`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`WILLOW INNOVATIONS, INC.
`
`Plaintiff,
`v.
`
`CHIARO TECHNOLOGY LTD.,
`
`Defendant.
`
`Civil Action No. 2:23-cv-00229-JRG
`
`JURY TRIAL DEMANDED
`
`WILLOW’S UNOPPOSED MOTION TO EXTEND
`THE DEADLINE TO COMPLY WITH P.R. 4-4
`
`Plaintiff Willow Innovations, Inc. (“Willow”) files this Unopposed Motion to Amend the
`
`Docket Control Order to Extend the Deadline to Comply with P.R 4-4 and complete Claim
`
`Construction Discovery.
`
`Due to scheduling conflicts, Willow cannot meet the current deadline of July 25, 2024 to
`
`complete depositions of Defendant Chiaro Technology Ltd.’s (“Elvie”) claim construction
`
`experts. The parties have agreed, however, that Willow will take the depositions of Elvie’s claim
`
`construction experts during the week of July 29, 2024.
`
`Thus, Willow respectfully requests that the Court enter an Order extending until August 2,
`
`2024 the Deadline to Comply with P.R 4-4 and complete Claim Construction Discovery. This
`
`extension will not affect any other deadlines set forth in the Court’s Docket Control Order (Dkt.
`
`38). Willow does not seek this extension for the purpose of delay, but to allow additional time to
`
`depose Elvie’s claim construction experts. Elvie does not oppose the relief sought in this Motion.
`
`
`
`Case 2:23-cv-00229-JRG Document 71 Filed 07/23/24 Page 2 of 3 PageID #: 5041
`
`Date: July 23, 2024
`
`Respectfully submitted,
`
`/s/ Timothy S. Durst
`
`O’MELVENY & MYERS LLP
`Timothy S. Durst (TX #00786924)
`tdurst@omm.com
`Cason Garrett Cole (TX #24109741)
`ccole@omm.com
`2801 North Harwood Street, Suite 1600
`Dallas, TX 75201
`Telephone: (972) 360-1900
`Facsimile: (972) 360-1901
`
`Robert F. Shaffer (admitted pro hac vice)
`rshaffer@omm.com
`Jason Fountain (admitted pro hac vice)
`jfountain@omm.com
`Miao Liu (admitted pro hac vice)
`mliu@omm.com
`1625 Eye St., NW
`Washington, DC 20006
`Telephone: (202) 383-5300
`Facsimile: (202) 383-5414
`
`Carolyn S. Wall (admitted pro hac vice)
`cwall@omm.com
`1301 Avenue of the Americas
`Suite 1700
`New York, NY 10019-6022
`Telephone: (212) 326-2000
`Facsimile: (212) 326-2061
`
`Laura Burson (TX # 24091995)
`lburson@omm.com
`400 South Hope St
`Los Angeles, CA 90071
`Telephone: (213) 430-6000
`Facsimile: (213) 430-6407
`
`Attorneys for Plaintiff Willow
`Innovations, Inc.
`
`2
`
`
`
`Case 2:23-cv-00229-JRG Document 71 Filed 07/23/24 Page 3 of 3 PageID #: 5042
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the parties met and conferred on July 23, 2024 and counsel for Elvie
`
`indicated it does not oppose the relief requested herein.
`
`/s/ Timothy S. Durst
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that counsel of record who are deemed to have consented
`
`to electronic services are being served with a copy of this document via the Court’s CM/
`
`ECF system per Local Rule CV-5(a)(3) on July 23, 2024.
`
`/s/ Timothy S. Durst
`
`3
`
`
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