IPVX Patent Holdings, Inc. v. 8x8, Inc.

Filing 55

STIPULATION AND ORDER re 54 STIPULATION WITH PROPOSED ORDER to Amend Dates For Meet And Confer And To File Rule 26(f) Report filed by 8x8, Inc., IPVX Patent Holdings, Inc. Rule 26 Meeting Report due by 7/16/2013.. Signed by Judge ARMSTRONG on 7/3/13. (lrc, COURT STAFF) (Filed on 7/5/2013)

Case4:13-cv-01707-SBA Document54 Filed07/02/13 Page1 of 5

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STROOCK & STROOCK & LAVAN LLP
DANIEL A. ROZANSKY (State Bar No. 161647)
2029 Century Park East
Los Angeles, CA 90067-3086
Telephone: [phone]
Facsimile [phone]
Email: [e-mail]
STROOCK & STROOCK & LAVAN LLP
PIERRE R. YANNEY (State Bar No. 2615599)
180 Maiden Lane
New York, N.Y. 10038
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
IPVX Patent Holdings, Inc.
Robert J. Crawford
CRAWFORD MAUNU PLLC
1150 Northland Drive, Suite 100
St. Paul, MN 55120
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant
8x8, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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IPVX PATENT HOLDINGS, INC.
Plaintiff,

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vs.

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8X8, INC.,

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No. C-13-01707-SBA
STIPULATION TO AMEND DATES FOR
MEET AND CONFER AND TO FILE
XXXXXXXXXXX
RULE 26(f) REPORT; [PROPOSED ]
ORDER
Judge: Hon. Saundra B. Armstrong

Defendant

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1. Defendant 8X8, Inc. (“8X8”) and Plaintiffs IPVX Patent Holdings, Inc., (“IPVX”),

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through their respective counsel, request that the Court amend the dates currently set for the

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parties to: (a) meet and confer regarding initial disclosures, ADR process selection, and

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discovery plan, to file an ADR certification signed by Parties and Counsel, to file either a

STIPULATION TO AMEND DATES FOR MEET AND CONFER
AND TO FILE RULE 26(f) REPORT; [PROPOSED ] ORDER - 1

Case4:13-cv-01707-SBA Document54 Filed07/02/13 Page2 of 5

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Stipulation to ADR Process or a Notice of Need for ADR Phone Conference (referred to

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collectively as the “Meet and Confer”) and (b) to file the Rule 26(f) report and Case

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Management Statement.

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2. Currently, the Case Schedule (ADR Multi-Option Program) filed on April 16, 2013

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requires the Meet and Confer to take place no later than July 2, 2013. The Case Schedule also

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provides that the last day for the parties to file the Rule 26(f) report and Case Management

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Statement is July 16, 2013.

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3. Counsel for 8X8 is currently out of the country. Therefore, 8x8 requests that the Court

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amend the date for the Meet and Confer to take place no later than July 16, 2013 and the filing of

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the Rule 26(f) report to take place on or before July 30, 2013. IPVX does not oppose this

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request.

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4. The parties understand that the initial Case Management Conference is scheduled for

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August 19, 2013. The proposed amended dates will not alter the date of the initial Case

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Management Conference.

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5. It is hereby AGREED and STIPULATED that the meet and confer regarding initial

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disclosures, ADR process selection, and discovery plan, to file an ADR certification signed by

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Parties and Counsel, to file either a Stipulation to ADR Process or a Notice of Need for ADR

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Phone Conference (referred to collectively as the “Meet and Confer”) take place no later than

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July 16, 2013 and (b) that the last day to file the Rule 26(f) report and Case Management

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Statement is July 30, 2013.

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Dated this 2nd day of July, 2013

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By: /s/ Robert J. Crawford
Robert J. Crawford
CRAWFORD MAUNU PLLC
Attorneys for Defendant
8x8, Inc.

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STIPULATION TO AMEND DATES FOR MEET AND CONFER
AND TO FILE RULE 26(f) REPORT; [PROPOSED ] ORDER - 2

Case4:13-cv-01707-SBA Document54 Filed07/02/13 Page3 of 5

By: /s/ Daniel A. Rozansky
Daniel A. Rozansky
Pierre R. Yanney
Stroock & Stroock & Lavan LLP
Attorneys for Plaintiff
IPVX Patent Holdings, Inc.

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STIPULATION TO AMEND DATES FOR MEET AND CONFER
AND TO FILE RULE 26(f) REPORT; [PROPOSED ] ORDER - 3

Case4:13-cv-01707-SBA Document54 Filed07/02/13 Page4 of 5

ORDER

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that the that the

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events and/or deadlines set in the Court’s Order, dated April 16, 2013, shall be changed and

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extended to:

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(1) July 16, 2013 shall be the last day to:
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meet and confer re: initial disclosures, early settlement, ADR process
selection, and discovery plan;

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file ADR Certification signed by Parties and Counsel;

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

file either Stipulation to ADR Process or Notice of Need for ADR Phone
Conference

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(2) July 30, 2013 shall be the last day to:
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file Rule 26(f) Report, complete initial disclosures or state objection in

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Rule 26(f) Report and file Case Management Statement per attached

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Standing Order re Contents of Joint Case Management Statement.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: July 3 2013
Hon. Saundra B. Armstrong

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STIPULATION TO AMEND DATES FOR MEET AND CONFER
AND TO FILE RULE 26(f) REPORT; [PROPOSED ] ORDER - 4

Case4:13-cv-01707-SBA Document54 Filed07/02/13 Page5 of 5

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CERTIFICATE OF SERVICE

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I hereby certify that, on July 2, 2013, copies of the foregoing STIPULATION TO

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AMEND DATES FOR MEET AND CONFER AND TO FILE RULE 26(f) REPORT;

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[PROPOSED ] ORDER were filed electronically and served by U.S. Mail on anyone unable to

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accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of

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the court’s electronic filing system or by U.S. Mail to anyone unable to accept electronic filing as
indicated on the Notice of Electronic Filing. Parties may access this filing through the court’s
EM/ECF System.

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By

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STIPULATION TO AMEND DATES FOR MEET AND CONFER
AND TO FILE RULE 26(f) REPORT; [PROPOSED ] ORDER - 5

/s/ Daniel A. Rozansky
Daniel A. Rozansky