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Rambus Inc v. International Business Machines Corporation

May 12, 2011

RAMBUS INC.,
PLAINTIFF,
v.
INTERNATIONAL BUSINESS MACHINES CORPORATION, ROBERT H. FISCHER
DEFENDANT.



The opinion of the court was delivered by: The Honorable Jeffrey S. White

Edward Kmett (CA Bar No. 204374) ekmett@fchs.com 2 FITZPATRICK, CELLA, HARPER & SCINTO 650 Town Center Drive 3 Suite 1600 Costa Mesa, CA 92626 4 Telephone: (714) 540-8700 Facsimile: (714) 540-9823 5 Anthony M. Zupcic (Pro Hac Vice) 6 azupcic@fchs.com Robert H. Fischer (Pro Hac Vice) 7 rfischer@fchs.com Douglas Sharrott (Pro Hac Vice) 8 dsharrott@fchs.com FITZPATRICK, CELLA, HARPER & SCINTO 9 1290 Avenue of the Americas New York, New York 10112 10 Telephone: (212) 218-2100 Facsimile: (212) 218-2200 11 Kenneth R. Adamo (Pro Hac Vice) 12 kradamo@kirkland.com KIRKLAND & ELLIS LLP 13 300 North LaSalle Chicago, IL 60654 14 Telephone: (312) 862-2671 Facsimile: (312) 862-2200 Attorneys For Defendant 16 International Business Machines Corporation 17

STIPULATION RE: CASESCHEDULE; SUPPORTING DECLARATION OF [PROPOSED] ORDER

Pursuant to Rule 6-2 and 7-12 of the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California, Plaintiff Rambus Inc. ("Rambus") 3 and Defendant International Business Machines Corporation ("IBM"), through their respective counsel 4 of record, wish to advise the Court that the parties have reached a settlement in principle, and 5 accordingly respectfully request, and with the Court's permission, stipulate to an additional two-week 6 extension of the current case schedule to allow the parties to prepare the necessary settlement papers. 7

More specifically, with the Court's permission, the parties hereby stipulate that the current schedule 8 set forth in the April 15, 2011, Stipulated Order [Dkt. 60] be modified as follows: 9

EVENT CURRENT SCHEDULE PROPOSED SCHEDULE

May 16, 2011 May 31, 2011 Exchange of Preliminary Claim Constructions and Extrinsic Evidence (Patent L.R. 4-2(a), (b)) 12

May 23, 2011 June 6, 2011 Meet and confer re Joint Claim Construction and Prehearing Statement (Patent L.R. 4-2(c)) Last day to request leave to May 27, 2011 June 10, 2011 designate additional terms for claims construction JSW 16 Standing Order ¶ 4

June 10, 2011 June 24, 2011 Joint Claim Construction and 17

Prehearing Statement (Patent

L.R. 4-3) -- Includes Expert 18

Testimony. Parties must attach copies of patents, make 19 available file histories to Court for each involved patent 20

Completion of Claim July 11, 2011 July 25, 2011 21

Construction Discovery (Patent

L.R. 4-3) 22

Rambus Opening Claim July 25, 2011 August 8, 2011 23

Construction Brief (Patent L.R. 4-5(a)). 25 page limit 24 CV 10-03736 JSW -- STIPULATION RE: CASE SCHEDULE; SUPPORTING

EVENT CURRENT SCHEDULE PROPOSED SCHEDULE

August 8, 2011 August 22, 2011 IBM Responsive Claim

Construction Brief (Patent L.R. 3

4-5(b)). 25 page limit 4

Rambus - Reply Brief and any August 15, 2011 August 29, 2011 evidence directly rebutting the 5 supporting evidence (Patent

L.R. 4-5(c)). - 15 page ...


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