GoPro, Inc. v. C&A Marketing, Inc. et al

Filing 37

STIPULATION AND ORDER re 36 STIPULATION WITH PROPOSED ORDER To Extend Time To Serve Damages Contentions and Responsive Damages Contentions filed by GoPro, Inc. Signed by Judge Jon S. Tigar on March 9, 2017. (wsn, COURT STAFF) (Filed on 3/9/2017)

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KILPATRICK TOWNSEND & STOCKTON LLP
STEVEN D. MOORE (Bar No. 290875)
[e-mail]
MEHRNAZ BOROUMAND SMITH (Bar No. 197271)
[e-mail]
DARIUS C. SAMEROTTE (Bar No. 296252)
[e-mail]
Two Embarcadero Center, Suite 1900
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415 576 0300
Attorneys for Plaintiff
GOPRO, INC.

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Plaintiff,

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Case No. 3:16-cv-03590-JST

GOPRO, INC.

v.
C&A MARKETING, INC., C&A
LICENSING, LLC, AND PLR IP
HOLDINGS, LLC,
Defendants.

STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO SERVE
DAMAGES CONTENTIONS AND
RESPONSIVE DAMAGES
CONTENTIONS

Complaint Filed:

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AND RELATED COUNTERCLAIMS

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
Case No. 3:16-cv-03590-JST

June 27, 2016

Pursuant to Local Rule 6-1(b), Plaintiff GoPro, Inc. (“GoPro”) and Defendants C&A

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Marketing, Inc.; C&A Licensing, LLC; and PLR IP Holdings, LLC (“Defendants”) hereby

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stipulate as follows:
WHEREAS, the Northern District of California revised its Patent Local Rules on

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January 17, 2017;
WHEREAS, these revised Patent Local Rules now require the exchange of Damages

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Contentions and Responsive Damages Contentions under Patent Local Rule (“Patent L.R.”) 3-8

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and 3-9, respectively;
WHEREAS, Patent L.R. 3-8 and 3-9 contemplate the prior identification of information

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and production of documents relating to damages under Patent L.R. 3-1(h), 3-2(f)–(j), and 3-4(c)–

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(e);

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WHEREAS, GoPro previously served Infringement Contentions under Patent L.R. 3-1,

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and the parties produced documents pursuant to Patent L.R. 3-2 and 3-4 prior to the revision of

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the Patent Local Rules;

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WHEREAS, the parties’ compliance with these new Patent Local Rules relating to

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damages would assist their completion of Damages Contentions and Responsive Damages

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Contentions;

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IT IS HEREBY STIPULATED AND AGREED that on April 5, 2017, GoPro will serve

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amended Infringement Contentions, amended only to “[i]dentify the timing of the point of first

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infringement, the start of claimed damages, and the end of claimed damages,” pursuant to Patent

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L.R. 3-1(h);

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IT IS FURTHER STIPULATED AND AGREED that on April 5, 2017, the parties will

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produce documents responsive to Patent L.R. 3-2(f)–(j) and 3-4(c)–(e) and in compliance with

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Patent L.R. 3-2 and 3-4;

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IT IS FURTHER STIPULATED AND AGREED that GoPro will serve its Patent L.R. 3-8

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Damages Contentions on May 25, 2017 (50 days after service of its amended Infringement

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Contentions);

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
Case No. 3:16-cv-03590-JST

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IT IS FURTHER STIPULATED AND AGREED that Defendants will serve their Patent

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L.R. 3-9 Responsive Damages Contentions on June 26, 2017 (30 days after service of the

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Damages Contentions).
The parties previously stipulated to extend time to respond to the Complaint, to continue

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the initial case management conference, and to serve invalidity contentions and exchange

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preliminary claim constructions. This extension will not otherwise affect the schedule for the

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case.

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Dated: March 7, 2017

Dated: March 7, 2017

/s/ Mehrnaz Boroumand Smith

/s/ Nathan B. Sabri

STEVEN D. MOORE (Bar No. 290875)
[e-mail]
MEHRNAZ BOROUMAND SMITH (Bar
No. 197271)
[e-mail]
DARIUS C. SAMEROTTE (Bar No. 296252)
[e-mail]
Two Embarcadero Center, Suite 1900
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415 576 0300

MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
NATHAN B. SABRI (CA SBN 252216)
[e-mail]
ESTHER KIM CHANG (CA SBN 258024)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff GoPro, Inc.

Attorneys for Defendants C&A Marketing,
Inc.; C&A Licensing, LLC; and PLR IP
Holdings, LLC

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
Case No. 3:16-cv-03590-JST

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: March 9, 2017

Honorable Jon S. Tigar
United States District Judge

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME
Case No. 3:16-cv-03590-JST

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