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

Filing 46

STIPULATION AND ORDER re 45 STIPULATION WITH PROPOSED ORDER Stipulation and Proposed Order Extending Time for Plaintiff to File Opposition to Defendants' Motion to Stay filed by GoPro, Inc. Signed by Judge Jon S. Tigar on May 8, 2017. (wsn, COURT STAFF) (Filed on 5/8/2017)

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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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MORRISON & FOERSTER LLP
MICHAEL A. JACOBS (CA SBN 111664)
[e-mail]
NATHAN B. SABRI (CA SBN 252216)
[e-mail]
ESTHER KIM CHANG (CA SBN 258024)
[e-mail]
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
C&A Marketing, Inc.; C&A Licensing, LLC;
and PLR IP Holdings, LLC

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
Case No. 3:16-cv-03590-JST

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

STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
PLAINTIFF TO FILE OPPOSITION TO
DEFENDANTS’ MOTION TO STAY
LITIGATION PENDING INTER PARTES
REVIEW (DKT. NO. 40)

Complaint Filed:

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AND RELATED COUNTERCLAIMS
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STIPULATION AND [PROPOSED] ORDER EXTENDING 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, on April 24, 2017, Defendants filed a Motion to Stay Litigation Pending

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Inter Partes Review (“Motion to Stay”) (Dkt. No. 40);
WHEREAS, GoPro requested a one week extension of time, and Defendants agreed to a

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one week extension;
WHEREAS, GoPro’s opposition is currently due on May 8, 2017, Defendants’ reply is

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due May 15, 2017, and the hearing is not set until June 15, 2017, thus providing sufficient time to

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adjust the briefing schedule while maintaining at least fourteen days between Defendants’ reply

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brief and the hearing;
IT IS HEREBY STIPULATED AND AGREED that the time by which GoPro may file an

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opposition to Defendants’ Motion to Stay (Dkt. No. 40) is extended one week from May 8, 2017

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to May 15, 2017;
IT IS FURTHER STIPULATED AND AGREED that the time by which Defendants shall

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reply to GoPro’s opposition to Defendants’ Motion to Stay (Dkt. No. 40) is extended one week

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from May 15, 2017 to May 22, 2017.
The parties previously stipulated to extend time to respond to the Complaint, to continue

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

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claim constructions, to serve damages contentions and responsive damages contentions, and to

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file an opposition brief to GoPro’s Motion for Leave to File an Amended Complaint. This

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extension will not otherwise affect the schedule for the case.

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

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Dated: May 5, 2017

Dated: May 5, 2017

KILPATRICK TOWNSEND & STOCKTON LLP

MORRISON & FOERSTER LLP

/s/ Mehrnaz Boroumand Smith
MEHRNAZ BOROUMAND SMITH

/s/ Nathan B. Sabri
NATHAN B. SABRI

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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ATTESTATION OF E-FILED SIGNATURE

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I, Mehrnaz Boroumand Smith, am the ECF User whose ID and password are being used to

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file this STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR

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PLAINTIFF TO FILE OPPOSITION TO DEFENDANTS’ MOTION TO STAY

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LITIGATION PENDING INTER PARTES REVIEW (DKT. NO. 40). In compliance with

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Local Rule 5-1(i)(3), I hereby attest that Nathan B. Sabri has concurred in this filing.

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Dated: May 5, 2017

/s/ Mehrnaz Boroumand Smith
Mehrnaz Boroumand Smith

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: May 8, 2017
Honorable Jon S. Tigar
United States District Judge

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69336719V.1

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

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