Case 1:22-cv-01257-GBW Document 48 Filed 08/30/23 Page 1 of 16 PageID #: 838
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ROBOTICVISIONTECH, INC.,
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`Plaintiff,
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`V.
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`C.A. No: 22-cv-01257-GBW
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`ABB INC.,
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`Defendant.
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`[PROPOSED] SCHEDULING ORDER
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`This 3o"'"' day of ~
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`2023 , the Court, having conducted an initial Rule 16(b)
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`scheduling conference pursuant to Local Rule 16.1 (b ), and the parties having determined after
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`discussion that the matter cannot be resolved at this juncture by settlement, voluntary mediation,
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`or binding arbitration;
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`IT IS HEREBY ORDERED that:
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`1.
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`Rule 26(a)(I) Initial Disclosures and E-Discovery Default Standard. Unless
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`otherwise agreed to by the parties, the parties shall make their initial disclosures pursuant to
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`Federal Rule of Civil Procedure 26(a)(l) within 5 days of the date the Court enters this Order. If
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`they have not already done so, the parties are to review the Court' s Default Standard for
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`Discovery, Including Discovery of Electronically Stored Information (" ESI"), which is posted at
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`http://www.ded.uscourts.gov (see Other Resources, Default Standard for Discovery) and is
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`incorporated herein by reference.
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`2.
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`Joinder of Other Parties and Amendment of Pleadings. All motions to join other
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`parties, and to amend or supplement the pleadings, w ithin 45 days of ABB filing its answer to
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`the Complaint (D.I. I). Unless otherwise ordered by the Court, any motion to join a party or
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`ABB Inc. Exhibit 1013, Page 1 of 16
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`Case 1:22-cv-01257-GBW Document 48 Filed 08/30/23 Page 2 of 16 PageID #: 839
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`motion to amend the pleadings shall be made pursuant to the procedures set forth in Paragraphs
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`4(g) and 5.
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`3.
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`Disclosures. On agreement among the parties, and approval of the Court:
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`(a)
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`Plaintiff has identified the accused products, including accused methods
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`and systems, and its damages model, as well as the asserted patents that the accused products
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`allegedly infringe(s). Plaintiff has also produced the file history for each asserted patent. Plaintiff
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`has also identified its alleged trade secrets with particularity. Within five days of this order,
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`Plaintiff shall serve amended Rule 26(a) disclosure and paragraph 3(a) disclosures and
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`Defendant shall serve Rule 26(a) disclosures and paragraph 3(a) disclosures.
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`(b)
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`By August 30, 2023, Defendant shall produce core technical documents
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`related to the accused products, sufficient to show how the accused products work, including but
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`not limited to non-publicly available operation manuals, product literature, schematics,
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`specifications, and source code. Defendant shall also produce sales figures for the accused
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`products, including units sold, price per unit, and aftermarket sales service and support for
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`domestic sales and global sales.
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`( c)
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`By November 8, 2023, Plaintiff shall produce an initial claim chart
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`relating each known accused product to the asserted claims each such product allegedly
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`infringes.
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`( d)
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`By December 15, 2023, Defendant shall produce its initial invalidity
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`contentions for each asserted claim, as well as the known related invalidating references.
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`( e)
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`(t)
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`By June 5, 2024, Plaintiff shall provide final infringement contentions.
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`By June 19, 2024, Defendant shall provide final invalidity contentions.
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`2
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`4.
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`Discovery. Unless otherwise ordered by the Court or agreed to by parties, the
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`limitations on discovery set forth in the Federal Rules of Civil Procedure shall be strictly
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`observed.
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`(a)
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`Fact Discovery Cut Off. All fact discovery in this case shall be initiated so
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`that it will be completed on or before July 5, 2024.
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`(b)
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`Document Production. Document production shall be substantially
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`complete by May 17, 2024.
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`(c)
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`Requests for Admission. A maximum of 50 requests for admission are
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`permitted for each side, excluding requests establishing authenticity of documents.
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`(d)
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`Interrogatories.
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`1.
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`A maximum of 30 interrogatories, including contention
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`interrogatories, are permitted for each side.
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`11.
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`The Court encourages the parties to serve and respond to
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`contention interrogatories early in the case. In the absence of agreement among the parties,
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`contention interrogatories, if filed, shall first be addressed by the party with the burden of proof.
