In re Ricoh Company Ltd. Patent Litigation

Filing 797

STIPULATION AND ORDER MODIFYING DUE DATE FOR SYNOPSYS INC.'S OPPOSITION TO RICOH'S MOTION FOR STAY re 796 STIPULATION WITH PROPOSED ORDER. Responses to Motion to Stay due by 6/11/2012. Signed by Chief Judge James Ware on June 7, 2012. (wsn, COURT STAFF) (Filed on 6/7/2012)

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RON E. SHULMAN, State Bar No. 178263
[e-mail]
TERRY KEARNEY, State Bar No. 160054
[e-mail]
RICHARD G. FRENKEL, State Bar No. 204133
[e-mail]
LATHAM & WATKINS LLP
140 Scott Drive
Menlo Park, CA 94025
Telephone: [phone]
Facsimile: [phone]

Gary M. Hoffman (Pro Hac Vice)
Kenneth W. Brothers (Pro Hac Vice)
Cathy Chen (Pro Hac Vice)
DICKSTEIN SHAPIRO LLP
1825 Eye Street, N.W.
Washington, D.C. 20006-5403
Phone [phone]
Fax [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff SYNOPSYS, INC.

Krista Carter (State bar No. 225229)
DICKSTEIN SHAPIRO LLP
700 Hansen Way
Palo Alto, CA 94304-1016
Phone [phone]
Fax [phone]
Email: [e-mail]

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ERED

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Attorneys for Defendant
RICOH COMPANY, LTD.

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Judge Ja
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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IN RE RICOH COMPANY LTD.
PATENT LITIGATION

CASE NO. C 03-02289 JW
STIPULATION AND [PROPOSED]
ORDER MODIFYING DUE DATE FOR
SYNOPSYS INC.’S OPPOSITION TO
RICOH’S MOTION FOR STAY OF
APRIL 26, 2012 ORDER PENDING
APPEAL AND FOR EXPEDITED
CONSIDERATION
Date: June 18, 2012
Time: 9:00 a.m.
Judge: Hon. James Ware
Dept.: Courtroom 9, 19th Floor

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ATTORNEYS AT LAW
SILICON VA LLE Y

STIPULATION AND [PROPOSED] ORDER
MODIFYING OPPOSITION DUE DATE
CASE NO.: C 03-02289 JW

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WHEREAS, on April 26, 2012, the Court issued an order requiring Defendant Ricoh

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Company, Ltd. (“Ricoh”) to pay to Plaintiff Synopsys, Inc. (“Synopsys”) the amount of

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$675,154.75 by May 25, 2012 (D.I. 790, “the April 26 Order”);

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WHEREAS, Ricoh filed a Notice of Appeal on April 21, 2012 (D.I. 791) and a Motion

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for Stay of April 26, 2012 Order Pending Appeal and for Expedited Consideration on May 23,

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2012 (D.I. 793, “Motion for Stay”);

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WHEREAS, Synopsys opposes Ricoh’s Motion for Stay;

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WHEREAS, Synopsys’s opposition to Ricoh’s Motion for Stay is due on June 6, 2012;

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WHEREAS, the parties are currently negotiating a compromise regarding Ricoh’s

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request for a stay of the payment of the $675,154.75 award to Synopsys in order to avoid further

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motion practice;

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WHEREAS, as set forth in the accompanying declaration of Richard G. Frenkel,

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modification of the due date for Synopsys’s Opposition to Ricoh’s Motion for Stay will not

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impact the schedule for the case going forward;

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WHEREAS, counsel for the parties have met and conferred and agreed upon an alternate

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due date for Synopsys’s Opposition to Ricoh’s Motion for Stay as set forth below, which the

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parties jointly and respectfully request that the Court adopt.

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Accordingly, IT IS HEREBY STIPULATED by the parties pursuant to N.D. Cal. Civil

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L.R. 6-2, that the due date for Synopsys’s Opposition to Ricoh’s Motion for Stay shall be June

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11, 2012.

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SO STIPULATED THROUGH COUNSEL OF RECORD.

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Respectfully submitted,
Dated: June 6, 2012

LATHAM & WATKINS LLP

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By: /s/ Richard G. Frenkel
Ron E. Shulman
Terry Kearney
Richard G. Frenkel

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Attorneys for SYNOPSYS, INC.

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ATTORNEYS AT LAW
SILICON VA LLE Y

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STIPULATION AND [PROPOSED] ORDER
MODIFYING OPPOSITION DUE DATE
CASE NO.: C 03-02289 JW

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Dated: June 6, 2012

DICKSTEIN SHAPIRO LLP

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By: /s/ Gary M. Hoffman
Gary M. Hoffman
Kenneth W. Brothers
Krista Carter
Cathy Chen

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Attorneys for RICOH COMPANY, LTD.
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ORDER
Based on the foregoing Stipulation and the accompanying Declaration of Richard G.
Frenkel, and good cause appearing,
IT IS HEREBY ORDERED that the due date for Synopsys’s Opposition to Ricoh’s
Motion for Stay is changed to June 11, 2012.

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June 7
Dated: ____________, 2012
Hon. Chief Judge James Ware
UNITED STATES DISTRICT JUDGE

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ATTORNEYS AT LAW
SILICON VA LLE Y

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STIPULATION AND [PROPOSED] ORDER
MODIFYING OPPOSITION DUE DATE
CASE NO.: C 03-02289 JW