Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 142

Joint MOTION ENTRY OF DISCOVERY ORDER by Uniloc Singapore Private Limited, Uniloc USA, Inc.. (Attachments: # 1 Text of Proposed Order)(Hill, Jack)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
UNILOC USA, INC., ET AL.
Plaintiffs,
vs.
SONY CORPORATION OF AMERICA,
ET AL.
Defendants.

UNILOC USA, INC., ET AL.
Plaintiffs,
vs.
DISK DOCTORS LABS, INC., ET AL.
Defendants.

UNILOC USA, INC., ET AL.
Plaintiffs,

vs.
NATIONAL INSTURMENTS COPR., ET
AL.
Defendants.

UNILOC USA, INC., ET AL.
Plaintiffs,
vs.
ENGRASP, INC., ET AL.
Defendants.

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CASE NO. 6:10-CV-373
PATENT CASE

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CASE NO. 6:10-CV-471
PATENT CASE

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CASE NO. 6:10-CV-472
PATENT CASE

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CASE NO. 6:10-CV-591
PATENT CASE

UNILOC USA, INC., ET AL.
Plaintiffs,
vs.
BMC SOFTWARE, INC., ET AL.
Defendants.

UNILOC USA, INC., ET AL.
Plaintiffs,
vs.
FOXIT CORPORATION, ET AL.
Defendants.

SYMANTEC CORPORATION, ET AL.
Plaintiffs,
vs.
UNILOC USA, INC., ET AL.
Defendants.

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CASE NO. 6:10-CV-636
PATENT CASE

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CASE NO. 6:10-CV-691
PATENT CASE

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CASE NO. 6:11-CV-33
PATENT CASE

JOINT MOTION FOR ENTRY OF DISCOVERY ORDER
Pursuant to the Court’s May 20, 2011 Order, Uniloc, Activision, Adobe, Aladdin, BMC,
Digital River, EA, Filemaker, Foxit, Freedom Scientific, GeoSpatial, Intego, Intuit, Magix,
McAfee, National Instruments, Onyx, Pinnacle, Safenet, Solar Winds, Sonic, Sony, Symantec,
Transmagic, and Wildpackets move the Court for entry of the attached Discovery Order. As
reflected in the certificate of conference attached hereto, 57 of the 60 defendants in all the related
cases have complied with the meet and confer requirements in Local Rule CV-7(h). While not

all parties have expressly joined in this motion, no party has expressed opposition to the
Discovery Order requested by this motion.

By: /s/ Paul J. Hayes (w/permission Wes Hill)
Paul J. Hayes – Lead Attorney
Dean G. Bostock
HAYES, BOSTOCK & CRONIN, LLC
300 Brickstone Square, 9th Floor
Andover, MA 01810
[phone]
[phone] (fax)
[e-mail]
T. John Ward, Jr.
Texas State Bar. No. 00794818
J. Wesley Hill
Texas State Bar. No. 24032294
WARD & SMITH LAW FIRM
111 West Tyler St.
Longview, Texas 75601
Tel: [phone]
Fax: [phone]
Email: [e-mail]
E-mail: [e-mail]
ATTORNEYS FOR PLAINTIFFS

CERTIFICATE OF CONFERENCE
I hereby certify that counsel for 57 of the 60 defendants has complied with the meet and
confer requirements in Local Rule CV-7(h). This motion is consented to and not opposed by the
parties listed below. Some parties have not participated.
The Court Issued its Order on May 20, 2011. Uniloc emailed to all defendants a
proposed Discovery Offer on May 22, 2011. A group of defendants circulated a counterproposal on May 26th. Seven group telephonic conferences were held May 27, 2011. Counsels
for Uniloc and various defendants exchanged numerous emails between May 22, and May 31,
2011. Uniloc circulated modifications on May 30, 2011. A group of defendants responded with
additional changes. A final meet and confer was conducted by telephone on May 31, 2011 with
counsels for a number of the parties. At the time of filing, twenty-seven (27) parties consented to
the Joint Proposed Discovery Order.
Parties consenting to the Joint Propose Discovery Order
Uniloc entities (2), Activision, Adobe, Aladdin entities (2), BMC, Digital River, EA, Filemaker,
Foxit, Freedom Scientific, GeoSpatial, Intego, Intuit, Magix, McAfee, National Instruments,
Onyx, Pinnacle, Safenet, Solar Winds, Sonic, Sony, Symantec, Transmagic, Wildpackets
/s/ Wesley Hill
Wesley Hill

CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have
consented to electronic service are being served with a copy of this document through the
Court’s CM/ECF system per Local Rule CV-5(a)(3) on the 31st day of May, 2011.

/s/ Wesley Hill
Wesley Hill