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`The adequacy of all interrogatory answers shall be judged by the level of detail each party
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`provides (i.e., the more detail a party provides, the more detail a party shall receive).
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`( e)
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`Depositions.
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`1.
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`Limitation on Hours for Deposition Discovery. Each side is limited
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`to a total of 70 hours of taking testimony by deposition upon oral examination for fact witnesses.
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`Any deposition ( other than third-party depositions) that lasts for less than four hours shall count
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`as four hours for the purposes of this paragraph.
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`11.
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`Location of Depositions. Any party or representative ( officer,
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`director, or managing agent) of a party filing a civil action in this district court must ordinarily be
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`3
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`required, upon request, to submit to a deposition at a place designated within this district.
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`Exceptions to this general rule may be made by order of the Court. A defendant who becomes a
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`counterclaimant, cross-claimant, or third-party plaintiff shall be considered as having filed an
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`action in this Court for the purpose of this provision.
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`(f)
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`Disclosure of Expert Testimony.
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`1.
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`Expert Reports. For the party who has the initial burden of proof
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`on the subject matter, the initial Federal Rule of Civil Procedure 26(a)(2) disclosure of expert
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`testimony is due on or before August 2, 2024. The supplemental disclosure to contradict or rebut
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`evidence on the same matter identified by another party is due on or before August 30, 2024.
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`Reply expert reports from the party with the initial burden of proof are due on or before
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`September 20, 2024. No other expert reports will be permitted without either the consent of all
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`parties or leave of the Court. Along with the submissions of the expert reports, the parties shall
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`advise of the dates and times of their experts' availability for deposition.
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`11.
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`Objections to Expert Testimony. To the extent any objection to
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`expert testimony is made pursuant to the principles announced in Daubert v. Merrell Dow
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`Pharmaceuticals, Inc. , 509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it
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`shall be made by motion no later than the deadline for dispositive motions set forth herein, unless
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`otherwise ordered by the Court. Briefing on such motions is subject to the page limits set out in
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`connection with briefing of case dispositive motions.
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`111.
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`Expert Discovery Cut-Off. All expert discovery in this case shall
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`be initiated so that it will be completed on or before October 23, 2024.
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`(g)
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`Discovery Matters and Disputes Relating to Protective Orders.
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`1.
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`Any discovery motion filed without first complying with the
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`following procedures will be denied without prejudice to renew pursuant to these procedures.
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`4
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`11.
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`Should counsel find, after good faith efforts - including verbal
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`communications among Delaware and Lead Counsel for all parties to the dispute - that they are
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`unable to resolve a discovery matter or a dispute relating to a protective order, the parties
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`involved in the discovery matter or protective order dispute shall submit a joint letter in
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`substantially the following form:
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`Dear Judge Williams:
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`The parties in the above-referenced matter write to request the scheduling
`of a discovery teleconference.
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`The following attorneys, including at least one Delaware Counsel and at
`least one Lead Counsel per party, participated in a verbal meet- and-confer (in
`person and/or by telephone) on the following date(s): _ _ _ _ _ _ _ _ _
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`Delaware Counsel: - - - - -
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`Lead Counsel: - - - - -
`The disputes requiring judicial attention are listed below:
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`[provide here a non-argumentative list of disputes requiring judicial attention]
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`m.
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`On a date to be set by separate order, generally not less than 48
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`hours prior to the conference, the party seeking relief shall file with the Court a letter, not to
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`exceed 3 pages, outlining the issues in dispute and its position on those issues. On a date to be set
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`by separate order, but generally not less than 24 hours prior to the conference, any party
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`opposing the application for relief may file a letter, not to exceed 3 pages, outlining that
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`party's reasons for its opposition.
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`1v.
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`Each party shall submit 2 courtesy copies of its discovery letter
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`and any attachments.
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`v.
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`Should the Court find further briefing necessary upon conclusion
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`of the telephone conference, the Court will order it. Alternatively, the Court may choose to
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`5
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`resolve the dispute prior to the telephone conference and will, in that event, cancel the
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`conference.
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`5.
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`Motions to Amend.
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`(a)
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`Any motion to amend (including a motion for leave to amend) a pleading
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`shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not
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`to exceed 3 pages, describing the basis for the requested relief, and shall attach the proposed
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`amended pleading as well as a "blackline" comparison to the prior pleading.
