ANTON HANDAL (Bar No. 113812)
anh@handal-law.com
PAMELA C. CHALK (Bar No. 216411)
pchalk@handal-law.com
GABRIEL HEDRICK (Bar No. 220649)
ghedrick@handal-law.com
HANDAL & ASSOCIATES
750 B Street, Suite 2510
San Diego, California 92101
Tel: 619.544.6400
Fax: 619.696.0323
Attorneys for Plaintiff
e.Digital Corporation
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
In Re e.Digital Corporation Cases
Case Nos.
15-CV-135-H-BGS
15-CV-141-H-BGS
15-CV-144-H-BGS
15-CV-314-H-BGS
PROPOSED REQUEST FOR
MODIFICATION OF THE COURT’S
PROPOSED SCHEDULING ORDER
CMC Date: May 12, 2015
Time: 10:30 a.m.
Judge: Judge Marilyn L. Huff
Assigned to the Honorable
Judge Marilyn L. Huff
Courtroom 15A (Annex)
On or about May 5, 2015, the Court issued its “(1) Consolidating Cases for
Pre-Trial Purposes, (2) Setting A Case Management Conference, and (3) Issuing
Tenative Scheduling Order” (Dkt #21 in the lead case consolidated case e.Digital
Corporation v.
e.Digital Corporation v. Lenovo (United States) Inc., et al. (Case
Number: 3:15-cv-135-H-BGS) (“CMC Order”) consolidating the following cases
for pre-trial purposes:

1) Case No. 3:15-cv-00135-H-BGS, e.Digital Corporation v. Lenovo
United States, Inc.;
2) Case No. 3:15-cv-141-H-BGS, e.Digital Corporation v. Spansion
Inc., et al.;
3) Case No. 3:15-cv-144-H-BGS, e.Digital Corporation v. Acer
America Corporation; and,
4) Case No. 3:15-cv-314-H-BGS, e.Digital Corporation v. SMART
Modular Technologies, Inc.
The above-listed cases are collectively referred to herein as the
“Consolidated Cases.” The Defendants in each of the above-listed cases are
collectively referred to as the “Defendants.” The Plaintiff in each of the abovelisted
cases, e.Digital Corporation, is referred to herein as “Plaintiff.” Plaintiff and
the Defendants are collectively referred to herein as the “Parties.”
In addition to consolidating the above-titled matters, the CMC Order ordered
counsel for the Parties to meet and confer via telephone regarding the tentative
schedule (“Tenative Scheduling Order”) set forth in the Court’s CMC Order.
(CMC Order, Dkt #21-1).
Plaintiff hereby respectfully submits the following request to modify the
Court’s Tenative Scheduling Order in advance of the Case Management
Conference currently set in the above-titled matters for May 12, 2015 at 10:30 a.m.
Upon information and belief, the Defendants join in this request and/or do
not object to the request made herein except as otherewise noted.
II. MEETING OF COUNSEL
The Parties in the Consolidated Cases, via their counsel, conducted a
telephonic meet-and-confer conference pursuant to the Court’s CMC Order on
May 8, 2015 and discussed the Court’s Tenative Scheduling Order. During the
conference, the Parties, via their counsel, agreed to request that the Court modify
its Tenative Scheduling Order as requested herein in order to avoid scheduling

conflicts of counsel. Plaintiff submits this request accordingly and respectfully asks
that the Court adopt the schedule proposed herein as the final order of the Court.
II. PROPOSED MODIFIED SCHEDULE
On behalf of the Parties and/or Plaintiff, Plaintiff hereby respectfully
requests that the Court modify the Court’s Tenative Scheduling Order for the
Consolidated Cases as follows:
Event Tentative Date Orderd
By The Court
Proposed
Modification
Initial Case Management
Conference or Further Case
Management
May 12, 2015 at 10:30
a.m.
N/A
Plaintiff's Disclosure of
Asserted Claims and
Infringement Contentions
to include Document
Production Accompanying
Disclosure
May 19, 2015 July 18, 2015
*All Defendants but
Spansion who proposes
July 7, 2015 instead. 1
Deadline to File Motion to
Amend Pleadings and/or
Add Parties
June 15, 2015 August 21, 2015
Defendant's Preliminary
Invalidity Contentions
June 22, 2015 August 21, 2015
Exchange Preliminary
Proposed Claim
Constructions and
Identification of Extrinsic
July 6, 2015 September 4, 2015
1 Spansion asserts that because the invalidity contentions are a responsive pleading,
it be provided 11 extra days from the normal period given that Plaintiff is
requesting at least six additional weeks from Court’s schedule in which to prepare
its infringement contentions.

Evidence
Exchange Responsive
Claim Constructions and
Identification of Extrinsic
Evidence
July 17, 2015 September 17, 2015
File Joint Claim
Construction Chart,
Worksheet, and Hearing
Statement
July 24, 2015 September 24, 2015
Amended and Final
Contentions
July 24, 2015 September 24, 2015
Amended and Final
Invalidity Contentions
August 14, 2015 October 14, 2015
Claim Construction
Discovery Ends
August 14, 2015 October 14, 2015
Opening Claim
Construction Briefs
August 28, 2015 October 28, 2015
Responsive Claim
Construction Briefs
September 11, 2015 November 13, 2015
Claim Construction
Hearing
September 18, 2015 November 19, 2015
Exchange Expert Witness
List (Trial Experts)
October 16, 2015 December 16, 2015
Supplemental Expert
Witness List
October 30, 2015 December 30, 2015
Service of Expert Reports November 25, 2015 February 5, 2016
Service of Supplemental
Expert Reports
December 18, 2015 February 26, 2016
Close of Fact Discovery January 8, 2016 March 18, 2016

Close of Expert Discovery February 26, 2016 May 4, 2016
Deadline for Filing
Dispositive Motions and
Any Motions Addressing
Daubert Issues
March 28, 2016 June 3, 2016
Juror Questionnaire April 1, 2016 June 6, 2016
Memo of Facts and
Contentions of Law; Pretrial
Disclosures
April 25, 2016 June 24, 2016
Exchange Exhibits and
Demonstratives
May 2, 2016 June 29, 2016
Jury Instructions,;
Proposed Verdict Forms;
Proposed Pretrial Order;
Proposed Jury Questions
May 13, 2016 July 11, 2016
Final Pretrial Conference;
Motions in Limine Hearing
May 16, 2016 July 15, 2016
Deposition Designations May 27, 2016
July 22, 2016
Deposition Counter-
Designations
June 2, 2016
July 27, 2016
Status Conference; bring
exhibits
June 6, 2016
August 8, 2016
Trial Date June 7, 2016 August 9, 2016
III. CONCLUSION
It is respectfully requested that:
1) The Court modify its Tenative Scheduling Order as stated above and
make the modified scheduled the final scheduling order of the Court.

PROPOSED MODIFICATION TO COURT’S CASE NOS.: 15-CV-135-H-BGS; 15-CV-141-H-BGS; 15-CV-144-H-BGS
PROPOSED SCHEDULING ORDER 15-CV-314-H-BGS

Dated: May 11, 2015
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk_________________
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation