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Rambus Inc v. International Business Machines Corporation

July 12, 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 3 Srikala P. Atluri (Admitted Pro Hac Vice) srikala.atluri@finnegan.com 4 FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 5 901 New York Avenue, N.W. Washington, D.C. 20001 6 Telephone: (202) 408-4000 Facsimile: (202) 408-4400 7 Tina E. Hulse (CA Bar No. 232936) 8 tina.hulse@finnegan.com FINNEGAN, HENDERSON, FARABOW, 9 GARRETT & DUNNER, L.L.P. 3300 Hillview Avenue 10 Palo Alto, California 94304-1203 Telephone: (650) 849-6600 11 Facsimile: (650) 849-6666 12 Attorneys for Plaintiff Rambus Inc.

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

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 one-week extension of certain 4 dates in the current case schedule. Because the parties' settlement negotiations have not progressed, 5 with the last discussion between the parties being just this past Friday on July 8, 2011, a one-week 6 extension is requested of four upcoming deadlines: three under the Patent Local Rules and one under 7 the Court's Standing Order for Patent Cases. By this extension, the parties do not request modifying 8 the previously-ordered briefing schedule for claim construction or the dates for the Court's 9 technology tutorial or claim construction hearing. More specifically, with the Court's permission, 10 the parties hereby stipulate that the current schedule set forth in the June 15, 2011, Stipulated Order

[Dkt. 66] be modified as follows:

EVENT CURRENT SCHEDULE PROPOSED DATE

Exchange of Preliminary Claim July 11, 2011 July 18, 2011 14 Constructions and Extrinsic Evidence (Patent L.R. 4-2(a), 15 (b)) Meet and confer re Joint Claim July 18, 2011 July 25, 2011 Construction and Prehearing Statement (Patent L.R. 4-2(c)) Last day to request leave to July 22, 2011 July 29, 2011 19 designate additional terms for claims construction JSW

Standing Order ¶ 4 21

Joint Claim Construction and August 5, 2011 August 12, 2011 Prehearing Statement (Patent 22

L.R. 4-3) -- Includes Expert 23

Testimony. Parties must attach copies of patents, make 24 available file histories to Court for each involved patent 25

Completion of Claim September 6, 2011 Same 26

Construction Discovery (Patent 27 L.R. 4-3)

EVENT CURRENT SCHEDULE PROPOSED DATE

Rambus Opening Claim September 19, ...


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