Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01436-JJF Document 34-2 Filed 05/23/2005 Page 1 of 2
Key Dates In Defendants’ Proposed Scheduling Order
14 days of agreed- Initial Disclosures
upon conclusion of
Rule 26(f) conference
6/10/2005 Commencement of Ownership Fact Discovery (commencement of
document production, interrogatories, and identification of fact witnesses
regarding ownership issue)
8/26/2005 Close of Certain Ownership Fact Discovery (close of document
production, contention interrogatories, and identification of fact witnesses
regarding ownership issue)
8/26/2005 ` Commencement of Ownership Fact Depositions
11/18/2005 Close of Remaining Ownership Fact Discovery (close of remaining fact
discovery regarding ownership issue)
12/9/2005 J oinder of Parties _
12/9/2005 Amendment of Pleadings
January 2006 Trial of Ownership Issue
2/13/2006 Commencement of Non-Ownership Fact Discovery (commencement of
document production, interrogatories, and identification of fact witnesses)
5/16/2006 Asserted Claims and Infringement Contentions (identification by
plaintiff of each claim asserted against each defendant and production of
infringement charts)
5/29/2006 Willfulness Election (election by defendants whether to rely on opinion of
counsel)
5/29/2006 Waiver Election (election by plaintiff whether to waive privilege
regarding patent applications)
6/28/2006 Willfulness Motion (filing by defendants of any motion to bifurcate)
7/17/2006 Close of Certain Non-Ownership Fact Discovery (close of document
production, contention interrogatories, and identification of fact witnesses)
7/17/2006 Commencement of Non-Ownership Fact Depositions
7/31/2006 Prior Art Disclosures (disclosure by defendants of prior art)
8/15/2006 Claim Construction (identification by each party of the terms, clauses or
phrases to be construed)
8/31/2006 Claim Construction (exchange by the parties of the proposed
constructions of the terms, clauses or phrases to be construed)
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Case 1:04-cv-01436-JJF Document 34-2 Filed 05/23/2005 Page 2 of 2
9/8/2006 Claim Construction (meet-and—confer by the parties regarding proposed
claim constructions)
9/15/2006 Claim Construction (filing of pre-claim construction statement)
10/6/2006 Claim Construction (tiling of opening claim construction briefs)
10/27/2006 Claim Construction (filing of rebuttal briefs)
November 2006 Markman Hearing
12/20/2006 Close of Remaining Ownership Fact Discovery
1/22/2007 Experts (filing of initial reports)
2/19/2007 Experts (filing of rebuttal reports)
4/18/2007 Experts (close of expert discovery/depositions)
5/18/2007 _ Case Dispositive Motions (filing of summary judgment and other case
dispositive motions)
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