Zyme Solutions, Inc. v. Infonow Corporation, dba Channelinsight
Filing
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ORDER CHANGING TIME FOR INVALIDITY CONTENTIONS AND SUBSEQUENT DEADLINES by Hon. William Alsup granting 47 Stipulation; referring to 39 Case Management Order(whalc1, COURT STAFF) (Filed on 2/18/2014)
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Jonathan Allan Klein (California Bar No. 162071)
Kelly, Hockel & Klein P.C.
1 Sansome Street, Suite 1800
San Francisco, CA 94104
Tel. (415) 951-0535
Fax (415) 391-7808
jaklein@khklaw.com
Andrew R. Shoemaker (appearing pro hac vice)
Shoemaker Ghiselli + Schwartz
1811 Pearl Street
Boulder, CO 80302
Tel. (303) 530-3452
Fax (303) 530-4071
ashoemaker@sgslitigation.com
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ATTORNEYS FOR DEFENDANT InfoNow Corporation, d/b/a Channelinsight
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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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ZYME SOLUTIONS, INC.,
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Plaintiff,
vs.
INFONOW CORPORATION, d/b/a
CHANNELINSIGHT,
Defendant.
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Case Number: C 3:13-cv-04082-WHA
STIPULATED REQUEST FOR ORDER
CHANGING TIME AND DECLARATION
IN SUPPORT THEREOF
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Page 1 of 4
STIPULATED REQUEST FOR ORDER CHANGING TIME AND DECLARATION IN SUPPORT THEREOF 3:13-CV-04082-WHA
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Plaintiff and Counterclaim Defendant Zyme Solutions, Inc. (“Zyme”) and Defendant and
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Counterclaim Plaintiff, InfoNow Corporation, d/b/a Channelinsight (“Channelinsight”) hereby
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file this stipulated request for an order extending certain time frames set in the Patent Local
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Rules, and the following declaration in support thereof, as required pursuant to Civil Local Rule
6-2(a). Among other reasons to seek this extension, lead counsel for Channelinsight will be
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traveling outside the country at the end of February and beginning of March, when Zyme’s
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disclosures under Patent L.R. 3-3 and 3-4 are due and when deadlines under Patent L.R. 4 begin
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to arise. To ensure that the parties have adequate time to comply with Patent L.R. 4-1 and 4-2,
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the parties jointly request a modest extension of the deadline under Patent L.R. 3-3 and 3-4 and
all subsequent deadlines timed therefrom. More specifically, the parties request that the deadline
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for Zyme to serve its Invalidity Contentions (Patent L.R. 3-3) and Document Production
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Accompanying Invalidity Contentions (Patent L.R. 3-4) be extended from February 24, 2014 to
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March 10, 2014 and deadlines timed therefrom pursuant to the Patent Local Rules be extended
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accordingly. No party will be prejudiced because the Case Management Order entered by the
Court on December 24, 2013, provides that claim construction in this case will occur during
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summary judgment or at trial in setting the jury instructions.
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There have been no previous time modifications in this matter, nor will the enlargement
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of time described above affect the deadlines contained in the Court’s Case Management Order,
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dated December 23, 2013. Therefore, the parties request that the Court grant this Stipulated
Request for Order Changing Time, pursuant to Civil Local Rule 6-2(b).
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Page 2 of 4
STIPULATED REQUEST FOR ORDER CHANGING TIME AND DECLARATION IN SUPPORT THEREOF 3:13-CV-04082-WHA
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Dated: February 13, 2014
KUTAK ROCK LLP
s/ Chad T. Nitta
Jacob Song
Chad T. Nitta (appearance pro hac vice)
Blair E. Kanis (appearance pro hac vice)
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Counsel for Plaintiff Zyme Solutions, Inc.
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Dated: February 13, 2014
SHOEMAKER GHISELLI + SCHWARTZ
s/ Andrew R. Shoemaker
Jonathan Allan Klein
Andrew R. Shoemaker (appearance pro hac
vice)
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Counsel for Defendant InfoNow Corporation,
d/b/a Channelinsight
All deadlines ordered in the Case Management Order remain
in place (Dkt. No. 39).
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: February 18, 2014.
________________________________________________
UNITED STATES DISTRICT/MAGISTRATE JUDGE
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Page 3 of 4
STIPULATED REQUEST FOR ORDER CHANGING TIME AND DECLARATION IN SUPPORT THEREOF 3:13-CV-04082-WHA
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