Oops, not all of it copied?
posted on
Apr 13, 2010 11:33PM
the parties what they need” to engage in meaningful settlement discussions and litigate this case most efficiently, without causing much delay in general discovery or the case schedule. For these reasons, Defendants propose the following schedule for this case: a. Initial Disclosures by Plaintiff due April 7: In addition to the disclosures required by the Federal Rules, Plaintiff will provide: (i) an identification of the accused products for each Defendant; (ii) an identification of the asserted claims for each Defendant; and (iii) Documents sufficient to show structure, operation and components of the “Flashback Digital Recorder” referred to in the Amendment A of the prosecution history of the ‘774 patent b. Initial Disclosures by Defendants due April 7: In addition to the disclosures required by the Federal Rules, Defendants will provide: (i) Documents sufficient to show structure, operation and components of each of the accused devices specifically identified by model name in the table of products included in Plaintiff’s First Set of Requests for Production of Documents to Defendants served on each of the Defendants. A Defendant may provide exemplary documentation for groupings of accused product if it in good faith believes it is appropriate to do so and it identifies the documentation associated with a particular group of products. c. April 15, 2010 – Parties exchange list of terms in asserted claims that parties believe require construction, along with their proposed constructions; d. April 29, 2010 – Deadline for parties to meet and confer in an effort to agree on proposed constructions; e. Supplemental Disclosures by Defendants due April 30: (i) Documents sufficient to show structure, operation and components of each of the products identified on the list provided by Plaintiff per disclosure (a)(i) for which documentation was not provided on April 7. A Defendant may provide exemplary documentation for groupings of accused product if it in good faith believes it is appropriate to do so and it identifies the documentation associated with a particular group of products.