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`(b) Within 7 days after the filing of a motion in compliance with this Order,
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`any party opposing such a motion shall file a responsive letter, not to exceed 5 pages.
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`(c) Within 3 days thereafter, the moving party may file a reply letter, not to
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`exceed 2 pages, and, by this same date, the parties shall file a letter requesting a teleconference to
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`address the motion to amend.
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`6.
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`Motions to Strike.
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`(a)
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`Any motion to strike any pleading or other document shall NOT be
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`accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed 3
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`pages, describing the basis for the requested relief, and shall attach the document to be stricken.
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`(b) Within 7 days after the filing of a motion in compliance with this Order,
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`any party opposing such a motion shall file a responsive letter, not to exceed 5 pages.
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`(c) Within 3 days thereafter, the moving party may file a reply letter, not to
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`exceed 2 pages, and, by this same date, the parties shall file a letter requesting a teleconference to
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`address the motion to strike.
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`7.
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`Technology Tutorials. Unless otherwise ordered by the Court, the parties jointly
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`shall provide the Court, no later than the date on which the Joint Claim Construction Chart is
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`due, a tutorial on the technology at issue. In that regard, the parties shall jointly submit to the
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`6
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`Court an electronic tutorial of not more than 30 minutes. The tutorial should focus on the
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`technology in issue and educate the Court about the same and should not be used for argument.
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`As to the format selected, the parties should confirm the Court' s technical abilities to access the
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`information contained in the tutorial. The parties may choose to file their tutorial under seal,
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`subject to any protective order in effect.
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`8.
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`Claim Construction Issue Identification. On or before December 22, 2024, the
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`parties shall exchange a list of those claim term(s)/phrase(s) that they believe need construction
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`and their proposed claim construction of those term(s)/phrase(s). On or before January 5, 2024,
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`the parties shall respond to and provide their proposed construction for any term(s)/phrase(s)
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`presented by the other side for which the party did not initially provide a construction. These
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`documents will not be filed with the Court. Subsequent to exchanging that list, the parties will
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`meet and confer to prepare a Joint Claim Construction Chart to be filed no later than January
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`12, 2024. The Joint Claim Construction Chart, in Word format, shall be e-mailed simultaneously
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`with filing to gbw _ civil@ded.uscourts.gov. The parties ' Joint Claim Construction Chart should
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`identify for the Court the term( s )/phrase( s) of the claim( s) in issue, and should include each
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`party's proposed construction of the disputed claim language with citation(s) only to the intrinsic
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`evidence in support of their respective proposed constructions. A copy of the patent(s) in issue as
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`well as those portions of the intrinsic record relied upon shall be submitted with this Joint Claim
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`Construction Chart. In this joint submission, the parties shall not provide argument.
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`9.
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`Claim Construction Briefing. Plaintiff shall serve, but not file, its opening brief,
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`not to exceed 5,000 words, on February 2, 2024. Defendant shall serve, but not file, its
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`answering brief not to exceed 7,500 words, on February 23, 2024. Plaintiff shall serve, but not
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`file, its reply brief, not to exceed 5,000 words, on March 8, 2024. Defendant shall serve, but not
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`file its sur-reply brief, not to exceed 2,500 words, on March 22, 2024. No later than March 29,
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`7
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`2024, the parties shall file a Joint Claim Construction Brief. The parties shall copy and paste
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`their untiled briefs into one brief, with their positions on each claim term in sequential order, in
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`substantially the form below.
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`JOINT CLAIM CONSTRUCTION BRIEF
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`I.
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`II.
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`Agreed-Upon Constructions
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`Disputed Constructions
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`[TERM 1]
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`1.
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`2.
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`3.
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`4.
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`Plaintiffs Opening Position
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`Defendant's Answering Position
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`Plaintiffs Reply Position
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`Defendant's Sur-Reply Position
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`[TERM 2]
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`1.
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`2.
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`3.
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`4.
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`Plaintiffs Opening Position
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`Defendant's Answering Position
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`Plaintiffs Reply Position
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`Defendant's Sur-Reply Position
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`If there are any materials that would be submitted in an index, the parties shall submit them in a
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`Joint Appendix.
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`,.A
`\·,oo ~ ·"' 1V'
`Hearing on Claim Construction. Beginning at..k:m. on
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`10.
