Mount Hamilton Partners LLC v. Google Inc.

Filing 96

ORDER Further Case Management Conference set for 5/10/13 is continued to 8/23/2013 03:00 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 5/9/13. (tfS, COURT STAFF) (Filed on 5/9/2013)

1 James T. Hultquist (pro hac vice)
2
3
4
5

Jenna F. Karadbil
[e-mail]
California State Bar No. 213574
PILLSBURY WINTHROP SHAW
PITTMAN LLP
1540 Broadway
New York, New York 10036
Telephone: [phone]
Facsimile: [phone]

[e-mail]
Khurram N. Gore (pro hac vice)
Adrian Shin (CA State Bar No. 256960)
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]

6
Attorneys for Defendant

Callie A. Bjurstrom
[e-mail]
California State Bar No. 137816
PILLSBURY WINTHROP SHAW
PITTMAN LLP
501 West Broadway
San Diego, California 92101
Telephone: [phone]
Facsimile: [phone]

7 GROUPON, INC.

8 James F. Valentine, CA SB# 149269
9 [e-mail]
James C. Pistorino, CA SB# 226496

10 [e-mail]
PERKINS COIE LLP

11 3150 Porter Drive

Palo Alto, CA 94304-1212

12 Telephone: [phone]
13 Facsimile: 650.838.4350

Attorneys for Plaintiff
MOUNT HAMILTON PARTNERS, LLC

14 Attorneys for Defendant
15

GOOGLE, INC.
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

17

SAN FRANCISCO DIVISION

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MOUNT HAMILTON PARTNERS, LLC,

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Plaintiff/Counterdefendant,
v.

STIPULATION AND [PROPOSED]
ORDER CONTINUING FURTHER CASE
MANAGEMENT CONFERENCE
[Civ. L.R. 6-2 & 7-12]

23 GOOGLE, INC.,
24

Case No. 3:12-CV-1698-SI

Defendant/Counterclaimant.

25
26
27
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Case Nos. C-12-1698 and
C-12-1700

STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1 MOUNT HAMILTON PARTNERS, LLC,
2

Case No. 3:12-CV-1700-SI

Plaintiff/Counterdefendant,

3

v.

4
5

GROUPON, INC.,

6

Defendant/Counterclaimant.

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8

Pursuant to Local Rules 6-2 and 7-12, Plaintiff Mount Hamilton Partners, LLC (“MHP” or

9 “Plaintiff”) and Defendants1 Groupon, Inc. (“Groupon”) and Google, Inc. (“Google”)
10 (collectively, “Defendants”), by and through their respective undersigned counsel, hereby jointly
11 move the Court for an order continuing the scheduled date for a Further Case Management
12 Conference, for the following reasons:
13

1.

Pursuant to this Court’s September 25, 2012 Case Management Conference Order

14 (Dkt. No. 47), the parties are required to participate in a Further Case Management Conference on
15 May 10, 2013.
16

2.

On May 3, 2013, this Court continued the Claim Construction Tutorial and Claim

17 Construction Hearing to June 20, 2013 and June 26, 2013, respectively.
18
3.
Accordingly, because it is the belief of the parties that holding a Further Case
19 Management Conference after the date of the Claim Construction Hearing in this case will be
20 more efficient for this Court and the parties, the parties hereby stipulate to and request the Court to
21 continue the Further Case Management Conference from May 10 to August 23, 2013 at 3:00 p.m.
22 or such other date and time that is agreeable with the Court’s calendar. The requested continuance
23 does not affect any other deadline ordered by the Court.
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1

The two above captioned cases (Mount Hamilton Partners, LLC v. Google Inc., Case No. 3:12-

27 cv-1698-SI (“Google case”); Mount Hamilton Partners, LLC v. Groupon, Inc., Case No. 3:12-cv28 1700-SI (“Groupon case”)) were consolidated for claim construction purposes only.
-2Case Nos. C-12-1698 and
C-12-1700

STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1
2

Dated: May 8, 2013

3
By:

4
5

/s/ Callie Bjurstrom
CALLIE A. BJURSTROM
JENNA F. KARADBIL
Attorneys for Plaintiff
MOUNT HAMILTON PARTNERS, LLC

6
7
8 Dated: May 8, 2013
9
10

By:

11
12
13

Attorneys for Defendant
GROUPON, INC.

