`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 15-842 (RGA)
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`CONSOLIDATED
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`IN RE CHANBOND, LLC
`PATENT LITIGATION
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`STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER
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`IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and
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`subject to the approval of the Court, that the following deadlines are hereby extended as set forth
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`in the attached Exhibit A.
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`BAYARD, P.A.
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`/s/ Stephen B. Brauerman
`Stephen B. Brauerman (No. 4952)
`Sara E. Bussiere (No. 5725)
`BAYARD, P.A.
`222 Delaware Avenue, Suite 900
`P.O. Box 25130
`Wilmington, Delaware 19899
`(302) 655-5000
`sbrauerman@bayardlaw.com
`sbussiere@bayardlaw.com
`Counsel for Plaintiff ChanBond, LLC
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`April 24, 2018
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`MORRIS, NICHOLS, ARSHT &TUNNELL LLP
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`/s/ Jennifer Ying
`Jack B. Blumenfeld (#1014)
`Jennifer Ying (#5550)
`1201 N. Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`(302) 658-9200
`jblumenfeld@mnat.com
`jying@mnat.com
`Attorneys for Defendants
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`IT IS SO ORDERED this _________ day of ________________________, 2018.
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`The Honorable Richard G. Andrews
`United States District Judge
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`Patent Owner Ex. 2005
`ARRIS International PLC v. ChanBond LLC
`IPR2018-00575
`Page 1
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`Exhibit A
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`Event
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`Close of fact discovery1
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`Current Deadline
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`Proposed New
`Deadline
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`April 30, 2018
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`June 1, 2018
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`Opening Expert Reports for party that bears burden
`of proof
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`June 1, 2018
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`July 2, 2018
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`Rebuttal Expert Reports
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`Reply Expert Reports
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`Close of Expert Discovery
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`Opening SJ/Daubert Briefs
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`July 13, 2018
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`August 13, 2018
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`August 3, 2018
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`August 31, 2018
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`August 28, 2018
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`September 28, 2018
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`September 18, 2018 October 19, 2018
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`Answering SJ/Daubert Briefs
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`October 18, 2018 November 19, 2018
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`Reply SJ/Daubert Briefs
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`November 8, 2018 December 7, 2018
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`Trial scheduling conference, with parties to submit a
`joint status report with their proposal(s) one week in
`advance.2
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`October 31, 2018 @
`8:30 am
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`TBA
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`SJ/Daubert Hearing
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`TBA
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`TBA
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`1
`The parties agree that the close of fact discovery is extended for 30 days to complete
`already served discovery. The parties agree that no new discovery shall be served without the
`consent of the other party, except that the parties shall be permitted to serve new Requests for
`Admissions up through thirty days prior to the close of fact discovery. Nothing in this provision
`shall prevent a party from supplementing its response to any discovery request.
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`2
`Plaintiff intends to include a proposal regarding trial consolidation at least in view of
`identical accused products and common factual questions across defendants, per 35 U.S.C. §
`299. Defendants believe consolidation for trial is not appropriate, for at least the reason that the
`parties cannot be properly consolidated under 35 U.S.C. § 299 and Fed. R. Civ. P. 20.
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`2
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`Patent Owner Ex. 2005
`ARRIS International PLC v. ChanBond LLC
`IPR2018-00575
`Page 2
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`Event
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`Current Deadline
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`Proposed New
`Deadline
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`TBA
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`TBA
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`TBA
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`TBA
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`Pre-trial Conference
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`First 5-day jury trial
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`3
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`Patent Owner Ex. 2005
`ARRIS International PLC v. ChanBond LLC
`IPR2018-00575
`Page 3
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