Chrimar Systems, Inc. et al v. Fortinet, Inc.

Filing 36

ORDER, Motions terminated: 35 STIPULATION WITH PROPOSED ORDER to Reschedule Case Management Conference filed by ChriMar Systems Inc, ChriMar Holding Company LLC. Initial Case Management Conference set for 4/22/2016 02:30 PM in Courtroom 1, 17th Floor, San Francisco.. Signed by Judge Susan Illston on 3/22/16. (tfS, COURT STAFF) (Filed on 3/22/2016)

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Bruce J. Zabarauskas, SBN. 248601
THOMPSON & KNIGHT LLP
707 Wilshire Blvd., Suite 4100
Los Angeles, California 90017
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
Justin S. Cohen (pro hac vice)
Richard L. Wynne, Jr. (pro hac vice)
THOMPSON & KNIGHT LLP
1722 Routh Street, Suite 1500
Dallas, Texas 75201
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
Email: [e-mail]

QUINN EMANUEL URQUHART &
SULLIVAN, LLP
John M. Neukom (275887)
Andrew M. Holmes (260475)
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
Fortinet, Inc.

Attorneys for Plaintiffs
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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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CHRIMAR SYSTEMS, INC., et al.,
Case No. 3:16-cv-00897-SI
Plaintiffs,

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vs.

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FORTINET, INC.,

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STIPULATION AND [PROPOSED] ORDER TO
RESCHEDULE CASE MANAGEMENT
CONFERENCE
Defendant.

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In accordance with Civil Local Rules 6-2 and 7-12, Plaintiffs Chrimar Systems, Inc. and
Chrimar Holding Company (collectively, “Chrimar”) and Defendant Fortinet, Inc. (“Fortinet”),
by and through their respective counsel, hereby stipulate and agree as follows:
On July 1, 2015, Chrimar filed suit against various defendants in the Eastern District of
Texas alleging infringement of U.S. Patent Nos. 8,155,012, 8,942,107, 8,902,760, and 9,019,838
(collectively, the “Patents-in-Suit”).
Four of the cases have been transferred to the Northern District of California, and are

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-1STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CMC
CASE NO. 3:16-CV-00897-SI

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presently before this Court: Chrimar Systems, Inc. et al. v. Juniper Networks, Inc., Case No. 3:16-

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cv-00558-SI (N.D. Cal.); Chrimar Systems, Inc. et al. v. Ruckus Wireless, Inc., Case No. 3:16-cv-

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186-SI (N.D. Cal.); Chrimar Systems, Inc. et al. v. NETGEAR, Inc., Case No. 3:16-cv-624-SI

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(N.D. Cal.); Chrimar Systems, Inc. et al. v. Fortinet, Inc., Case No. 3:16-cv-00897-SI (N.D. Cal.)

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(collectively, the “N.D. Cal. Chrimar Cases”).

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The Court has set the four N.D. Cal. Chrimar cases for case management conferences

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(“CMCs”) on four separate dates: April 15, 2016 (Case No. -897); April 22, 2016 (Case No. 186);

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May 6, 2016 (Case No. -558); and May 20, 2016 (Case No. -624).

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Counsel for the parties in all of the N.D. Cal. Chrimar Cases have conferred and believe

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that there would be benefits to the Court and the parties to schedule the CMCs for all of the cases

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scheduled on the same date, and at the Court’s convenience, at the same time if possible.

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Counsel for the parties in all of the N.D. Cal. Chrimar Cases are available for CMC on

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April 22, 2016, which is the date the Court had set the CMC for the Chrimar v. Ruckus case (No.

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3:16-cv-186). Accordingly, if the Court’s schedule permits, counsel for the parties in this action

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have agreed to reschedule the CMC currently set for April 15, 2016, to April 22, 2016, at or near

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2:30 p.m., when the Ruckus CMC is currently scheduled.

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No prior changes to the schedule have been made since this action was transferred to this
Court.

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Because the Court has not entered a Scheduling Order in any of the four N.D. Cal.

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Chrimar Cases, the requested time modification will have no effect on the schedule for this or any

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of the cases.

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IT IS HEREBY AGREED AND STIPULATED, that the CMC in this case shall be

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rescheduled to April 22, 2016, at 2:30 p.m. and the related deadline for filing a joint CMC

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statement is adjusted to April 15, 2016.

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-2STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CMC
CASE NO. 3:16-CV-00897-SI

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Respectfully submitted,

Respectfully submitted,

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/s/ Richard L. Wynne, Jr.
Richard L. Wynne, Jr.
Thompson & Knight LLP

/s/ John M. Neukom w/permission R. Wynne
John M. Neukom (275887)
Quinn Emanuel Urquhart & Sullivan, LLP

Counsel for Plaintiffs

Counsel for Defendant Fortinet, Inc.

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-3STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CMC
CASE NO. 3:16-CV-00897-SI

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CERTIFICATE OF SERVICE

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Case No. 3:16-cv-00897-SI

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STATE OF TEXAS, COUNTY OF DALLAS

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I am employed in the County of Dallas, State of Texas. I am over the age of 18 and not a
party to the within action. My business address is 1722 Routh Street, Suite 1500, Dallas, Texas
75201. On April 21, 2015, I served documents described as follows:

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Stipulation and [Proposed] Order to Reschedule Case Management Conference

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I served the document listed above on the interested parties below, using the following
means:
[X]

(By Court’s CM/ECF System) Pursuant to Local Rule, I electronically filed
the documents with the Clerk of the Court using the CM/ECF system, which
sent notification of that filing to the persons listed on the CM/ECF service list.

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I declare under penalty of perjury under 28 U.S.C. § 1746 that the foregoing is true and
correct.
Executed on March 18, 2016, at Dallas, Texas.

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/s/ Richard L. Wynne, Jr.
Richard L. Wynne, Jr.

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-4STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CMC
CASE NO. 3:16-CV-00897-SI

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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March 22
Dated: __________, 2016

THE HONORABLE SUSAN ILLSTON
UNITED STATES DISTRICT JUDGE

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-5STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CMC
CASE NO. 3:16-CV-00897-SI