WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al
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)
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
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.
Vinson & Elkins LLP
2801 Via Fortuna, Suite 100
Austin, TX 78746-7568
From: Wynne, Richard L. [mailto:Richard.Wynne@tklaw.com]
Sent: Monday, April 15, 2013 4:30 PM
To: Weaver, David; Wi-LAN; email@example.com; firstname.lastname@example.org; 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
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.
Richard L. Wynne, Jr.
Thompson & Knight LLP
1722 Routh Street, Suite 1500
Dallas, Texas 75201
vCard | Bio | TK Website
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