STC.UNM v. Intel Corporation

Filing 95

MOTION for Leave to File To File A Supplemental Submission In Support of Motion to Compel by STC. UNM. (Attachments: # 1 STC's Supplemental Submission In Support of Motion to Compel, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Pedersen, Steven)

Download PDF
UNITED STATES DISTRICT COURT DISTRICT OF NEW MEXICO STC.UNM, Plaintiff, v. INTEL CORPORATION, Civil No. 10-CV-01077-RB-WDS Defendant. STC'S MOTION FOR LEAVE TO FILE A SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL Pursuant to Local Rule 7.4(b), STC seeks leave of the Court to file a short submission in response to statements made by Intel’s counsel during oral argument. As shown in the accompanying memorandum, Intel’s counsel made misrepresentations to the Court concerning the holding in Merck & Co., Inc. v. Mediplan Health that it specifically rejected AME damages for reasonable royalties when it did not. Also, Merck’s brief in that case cited a decision where AME royalty damages were awarded. Dated: May 25, 2011 Respectfully submitted, Deron B. Knoner KELEHER & MCLEOD, P.A 201 Third Street NW, 12th Floor PO Box AA Albuquerque, New Mexico 87103 (505) 346-4646 /s/ Steven R. Pedersen Rolf O. Stadheim Joseph A. Grear George C. Summerfield Keith A. Vogt Steven R. Pedersen STADHEIM & GREAR, LTD. 400 N. Michigan Avenue, Suite 2200 Chicago, Illinois 60611 (312) 755-4400 Attorneys for Plaintiff STC.UNM Certificate of Conference: The undersigned conferred with counsel for Intel regarding the instant motion. Intel does not consent to the motion. /s/ Steven R. Pedersen Certificate of Service: I hereby certify that on May 25, 2011, I caused the foregoing to be electronically filed with the Clerk of the Court using the CM/ECF system which will send notification of such filing via electronic mail to all counsel of record. /s/ Steven R. Pedersen 2  

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?