WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 224

Unopposed MOTION to Amend/Correct 99 Order and 215 Order by WI-LAN Inc.. (Attachments: # 1 Text of Proposed Order)(Pai, Ajeet)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
WI-LAN INC.,
Plaintiff,
v.
ALCATEL-LUCENT USA INC.;
TELEFONAKTIEBOLAGET LM ERICSSON;
ERICSSON INC.; SONY MOBILE
COMMUNICATIONS AB; SONY MOBILE
COMMUNICATIONS (USA) INC.; HTC
CORPORATION; HTC AMERICA, INC.;
EXEDEA INC.; LG ELECTRONICS, INC.; LG
ELECTRONICS MOBILECOMM U.S.A., INC.;
LG ELECTRONICS U.S.A., INC.
Defendants.

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Civil Action No. 6:10-cv-521-LED
JURY TRIAL DEMANDED

UNOPPOSED MOTION TO AMEND DOCKET CONTROL ORDER
Plaintiff Wi-LAN Inc. (“Wi-LAN”) brings this unopposed Motion to Amend the Docket
Control Order (Dkt. Nos. 99, 215) and would respectfully show the Court the following:
The proposed modification is necessary to permit the parties to complete certain
damages-related discovery (including 30(b)(6) depositions) so that it can be incorporated in
initial damages expert reports. All other dates currently specified by the Docket Control
Order would remain unchanged, with the relevant pre-trial and trial dates unaffected.
Accordingly, Wi-LAN respectfully requests that the Court enter the attached proposed Order
effecting the above modifications as follows. No party opposes this motion.
Event
Parties with burden of proof designate expert
witnesses (non-damages issues). Expert witness
reports due (non-damages issues).

Current

Sept. 21, 2012

Revised

(no change)

Parties with burden of proof designate expert
witnesses (damages issues). Expert witness
reports due (damages issues).

Sept. 21, 2012

Sept. 26, 2012

Parties designate rebuttal expert witnesses (nondamages issues). Rebuttal expert witness reports
due (non-damages issues).

Oct. 19, 2012

(no change)

Parties designate rebuttal expert witnesses
(damages issues). Rebuttal expert witness reports
due (damages issues).

Oct. 19, 2012

Oct. 24, 2012

Dated: September 5, 2012

Respectfully submitted,

Local Counsel
Johnny Ward (TX Bar No. 00794818)
Wesley Hill (TX Bar No. 24032294)
WARD & SMITH LAW FIRM
P.O. Box 1231
1127 Judson Rd., Ste. 220
Longview, TX 75606-1231
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

By:

/s/ Ajeet P. Pai
David B. Weaver (TX Bar No. 00798576)
Lead Attorney
Michael A. Valek (TX Bar No. 24044028)
Avelyn M. Ross (TX Bar No. 24027817)
Ajeet P. Pai (TX Bar No. 24060376)
Syed K. Fareed (TX Bar No. 24065216)
Jeffrey T. Han (TX Bar No. 24069870)
Janice Ta (TX Bar No. 24075138)
Seth A. Lindner (TX Bar No. 24078862)
VINSON & ELKINS LLP
2801 Via Fortuna, Suite 100
Austin, TX 78746
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Chuck P. Ebertin
California Bar No. 161374
VINSON & ELKINS LLP
525 University Avenue, Suite 410
Palo Alto, CA 94301-1918
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff, Wi-LAN Inc.

CERTIFICATE OF CONFERENCE
The undersigned certifies that Plaintiff Wi-LAN, Inc. has complied with the requirements of
Local Rule CV-7(h), and no party opposes the relief sought herein.
/s/ Ajeet P. Pai
Ajeet P. Pai

CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was filed electronically in compliance with
Local Rule CV-5(a). As such, this document was served on all counsel who are deemed to have
consented to electronic service. Local Rule CV-5(a)(3)(A). All other counsel of record not deemed to
have consented to electronic service were served with a true and correct copy of the foregoing by email,
on September 5, 2012.

/s/ Ajeet P. Pai
Ajeet P. Pai
US 1555720