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

Filing 229

Unopposed MOTION to Amend/Correct 99 Order Docket Control 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.; et al.,
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, 226) and would respectfully show the Court the following:
Defendants and Wi-LAN have agreed to extend the date for opening expert reports
relating to damages to October 3, 2012, and responsive damages reports to October 31, 2012.
Further, HTC, Sony Mobile, and Wi-LAN have agreed to allow Wi-LAN to supplement, by
October 5, 2012, its infringement expert report with respect to HTC and Sony Mobile, and to
extend the date for HTC’s and Sony Mobile’s responsive non-infringement reports to
November 2, 2012. The proposed modifications are necessary to allow sufficient time to
complete and analyze fact discovery. 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 parties’ agreement above.

Dated: September 26, 2012

Respectfully submitted,

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]

Local Counsel
Johnny Ward (TX Bar No. 00794818)
Wesley Hill (TX Bar No. 24032294)
WARD & SMITH LAW FIRM
P.O. Box 1231
1127 Judson Road, Suite 220
Longview, TX 75606-1231
Tel: [phone]
Fax: [phone]
[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 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 26, 2012.
/s/ Ajeet P. Pai
Ajeet P. Pai

CERTIFICATE OF CONFERENCE
The undersigned certifies that Plaintiff Wi-LAN Inc. has complied with the requirements
of Local Rule CV-7(h), and Defendants do not oppose the relief sought herein.
/s/ Ajeet P. Pai
Ajeet P. Pai
US 1585288v.1