Implicit Networks, Inc. v. Juniper Networks, Inc.

Filing 46

STIPULATION AND ORDER Granting Leave to Serve Amended Disclosures. Signed by Judge Susan Illston on 12/12/2011. (rbe, COURT STAFF) (Filed on 12/12/2011)

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SPENCER HOSIE (CA Bar No. 101777)
[e-mail]
GEORGE F. BISHOP (CA Bar No. 89205)
[e-mail]
DIANE S. RICE (CA Bar No. 118303)
[e-mail]
WILLIAM P. NELSON (CA Bar No. 196091)
[e-mail]
HOSIE RICE LLP
Transamerica Pyramid, 34th Floor
600 Montgomery Street
San Francisco, CA 94111
[phone] Tel.
[phone] Fax

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Attorneys for Plaintiff
IMPLICIT NETWORKS, INC.

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Additional Attorneys Listed on Signature Page

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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IMPLICIT NETWORKS, INC.,
Case No. C 10-4234 SI

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Plaintiff,

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v.

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JUNIPER NETWORKS, INC.,

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Defendant.

STIPULATED MOTION FOR
LEAVE TO SERVE AMENDED
DISCLOSURES UNDER PATENT
LOCAL RULES 3-1 TO 3-4 AND
[PROPOSED] ORDER

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Pursuant to Civil Local Rule 7-12 and Patent Local Rule 3-6, Plaintiff Implicit
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Networks, Inc. (“Plaintiff”) and Defendant Juniper Networks, Inc. (“Defendant”) hereby
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stipulate through their respective counsel of record as follows:
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STIPULATED MOTION FOR LEAVE TO SERVE
AMENDED DISCLOSURES AND [PROPOSED]
ORDER

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Case No. C 10-4234 SI

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WHEREAS, on May 23, 2011, Plaintiff served its disclosures under Patent Local
Rules 3-1 and 3-2 (“infringement contentions”);

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WHEREAS, on July 22, 2011, Defendant served its disclosures under Patent
Local Rules 3-3 and 3-4 ("invalidity contentions");

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WHEREAS, the parties have recently learned additional information pertinent to

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these infringement and invalidity contentions based on ongoing discovery and

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disclosures exchanged in connection with the claim construction proceedings in this

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case;

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WHEREAS, Plaintiff seeks also to streamline its contentions in this case by

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narrowing contentions as to alleged infringement by certain products or services; and

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WHEREAS, Plaintiff has already, on November 15, 2011, served its amended

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infringement contentions on Defendant; and
WHEREAS, in light of Plaintiff’s amended infringement contentions, Defendant
seeks to amend its invalidity contentions no later than January 31, 2012.
NOW THEREFORE the parties through their undersigned counsel, pursuant to
Patent Local Rule 3-6, hereby stipulate and request the Court to grant leave:
1. For Plaintiff to provide amended infringement contentions pursuant to Patent
Local Rules 3-1 and 3-2, as served on Juniper on November 15, 2011; and
2. For Defendant to provide amended invalidity contentions pursuant to Patent

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Local Rules 3-3 and 3-4, to be served on Plaintiff no later than January 31, 2012.

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IT IS SO STIPULATED.

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STIPULATED MOTION FOR LEAVE TO SERVE
AMENDED DISCLOSURES AND [PROPOSED]
ORDER

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Case No. C 10-4234 SI

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Dated: December 8, 2011

HOSIE RICE LLP

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By: /s/ George F. Bishop_______________
George F. Bishop
Attorneys for Plaintiff Implicit Networks, Inc.

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Dated: December 8, 2011

IRELL & MANELLA LLP

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By: /s/ Daniel P. Hipskind_____________
Daniel P. Hipskind

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Attorneys for Defendant Juniper Networks, Inc.

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I hereby attest pursuant to General Order 45.X.B. that concurrence in the

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electronic filing of this document has been obtained from the other signatories.

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DATED: December 8, 2011
/s/George F. Bishop
_______________________________
George F. Bishop

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STIPULATED MOTION FOR LEAVE TO SERVE
AMENDED DISCLOSURES AND [PROPOSED]
ORDER

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Case No. C 10-4234 SI

ORDER

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Pursuant to the stipulation of the parties, it is hereby ORDERED that leave is

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granted (1) for Plaintiff to provide amended infringement contentions pursuant to Patent

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Local Rules 3-1 and 3-2, as served on Juniper on November 15, 2011; and (2) for

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Defendant to provide amended invalidity contentions pursuant to Patent Local Rules 3-3

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and 3-4, to be served on Plaintiff no later than January 31, 2012.

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ston
usan Ill

NO

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Judge S

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UNIT
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DISTR

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_____________________________
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Honorable Susan Illston
United States District Judge

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Dated: December 12 2011
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PURSUANT TO STIPULATION IT IS SO ORDERED.

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N

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STIPULATED MOTION FOR LEAVE TO SERVE
AMENDED DISCLOSURES AND [PROPOSED]
ORDER

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Case No. C 10-4234 SI