STMicroelectronics,Inc., v. Invensense Inc.

Filing 61

ORDER GRANTING 60 STIPULATION TO EXTEND TIME TO EXCHANGE PROPOSED TERMS FOR CONSTRUCTION. Signed by Judge JEFFREY S. WHITE on 1/2/13. (jjoS, COURT STAFF) (Filed on 1/2/2013)

Case3:12-cv-02475-JSW Document60 Filed12/14/12 Page1 of 3

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RACHEL KREVANS (CA SBN 116421)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
RUDY Y. KIM (CA SBN 199426)
[e-mail]
MORRISON & FOERSTER LLP
755 Page Mill Road
Palo Alto, California 94304-1018
Telephone: [phone]
Facsimile: 650.494.0792
Attorneys for Defendant
INVENSENSE, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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STMICROELECTRONICS, INC.,
Plaintiff,

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v.
INVENSENSE, INC.,

Case No. CV 12-CV-2475 JSW
STIPULATION AND
[PROPOSED] ORDER TO
EXTEND TIME TO EXCHANGE
PROPOSED TERMS FOR
CONSTRUCTION

Defendant.

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Pursuant to Local Rules 6-2 and 7-12, Plaintiff STMicroelectronics, Inc., (“ST”)

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and Defendant InvenSense, Inc., (“InvenSense”) (collectively, “Parties”), through their

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respective undersigned counsel, hereby stipulate and request an order extending the due

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date for the Parties’ Patent L.R. 4-1 Exchange of Proposed Terms for Construction from

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December 17, 2012 to December 21, 2012. This extension of time will provide the

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Parties the time necessary to prepare and complete the Proposed Terms for Construction.

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The requested time modification would change no other due dates and would have no

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE PROPOSED TERMS FOR CONSTRUCTION
CASE NO. CV 12-CV-2475 JSW
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Case3:12-cv-02475-JSW Document60 Filed12/14/12 Page2 of 3

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effect on the remaining schedule for the case. Accordingly, ST and InvenSense hereby

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stipulate through their respective counsel of record as follows:

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WHEREAS, on or about May 24, 2012, the Parties stipulated to an extension of
time for InvenSense to respond to the Complaint; and
WHEREAS, on or about July 27, 2012, the Parties stipulated to an extension of
time for ST to respond to the InvenSense’s Counterclaims; and
WHEREAS, on or about July 31, 2012, the Court ordered a continuance of the
Case Management Conference; and
WHEREAS, on or about October 12, 2012, the Court granted an order to shorten
time for hearing; and
WHEREAS, on or about October 22, 2012, the Court ordered an extension of

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time to respond to the Parties’ L.R. 3-2 Document Productions Accompanying Disclosure

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of Asserted Claims and Infringement Contentions; and

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WHEREAS, on or about December 4, 2012, the Court ordered an extension of

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time to respond to the Parties’ L.R. 3-4 Document Productions Accompanying Disclosure

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of Invalidity Contentions and Patent L.R. 3-3 Invalidity Contentions; and

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WHEREAS, pursuant to the Court’s Case Management Order entered September

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14, 2012, and pursuant to the Patent Local Rules, the current due date for the Parties’

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Exchange of Proposed Terms for Construction is December 17, 2012; and

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WHEREAS, the Parties require additional time to prepare their Exchange of

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Proposed Terms for Construction, and ST and InvenSense, through their respective

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counsel of record, have agreed to extend the due date for the Exchange of Proposed

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Terms for Construction from December 17, 2012 to December 21, 2012;

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IT IS HEREBY STIPULATED by and between the Parties hereto that the Parties shall

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have to and including December 21, 2012, to exchange their Proposed Terms for Construction.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE PROPOSED TERMS FOR CONSTRUCTION
CASE NO. CV 12-CV-2475 JSW
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Case3:12-cv-02475-JSW Document60 Filed12/14/12 Page3 of 3

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Dated: December 14, 2012

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RACHEL KREVANS
RUDY Y. KIM
MORRISON & FOERSTER LLP

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By:

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Attorneys for Defendant
INVENSENSE, INC.

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/s/ Rudy Y. Kim
RUDY Y. KIM

Dated: December 14, 2012

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CHARLES K. VERHOEVEN
SEAN PAK
MICHELLE A. CLARK
LANCE YANG
MICHAEL POWELL
SUONG T. NGUYEN
THOMAS D. PEASE
CARLOS A. RODRIGUEZ
QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By:

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/s/ Michael Powell
MICHAEL POWELL
Attorneys for Plaintiff
STMICROELECTRONICS, INC.

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ATTESTATION OF CONCURRENCE
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I, Rudy Y. Kim, am the ECF User whose ID and password are being used to file this
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STIPULATION TO EXCHANGE PROPOSED TERMS FOR CONSTRUCTION. In
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compliance with General Order 45, X.B., I hereby attest that Michael Powell has concurred in this
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filing.
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Dated:

December 14, 2012

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By:

/s/ Rudy Y. Kim
RUDY Y. KIM

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PURSUANT TO STIPULATION IT IS SO ORDERED.

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January 2, 2013
Dated: __________________

By: ________________________________
The Honorable Jeffrey S. White
UNITED STATES DISTRICT JUDGE

STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO EXCHANGE PROPOSED TERMS FOR CONSTRUCTION
CASE NO. CV 12-CV-2475 JSW
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