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Rambus Inc v. International Business Machines Corporation

May 31, 2011

RAMBUS INC.,
PLAINTIFF,
v.
INTERNATIONAL BUSINESS MACHINES CORPORATION,
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 2 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) 849-6600 Facsimile: (650) 849-6666 Attorneys for Plaintiff Rambus Inc.

STIPULATION RE: CASE SCHEDULE; SUPPORTING DECLARATION OF TINA E. HULSE;

[PROPOSED] ORDER AS MODIFIED

Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Rambus Inc. ("Rambus") and Defendant International Business Machines Corporation ("IBM"), through their respective counsel of record, 3 respectfully request, and with the Court's permission, stipulate to a two-week extension of the 4 current case schedule to allow the parties to finalize the settlement agreement and associated papers.

The parties note that they have exchanged drafts and are currently working on finalizing the papers.

More specifically, with the Court's permission, the parties hereby stipulate that the current schedule 7 set forth in the May 12, 2011, Stipulated Order [Dkt. 62] be modified as follows:

EVENT CURRENT SCHEDULE PROPOSED DATE

Exchange of Preliminary Claim May 31, 2011 June 13, 2011 10 Constructions and Extrinsic Evidence (Patent L.R. 4-2(a), (b))

Meet and confer re Joint Claim June 6, 2011 June 20, 2011 Construction and Prehearing Statement (Patent L.R. 4-2(c))

Last day to request leave to June 10, 2011 June 24, 2011 15 designate additional terms for claims construction JSW Standing Order ¶ 4 Joint Claim Construction and June 24, 2011 July 8, 2011 Prehearing Statement (Patent L.R. 4-3) -- Includes Expert Testimony. Parties must attach copies of patents, make 20 available file histories to Court for each involved patent Completion of Claim July 25, 2011 August 8, 2011 Construction Discovery (Patent L.R. 4-3)

Rambus Opening Claim August 8, 2011 August 22, 2011 Construction Brief (Patent L.R. 4-5(a)). 25 page limit

IBM Responsive Claim August 22, 2011 September 6, 2011

Construction Brief (Patent L.R. 4-5(b)). ...


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