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`May 15, 2023
`
`Via CM/ECF
`The Honorable Jennifer L. Hall
`J. Caleb Boggs Federal Building
`844 N. King Street
`Unit 17, Room 3124
`Wilmington, DE 19801-3555
`
`
`
`
`Re: Arendi S.A.R.L. v. Google LLC (13-919-JLH)
`
`Dear Judge Hall:
`
`
`Pursuant to the Court’s Order for a joint status letter that sets forth the parties’ proposals
`regarding how the case should proceed (D.I. 546), the parties jointly submit this letter.
`
`Arendi and Google anticipate that Arendi will file Rule 50(b) motions and propose that
`opening briefs be due on or before June 2, 2023; responsive briefs be due on or before June 30,
`2023; and reply briefs be due on or before July 21, 2023, subject to the page limits set forth in
`Paragraph 23 of the Court’s Form Scheduling Order for Patent Cases. The parties submit that all
`other deadlines for post-trial proceedings should be governed by the applicable rules.
`
`Arendi presently intends to renew motions for judgment as a matter of law which it made
`on the record on May 1, 2023, pursuant to Fed. R. Civ. P. 50(a). Trial Tr. 1423:20-1428:20.
`Specifically, Arendi intends to file motions for judgment as a matter of law of no invalidity for
`anticipation under 35 U.S.C. § 102 and no invalidity for obviousness under 35 U.S.C. § 103.
`Arendi further intends to file a motion for judgment as a matter of law of no invalidity pursuant to
`35 U.S.C. § 315(e) and common law estoppel principles.
`
`Google does not presently intend to file any Rule 50(b) motions. It reserves the right to
`file motions for costs and attorney’s fees, pursuant to the deadlines under the Court’s Judgment
`dated May 10, 2023 (D.I. 545).
`
`
`Thank you for Your Honor’s assistance.
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`Case 1:13-cv-00919-JLH Document 548 Filed 05/15/23 Page 2 of 2 PageID #: 56403
`
`The Honorable Jennifer L. Hall
`May 15, 2023
`Page 2
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`Respectfully,
`
`Neal C. Belgam
`
`Neal C. Belgam (No. 2721)
`
`cc:
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`Clerk of Court (via CM/ECF)
`All Counsel of Record (via CM/ECF)
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