE 110
`LPR 110(6) The parties do not currently have confidentiality concerns that would
`affect the disclosures contemplated in the Local Patent Rules.
`LPR 110(7) The parties believe that a technology tutorial on the day of, and
`immediately preceding, the claim construction hearing would benefit the Court.
`LPR 110(8) The parties believe discovery should be allowed before the disclosures
`required by Local Patent Rule 120, subject to the restrictions of the Federal Rules of Civil
`Procedure, the Local Rules, the Local Patent Rules, and the Orders of this Court.
`LPR 110(9) CyWee does not plan to seek a preliminary injunction or to file a
`dispositive motion before claim construction.
`LPR 110(10) The parties are not aware of the need for any specific limits on discovery
`relating to claim construction.
`LPR 110(11) The parties do not believe the Court should appoint an expert in this case.
`LPR 110(12) The parties do not currently envision the use of live testimony at the claim
`construction hearing, but will provide their final recommendations in the Joint Claim Chart
`pursuant to Local Patent Rule 132(f). Should either party rely on expert testimony addressing
`claim construction, the other party reserves its right to call and cross-examine that expert at the
`claim construction hearing.
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 14
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`

`

`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 15 of 17
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`
`
`Dated this 21st day of November, 2017.
`
`
`Respectfully submitted,
`
`
`
`/s/ Carmen Bremer
`Carmen E. Bremer, WSBA 47,565
`carmen.bremer@bremerlawgroup.com
`BREMER LAW GROUP PLLC
`1700 Seventh Avenue, Suite 2100
`Seattle, WA 98101
`Tel: (206) 357-8442
`Fax: (206) 858-9730
`
`David A. Lowe, WSBA 24,453
`Lowe@LoweGrahamJones.com
`Tim J. Billick, WSBA No. 46,690
`Billick@LoweGrahamJones.com
`LOWE GRAHAM JONES PLLC
`701 Fifth Avenue, Suite 4800
`Seattle, WA 98104
`Tel: (206) 381-3300
`Fax: (206) 381-3301
`
`Michael W. Shore* (mshore@shorechan.com)
`Alfonso G. Chan* (achan@shorechan.com)
`Christopher Evans* (cevans@shorechan.com)
`Ari B. Rafilson* (arafilson@shorechan.com)
`Paul T. Beeler* (pbeeler@shorechan.com)
`SHORE CHAN DEPUMPO LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
` Admitted pro hac vice
`
` *
`
`
`Attorneys for Plaintiff CyWee Group Ltd.
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 15
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 16 of 17
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`/s/ Gregory L. Watts
`Gregory L. Watts
`WILSON SONSINI GOODRICH & ROSATI PC
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104-7036
`Tel: (206) 883-2500
`Fax: (206) 883-2699
`gwatts@wsgr.com
`
`James C. Yoon*
`Ryan R. Smith*
`Albert Shih*
`Jamie Y. Otto*
`WILSON SONSINI GOODRICH & ROSATI PC
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Tel: 650) 493-9300
`Fax: (650) 565-5100
`jyoon@wsgr.com
`rsmith@wsgr.com
`ashih@wsgr.com
`jotto@wsgr.com
`
` *
`
` Admitted pro hac vice
`
`
`Attorneys for Defendants HTC Corporation and
`HTC America, Inc.
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 16
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
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`Case 2:17-cv-00932-JLR Document 41 Filed 11/21/17 Page 17 of 17
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`CERTIFICATE OF SERVICE
`I hereby certify that on November 21, 2017, I presented this JOINT STATUS REPORT
`
`AND DISCOVERY PLAN to the Clerk of the Court for filing and uploading to the CM/ECF
`system, which will send notification of such filing to all counsel of record.
`
`Dated: November 21, 2017
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`/s/ Carmen Bremer
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`JOINT STATUS REPORT AND DISCOVERY
`PLAN
`CASE NO. 2:17-CV-932-JLR– 17
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`BREMER LAW GROUP PLLC
`1700 SEVENTH AVENUE, SUITE 2100
`SEATTLE, WA 98101
`TELEPHONE: 206.357.8442
`
`