Personalized User Model LLP v. Google Inc.

Filing 353

STIPULATION Regarding Expert Discovery Schedule by Google Inc.. (Horwitz, Richard)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PERSONALIZED USER MODEL, L.L.P.,
Plaintiff,
v.
GOOGLE INC.,
Defendant.

)
)
)
)
)
)
)
)
)

C.A. No. 09-525-LPS
JURY TRIAL DEMANDED

STIPULATION REGARDING EXPERT DISCOVERY SCHEDULE
WHEREAS, pursuant to this Court’s Scheduling Order (D.I.104), the deadlines
for the parties to exchange opening expert reports, rebuttal expert reports, complete expert
depositions, and file dispositive motions, trigger off of the date the Court issues an order on
claim construction;
WHEREAS, the Court issued an order on claim construction on January 25, 2012;
WHEREAS, the parties have agreed to extend these deadlines as set forth in the
chart below.
NOW, THEREFORE, IT IS HEREBY STIPULATED by and among the parties,
subject to the approval of the Court, that the April 12, 2010 Rule 16 Scheduling Order (D.I. 32),
as amended by the September 30, 2010 Stipulated Amended Scheduling Order (D.I. 104) shall
be amended as follows:
Activity

Former Date

Reports from retained experts required
by Fed. R. Civ. P. 26(a)(2) due from
the party with the burden of proof on
the issue the expert is offered

30 days after the issuance
of the Court's Markman
decision

New Date

March 23, 2012

Rebuttal reports due1
Deadline to notice and complete
depositions of expert witnesses
Case dispositive motions

30 days from the date
Opening Reports are due
30 days from the date
rebuttal reports are due
Within 30 days of the
close of expert discovery.
No case dispositive
motion may be filed more
than ten (10) days from
the above date without
leave of the Court.

May 22, 2012
July 20, 2012
August 20, 20122
No case dispositive
motion may be filed more
than ten (10) days from
the above date without
leave of the Court.

MORRIS, NICHOLS, ARSHT & TUNNELL
LLP

POTTER ANDERSON & CORROON LLP

By: /s/ Karen Jacobs Louden
Karen Jacobs Louden (#2881)
Jeremy A. Tigan (#5239)
1201 N. Market Street
Wilmington, DE 19801
[phone]
[e-mail]
[e-mail]

By: /s/ Richard L. Horwitz
Richard L. Horwitz (#2246)
David E. Moore (#3983)
Hercules Plaza, 6th Floor
1313 N. Market Street
Wilmington, DE 19801
Tel: [phone]
[e-mail]
[e-mail]

Attorneys for Plaintiff Personalized User
Model, L.L.P.

Attorneys for Defendant Google, Inc.

SO ORDERED this _______ day of __________, 2012.

___________________________________
U.S.D.J.

1045295 / 34638

1

No other expert reports are permitted without consent of all parties or leave of the Court.
The deadlines for filing oppositions to and replies in support of case dispositive motions shall
be as set forth in the Local Rules, unless otherwise agreed in writing by the parties or ordered by
the Court.
2