International Test Solutions, Inc v. MIPOX International Corporation et al

Filing 40

STIPULATION AND ORDER TO EXTEND TIME TO DISCLOSE INVALIDITY CONTENTIONS. Signed by Judge Richard Seeborg on 7/22/16. (cl, COURT STAFF) (Filed on 7/22/2016)

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BARNES & THORNBURG LLP
Thomas J. Donovan (admitted pro hac vice)
[e-mail]
Roya Rahmanpour Bar, No. 285076
[e-mail]
2029 Century Park East, Suite 300
Los Angeles, California 90067
Telephone:
310. 284.3880
Facsimile:
310. 284.3894
Attorneys for Defendants
MIPOX INTERNATIONAL CORP.
and MGN INTERNATIONAL, INC.
TROUTMAN SANDERS LLP
Dean A. Morehous, Bar No. 111841
[e-mail]
Charanjit Brahma, Bar No. 204771
[e-mail]
Marcus T. Hall, Bar No. 206495
[e-mail]
580 California Street, 11th floor
San Francisco, CA 94104
Telephone:
415.477.5700
Facsimile:
415.477.5710

WINSTON & STRAWN LLP
David S. Bloch, Bar No. 184530
[e-mail]
Amanda L. Groves, Bar No. 187216
[e-mail]
101 California Street, Suite 3400
San Francisco, CA 94111-5840
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff
INTERNATIONAL TEST SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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INTERNATIONAL TEST SOLUTIONS,
INC.,

Case No. 3:16-cv-00791-RS

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Plaintiff,
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v.

STIPULATION AND [PROPOSED] ORDER
TO EXTEND TIME TO DISCLOSE
INVALIDITY CONTENTIONS

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MIPOX INTERNATIONAL
CORPORATION and MGN
INTERNATIONAL, INC.,

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Defendant.
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STIPULATION AND [PROPOSED] ORDER

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Pursuant to Local Rules 6-2 and 7-12, Plaintiff International Test Solutions, Inc., (“ITS”)
and Defendants Mipox International Corporation (“Mipox”) and MGN International, Inc.
(“MGN”) (collectively, “Parties”), through their respective undersigned counsel, hereby stipulate
and request an order extending the due date for Defendant Mipox and MGN’s Patent L.R. 3-3
Invalidity Contentions and Patent L.R. 3-4 Document Productions Accompanying Disclosure of
Invalidity Contentions by two weeks, from July 25, 2016 to August 8, 2016. This extension of time
will provide Mipox and MGN the time necessary to prepare and complete the Invalidity
Contentions and accompanying production. The requested time modification would change no
other due dates and would have no effect on the remaining schedule for the case. Accordingly, the
Parties hereby stipulate through their respective counsel of record as follows:
WHEREAS, pursuant to the Court’s Case Management Scheduling Order entered May 26,
2016, and pursuant to the Patent Local Rules, the current due date for the Mipox and MGN’s
Invalidity Contentions and accompanying production of documents is July 25, 2016; and
WHEREAS, the Mipox and MGN require additional time to prepare their Document
Productions Accompanying Disclosure of Invalidity Contentions and Invalidity Contentions, and
ITS, through its counsel of record, has agreed to extend the due date for Document Productions
Accompanying Disclosure of Invalidity Contentions and Invalidity Contentions the by two weeks,
from July 25, 2016 to August 8, 2016;
IT IS HEREBY STIPULATED by and between the Parties hereto that Mipox and MGN
shall have to and including August 8, 2016, to serve their Document Productions Accompanying
Disclosure of Invalidity Contentions and Invalidity Contentions.

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STIPULATION AND [PROPOSED] ORDER

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Dated: July 22, 2016

WINSTON & STRAWN LLP

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By: /s/ Amanda L. Groves
Amanda L. Groves
Attorneys for Plaintiff
International Test Solutions, Inc.

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Dated: July 22, 2016

BARNES & THORNBURG LLP

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By: /s/ Roya Rahmanpour
Thomas J. Donovan
Roya Rahmanpour
Attorneys for Defendants
Mipox International Corporation and MGN
International, Inc.

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CONCURRENCE IN FILING
I, Roya Rahmanpour, hereby attest that the concurrence to the filing of this document has
been obtained from each signatory hereto.

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Dated: July 22, 2016

/s/ Roya Rahmanpour
Roya Rahmanpour

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: 7/22/16

____________________________________
Richard Seeborg
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER