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) firstname.lastname@example.org Naveen Modi (Admitted Pro Hac Vice) email@example.com Srikala P. Atluri (Admitted Pro Hac Vice) firstname.lastname@example.org 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 email@example.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
STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE
Joint Claim Construction and Prehearing Statement (Patent L.R. 4-3) -- Includes Expert Testimony. Parties must attach copies of patents, make available file histories to Court for each involved patent August 19, 2011 August 26, 2011
Completion of Claim Construction Discovery (Patent L.R. 4-4) September 6, 2011 September 27, 2011
Rambus Opening Claim Construction Brief (Patent L.R. 4-5(a)). 25 page limit September 19, 2011 October 11, 2011
IBM Responsive Claim Construction Brief (Patent L.R. 4-5(b)). 25 page limit October 4, 2011 October 25, 2011
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 three-week extension of the 4 current case schedule. In the last several weeks, the parties have resumed active settlement 5 discussions and believe that they can reach an agreement shortly to resolve this matter and related 6 case, International Business Machines Corp. v. Rambus Inc., No. C 10-04017 JSW. 7
Specifically, the parties seek a one-week extension of the deadline for submission of the Joint Claim Construction and Prehearing Statement, and a three-week extension of each of the succeeding 9 dates, including the date of the claim construction hearing. Due to compression of the scheduling 10 occasioned by previous extensions that left that claim construction hearing date unchanged, any 11 further schedule extension necessitates movement of the hearing date, as well. The proposed 12 schedule therefore generally restores the intervals between dates as per the original schedule. 13
More specifically, with the Court's permission, the parties hereby stipulate that the current 14 schedule set forth in the August 11, 2011, Stipulated Order [Dkt. 70] be modified as follows: 15
EVENT CURRENT SCHEDULE PROPOSED DATE
Rambus - Reply Brief and any evidence directly rebutting the supporting evidence (Patent L.R. 4-5(c)). 15 page limit Amended Joint Claim Construction Statement October 11, 2011 November 1, 2011
Tutorial for the Court November 1, 2011 November 22, 2011, or any later date, subject to the convenience of the ...