Case 1:13-cv-00920-LPS Document 209 Filed 11/04/20 Page 1 of 2 PageID #: 6438
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`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`302 984 6000
`www.potteranderson.com
`
`David E. Moore
`Partner
`Attorney at Law
`dmoore@potteranderson.com
`302 984-6147 Direct Phone
`
`November 4, 2020
`
`VIA ELECTRONIC-FILING
`The Honorable Leonard P. Stark
`The United Stated District Court
` for the District of Delaware
`J. Caleb Boggs Federal Building
`844 N. King Street
`Wilmington, DE 19801
`
`Re:
`
`Arendi S.A.R.L. v. LG Electronics, Inc., et al., C.A. No. 12-1595-LPS
`Arendi S.A.R.L. v. Apple Inc. C.A. No. 12-1596-LPS
`Arendi S.A.R.L. v. Blackberry Limited, et al., C.A. No. 12-1597-LPS
`Arendi S.A.R.L. v. Motorola Mobility LLC, C.A. No. 12-1601-LPS
`Arendi S.A.R.L. v. Sony Mobile Commc’ns (USA) Inc., et al., C.A. No. 12-1602-LPS
`Arendi S.A.R.L. v. Google LLC, C.A. No. 13-919-LPS
`Arendi S.A.R.L. v. Oath Holdings Inc., et al., C.A. No. 13-920-LPS
`
`Dear Chief Judge Stark:
`
`Defendants write in response to Plaintiff Arendi S.A.R.L.’s (“Arendi”) request that the
`Court now schedule trial dates in the above actions. The parties previously agreed on, and
`stipulated to, a case schedule that set the conference for ordering and scheduling of trials after
`briefing on dispositive motions is complete. In June 2020, the parties filed a Joint Stipulation and
`[Proposed] Order For Extension of Certain Case Deadlines that confirmed the agreement that the
`conference for ordering and scheduling of trials should occur after completion of dispositive
`motion briefing. See Case 1:13-cv-00919, D.I. 210; June 5, 2020 Docket Text Order. The case
`schedule agreed to and proposed in the June 2020 Joint Stipulation, and adopted by the Court,
`was made with full knowledge and understanding of the “COVID-19 pandemic and its effect on
`the Court’s trial docket” - the circumstance that Arendi invokes in its letter as a basis for the
`immediate request to schedule trial dates. Arendi’s letter fails to remind the Court that its current
`request runs counter to the stipulated schedule for trial scheduling.
`
`Arendi has not shown the required “good cause” to modify the stipulated schedule for the
`ordering and scheduling of trials, and none exists. The parties stipulated to setting the trial
`scheduling conference only after dispositive motions precisely because it is difficult, if not
`impossible, to determine (a) which of the seven separate cases involved are likely to go to trial,
`and on which issues; (b) the likely time required for each trial; and (c) the most efficient and
`practical ordering of the seven separate trials, until dispositive motions are fully briefed and can
`be evaluated by the parties and the Court. In fact, given that the parties currently are in the
`middle of expert discovery, setting trial order and schedules now makes no sense and begs for
`later alteration once summary judgment and Daubert motions are filed and ruled upon.
`
`

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`Case 1:13-cv-00920-LPS Document 209 Filed 11/04/20 Page 2 of 2 PageID #: 6439
`The Honorable Leonard P. Stark
`November 4, 2020
`Page 2
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`Because Arendi offers no justification for modifying the stipulated case schedule at this
`time, the Court should maintain the existing schedule, as previously ordered, and should deny
`Arendi’s request immediately to schedule trial dates.
`
`Respectfully,
`
`/s/ David E. Moore
`
`David E. Moore
`
`DEM:nmt/6923287/40549
`
`cc:
`
`Counsel of record (via electronic mail)
`
`