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`_i_, 2024, the
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`Court will hear argument on claim construction. The parties shall notify the Court, by joint letter
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`submission, no later than the date on which their answering claim construction briefs are due: (i)
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`whether they request leave to present testimony at the hearing; and (ii) the amount of time they
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`are requesting be allocated to them for the hearing.
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`Provided that the parties comply with all portions of this Scheduling Order, and any
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`other orders of the Court, the parties should anticipate that the Court will issue its claim
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`construction order within 60 days of the conclusion of the claim construction hearing. If the
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`8
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`Court is unable to meet this goal, it will advise the parties no later than 60 days after the
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`conclusion of the claim construction hearing.
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`11.
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`Interim Status Report. On June 21, 2024, counsel shall submit a joint letter to the
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`Court with an interim report of the matters in issue and the progress of discovery to date.
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`Thereafter, if the Court deems it necessary, it will schedule a status conference.
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`12.
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`Case Dispositive Motions.
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`(a)
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`All case dispositive motions, an opening brief, and affidavits, if any, in
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`support of the motion shall be served and filed on or before November 20, 2024, [a date
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`approximately four months prior to the pretrial conference, the four months being calculated
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`from the conclusion of the briefing]. Briefing will be presented pursuant to the Court's Local
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`Rules. No case dispositive motion under Rule 56 may be filed more than 10 days before the
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`above date without leave of the Court.
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`(b) Concise Statement of Facts Requirement. Any motion for summary
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`judgment shall be accompanied by a separate concise statement, not to exceed 6 pages, which
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`details each material fact which the moving party contends is essential for the Court' s
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`resolution of the summary judgment motion (not the entire case) and as to which the moving
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`party contends there is no genuine issue to be tried. Each fact shall be set forth in a separate
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`numbered paragraph and shall be supported by specific citation( s) to the record.
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`Any party opposing the motion shall include with its opposing papers a response to the
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`moving party's concise statement, not to exceed 6 pages, which admits or disputes the facts set
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`forth in the moving party's concise statement on a paragraph-by-paragraph basis. To the extent a
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`fact is disputed, the basis of the dispute shall be supported by specific citation( s) to the record.
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`Failure to respond to a fact presented in the moving party's concise statement of facts shall
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`indicate that fact is not in dispute for purposes of summary judgment. The party opposing the
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`motion may also include with its opposing papers a separate concise statement, not to exceed 4
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`pages, which sets forth material facts as to which the opposing party contends there is a genuine
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`issue to be tried. Each fact asserted by the opposing party shall also be set forth in a separate
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`numbered paragraph and shall be supported by specific citation(s) to the record.
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`The moving party shall include with its reply papers a response to the opposing party's
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`concise statement of facts, not to exceed 4 pages, on a paragraph-by-paragraph basis. Failure to
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`respond to a fact presented in the opposing party' s concise statement of facts shall indicate that
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`fact remains in dispute for purposes of summary judgment.
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`( c)
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`Page limits combined with Daubert motion page limits. Each party is
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`permitted to file as many case dispositive motions as desired provided, however, that each SIDE
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`will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40
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`pages for all answering briefs, and a combined total of 20 pages for all reply briefs regardless of
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`the number of case dispositive motions that are filed. In the event that a party files, in addition to
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`a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an
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`expert's testimony, the total amount of pages permitted for all case dispositive and Daubert
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`motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs,
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`and 25 pages for all reply briefs for each SIDE. 1
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`( d)
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`Ranking of Summary Judgment Motions. Any party that files more than
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`one summary judgment motion shall number each motion to indicate the order in which the
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`party wishes the Court to review its pending motions. The first motion the party wishes the
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`1 The parties must work together to ensure that the Court receives no more than a total of 250
`pages (i.e., 50 + 50 + 25 regarding one side' s motions, and 50 + 50 + 25 regarding the other
`side's motions) of briefing on all case dispositive motions and Daubert motions that are covered
`by this scheduling order and any other scheduling order entered in any related case that is
`proceeding on a consolidated or coordinated pretrial schedule.
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`ABB Inc. Exhibit 1013, Page 10 of 16
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`Court to consider shall be designated # 1, the second motion shall be designated #2, and so on.
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`The Court will review the party' s summary judgment motions in the order designated by the
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`party. If the Court decides to deny a motion filed by the party, barring exceptional reasons
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`determined sua sponte by the Court, the Court will not review any lower ranked summary
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`judgment motions filed by the party.
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`13.
