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)

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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 (505) 764-8111 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 (505) 842-9150 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

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