Judge Eleanor G. Tennyson

Unless otherwise agreed to by the parties, the parties shall make their initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(l) within five (5) days of the date this Order is entered by the Court.

Each side is limited to a total of ___ hours of taking testimony by deposition upon oral examination.

Briefing on such motions is subject to the page limits set out in connection with briefing of case dispositive motions.

After reviewing the motion, the Court will issue an order setting a discovery conference and outlining the specific dispute procedure to be used. On the date set by court order, generally not less than seventy-two (72) hours prior to the conference, the party seeking relief shall file with the Court a letter not to exceed three (3) pages in 12-point font

On the date set by court order, generally not less than forty-eight (48) hours prior to the conference, any party opposing the application for relief may file a letter not to exceed three (3) pages in 12-point font outlining that party’s reason for its opposition.

Plaintiff shall serve, but not file, its opening brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its answering brief, not to exceed 30 pages, on [DATE]. Plaintiff shall serve, but not file, its reply brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its sur-reply brief, not to exceed 10 pages, on [DATE].

No later than [DATE], the parties shall file a joint claim construction brief. The parties shall copy and paste their unfiled briefs into one brief, with their positions on each claim term in sequential order, in substantially the form below. If the joint brief as submitted is more than 80 pages, the parties must certify that the page limits in the Scheduling Order have not been violated and provide a brief explanation (e.g., formatting issues, listing of agreed-upon terms, etc.) as to why the brief is longer than 80 pages.

Any party opposing the motion shall include with its opposing papers a response to the moving party's concise statement, not to exceed six (6) pages, which admits or disputes the facts set forth in the moving party's concise statement on a paragraph-by-paragraph basis.

The moving party shall include with its reply papers a response to the opposing party's concise statement of facts, not to exceed four (4) pages, on a paragraph-by-paragraph basis.

The party opposing the motion may also include with its opposing papers a separate concise statement, not to exceed four (4) pages, which sets forth material facts as to which the opposing party contends there is a genuine issue to be tried.

Any motion for summary judgment must be accompanied by a separate concise statement, not to exceed six (6) pages, which details each material fact that the moving party contends is essential for the Court's resolution of the summary judgment motion (not the entire case) and for which the moving party contends there is no genuine issue to be tried.

permitted to file as many case dispositive motions as desired, but each SIDE will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40 pages for all answering briefs, and a combined total of 20 pages for all reply briefs, regardless of the number of case dispositive motions that are filed.

The parties must work together to ensure that the Court receives no more than a total of 250 pages (i.e., 50 + 50 + 25 regarding one side’s motions, and 50 + 50 + 25 regarding the other side’s motions) of briefing on all case dispositive motions and Daubert motions that are covered by this scheduling order and any other scheduling order entered in any related case that is proceeding on a consolidated or coordinated pretrial schedule.

The in limine request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request.

In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert’s testimony, the total amount of pages permitted for each SIDE for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs.

to a maximum of 20 pages of opening briefs, 20 pages of answering briefs, and 10 pages of reply briefs relating to any post-trial motions filed by that side, regardless of the number of motions filed.

to a maximum of 20 pages of opening briefs, 20 pages of answering briefs, and 10 pages of reply briefs relating to any post-trial motions filed by that side, regardless of the number of motions filed.

On the date set by court order, generally not less than seventy-two (72) hours prior to the conference, the party seeking relief shall file with the Court a letter not to exceed three (3) pages in 12-point font

In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert's testimony, the total amount of pages permitted for each SIDE for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs.

Plaintiff shall serve, but not file, its opening brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its answering brief, not to exceed 30 pages, on [DATE]. Plaintiff shall serve, but not file, its reply brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its sur-reply brief, not to exceed 10 pages, on [DATE].

On the date set by court order, generally not less than forty-eight (48) hours prior to the conference, any party opposing the application for relief may file a letter not to exceed three (3) pages in 12-point font outlining that party's reason for its opposition.

Each SIDE shall be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request. If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three (3) page submission. No reply shall be submitted on in limine requests unless otherwise permitted by the Court.

each SIDE will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40 pages for all answering briefs, and a combined total of 20 pages for all reply briefs, regardless of the number of case dispositive motions that are filed. In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert's testimony, the total amount of pages permitted for each SIDE for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs.

On the date set by court order, generally not less than seventy-two (72) hours prior to the conference, the party seeking relief shall file with the Court a letter not to exceed three (3) pages in 12-point font outlining the issues in dispute and that party's position on those issues. This submission shall include as exhibits (1) a proposed order that identifies with specificity the relief sought on an issue-

any party opposing the application for relief may file a letter not to exceed three (3) pages in 12-point font outlining that party's reason for its opposition.

any party opposing the application for relief may file a letter not to exceed three (3) pages in 12-point font outlining that party’s reason for its opposition.

Plaintiff shall serve, but not file, its opening brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its answering brief, not to exceed 30 pages, on [DATE]. Plaintiff shall serve, but not file, its reply brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its sur-reply brief, not to exceed 10 pages, on [DATE].

Plaintiff shall serve, but not file, its opening brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its answering brief, not to exceed 30 pages, on [DATE]. Plaintiff shall serve, but not file, its reply brief, not to exceed 20 pages, on [DATE]. Defendant shall serve, but not file, its sur-reply brief, not to exceed 10 pages, on [DATE].

No later than [DATE], the parties shall file a joint claim construction brief. The parties shall copy and paste their unfiled briefs into one brief, with their positions on each claim term in sequential order, in substantially the form below. If the joint brief as submitted is more than 80 pages, the parties must certify that the page limits in the Scheduling Order have not been violated and provide a brief explanation (e.g., formatting issues, listing of agreed-upon terms, etc.) as to why the brief is longer than 80 pages.

The in limine request shall be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request.

Each SIDE shall be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine requests shall be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request.

The in limine requests shall be supported by a maximum of three (3) pages of argument, may be opposed by a maximum of three (3) pages of argument, and the side making the in limine request may add a maximum of one (l) additional page in reply in support of its request.

Should any party subsequently choose to make a request for sealing or redaction, it must, promptly after the completion of the transcript, file with the Court a motion for sealing/redaction, and include as attachments (1) a copy of the complete transcript highlighted so the Court can easily identify and read the text proposed to be sealed/redacted and (2) a copy of the proposed redacted/sealed transcript.

Absent agreement among the parties and approval of the Court: (a) Identification of Accused Products and Asserted Patents. On or before [DATE], Plaintiff shall identify the accused product(s) [or method(s) or system(s)], the asserted patent(s) and Plaintiff’s damages theory. On the same date, Plaintiff shall also produce the prosecution history for each asserted patent.

(d) Invalidity Contentions. On or before [DATE], Defendant shall provide its initial invalidity contentions for each asserted claim and the related invalidating references. On or before [DATE], Plaintiff shall provide its initial validity contentions in response to Defendant’s initial contentions. On or before [DATE], Defendant shall provide its final invalidity contentions. On or before [DATE], Plaintiff shall provide its final validity contentions in response to Defendant’s final contentions.

(e) All final contentions (i.e., infringement, non-infringement, invalidity, validity) must include a party’s contentions under its proposed claim construction(s), as well as under the opposing claim construction(s) (if such an alternative contention exists).

(c) Infringement Contentions. On or before [DATE], Plaintiff shall provide its initial infringement contentions for each asserted claim. On or before [DATE], Defendant shall provide its initial non-infringement contentions in response to Plaintiff’s initial contentions. On or before [DATE], Plaintiff shall provide its final infringement contentions. On or before [DATE],

(b) Core Technical Documents. On or before [DATE], Defendant shall produce core technical documents related to the accused product(s) sufficient to show the functionality of the accused product(s), including but not limited to non-publicly available operation manuals, product literature, schematics and specifications. Defendant shall also produce sales figures for the accused product(s).

(a) Fact Discovery Cutoff. All fact discovery in this case shall be initiated so that it will be completed on or before [DATE].

(b) Document Production. Document production shall be substantially complete by [DATE].

For the party who has the initial burden of proof on the subject matter, the initial Federal Rule of Civil Procedure 26(a)(2) disclosure of expert testimony is due on or before [DATE]. The supplemental disclosure to contradict or rebut evidence on the same matter identified by another party is due on or before [DATE]. Reply expert reports from the party with the initial burden of proof are due on or before [DATE]. No other expert reports will be permitted without either the consent of all parties or leave of the Court.

To the extent that any objection to expert testimony is made pursuant to the principles announced in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it shall be made by motion no later than the deadline for dispositive motions set forth herein, unless otherwise ordered by the Court.

