STC.UNM v. Intel Corporation

Filing 97

Unopposed MOTION to Amend/Correct 75 Order on Motion to Extend (other) : Unopposed Joint Motion to Amend Scheduling Order (Doc. No. 75) and Extend Claim Construction Deadlines by STC. UNM. (Pedersen, Steven)

UNITED STATES DISTRICT COURT
DISTRICT OF NEW MEXICO
STC.UNM,
Plaintiff,
v.
INTEL CORPORATION,

No. 10-CV-01077-RB-WDS

Defendant.

UNOPPOSED JOINT MOTION TO AMEND SCHEDULING ORDER
[DOC. NO. 75] AND EXTEND CLAIM CONSTRUCTION DEADLINES
The parties hereby respectfully request the Court extend the deadlines for the claim
construction briefs. Amendment of the Scheduling Order as proposed by the parties herein will
not result in a delay in the timely disposition of this case and does not change the current fact or
expert discovery cutoffs previously set by the Court. By requesting this amendment of the
Scheduling Order, the parties are only requesting that the Court extend the following two
deadlines which relate to the briefing of claim constructions: (1) the deadline for the parties’
initial claim construction briefs (from June 10, 2011 to June 21) and (3) the deadline for the
parties’ responsive claim construction briefs (from July 15, 2011 to July 25).
The parties submit that the requested extension will provide more time for the parties to
continue their collaborative efforts to limit the number of claim terms for construction, which
will ultimately make the process more efficient for the Court.
Pursuant to D.N.M. LR-Civ. 7.1(a), this Motion is jointly made on behalf of all parties to
this litigation and is unopposed.

The parties agree that due to the possibility for further

compromise, good cause exists to extend the present deadlines for the exchange and briefing of

552534.01

claims constructions.
WHEREFORE, for the reasons set forth above, the parties respectfully request that the
Court enter its Order amending the April 18, 2011 Scheduling Order [Doc. No. 75] and
extending the deadlines for the parties’ exchange of claim construction and construction briefs.
Respectfully submitted,
ATKINSON, THAL & BAKER, P.C.
/s/ Brian L. Ferrall
Clifford K. Atkinson
Douglas A. Baker
Justin D. Rodriguez
201 Third St. NW, Suite 1850
Albuquerque, New Mexico 87102
[phone]
Robert A. Van Nest
Brian L. Ferrall
KEKER & VAN NEST LLP
Chad S. Campbell
Jonathan M. James
Timothy J. Franks
Mark E. Strickland
Jonathan L. McFarland
PERKINS COIE LLP
Attorneys for Defendant
Intel Corporation
-AND-

552534.01

2

/s/ Steven R. Pedersen
Deron B. Knoner, Esq.
KELEHER & MCLEOD, P.A.
PO Box AA
Albuquerque, NM 87103
[phone]
George C. Summerfield, Esq.
Joseph A. Grear, Esq.
Keith A. Vogt, Esq.
Rolf O. Stadheim, Esq.
Steven R. Pedersen, Esq.
STADHEIM & GREAR, LTD.
Attorneys for Plaintiff
STC.UNM
CERTIFICATE OF SERVICE
The undersigned certifies that on the 31st day of May, 2011 the foregoing was filed
electronically through the CM/ECF system, which caused all parties or counsel to be served by
electronic means.
/s/ Steven R. Pedersen
Steven R. Pedersen

552534.01

3