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15

/s/ Adrian Shin
JAMES T. HULTQUIST
KHURRAM NASIR GORE
ADRIAN SHIN

Dated: May 8, 2013

16
By:

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18

/s/ James F. Valentine
JAMES F. VALENTINE
Attorney for Defendant
GOOGLE INC.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

22
5/9
23 Dated: ___________, 2013

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25
HONORABLE SUSAN ILLSTON
UNITED STATES DISTRICT COURT JUDGE

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-3Case Nos. C-12-1698 and
C-12-1700

STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

SIGNATURE ATTESTATION

1
2
3

I, Adrian Shin, hereby attest, pursuant to N.D. Cal. General Order No. 45, that the
concurrence to the filing of this document has been obtained from each signatory hereto.

4 Dated: May 8, 2013

REED SMITH LLP

5
6

By: /s/ Adrian Shin
Adrian Shin
Attorneys for Defendant

7
8

GROUPON, INC.

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10
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15
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27
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-4Case Nos. C-12-1698 and
C-12-1700

STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1
2
3
4
5
6
7
8
9

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10
11
12
13
14

James T. Hultquist (pro hac vice)
[e-mail]
Khurram N. Gore (pro hac vice)
Adrian Shin (CA State Bar No. 256960)
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
GROUPON, INC.
James F. Valentine, CA SB# 149269
[e-mail]
James C. Pistorino, CA SB# 226496
[e-mail]
PERKINS COIE LLP
3150 Porter Drive
Palo Alto, CA 94304-1212
Telephone: [phone]
Facsimile: 650.838.4350

Jenna F. Karadbil
[e-mail]
California State Bar No. 213574
PILLSBURY WINTHROP SHAW
PITTMAN LLP
1540 Broadway
New York, New York 10036
Telephone: [phone]
Facsimile: [phone]
Callie A. Bjurstrom
[e-mail]
California State Bar No. 137816
PILLSBURY WINTHROP SHAW
PITTMAN LLP
501 West Broadway
San Diego, California 92101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
MOUNT HAMILTON PARTNERS, LLC

Attorneys for Defendant
GOOGLE, INC.

15
16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA

18

SAN FRANCISCO DIVISION

19
20
21
22
23
24

MOUNT HAMILTON PARTNERS, LLC,
Plaintiff/Counterdefendant,
v.
GOOGLE, INC.,
Defendant/Counterclaimant.

Case No. 3:12-CV-1698-SI
DECLARATION OF KHURRAM N. GORE
IN SUPPORT OF STIPULATION AND
[PROPOSED] ORDER CONTINUING
FURTHER CASE MANAGEMENT
CONFERENCE
[Civ. L.R. 6-2 & 7-12]

25
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27
28
-1-

Case Nos. C-12-1698 and C-12-1700
DECLARATION OF GORE IN SUPPORT STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE

1 MOUNT HAMILTON PARTNERS, LLC,

Case No. 3:12-CV-1700-SI

Plaintiff/Counterdefendant,

2

v.

3

4 GROUPON, INC.,
Defendant/Counterclaimant.

5
6
7

I, Khurram Nasir Gore, declare:

8

1.

I am an associate with Reed Smith LLP, counsel for Defendants Groupon, Inc.
, in the above-captioned action. The contents of this declaration are based upon my

9

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 personal knowledge and are true and correct to the best of my knowledge and belief. If called upon
11 I could and would testify competently thereto.
12

2.

On September 25, 2012, this Court entered the Case Management Conference Order

13 (Dkt. No. 47).
14

3.

Pursuant to the Case Management Conference Order, the parties are required to

15 participate in a Further Case Management Conference on May 10, 2013.
16

4.

On May 3, 2013, this Court continued the Claim Construction Tutorial and Claim

17 Construction Hearing to June 20, 2013 and June 26, 2013, respectively.
18

6.

Accordingly, because it is the belief of the parties that holding a Further Case

19 Management Conference after the date of the Claim Construction Hearing in this case will be more
20 efficient for this Court and the parties, the parties have agreed to continue the Further Case
21 Management Conference from May 10 to August 23, 2013 at 3:00 p.m. or such other date and time
22 that is agreeable with this
23 deadline ordered by this Court.
24

I declare under penalty of perjury of the laws of the United States of America that the

25 foregoing is true and correct.
26

DATED: May 8, 2013.

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By /s/ Khurram Nasir Gore
Khurram Nasir Gore
Case Nos. C-12-1698 and C-12-1700
-2DECLARATION OF GORE IN SUPPORT STIPULATION AND [PROPOSED] ORDER
CONTINUING FURTHER CASE MANAGEMENT CONFERENCE