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`Applications by Motion. Except as otherwise specified herein, any application to
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`the Court shall be by written motion. Any non-dispositive motion should contain the statement
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`required by Local Rule 7 .1 .1.
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`14.
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`Application to Court for Protective Order. Should counsel find it will be
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`necessary to apply to the Court for a protective order specifying terms and conditions for the
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`disclosure of confidential information, counsel should confer and attempt to reach an agreement
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`on a proposed form of order and submit it to the Court within 10 days from the date the Court
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`enters this Order. Should counsel be unable to reach an agreement on a proposed form of order,
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`counsel must follow the provisions of Paragraph 4(g) above.
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`Any proposed protective order must include the following paragraph:
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`Other Proceedings. By entering this order and limiting the disclosure of
`information in this case, the Court does not intend to preclude another court from
`finding that information may be relevant and subject to disclosure in another case.
`Any person or party subject to this order who becomes subject to a motion to
`disclose another party' s information designated "confidential" [the parties should
`list any other level of designation, such as "highly confidential," which may be
`provided for in the protective order] pursuant to this order shall promptly notify
`that party of the motion so that the party may have an opportunity to appear and
`be heard on whether that information should be disclosed.
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`15.
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`Papers Filed Under Seal. In accordance with section G of the Revised
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`Administrative Procedures Governing Filing and Service by Electronic Means, a redacted
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`version of any sealed document shall be filed electronically within 7 days of the filing of the
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`sealed document.
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`11
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`16.
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`Courtesy Copies. The parties shall provide to the Court 2 courtesy copies of
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`filings (i.e., briefs, appendices, exhibits, declarations, affidavits etc.). Courtesy copies of
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`appendices and exhibits should include hard tabs. This provision also applies to papers filed
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`under seal.
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`17. Motions in Limine. Motions in limine shall not be separately filed. All in limine
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`requests and responses thereto shall be set forth in the proposed pretrial order. Each SIDE shall
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`be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine
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`request and any response shall contain the authorities relied upon; each in limine request may be
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`supported by a maximum of 3 pages of argument, may be opposed by a maximum of 3 pages of
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`argument, and the side making the in limine request may add a maximum of 1 additional page in
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`reply in support of its request. If more than one party is supporting or opposing an in limine
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`request, such support or opposition shall be combined in a single 3 page submission ( and, if the
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`moving party, a single 1 page reply), unless otherwise ordered by the Court. No separate briefing
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`shall be submitted on in limine requests, unless otherwise permitted by the Court.
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`18.
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`Pretrial Conference. On April 10, 2025, the Court will hold a pretrial conference
`3:00 P""
`in Court with counsel beginning at -9-tt:m. Unless otherwise ordered by the Court, the parties
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`should assume that filing the pretrial order satisfies the pretrial disclosure requirement of Federal
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`Rule of Civil Procedure 26( a)(3). The parties shall file with the Court the joint proposed final
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`pretrial order in compliance with Local Rule 16.3(c) and the Court' s Preferences and Procedures
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`for Civil Cases not later thJ~ days before the pretrial conference. Unless otherwise ordered by
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`the Court, the parties shall comply with the time:frames set forth in Local Rule 16.3( d)(l)-(3) for
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`the preparation of the joint proposed final pretrial order.
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`12
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`The parties shall provide the Court 2 courtesy copies of the joint proposed final pretrial
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`order and all attachments. The proposed final pretrial order shall contain a table of contents and
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`the paragraphs shall be numbered.
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`19.
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`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a case is to be
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`tried to a jury, pursuant to Local Rules 47.l(a)(2) and 51.1 the parties should file (i) proposed
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`voir dire, (ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict
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`forms 7 business days before the final pretrial conference. This submission shall be accompanied
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`by a courtesy copy containing electronic files of these documents, in Microsoft Word format,
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`which may be submitted by e-mail to gbw_civil@ded.uscourts.gov.
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`20.
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`Trial. This matter is scheduled for a\ day jury trial beginning at 9:30 a.m. on
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`April 21, 2025, with the subsequent trial days beginning at 9:30 a.m. Until the case is submitted
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`to the jury for deliberations, the jury will be excused each day at 5 :30 p.m. The trial will be
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`timed, as counsel will be allocated a total number of hours in which to present their respective
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`cases.
`
`21.
