Barnes & Noble Inc. v. LSI Corporation et al.

Filing 75

STIPULATION AND ORDER RE TIME FOR PATENT LOCAL RULE DISCLOSURES re 73 Stipulation filed by LSI Corporation, Agere Systems, Inc.. Signed by Judge Edward M. Chen on 12/28/11. (bpf, COURT STAFF) (Filed on 12/28/2011)

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QUINN EMANUEL URQUHART &
SULLIVAN, LLP
John B. Quinn (Bar No. 90378)
Shon Morgan (Bar No. 187736)
865 S Figueroa St 10th Floor
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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David Eiseman (Bar No. 114758)
Melissa J. Baily (Bar No. 237649)
Carl G. Anderson (Bar No. 239927)
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

CHARLENE M. MORROW (CSB NO.
136411)
[e-mail]
VIRGINIA K. DEMARCHI (CSB NO.
168633)
[e-mail]
HECTOR J. RIBERA (CSB NO. 221511)
[e-mail]
RYAN TYZ (CSB NO. 234895)
[e-mail]
RAVI RANGANATH (CSB NO. 272981)
[e-mail]
FENWICK & WEST LLP
Silicon Valley Center
801 California Street
Mountain View, California 94041
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
LSI Corporation and
Agere Systems Inc.

Attorneys for Plaintiffs
Barnes & Noble, Inc. and
barnesandnoble.com llc

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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BARNES & NOBLE, INC. and
BARNESANDNOBLE.COM LLC,

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Plaintiffs,
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v.
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LSI CORPORATION and
AGERE SYSTEMS INC.,

Case No. 11-cv-02709 EMC
JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
TIME FOR PATENT LOCAL RULE
DISCLOSURES
Trial Date: None set

Defendants.

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Pursuant to Local Rule 6-2, Plaintiffs Barnes & Noble, Inc. and Barnesandnoble.com LLC

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(“Plaintiffs”) and Defendants LSI Corporation and Agere Systems Inc. (“Defendants”)

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(collectively, the “Parties”), by and through their respective counsel of record, hereby stipulate

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and agree as follows:
STIPULATION REGARDING TIME FOR
PATENT LOCAL RULE DISCLOSURES

CASE NO.: 11-CV-02709 EMC

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WHEREAS, the Court, by Order dated November 2, 2011 [Dkt. No. 63], set a Case

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Management Conference in this matter for January 20, 2012, and required the Parties to file a

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joint case management conference statement by January 13, 2012;

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WHEREAS, the Court, by Order dated November 16, 2011 [Dkt. No. 65], granted the

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Parties’ Joint Stipulation giving Defendants until February 3, 2012 to serve their Disclosure of

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Asserted Claims and Infringement Contentions pursuant to Patent L.R. 3-1 and 3-5 and produce

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documents pursuant to Patent L.R. 3-2;

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WHEREAS, the Parties agree that Defendants shall have a sixty day extension until April
3, 2012 to serve their Disclosure of Asserted Claims and Infringement Contentions pursuant to
Patent L.R. 3-1 and 3-5 and produce documents pursuant to Patent L.R. 3-2;

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WHEREAS, the Parties further agree that all other deadlines for disclosures pursuant to

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F ENWICK & W EST LLP

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the Court’s Patent Local Rules shall likewise be extended by a period of sixty days, and that the

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Parties will provide the Court a complete proposed case schedule in conjunction with their Joint

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Case Management Statement and Rule 26 Report;

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WHEREAS, Defendants believe this extension is appropriate in view of the pending status
of the protective order and Plaintiffs’ recently released model of the accused NOOKTM devices;

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WHEREAS, the Parties do not expect that these proposed extensions will impact the

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schedule ultimately set by the Court or alter the date of any event or deadline already fixed by

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Court Order, with the exception of the date set forth in the Court’s November 16, 2011 Order

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granting the Parties’ prior Joint Stipulation [Dkt. No. 65];

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THE PARTIES HEREBY STIPULATE that Defendants shall have until April 3, 2012 to

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serve their Disclosure of Asserted Claims and Infringement Contentions pursuant to Patent L.R.

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3-1 and 3-5 and produce documents pursuant to Patent L.R. 3-2, all other deadlines for

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disclosures pursuant to the Court’s Patent Local Rules shall likewise be extended by a period of

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sixty days, and the Parties will provide the Court a case schedule providing a complete proposed

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case schedule in conjunction with their Joint Case Management Statement and Rule 26 Report.

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///
///

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STIPULATION REGARDING TIME FOR
PATENT LOCAL RULE DISCLOSURES

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CASE NO.: 11-CV-02709 EMC

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Dated: December 23, 2011

FENWICK & WEST LLP

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By: /s/ Ravi Ranganath
Ravi Ranganath
Attorneys for Defendants
LSI Corporation and Agere Systems Inc.

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Dated: December 23, 2011

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By: /s/ Carl G. Anderson
Carl G. Anderson
Attorneys for Plaintiffs
Barnes & Noble, Inc. and
barnesandnoble.com LLC

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PURSUANT TO STIPULATION, IT IS SO
ORDERED.
DISTR

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Edward M. Chen O ORDERED
United StatesIS S
IT District Judge

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STIPULATION REGARDING TIME FOR
PATENT LOCAL RULE DISCLOSURES

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CASE NO.: 11-CV-02709 EMC

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ATTESTATION PURSUANT TO GENERAL ORDER 45

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Pursuant to General Order No. 45, § X(B), regarding signatures, I attest under penalty of

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perjury that the concurrence in the filing of this document has been obtained from its signatories.

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Dated: December 23, 2011

FENWICK & WEST LLP

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By: /s/ Ravi Ranganath
Ravi Ranganath
Attorneys for Defendants
LSI Corporation and Agere Systems Inc.

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F ENWICK & W EST LLP

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STIPULATION REGARDING TIME FOR
PATENT LOCAL RULE DISCLOSURES

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CASE NO.: 11-CV-02709 EMC