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International Business Machines Corporation v. Rambus Inc

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


April 15, 2011

INTERNATIONAL BUSINESS MACHINES CORPORATION, PLAINTIFF,
v.
RAMBUS INC.,
DEFENDANT.

The opinion of the court was delivered by: The Honorable Jeffrey S. White United States District Judge Northern District of California

Barbara Clarke McCurdy (Admitted Pro Hac Vice) barbara.mccurdy@finnegan.com Naveen Modi (Admitted Pro Hac Vice) naveen.modi@finnegan.com Srikala P. Atluri (Admitted Pro Hac Vice) srikala.atluri@finnegan.com FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, N.W. Washington, D.C. 20001 Telephone: (202) 408-4000 Facsimile: (202) 408-4400 Tina E. Hulse (CA Bar No. 232936) 8 tina.hulse@finnegan.com FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 3300 Hillview Avenue Palo Alto, California 94304-1203 Telephone: (650) 849-660 Facsimile: (650) 849-6666 Attorneys for Defendant Rambus Inc.

STIPULATION RE: CASE SCHEDULE; SUPPORTING DECLARATION OF TINA E. HULSE; [PROPOSED] ORDER

Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff International Business Machines Corporation ("IBM") and Defendant Rambus Inc. ("Rambus"), through their respective counsel of 3 record, respectfully request, and with the Court's permission, stipulate to a four-week extension of 4 the current case schedule to allow the parties to effectively discuss settlement. More specifically, 5 with the Court's permission, the parties hereby stipulate that the current schedule set forth in the January 18, 2011, Civil Minute Order [Dkt. 38] be modified as follows:

EVENT CURRENT SCHEDULE PROPOSED DATE

Rambus shall file opening June 24, 2011 July 22, 2011 9 summary judgment motion IBM shall file opposition and July 8, 2011 August 5, 2011 cross-motion for summary 12 judgment Rambus shall file reply and July 22, 2011 August 19, 2011 14 opposition to cross-motion for summary judgment IBM shall file reply in support July 29, 2011 August 26, 2011 16 of cross-motion for summary judgment 17 Hearing on Cross-Dispositive August 26, 2011 September 23, 2011, or any Motions later date, subject to the 19 convenience of the Court's calendar

By her signature below, counsel for Defendant attests that counsel for Plaintiff concurs in the filing of this stipulation.

Respectfully submitted,

SUPPORTING DECLARATION OF TINA E. HULSE

I, TINA E. HULSE, declare as follows: 3

1. I am an associate at Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P., counsel for Defendant Rambus Inc. ("Rambus"). I submit this declaration in support of the parties' 5 Stipulation Regarding Case Schedule. I make this declaration of my own personal knowledge and 6 will competently testify thereto if called upon to do so.

2. On January 18, 2011, the Court entered a Civil Minute Order ("Order") [Dkt. 38] following the initial Case Management Conference. The Order set forth a briefing schedule for 9 cross-motions for summary judgment. The Order also set the hearing on cross-dispositive motions 10 for August 26, 2011, at 9:00 a.m. 11

3. The parties, both the respective corporate representatives and outside counsel, have been actively discussing resolution of this case. Accordingly, the parties have met and conferred and 13 agree that continuing the case schedule for four weeks will facilitate these settlement discussions.

4. There have been no previous time modifications of the case schedule set forth in the Order. Otherwise, the only time modification in this case was to change the Case Management Conference from December 3, 2010, to January 14, 2011, to coincide with the hearing on Rambus's 17 motion to dismiss. See Dkt. 30.

5. The requested modification in the current case schedule will not affect any other pre-trial 19 deadlines, as the pre-trial schedule has not yet been entered in this case.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct, and this declaration was executed this 14th day of April, 2011.22

Tina E. Hulse

Tina E. Hulse

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: April __, 2011

20110415

© 1992-2011 VersusLaw Inc.



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