The Court having considered Plaintiff Inpria Corporation’s (“Inpria”) Motion for Exemption of Persons from the District of Delaware’s May 17, 2024 Standing Order on Personal Devices (the “Motion”), IT IS SO ORDERED this 6th day of November, 2024 that:

The Motion is GRANTED; For purposes of the November 6, 2024 hearing, the following persons are exempt from the District of Delaware’s May 17, 2024 Standing Order and shall be permitted to retain and use their personal electronic devices: • Joseph Palys • Phillip Citroen; • Joseph Rumpler; • Paul Anderson; • Brooke Wilner; and

Such persons listed in Paragraph 2 above shall present this Order, along with a valid photographic I.D., to the United States Marshals upon entry to the J. Caleb Boggs Federal Building and United States Courthouse.

United States Magistrate Judge

The Honorable Christopher J. Burke J. Caleb Boggs Federal Building 844 N. King Street, Room 2325 Wilmington, DE 19801-3555 Re: Inpria Corporation v. Lam Research Corp., Case No. 1:22-cv-01359-CJB Dear Judge Burke: Pursuant to this Court’s May 22, 2024 Oral Order [Docket Index 120], the parties in the above- referenced matter write to inform the Court that counsel for the parties (including at least one Delaware counsel and the most senior attorney on each side who has familiarity with the disputes) have participated in a further verbal meet and confer regarding the issues listed in the parties May 17, 2024 letter to the Court [Docket Index 118].

The parties have resolved or tabled some, but not all, of the issues.

The following disputes remain to be resolved by the Court.

Whether Inpria should be required to now supplement its response to Defendant’s Interrogatory No. 7, instead of after the completion of document production (when Plaintiff has had the opportunity to develop its contentions based on a fuller record), which asks Inpria to state its position as to whether it contends it practices any of the claims of the asserted patents and, if so, to identify evidence and provide a claim chart showing in detail how each such claim limitation is practiced by each alleged practicing Inpria product, service, or other instrumentality; and 2.

All Counsel of Record (via ECF)

31) Since then, the Court has tried to get the case moving, and it and the parties have done some real work on the matter in that time— including holding a scheduling conference, beginning fact discovery, and addressing and resolving Defendant’s motion to transfer, (D.I.

On the one hand, if the SUNY case ends up getting resolved via a finding that Plaintiff Inpria Corp. (“Plaintiff” or “Inpria”) failed to list the proper inventors as to all eight of the patents asserted in this matter, then there would be complete simplification of the issues here.

Therefore, and without going too deep into the underlying merits of the inventorship issues, see Kaavo Inc., 2015 WL 1737476, at *2 n.4, the Court can still observe that simply from a high-level, statistical perspective, it seems very possible that the result of the SUNY case will be that Plaintiff loses the chance to move forward here as to none or some asserted patents, but not all.

On balance, while the prospect for some simplification helps Defendant, in light of the countervailing concerns addressed herein, this factor only slightly favors grant of the Motion.

109 at 1) For example, Plaintiff points to 2018 and 2019 Lam presentations in which Defendant analyzes Plaintiff’s technology and asserts that its stated goal is “to provide a robust solution ... that exceeds that of the leading competitor[] (Inpria)[.

Information or material designated as CONFIDENTIAL, or copies or extracts therefrom and compilations and summaries thereof, may be disclosed, summarized, described, characterized, or otherwise communicated or made available in whole or in part only to the following persons:

Any other person only upon order of the Court or upon written consent of the Party or nonparty producing the confidential information or material subject to and conditioned upon compliance with Paragraph 10 below; and

Information or material designated as HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY, or copies or extracts therefrom and compilations and summaries thereof, may be disclosed, summarized, described, characterized, or otherwise communicated or made available in whole or in part only to the following persons:

Summaries of inadvertently produced documents and the one remaining copy used solely for the purpose of challenging the privilege shall be destroyed by the receiving party within ten (10) business days if a motion to compel is not brought or is denied.

The terms of this Protective Order shall apply to all manner and means of discovery, including entry onto land or premises, and inspection of books, records, documents, and tangible things.

Along with their respective letter briefs, each side should include as an attachment the side’s proposal as to how the content of the disputed portion(s) of the protective order should read.

The parties may (though they are not required to) provide the Court, no later than the date on which the Joint Claim Construction Brief is due, with a tutorial on the technology at issue.

On December 13, 2024, counsel shall file a joint letter with the Court with an interim report on the nature of the matters in issue and the progress of discovery to date.

The moving party shall include with its reply papers a response to the opposing party’s concise statement of facts, not to exceed four pages, on a paragraph-by paragraph basis.

This submission shall be accompanied by a courtesy copy containing electronic files of these documents, in Word format, which may be submitted by e-mail to the trial judge’s staff.

Pursuant to Local Rule 83.5 and the attached certifications, counsel moves the admission pro hac vice of Yi (Sunnie) Ning and Sarah Propst of LATHAM & WATKINS LLP to represent Defendant Lam Research Corp. in this matter.

Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am admitted, practicing and in good standing as a member of the Bar of the State of California and pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged misconduct which occurs in the preparation or course of this action.

In accordance with Standing Order for District Court Fund effective 1/1/24, I further certify that the fee of $50.00 will be submitted to the Clerk’s Office upon the filing of this motion.

Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am admitted, practicing and in good standing as a member of the Bar of the District of Columbia and pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged misconduct which occurs in the preparation or course of this action.

In accordance with Standing Order for District Court Fund effective 1/1/24, I further certify that the fee of $50.00 will be submitted to the Clerk’s Office upon the filing of this motion.

Pursuant to Local Rule 83.5 and the attached certification, counsel moves the admission pro hac vice of Patricia Young of LATHAM & WATKINS LLP to represent Defendant Lam Research Corp. in this matter.

Rodger D. Smith II (#3778) Cameron P. Clark (#6647) 1201 North Market Street P.O.

IT IS HEREBY ORDERED that counsel’s motion for admission pro hac vice of Patricia Young is granted.

Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am admitted, practicing and in good standing as a member of the Bars of the State of New York and the State of California and pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged misconduct which occurs in the preparation or course of this action.

In accordance with Standing Order for District Court Fund effective 1/1/24, I further certify that the fee of $50.00 will be submitted to the Clerk’s Office upon the filing of this motion.