`
`Judgment on Verdict and Post-Trial Status Report. Within 7 days after a jury
`
`returns a verdict in any portion of a jury trial, the parties shall jointly submit a form of order to
`
`enter judgment on the verdict. At the same time, the parties shall submit a joint status report,
`
`indicating among other things how the case should proceed and listing any post-trial motions
`
`each party intends to file.
`
`22.
`
`Post-Trial Motions. Unless otherwise ordered by the Court, all SIDES are limited
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`to a maximum of 20 pages of opening briefs, 20 pages of answering briefs, and 10 pages of reply
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`briefs relating to any post-trial motions filed by that side, no matter how many such motions are
`
`filed.
`
`13
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`ABB Inc. Exhibit 1013, Page 13 of 16
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
`
`

`

`Case 1:22-cv-01257-GBW Document 48 Filed 08/30/23 Page 14 of 16 PageID #: 851
`
`23.
`
`ADR Process. This matter is referred to magistrate judge to explore the
`
`possibility of alternative dispute resolution.
`
`The Honorable Gregory B. Williams
`United States District Judge
`
`14
`
`ABB Inc. Exhibit 1013, Page 14 of 16
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
`
`

`

`Case 1:22-cv-01257-GBW Document 48 Filed 08/30/23 Page 15 of 16 PageID #: 852
`
`Counsel Shall Provide a Chart of All Relevant Deadlines
`
`EVENT
`Plaintiff shall identify the accused products, damages
`model, asserted patents, and produce the file history
`for each asserted patent. Plaintiff shall also identify its
`alleged trade secrets with particularity.
`
`DEADLINE
`
`Completed
`
`Plaintiff shall serve amended Rule 26(a) disclosures & Within 5 days from the entry of this
`paragraph 3(a) disclosures, and Defendant shall serve
`Scheduling Order
`Rule 26(a) disclosures & paragraph 3(a) disclosures.
`
`Defendant produces core technical documents,
`including operation manuals, product literature,
`schematics, specifications, and source code.
`Defendant shall also produce sales figures for the
`accused products.
`
`Plaintiff shall produce an initial infringement
`contention claim chart.
`
`Defendant shall produce its initial invalidity
`contentions for each asserted claim, as well as the
`known related invalidating references
`
`Parties shall exchange a list of terms and their
`proposed claim constructions.
`
`Parties respond to claim constructions presented by
`the other side for which the party did not initially
`provide a construction.
`
`August 30, 2023
`
`November 8, 2023
`'
`
`December 15, 2023
`
`December 22, 2023
`
`January 5, 2024
`
`Meet and confer to prepare a Joint Claim Construction
`Chart
`
`January 12, 2024
`
`Plaintiff shall serve opening claim construction brief
`
`February 2, 2024
`
`Defendant shall serve answering claim construction
`brief
`
`February 23, 2024
`
`Plaintiff shall serve reply claim construction brief.
`
`March 8, 2024
`
`Defendant shall serve sur-reply claim construction
`brief
`
`March 22, 2024
`
`Parties shall file Joint Claim Construction Brief.
`
`March 29, 2024
`
`15
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`ABB Inc. Exhibit 1013, Page 15 of 16
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
`
`

`

`Case 1:22-cv-01257-GBW Document 48 Filed 08/30/23 Page 16 of 16 PageID #: 853
`
`EVENT
`Hearing on Claim Construction
`
`Deadline for joinder and amending pleadings
`
`DEADLINE
`
`2024
`~
`Mo:y I>
`45 days after Defendants answer
`complaint
`
`Document production shall be substantially complete
`
`May 17, 2024
`
`Final infringement contentions
`
`Final invalidity contentions
`
`Interim Status Report
`
`Close of fact discovery
`
`Opening Expert Reports.
`
`Rebuttal Expert Reports
`
`Reply expert reports
`
`Close of Expert Discovery
`
`Opening case dispositive motions
`
`Pretrial Conference
`
`Trial begins
`
`June 5, 2024
`
`June 19, 2024
`
`June 21 , 2024
`
`July 5, 2024
`
`August 2, 2024
`
`August 30, 2024
`
`September 20, 2024
`
`October 23 , 2024
`
`November 20, 2024
`
`April 10, 2025
`
`April 21 , 2025
`
`16
`
`ABB Inc. Exhibit 1013, Page 16 of 16
`ABB Inc. v. Roboticvisiontech, Inc.
` IPR2023-01426
`
`