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IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`)
`)
`)
`)
`)
`
`C.A. No. 15-842 (RGA)
`
`CONSOLIDATED
`
`
`
`
`IN RE CHANBOND, LLC
`PATENT LITIGATION
`
`
`
`STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER
`
`IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and
`
`subject to the approval of the Court, that the following deadlines are hereby extended as set forth
`
`in the attached Exhibit A.
`
`BAYARD, P.A.
`
`/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
`
`
`April 24, 2018
`
`
`
`
`
`
`
`MORRIS, NICHOLS, ARSHT &TUNNELL LLP
`
`/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
`
`
`IT IS SO ORDERED this _________ day of ________________________, 2018.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Honorable Richard G. Andrews
`United States District Judge
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner Ex. 2005
`ARRIS International PLC v. ChanBond LLC
`IPR2018-00575
`Page 1
`
`

`

`Exhibit A
`
`Event
`
`Close of fact discovery1
`
`Current Deadline
`
`Proposed New
`Deadline
`
`April 30, 2018
`
`June 1, 2018
`
`Opening Expert Reports for party that bears burden
`of proof
`
`June 1, 2018
`
`July 2, 2018
`
`
`Rebuttal Expert Reports
`
`Reply Expert Reports
`
`Close of Expert Discovery
`
`Opening SJ/Daubert Briefs
`
`July 13, 2018
`
`August 13, 2018
`
`August 3, 2018
`
`August 31, 2018
`
`August 28, 2018
`
`September 28, 2018
`
`September 18, 2018 October 19, 2018
`
`Answering SJ/Daubert Briefs
`
`October 18, 2018 November 19, 2018
`
`Reply SJ/Daubert Briefs
`
`November 8, 2018 December 7, 2018
`
`Trial scheduling conference, with parties to submit a
`joint status report with their proposal(s) one week in
`advance.2
`
`
`October 31, 2018 @
`8:30 am
`
`
`
`TBA
`
`SJ/Daubert Hearing
`
`TBA
`
`TBA
`
`
`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.
`
`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.
`
`2
`
`Patent Owner Ex. 2005
`ARRIS International PLC v. ChanBond LLC
`IPR2018-00575
`Page 2
`
`

`

`Event
`
`Current Deadline
`
`Proposed New
`Deadline
`
`TBA
`
`TBA
`
`TBA
`
`TBA
`
`Pre-trial Conference
`
`First 5-day jury trial
`
`
`3
`
`Patent Owner Ex. 2005
`ARRIS International PLC v. ChanBond LLC
`IPR2018-00575
`Page 3
`
`

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