IconFind, Inc. v. Google, Inc.

Filing 71

STIPULATION and PROPOSED ORDER for Additional Claim Construction Deadlines by IconFind, Inc.. (Baxter, Daniel)

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WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP
THOMAS G. REDMON (SBN 047090)
DANIEL L. BAXTER (SBN 203862)
400 Capitol Mall, Twenty-Second Floor
Sacramento, CA 95814
Telephone:
[phone]
Facsimile:
[phone]
NIRO, HALLER & NIRO
RAYMOND NIRO, JR. (admitted pro hac vice)
ANNA B. FOLGERS (admitted pro hac vice)
BRIAN E. HAAN (admitted pro hac vice)
181 West Madison Street
Chicago, IL 60602
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff ICONFIND, INC.
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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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ICONFIND, INC,

Case No. 2:11-CV-00319 GEB JFM
Plaintiff,

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v.

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GOOGLE INC.

STIPULATION AND [PROPOSED]
ORDER SETTING ADDITIONAL CLAIM
CONSTRUCTION DEADLINES
Complaint Filed: February 3, 2011

Defendant.

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WILKE, FLEURY,
HOFFELT, GOULD &
BIRNEY, LLP

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ATTORNEYS AT LAW

STIPULATION AND ORDER RE ADDITIONAL CLAIM CONSTRUCTION DEADLINES (Case No. 11-00319 GEB JFM)

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RECITALS

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On June 7, 2011, the Court issued its Status (Pretrial Scheduling) Order. (CM/ECF Doc.

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No. 55.) In that Order, the Court set the claim construction hearing in this matter for July 23,

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2012, with the parties to file their Joint Claim Construction Statement by May 11, 2012.

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Recent discussions between Plaintiff ICONFIND INC. and Defendant GOOGLE INC.

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have elicited a mutually-held desire to install additional deadlines relating to the claim

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construction process, all of which are consistent with the above-mentioned deadlines already

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imposed by the Court. The additional deadlines agreed to by the parties are set forth below.

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STIPULATION

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Given the above, the parties HEREBY STIPULATE, subject to the Court’s approval, that

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the below claim construction-related deadlines shall operate in this matter. (Note that the dates

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already ordered by the Court are italicized and bolded, while the newly-added dates are in regular

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text.)

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1.

February 13, 2012: Last day for each party to serve on the other its Proposed

Terms for Construction.
2.

March 28, 2012:

Last day for the parties to simultaneously exchange their

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Proposed Claim Constructions and Extrinsic Evidence. (Simultaneous exchange to occur at a

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specific time of the parties’ choosing.)

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3.

May 11, 2012: Last day for the parties to file their Joint Claim Construction and

Prehearing Statement.
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May 15, 2012: Last day for each party to file its opening claim construction brief

and supporting evidence.
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June 12, 2012: Last day for each party to serve and file its responsive claim

construction brief and supporting evidence.
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June 25, 2012 at 9:00 a.m.: In-court tutorial described at Paragraph 6 of the

Court’s June 7, 2011 Order.

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7.

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All specifications set forth in the Court’s June 7, 2011 Order remain fully operative.

July 23, 2012 at 9:00 a.m.: Claim construction hearing.

WILKE, FLEURY,
HOFFELT, GOULD &
BIRNEY, LLP

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ATTORNEYS AT LAW

STIPULATION AND ORDER RE ADDITIONAL CLAIM CONSTRUCTION DEADLINES (Case No. 11-00319 GEB JFM)

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IT IS SO STIPULATED.
DATED: October 5, 2011

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WILKE, FLEURY, HOFFELT,
GOULD & BIRNEY, LLP

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By:

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/s/ Daniel L. Baxter
DANIEL L. BAXTER
Attorneys for Plaintiff
ICONFIND, INC.

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DATED: October 5, 2011

KAYE SCHOLER LLP

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By:

/s/ Kenneth Maikish
KENNETH MAIKISH
Attorneys for Defendant
GOOGLE INC.

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ORDER

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IT IS SO ORDERED.

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DATED:
UNITED STATES DISTRICT JUDGE

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719723.1

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WILKE, FLEURY,
HOFFELT, GOULD &
BIRNEY, LLP

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ATTORNEYS AT LAW

STIPULATION AND ORDER RE ADDITIONAL CLAIM CONSTRUCTION DEADLINES (Case No. 11-00319 GEB JFM)