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

Filing 57

STIPULATION AND ORDER TO EXTEND TIME FOR OPENING CLAIM CONSTRUCTION BRIEF. Signed by Judge Richard Seeborg on 11/18/16. (cl, COURT STAFF) (Filed on 11/18/2016)

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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DAVID S. BLOCH (SBN: 184530)
[e-mail]
AMANDA L. GROVES (SBN: 187216)
[e-mail]
WINSTON & STRAWN LLP
101 California Street
San Francisco, CA 94111-5840
Telephone:
[phone]
Facsimile:
[phone]
LOWELL D. JACOBSON (Pro Hac Vice)
[e-mail]
WINSTON & STRAWN LLP
35 W. Wacker Dr.
Chicago IL 60601
Telephone: [phone]
Facsimile:
[phone]
JAMES C. LIN (SBN: 271673)
[e-mail]
WINSTON & STRAWN LLP
275 Middlefield Rd., Suite 205
Menlo Park, CA 94025
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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SAN FRANCISCO DIVISION

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INTERNATIONAL TEST SOLUTIONS,
INC.

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

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
OPENING CLAIM CONSTRUCTION
BRIEF

Plaintiff,
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v.
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MIPOX INTERNATIONAL CORPORATION
and MGN INTERNATIONAL, INC.

Action Filed: February 17, 2016
Judge: Honorable Richard Seeborg

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Defendants.

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
CASE NO.: 3:16-CV-00791-RS

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Pursuant to Local Rules 6-2 and 7-12, Plaintiff International Test Solutions, Inc., (“ITS”) and

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Defendants Mipox International Corporation (“Mipox”) and MGN International, Inc. (“MGN”)

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(collectively, “Parties”), through their respective undersigned counsel, hereby stipulate and request

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an order extending the due date for the Opening Claim Construction Brief from November 25, 2016

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to December 5, 2016. This extension of time will provide ITS the additional time necessary to

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prepare and complete the Opening Claim Construction Brief in view of the Thanksgiving holiday.

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The requested time modification will change the due dates for the Responsive Claim Construction

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Brief and the Reply Claim Construction Brief in accordance with Patent Local Rule 4-5 but would

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otherwise have no effect on the remaining schedule for the case, including the Markman hearing

101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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scheduled for January 30, 2017. Accordingly, the Parties hereby stipulate through their respective

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counsel of record as follows:

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WHEREAS, the Parties served and filed the Joint Claim Construction and Prehearing
Statement on October 10, 2016; and

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WHEREAS, pursuant to Patent Local Rule 4-5(a), the due date for the Opening Claim

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Construction Brief is not later than 45 days after serving and filing the Joint Claim Construction and

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Prehearing Statement, which is November 25, 2016; and

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WHEREAS, ITS requires additional time to prepare the Opening Claim Construction Brief in
view of the Thanksgiving holiday; and
WHEREAS, extending the deadline for the Opening Claim Construction Brief from

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November 25, 2016 to December 5, 2016 will change the due dates for the Responsive Claim

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Construction Brief and Reply Claim Construction Brief in accordance with Patent Local Rule 4-5

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but would not otherwise affect the remaining schedule for the case, including the Markman hearing

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scheduled for January 30, 2017;

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IT IS HEREBY STIPULATED by and between the Parties hereto that ITS shall have to and
including December 5, 2016 to serve and file the Opening Claim Construction Brief.

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
CASE NO.: 3:16-CV-00791-RS

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WINSTON & STRAWN LLP
Date: November 17, 2016

By: /s/ David S. Bloch
Amanda L. Groves
David S. Bloch
Lowell D. Jacobson
James C. Lin

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Attorneys for Plaintiff
International Test Solutions, Inc.

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BARNES & THORNBURG LLP
Date: November 17, 2016

By: /s/ Thomas J. Donovan
Thomas J. Donovan
Roya Rahmanpour
Attorneys for Defendants

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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Mipox International Corporation and
MGN International, Inc.

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CONCURRENCE IN FILING
I, David S. Bloch, hereby attest that the concurrence to the filing of this document has
been obtained from each signatory hereto.
Date: November 17, 2016

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By: /s/ David S. Bloch
David S. Bloch

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Date: 11/18/16

By:
Richard Seeborg
UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
CASE NO.: 3:16-CV-00791-RS