`
`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`MEDALLIA INC.,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`CONTENT SQUARE SAS,
`
`
`Defendant.
`
`
`
`
`
`
`
`CASE NO. 6:21-cv-00532-ADA
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`
`
`
`
`JURY TRIAL DEMANDED
`
`
`CASE READINESS STATUS REPORT
`
`Plaintiff Medallia Inc. (“Plaintiff” or “Medallia”) and Defendant Content Square SAS
`
`(“Defendant” or “Content Square”), hereby provide the following status report in advance of the
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`initial Case Management Conference (“CMC”).
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`FILING AND EXTENSIONS
`
`Plaintiff’s Complaint was filed on May 26, 2021 (Dkt. 1). There were two extensions to
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`respond to the Complaint (Dkt. 16; Dkt. 19), extending the deadline by a total of approximately
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`45 days. Defendant responded to the Complaint with a Motion to Dismiss, filed on August 24,
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`2021 (Dkt. 20). Plaintiff responded to the Motion to Dismiss by filing an Amended Complaint
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`on September 14, 2021 (Dkt. 26). There has been one extension to respond to the Amended
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`Complaint (Dkt. 28), extending the deadline by a total of approximately 14 days.
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`RESPONSE TO THE COMPLAINT
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`Defendant’s response to the Amended Complaint is currently due October 12, 2021 (Dkt.
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`28).
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`1
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`Case 6:21-cv-00532-ADA Document 32 Filed 10/05/21 Page 2 of 4
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`PENDING MOTIONS
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`There are no pending motions. Defendant reserves its rights to file a motion to dismiss as
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`part of its response to the Amended Complaint, currently due October 12, 2021.
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`RELATED CASES IN THIS JUDICIAL DISTRICT
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`There are no related cases in this Judicial District.
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`IPR, CBM, AND OTHER PGR FILINGS
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`There are no known IPR, CBM, or other PGR filings.
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`NUMBER OF ASSERTED PATENTS AND CLAIMS
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`Plaintiff has asserted one patent, U.S. Patent No. 8,886,552, with a total of 19 claims.
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`Plaintiff will identify specific asserted claims no later than seven days before the CMC in
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`accordance with this Court’s procedures.
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`APPOINTMENT OF TECHNICAL ADVISER
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`Plaintiff does not believe a technical advisor is necessary in this case, but has no
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`objection to the Court’s use of Dr. Yi., the Court’s technical advisor, if it feels such would be
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`beneficial.
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`Defendant does not currently believe a technical advisor is necessary in this case, but will
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`revisit once the claim construction disputes, if any, are better identified.
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`MEET AND CONFER STATUS
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`Plaintiff and Defendant continue to meet and confer regarding Medallia’s contention that
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`Cooley LLP, Content Square’s lead counsel, should be disqualified from this matter given its
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`former representation of Medallia. Defendant does not agree that a conflict exists and contends
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`that disqualification is not warranted. Should the parties fail to resolve the issue, Medallia
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`2
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`Case 6:21-cv-00532-ADA Document 32 Filed 10/05/21 Page 3 of 4
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`anticipates filing a motion with the Court. The parties have no other pre-Markman issues to raise
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`at the CMC.
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`Dated: October 5, 2021
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`Respectfully Submitted,
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`By: /s/ Melissa R. Smith
` Karineh Khachatourian (CA SBN 202634) (Pro
`Hac Vice)
`karineh.k@rimonlaw.com
`Amir A. Tabarrok (CA SBN 238781) (Pro Hac
`Vice)
`amir.tabarrok@rimonlaw.com
`David T. Xue (CA SBN 256668) (Pro Hac Vice)
`david.xue@rimonlaw.com
`Nikolaus A. Woloszczuk (CA SBN 286633) (Pro
`Hac Vice)
`nikolaus.woloszczuk@rimonlaw.com
`Oren J. Torten (CA SBN 332720) (Pro Hac Vice)
`oren.torten@rimonlaw.com
`RIMON, P.C.
`2445 Faber Place, Suite 250
`Palo Alto, California 94303
`Telephone: 650.461.4433
`Facsimile: 650.461.4433
`
`MELISSA R. SMITH (TX SBN 24001351)
`melissa@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Telephone: 903-934-8450
`Facsimile: 903-934-9257
`
`Attorneys for Plaintiff, MEDALLIA, INC.
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`3
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`Case 6:21-cv-00532-ADA Document 32 Filed 10/05/21 Page 4 of 4
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`By: /s/ Deron R Dacus
` Deron R Dacus (TX SBN 00790553)
`THE DACUS FIRM, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, TX 75701
`Telephone: 903-705-1117
`Facsimile: 903-581-2543
`ddacus@dacusfirm.com
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`Attorneys for Defendant, CONTENT SQUARE
`SAS
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that the foregoing document was filed electronically with the
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`Clerk of Court using the CM/ECF system, which will send notification of such filing to all
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`counsel of record on October 5, 2021.
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`/s/ Melissa R. Smith
`Melissa Smith
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`4
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