All expert discovery in this case shall be initiated so that it will be completed on or before [DATE].

[will not] permit expert declarations to be filed in connection with motions briefing (including case dispositive motions).

Any discovery motion filed without first complying with the following procedures will be denied without prejudice to renew pursuant to these procedures.

Any such motion shall attach the proposed amended pleading (as well as a “redline” comparison to the prior pleading) or the document proposed to be stricken.

the parties shall include a joint appendix with the joint claim construction brief, and the joint appendix shall include a copy of the patent(s) at issue and portions of all relevant intrinsic evidence, as well as any additional evidence cited in the parties’ briefing.

Any party opposing the motion shall include with its opposing papers a response to the moving party’s concise statement, not to exceed six (6) pages, which admits or disputes the facts set forth in the moving party’s concise statement on a paragraph-by-paragraph basis.

The moving party shall include with its reply papers a response to the opposing party’s concise statement of facts, not to exceed four (4) pages, on a paragraph-by-paragraph basis.

Any motion for summary judgment must be accompanied by a separate concise statement, not to exceed six (6) pages, which details each material fact that the moving party contends is essential for the Court's resolution of the summary judgment motion (not the entire case) and for which the moving party contends there is no genuine issue to be tried. Each fact shall be set forth in a separate numbered paragraph and shall be supported by specific citation(s) to the record.

The party opposing the motion may also include with its opposing papers a separate concise statement, not to exceed four (4) pages, which sets forth material facts as to which the opposing party contends there is a genuine issue to be tried.

Any motion for summary judgment must be accompanied by a separate concise statement, not to exceed six (6) pages, which details each material fact that the moving party contends is essential for the Court’s resolution of the summary judgment motion (not the entire case) and for which the moving party contends there is no genuine issue to be tried.

At least seven (7) days before the final pretrial conference, the parties shall file proposed voir dire, preliminary jury instructions, final jury instructions and special verdict forms pursuant to Local Rules 47.1(a)(2) and 51.1. The Court expects the parties to work together to submit joint proposed versions of the voir dire, preliminary jury instructions and final jury instructions, indicating within those joint submissions any differences between the parties’ proposals.

Any non-dispositive motion must contain the statement required by Local Rule 7.1.1.

The proposed final pretrial order shall contain a table of contents and the paragraphs must be numbered.

Any such motion shall attach the proposed amended pleading (as well as a "redline" comparison to the prior pleading) or the document proposed to be stricken.

Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order.

Intrinsic evidence (including copies of the patent(s) at issue) shall NOT be attached to the joint claim construction chart and, instead, the parties shall include a joint appendix with the joint claim construction brief, and the joint appendix shall include a copy of the patent(s) at issue and portions of all relevant intrinsic evidence, as well as any additional evidence cited in the parties' briefing.

include as exhibits (1) a proposed order that identifies with specificity the relief sought on an issue-by-issue basis and (2) copies of any discovery requests and responses relating to the dispute

All motions to join other parties, and to amend or supplement the pleadings, shall be filed on or before [DATE].

Unless otherwise agreed to by the parties, the parties shall make their initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(l) within five (5) days of the date this Order is entered by the Court.

Should any party subsequently choose to make a request for sealing or redaction, it must, promptly after the completion of the transcript, file with the Court a motion for sealing/redaction, and include as attachments (1) a copy of the complete transcript highlighted so the Court can easily identify and read the text proposed to be sealed/redacted and (2) a copy of the proposed redacted/sealed transcript.

Any proposed protective order must include the following paragraph: Other Proceedings. By entering this order and limiting the disclosure of information in this case, the Court does not intend to preclude another court from finding that information may be relevant and subject to disclosure in another case. Any person or party subject to this order who becomes subject to a motion to disclose another party's information designated "confidential" [the parties should list any other level of designation, such as "highly confidential," which may be provided for in the protective order] pursuant to this order shall promptly notify that party of the motion so that the party may have an opportunity to appear and be heard on whether that information should be disclosed.

This submission shall include as exhibits (1) a proposed order that identifies with specificity the relief sought on an issue-

Any such motion shall attach the proposed amended pleading (as well as a "redline" comparison to the prior pleading) or the document proposed to be stricken.

All joint claim construction charts shall be in substantially the same form as the sample joint claim construction chart found in the "Forms" section of Magistrate Judge Tennyson's portion of the Court's website.