`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`Quartz Auto Technologies LLC,
`
`Plaintiff,
`
`v.
`
`Uber Technologies, Inc.,
`
`Defendant.
`
`CIVIL ACTION NO. 6:20-CV-00126
`
`THE HONORABLE ALAN D. ALBRIGHT
`
`
`
`
`
`
`
`Deadline
`June 12, 2020
`
`July 6, 2020
`
`September 4, 2020
`
`September 25, 2020
`October 9, 2020
`
`
`JOINT PROPOSED SCHEDULING ORDER
`
`Item
`Plaintiff serves preliminary infringement contentions in the
`form of a chart setting forth where in the accused
`product(s) each element of the asserted claim(s) are found.
`Plaintiff shall also identify the earliest priority date (i.e. the
`earliest date of invention) for each asserted claim and
`produce: (1) all documents evidencing conception and
`reduction to practice for each claimed invention, and (2) a
`copy of the file history for each patent in suit.
`Deadline for Motions to Transfer.
`
`Defendant serves preliminary invalidity contentions in the
`form of (1) a chart setting forth where in the prior art
`references each element of the asserted claim(s) are found,
`(2) an identification of any limitations the Defendant
`contends are indefinite or lack written description under
`section 112, and (3) an identification of any claims the
`Defendant contends are directed to ineligible subject
`matter under section 101. Defendant shall also produce (1)
`all prior art referenced in the invalidity contentions, (2)
`technical documents, including software where applicable,
`sufficient to show the operation of the accused product(s),
`and (3) summary, annual sales information for the accused
`product(s) for the prior two years, unless the parties agree
`to some other timeframe.
`Plaintiff narrows number of asserted claims to 50.
`Parties exchange claim terms for construction.
`
`1
`
`
`
`
`
`Case 6:20-cv-00126-ADA Document 28 Filed 07/04/20 Page 2 of 2
`
`Deadline
`October 23, 2020
`
`October 30, 2020
`
`
`November 6, 2020
`
`November 13, 2020
`
`December 4, 2020
`
`December 18, 2020
`
`December 23, 2020
`
`January 15, 2021
`January 22, 2021
`
`
`
`
`
`
`Item
`Parties exchange proposed claim constructions.
`
`Parties disclose extrinsic evidence. The parties shall
`disclose any extrinsic evidence, including the identity of
`any expert witness they may rely upon with respect to
`claim construction or indefiniteness. With respect to any
`expert identified, the parties shall also provide a summary
`of the witness’s expected testimony including the opinions
`to be expressed and a general description of the basis and
`reasons therefore. A failure to summarize the potential
`expert testimony in a good faith, informative fashion may
`result in the exclusion of the proffered testimony. With
`respect to items of extrinsic evidence, the parties shall
`identify each such item by production number or produce a
`copy of any such item if not previously produced.
`Deadline to meet and confer to narrow terms in dispute and
`exchange revised list of terms/constructions.
`Parties file Opening claim construction briefs, including
`any arguments that any claim terms are indefinite.
`Parties file Responsive claim construction briefs.
`
`Parties file Reply claim construction briefs.
`
`Parties submit Joint Claim Construction Statement. In
`addition to filing, the parties shall jointly submit, via USB
`drive, cloud-storage, or email to the law clerk pdf versions
`of all as-filed briefing and exhibits. Absent agreement of
`the parties, the Plaintiff shall be responsible for the timely
`submission of this and other Joint filings.
`Parties to submit electronic tutorial.
`Markman Hearing at 9:00 a.m.
`
`SIGNED this ___________ day of _________________, 2020.
`
`
`
`
`
`______________________________
`Alan D Albright
`United States District Judge
`
`
`
`2
`
`
`
`
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