`
`
`
`Benjamin W. Hattenbach (SBN 186455)
`bhattenbach@irell.com
`Ellisen S. Turner (SBN 224842)
`eturner@irell.com
`Christopher T. Abernethy (SBN 275986)
`cabernethy@irell.com
`Rosalyn M. Kautz (SBN 307831)
`rkautz@irell.com
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Telephone: (310) 277-1010
`Facsimile:
`(310) 203-7199
`
`Attorneys for Defendant
`OSRAM SYLVANIA Inc.
`
`Brian Ledahl (SBN 186579)
`E-Mail: BLedahl@raklaw.com
`Neil A. Rubin (SBN 250761)
`E-Mail: NRubin@raklaw.com
`Jacob Buczko (SBN 269408)
`E-Mail: JBuczko@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, CA 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
`
`
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`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`
`
`
`Plaintiff,
`
`
`DOCUMENT SECURITY SYSTEMS,
`INC.,
`
`
`
`
`
`v.
`
`
`
`OSRAM GMBH; OSRAM OPTO
`SEMICONDUCTORS GMBH & CO.;
`OSRAM Licht AG; and OSRAM
`SYLVANIA INC.,
`
`
`
`
`Defendants.
`
`
`Case No. 2:17-cv-05184-JVS-JCG
`
`STIPULATION TO EXTEND
`TIME FOR DEFENDANT
`OSRAM SYLVANIA INC.
`TO SERVE INVALIDITY
`CONTENTIONS AND
`[PROPOSED] ORDER THEREON
`
`Current Service Deadline: Jan. 22, 2018
`New Service Deadline: Feb. 5, 2018
`
`10428693
`
`
`
`- 1 -
`
`STIPULATION TO EXTEND TIME FOR
`OSI TO SERVE INVALIDITY CONTENTIONS
`Case No. 2:17-cv-05184-JVS-JCG
`
`
`
`Case 2:17-cv-05184-JVS-JCG Document 59 Filed 01/17/18 Page 2 of 3 Page ID #:646
`
`
`
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`
`IT IS HEREBY STIPULATED by and between Plaintiff Document Security
`Systems, Inc. ("DSS") and Defendant OSRAM SYLVANIA Inc. ("OSI"), through
`their respective attorneys of record, as follows:
`WHEREAS, DSS and OSI filed a Joint Stipulation for Order Setting Case
`Schedule (Dkt. 42) and Proposed Order Setting Case Schedule (Dkt. 42-1) on
`October 30, 2017;
`WHEREAS, the Court issued an Order Setting Case Schedule (Dkt. 43) on
`October 31, 2017, adopting the parties' proposed schedule;
`WHEREAS, pursuant the Court's Order Setting Case Schedule (Dkt. 43 at 2),
`OSI's Invalidity Contentions under Patent Rule 3-3 are presently due to be served on
`DSS on January 22, 2018;
`WHEREAS, DSS and OSI agree that, in connection with certain ongoing
`discussions between the parties, it would be prudent and beneficial to extend OSI's
`Invalidity Contention deadline by two weeks, to February 5, 2018;
`WHEREAS, there have been no previous extensions of the time to serve
`OSI's Invalidity Contentions, no other deadlines would be altered or affected, there
`exists good cause for the extension in light of the parties' ongoing discussions, and
`this extension is not sought for any improper purpose;
`THEREFORE, DSS and OSI hereby stipulate to the following extension, as
`stated in the attached [Proposed] Order, subject to the approval of the Court:
`The deadline for Defendant OSRAM SYLVANIA Inc. to serve its
`1.
`Invalidity Contentions under Patent Rule 3-3 is extended to February 5, 2018.
`
`Respectfully submitted,
` /s/ Christopher T. Abernethy
`By:
`Christopher T. Abernethy
`IRELL & MANELLA LLP
`
`Attorneys for Defendant
`OSRAM SYLVANIA Inc.
`
`
`DATED: January 17, 2018
`
`10428693
`
`
`
`- 2 -
`
`STIPULATION TO EXTEND TIME FOR
`OSI TO SERVE INVALIDITY CONTENTIONS
`Case No. 2:17-cv-05184-JVS-JCG
`
`
`
`Case 2:17-cv-05184-JVS-JCG Document 59 Filed 01/17/18 Page 3 of 3 Page ID #:647
`
`DATED: January 17, 2018
`
`By:
`
`/s/ Brian Ledahl
`Brian Ledahl
`RUSS AUGUST & KABAT
`
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
`
`
`ATTESTATION OF AUTHORIZATION
`
`
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`
`Pursuant to Central District of California Local Rule 5-4.3.4(a)(2)(i), I hereby
`certify that the content of this document is acceptable to Brian Ledahl, counsel for
`Plaintiff, and I have obtained his authorization to affix his electronic signature to
`this document.
`
`DATED: January 17, 2018
`
`
`
`
`
`
`By:
`
`
` /s/ Christopher T. Abernethy
`Christopher T. Abernethy
`
`
`
`
`
`10428693
`
`
`
`- 3 -
`
`STIPULATION TO EXTEND TIME FOR
`OSI TO SERVE INVALIDITY CONTENTIONS
`Case No. 2:17-cv-05184-JVS-JCG
`
`
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