Pacer- e.DIGITAL v Dropcam - Joint case management statement
in response to
by
Message: Maycom had our technology...
Scheduling
The Parties request that the Court enter their proposed schedule which is attached as
Exhibit A.
XVIII. Trial
The Parties agree that this matter should be tried before a jury. Plaintiff estimates that
trial will be 5-7 days. Defendant believes that it is too early to determine the length of trial but
estimates that trial will take 5-7 Court days.
JOINT CASE MANAGEMENT
CASE STATEMENT
AND [PROPOSED] ORDER
NO. C-14-04922 JST
-14-
XIX. Disclosure of Non-party Interested Entities or Persons
Each party has filed a certification pursuant to Civil L.R. 3-16. (Dkt #5, 16).
Pursuant to Fed. R. Civ. P. 7.1 and Civil L.R. 3-16, Defendant Dropcam hereby discloses
that Dropcam is a wholly-owned subsidiary of Nest Labs, Inc. (“Nest”). Nest is a wholly-owned
subsidiary of public company Google Inc. (“Google”). No parent company or publicly-held
corporation owns 10% or more of Google’s stock.
XX. Professional Conduct
Counsel for the parties have reviewed the Guidelines for Professional Conduct.
XXI. Other
The parties are unaware of any other such matters at this time.
XXII. Patent Local Rule 2-1(a) Initial Case Management Conference Requirements
(1) Proposed Modification of the Obligations or Deadlines Set Forth in the Patent
Local Rules: The Parties have submitted the proposed schedule regarding the
deadlines for compliance with the Patent Local Rules, as set forth in Exhibit A.
(2) Scope and Timing of Claim Construction Discovery: The Parties have not yet
determined whether there is any need for expert testimony at the claim
construction hearing. Any party that expects to present, whether live or by
declaration or affidavit, expert testimony in support of its claim construction
position, will serve the Fed. R. Civ. P. 26(a)(2) disclosures at least thirty (30) days
before the due date for filing opening briefs on claim construction and make its
expert witness available for deposition at a mutually agreeable time after service
of the expert disclosures. The Parties will meet and confer regarding any
necessary claim construction discovery as the case progresses.
(3) Claim Construction Hearing: The Parties anticipate the Claim Construction
Hearing will take no more than a half-day. The Parties agree that, on a term-byterm
basis, Plaintiff will proceed first in the event of a contested construction and
Defendant will proceed first if Defendant has offered a claim construction and
Case3:14-cv-04922-JST Document41 Filed01/27/15 Page14 of 20
JOINT CASE MANAGEMENT
CASE STATEMENT
AND [PROPOSED] ORDER
NO. C-14-04922 JST
-15-
Plaintiff has not offered claim construction or otherwise proposed plain and
ordinary meaning. The Parties will meet and confer regarding any of the logistics
associated with the Claim Construction Hearing as the case progresses.
(4) Technology Tutorial: The Parties have proposed a technology tutorial be
presented to the Court.
Dated: January 27, 2015
HANDAL & ASSOCIATES
By:
/s/ Pamela C. Chalk
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
Dated: January 27, 2015
WILSON SONSINI GOODRICH & ROSATI
By:
/s/ Stefani E. Shanberg
Stefani E. Shanberg
Jennifer J. Schmidt
Madeleine E. Greene
Attorneys for Defendant
Dropcam, Inc.
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