Leader Technologies Inc. v. Facebook Inc.

Filing 521

Letter to The Honorable Leonard P. Stark from Steven L. Caponi regarding 32 Pending Motions To Be Resolved. (Attachments: # 1 Exhibit A)(Caponi, Steven)

EXHIBIT A
Below is a list of the current matters outstanding in this matter:
1.

Facebook’s Motion For Leave to Amend its Responsive Pleading to Add a Defense
and Counterclaim of Inequitable Conduct and to Amend Its False Marking
Counterclaim, filed March 25, 2010

2.

Facebook’s Motion for Summary Judgment No. 1: Invalidity of Claims 1, 4, 7, 21,
23, 25 31 and 32 of U.S. Patent No. 7,139,761, filed May 14, 2010

3.

Facebook’s Motion For Summary Judgment No. 2: Non-Infringement and No
Damages, filed May 14, 2010

4.

Facebook’s Motion For Summary Judgment No. 3: Non-Infringement, filed May 14,
2010

5.

Facebook’s Motion for Summary Judgment No. 4: No Willful Infringement, filed
May 14, 2010

6.

Facebook’s Motion For Summary Judgment No. 5: Invalidity of U.S. Patent No.
7,139,761 Based on the On-Sale Bar, filed May 14, 2010

7.

Facebook’s Motion For Summary Judgment No. 6: Validity of U.S. Patent No.
7,139,761 Based on Anticipation Under 35 U.S.C. Section 102(b), filed May 14, 2010

8.

Leader’s Motion For Summary Judgment of Facebook’s False Marking
Counterclaim, filed May 14, 2010

9.

Facebook’s Motion In Limine No. 1: To Preclude Any Doctrine of Equivalents
Argument, filed May 20, 2010

10.

Facebook’s Motion In Limine No. 2: To Preclude Evidence or Argument Beyond the
Three “Use Cases” Disclosed in LTI’s Expert Report, filed May 20, 2010

11.

Facebook’s Motion In Limine No. 3: To Preclude LTI from Using the Term
“Platform” to Refer to Facebook’s Product, filed May 20, 2010

12.

Facebook’s Motion In Limine No. 4: To Preclude Evidence or Argument Relating to
Internal Use of Accused Systems by Facebook Employees, filed May 20, 2010

13.

Facebook’s Motion In Limine No. 5: To Exclude the Deposition Errata of Jeffrey R.
Lamb, filed May 20, 2010

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14.

Facebook’s Motion In Limine No. 6: To Exclude LTI’s Late-Produced NonDisclosure Agreement, filed May 20, 2010

15.

Facebook’s Motion In Limine No. 7: To Exclude Reference to Any Other Litigation
Involving Facebook or Mark Zuckerberg, and the Circumstances Surrounding Those
Disputes, filed May 20, 2010

16.

Facebook’s Motion In Limine No. 8: To Preclude LTI from Referring to or
Introducing Any Evidence Relating to Any Alleged Acts of “Hacking” or
Unauthorized Access by Facebook or Mark Zuckerberg, filed May 20, 2010

17.

Facebook’s Motion In Limine No. 9: To Exclude Evidence or Argument that Mark
Zuckerberg Copied LTI’s White Papers, filed May 20, 2010

18.

Facebook’s Motion In Limine No. 10: To Preclude LTI Testimony on Topics for
Which Mr. McKibben Claimed Privilege at Deposition, filed May 20, 2010

19.

Facebook’s Motion In Limine No. 11: To Preclude References to Hurricane Katrina,
Terrorism or Virginia Tech, filed May 20, 2010

20.

Facebook's Motion In Limine No. 12: To Exclude Testimony and Evidence of Advice
of Counsel as a Defense to Facebook’s False Marking Counterclaim, filed May 20,
2010

21.

Facebook’s Daubert Motion No. 1: To Preclude Testimony by Leader Infringement
Expert Giovanni Vigna, filed May 20, 2010

22.

Facebooks’s Daubert Motion No. 2: To Preclude Testimony by Leader Expert James
Herbsleb, filed May 20, 2010

23.

Facebook’s Daubert Motion No. 3: To Preclude Testimony by Leader Expert Russell
L. Parr, filed May 20, 2010

24.

Leader’s Motion In Limine No. 1: To Exclude Portions of Expert Testimony of Saul
Greenberg, filed May 20, 2010

25.

Leader’s Motion In Limine No. 2: To Exclude Portions of Expert Testimony of
Michael Kearns, filed May 20, 2010

26.

Leader’s Motion In Limine No. 3: To Exclude Evidence of Facebook’s Settlement
Agreements and Expert Testimony Regarding Potential Design Arounds or NonInfringing Alternatives, filed May 20, 2010

27.

Leader’s Motion In Limine No. 4: To Exclude Evidence of Reexamination, filed May
20, 2010

28.

Leader’s Motion In Limine No. 5: To Exclude On-Sale and Public Disclosure
Defense, filed May 20, 2010
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29.

Leader’s Motion In Limine No. 6: To Exclude a Product-to-Product Comparison,
filed May 20, 2010

30.

Leader’s Motion In Limine No. 7: To Exclude References to a Potential Injunction,
filed May 20, 2010

31.

Leader’s Daubert Motion to Exclude Testimony in its Entirety of Facebook’s Experts
James Hughes and Kimberly Felix, filed May 20, 2010

32.

Leader’s Objections to Magistrate Judge Stark’s Order of March 12, 2010, filed
March 26, 2010

33.

Facebook's Motion for Redaction of Electronic Transcript of Hearing Dated April 9,
2010, filed May 7, 2010

34.

Facebook's Objections to Magistrate Judge Stark Order of April 27, 2010, filed
May 11, 2010

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