Cadence Design Systems, Inc. v. Skyworth Digital Holdings Ltd. et al

Filing 51

STIPULATION AND ORDER resetting 27 MOTION to Dismiss , 42 MOTION to Dismiss , 22 MOTION to Dismiss or for More Definite Statement. Motion Hearing reset for 11/15/2018 01:30 PM in San Francisco, Courtroom 05, 1 7th Floor before Judge Edward M. Chen. Case Management Statement due by 11/8/2018. Further Case Management Conference reset for 11/15/2018 01:30 PM in San Francisco, Courtroom 05, 17th Floor. Signed by Judge Edward M. Chen on 8/15/18. (bpfS, COURT STAFF) (Filed on 8/15/2018)

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Mark C. Holscher (SBN 139582)
[e-mail]
Diana M. Torres (SBN 162284)
[e-mail]
Tanya Greene (SBN 267975)
[e-mail]
Lauren Schweitzer (SBN 301654)
[e-mail]
KIRKLAND & ELLIS LLP
333 South Hope Street
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
CADENCE DESIGN SYSTEMS, 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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CADENCE DESIGN SYSTEMS, INC., a
Delaware corporation,
Plaintiff,
v.
SKYWORTH DIGITAL HOLDINGS
LTD.; SHENZHEN SKYWORTH
AUTOMOBILE ELECTRONICS CO.
LTD.; SKYWORTH ELECTRONIC
APPLIANCE LTD.; SKYWORTH
ELECTRONICS INC.; SKYWORTH USA
CORPORATION,
Defendants.

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CASE NO. 3:18-cv-02474-EMC
STIPULATION TO CONTINUE
OUTSTANDING DEADLINES AND
HEARINGS DUE TO SETTLEMENT IN
PRINCIPLE; [PROPOSED] ORDER
Judge:

Honorable Edward M. Chen

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Stipulation to Continue Outstanding Deadlines and Hearings Due to Settlement in Principle

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Plaintiff Cadence Design Systems, Inc. (“Cadence”) and Defendants Skyworth Digital Holdings

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Ltd. (“Skyworth Parent”), Shenzhen Skyworth Automobile Electronics Co. Ltd. (“Skyworth Auto”),

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Skyworth Electronic Appliance Ltd. (“Skyworth EA”), Skyworth Electronics Inc. (“SEI”) and Skyworth

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USA Corporation (“Skyworth USA”) (collectively the “Parties”) by and through their counsel of record,

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hereby stipulate and agree as follows:

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WHEREAS, on April 25, 2018, Cadence filed its Complaint in this Action;

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WHEREAS, the Parties’ Joint Case Management Statement and Rule 26(f) Report is due on

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August 16, 2018;
WHEREAS, the Court has scheduled an initial Case Management Conference and hearings on
SEI’s and Skyworth USA’s motions to dismiss for August 23, 2018;
WHEREAS, Cadence’s Opposition to the motion to dismiss filed by Skyworth Parent, Skyworth

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Auto, and Skyworth EA (collectively “the Non-US Skyworth Entities”) is due on August 21, 2018, and

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the Non-US Skyworth Entities’ Reply is due on August 28, 2018;

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WHEREAS, the Court has scheduled a hearing on the Non-US Skyworth Entities’ motion for
September 13, 2018;

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WHEREAS, the Court has ordered the Parties to hold a mediation by November 8, 2018;

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WHEREAS, the Parties have reached a resolution in principal of their dispute and are in the

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process of finalizing their agreement;
WHEREAS, the Parties agree that it is in the interest of judicial efficiency to postpone all
outstanding deadlines by roughly 60 days in order to document their settlement in principle;
WHEREAS, the Parties agree that the following deadlines shall be continued as follows:

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Joint Case Management Statement and Rule 26(f) Report: October 15, 2018

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Initial Case Management Conference and Hearings on SEI’s and Skyworth USA’s
Motions to Dismiss: November 15, 2018 at 1:30 P.M.

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Cadence’s Opposition to Non-US Skyworth Entities’ Motion: October 22, 2018

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Non-US Skyworth Entities’ Reply: October 29, 2018

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Hearing on Non-US Skyworth Entities Motion: November 15, 2018 at 1:30 P.M.

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Deadline to Conduct Mediation: January 7, 2019

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Stipulation to Continue Outstanding Deadlines and Hearings Due to Settlement in Principle

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DATED: August 14, 2018

KIRKLAND & ELLIS LLP

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By: /s/ Lauren Schweitzer
Diana M. Torres
Mark C. Holscher
Tanya Greene (SBN 267975)
Lauren Schweitzer

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Respectfully submitted,

Dated: August 14, 2018

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Attorney for Plaintiff
CADENCE DESIGN SYSTEMS, INC.
Respectfully submitted,
LOCKE LORD LLP

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By: /s/ Bryan G. Harrison
Regina J. McClendon
Bryan G. Harrison
Meagan S. Tom

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Attorneys for Defendant
SKYWORTH ELECTRONICS INC.

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Dated: August 14, 2018

Respectfully submitted,
DORSEY & WHITNEY LLP
By: /s/ Jeremy T. Elman
Jeremy T. Elman
Kent J. Schmidt
J. Michael Keyes
Attorneys for Defendants
SKYWORTH USA CORPORATION
SKYWORTH DIGITAL HOLDINGS LTD.
SHENZHEN SKYWORTH AUTOMOBILE
ELECTRONICS CO. LTD.
SKYWORTH ELECTRONIC APPLIANCE
LTD.

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Stipulation to Continue Outstanding Deadlines and Hearings Due to Settlement in Principle

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CERTIFICATION
Pursuant to Local Rule 5-1(i)(3), the filing attorney attests that he has obtained concurrence
regarding the filing of this document from the indicated signatories to the document.
DATED: August 14, 2018

KIRKLAND & ELLIS LLP

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By: /s/ Lauren Schweitzer
Lauren Schweitzer

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Stipulation to Continue Outstanding Deadlines and Hearings Due to Settlement in Principle

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[PROPOSED] ORDER
Good cause appearing, the below hearings and deadlines are continued as follows:

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Joint Case Management Statement and Rule 26(f) Report: October 15, 2018

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Initial Case Management Conference and Hearings on SEI’s and Skyworth USA’s
Motions to Dismiss: November 15, 2018 at 1:30 P.M.

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Cadence’s Opposition to Non-US Skyworth Entities’ Motion: October 22, 2018

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Non-US Skyworth Entities’ Reply: October 29, 2018

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Hearing on Non-US Skyworth Entities Motion: November 15, 2018 at 1:30 P.M.

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Deadline to Conduct Mediation: January 7, 2019

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ER

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R NIA

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Hon. Edward M. Chen
United States District Judge
n
M. Che
Edward
Judge

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Dated: _________________

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RDERE
S SO O
______________________________________
IT I

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8/15/2018

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UNIT
ED

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IT IS SO ORDERED.

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S DISTRICT
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D IS T IC T O
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[Proposed] Order