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

Filing 389

Opposed MOTION to Expedite Briefing Schedule on Motion to Enforce Compliance with the Court's Order of March 14, 2013 [Dkt. 388] by Alcatel-Lucent USA Inc., Ericsson Inc., Exedea INC., HTC America, Inc., HTC Corporation, Sony Mobile Communications (USA) Inc., Sony Mobile Communications AB, Telefonaktiebolaget LM Ericsson. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Text of Proposed Order)(Cornelius, William)

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Exhibit B From: To: Cc: Subject: Date: Pai, Ajeet Wynne, Richard L.; Alcatel-Lucent-Wi-LAN-Defense@kirkland.com; LegalTm-WiLANAlcatel@sheppardmullin.com; Ericsson: WI LAN Defense; William Cornelius (WC@WilsonLawFirm.com) Weaver, David; Wi-LAN RE: Wi-LAN v. Alcatel-Lucent et al. -- Meet and Confer on Defendants" Expedited Motion Tuesday, April 16, 2013 3:56:01 PM Rich,   Although we understand that Defendants wish to shorten the briefing schedule for Defendants’ proposed motion in order to permit the Court to take up that motion at the May 3, 2013 hearing (if it so chooses), the schedule proposed by Defendants is unreasonably compressed.   Wi-LAN is willing to agree to the following schedule as a compromise in order to accommodate Defendants’ desire to expedite the Court’s consideration of their motion:   · Defendants file motion:  April 16 · Plaintiff files response:  April 26 (ten days later). · No reply or sur-reply filed.   Wi-LAN would be unduly prejudiced by, and cannot agree to, a schedule which has briefing continuing during the week before the May 3 summary judgment hearing.   Please confirm that Defendants agree to the schedule proposed above.   Ajeet Pai Associate Vinson & Elkins LLP 2801 Via Fortuna, Suite 100 Austin, TX 78746-7568 Tel +1.512.542.8798 Fax +1.512.236.3317 apai@velaw.com   From: Wynne, Richard L. [mailto:Richard.Wynne@tklaw.com] Sent: Monday, April 15, 2013 4:30 PM To: Weaver, David; Wi-LAN; wh@wsfirm.com; jw@wsfirm.com; Alcatel-Lucent-Wi-LANDefense@kirkland.com; LegalTm-WiLAN-Alcatel@sheppardmullin.com Cc: Ericsson: WI LAN Defense; William Cornelius (WC@WilsonLawFirm.com) Subject: RE: Wi-LAN v. Alcatel-Lucent et al. -- Meet and Confer on Defendants' Expedited Motion to Enforce the Court's Order   David,                   Further to our call this afternoon, Defendants propose the following briefing schedule for the Defendants’ motion to enforce the Court’s order and to reject Plaintiff’s clawback request:   Ds File:  April 16 P Response:  April 23 Ds Reply:  April 26 P Sur-Reply: April 30 (or May 1)                   We would propose that, to the extent that it is consistent with the Court’s schedule and the Court wishes to entertain argument on the motion, it be heard on May 3rd , when the pending PCRA-related summary-judgment motions are set for hearing.  For that reason, we believe that it might be more appropriate for Wi-LAN to serve the sur-reply on April 30 th rather than May 1st, but Defendants are not opposed if Wi-LAN needs until May 1st to file the surreply under this schedule.                   Please let us know whether Wi-LAN is opposed to a motion to expedite the briefing according to this schedule.   Rich       Richard L. Wynne, Jr. Thompson & Knight LLP 1722 Routh Street, Suite 1500 Dallas, Texas 75201 214.969.1386 (direct) 214.880.3267 (fax) richard.wynne@tklaw.com vCard | Bio | TK Website Treasury Circular 230 Disclosure: To the extent this communication contains any statement regarding federal taxes, that statement was not written or intended to be used, and it cannot be used, by any person (i) as a basis for avoiding federal tax penalties that may be imposed on that person, or (ii) to promote, market or recommend to another party any transaction or matter addressed herein. CONFIDENTIALITY NOTICE: The information in this email may be confidential and/or privileged. This email is intended to be reviewed by only the individual or organization named above. If you are not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any review, dissemination or copying of this email and its attachments, if any, or the information contained herein is prohibited. If you have received this email in error, please immediately notify the sender by return email and delete this email from your system. Thank You.

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