Free Order Returning Sealed Documents - District Court of Delaware - Delaware

Case 1:04-cv-00960-SLR

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Filed 07/31/2007

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By Larisha Davis at 11:20 am, Jun 20, 2007

CLOSED, PaperDocuments

U.S. District Court District of Delaware (Wilmington) CIVIL DOCKET FOR CASE #: 1:04-cv-00960-SLR Internal Use Only

J-Squared Inc., et al v. Motorola Inc. Assigned to: Honorable Sue L. Robinson Demand: $0 Related Case: 1:06-cv-00114-SLR Cause: 28:1332 Diversity-Breach of Contract Plaintiff J-Squared Technologies Inc. a Canadian corporation

Date Filed: 08/20/2004 Date Terminated: 10/27/2006 Jury Demand: Plaintiff Nature of Suit: 190 Contract: Other Jurisdiction: Diversity

represented by David A. Felice Cozen O'Connor Chase Manhattan Centre 1201 North Market St., Suite 1400 Wilmington, DE 19801 (302) 295-2000 Fax: (302) 295-2013 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Sean J. Bellew Cozen O'Connor Chase Manhattan Centre 1201 North Market St., Suite 1400 Wilmington, DE 19801 (302) 295-2000 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff J-Squared Technologies (Oregon) Inc. an Oregon corporation represented by David A. Felice (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Sean J. Bellew (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED V.

Case 1:04-cv-00960-SLR

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Defendant Motorola Inc. a Delaware corporation represented by William W. Bowser Young Conaway Stargatt & Taylor, LLP The Brandywine Building 1000 West Street, 17th Floor P.O. Box 391 Wilmington, DE 19899-0391 (302) 571-6601 Fax: (302) 576-3282 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Cory A. Talbot Pro Hac Vice Email: [email protected] ATTORNEY TO BE NOTICED Emily S. Cates Pro Hac Vice Email: [email protected] ATTORNEY TO BE NOTICED

Date Filed 08/20/2004 08/20/2004 08/20/2004 08/23/2004 08/31/2004 09/01/2004 09/10/2004 09/10/2004 09/10/2004

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Docket Text 1 COMPLAINT filed. Magistrate Consent Notice to Pltf. FILING FEE $ 150.00 RECEIPT # 136720 (els) (Entered: 08/23/2004) DEMAND for jury trial by J-Squared Inc., J-Squared (Oregon) (els) (Entered: 08/23/2004) SUMMONS(ES) issued for Motorola Inc. (els) (Entered: 08/23/2004) 2 RETURN OF SERVICE executed as to Motorola Inc. 8/20/04 Answer due on 9/9/04 for Motorola Inc. (dab) (Entered: 08/23/2004) 3 Disclosure Statement pursuant to Rule 7.1 by J-Squared Inc., J-Squared (Oregon) (dab) (Entered: 08/31/2004) 4 CASE assigned to Judge Sue L. Robinson . Notice to all parties. (rjb) (Entered: 09/01/2004) 5 NOTICE of attorney appearance for Motorola Inc. by William W. Bowser (fmt) (Entered: 09/10/2004) 6 MOTION by Motorola Inc. with Proposed Order for Richard A. Halloran, Esquire to Appear Pro Hac Vice (fmt) (Entered: 09/10/2004) 7 MOTION by Motorola Inc. with Proposed Order for Randy S. Papetti, Esquire to Appear Pro Hac Vice (fmt) (Entered: 09/10/2004)

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01/18/2006) 01/18/2006 01/18/2006 01/19/2006 70 NOTICE to Take Deposition of Steve Bloome on Thursday, February 2, 2006, 2 p.m., by Motorola Inc..(Bowser, William) (Entered: 01/18/2006) 71 NOTICE to Take Deposition of Jeffrey Gibson on Tuesday, January 31, 2006, 9 a.m., by Motorola Inc..(Bowser, William) (Entered: 01/18/2006) 72 NOTICE OF SERVICE of JST's Second Set of Interrogatories Directed to Defendant, JSO's Second Set of Interrogatories Directed to Defendant; Plaintiffs' First Request for Admissions Directed to Plaintiff, and JSO's First Set of Requests for Production by J-Squared Technologies Inc., JSquared Technologies (Oregon) Inc..(Felice, David) (Entered: 01/19/2006) 73 Joint STIPULATION TO EXTEND TIME Discovery Cutoff and Expert Disclosure Deadlines to April 3, 2006, for discovery cutoff, and March 1, 2006, for expert disclosure deadline, and April 3, 2006, for rebuttal expert disclosure deadline - filed by Motorola Inc.. (Bowser, William) (Entered: 01/30/2006) SO ORDERED, re 73 Joint STIPULATION TO EXTEND TIME Discovery Cutoff and Expert Disclosure Deadlines to April 3, 2006, for discovery cutoff, and March 1, 2006, for expert disclosure deadline, and April 3, 2006, for rebuttal expert disclosure deadline filed by Motorola Inc., ReSetting Deadlines: Discovery due by 4/3/2006. Signed by Judge Sue L. Robinson on 2/1/06. (rld, ) (Entered: 02/01/2006) 74 NOTICE OF SERVICE of Subpoena - Avnet, Inc. by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Attachments: # 1 Exhibit A)(Felice, David) (Entered: 02/03/2006) 75 SUBPOENA Returned Executed as to Arrow Electronics, Inc. on January 31, 2005 (Attachments: # 1 Exhibit A - Subpoena and Affidavit of Service - Arrow Electronics, Inc.)(Felice, David) (Entered: 02/06/2006) 76 SEALED MOTION to Compel Motorola to Respond to Interrogatories and Produce Documents - filed by J-Squared Technologies Inc., JSquared Technologies (Oregon) Inc.. (Felice, David) (Entered: 02/22/2006) 77 NOTICE OF SERVICE of Defendant's Response to Plaintiff J-Squared Technologies Inc.'s Second Set of Interrogatories (Nos. 21-25) by Motorola Inc..(Bowser, William) (Entered: 02/27/2006) 78 NOTICE OF SERVICE of Defendant's Response to Plaintiff J-Squared Technologies (Oregon), Inc.'s Second Set of Interrogatories (Nos. 3-19 [sic]) by Motorola Inc..(Bowser, William) (Entered: 02/27/2006) 79 NOTICE OF SERVICE of Defendant's Response to Plaintiff's Request for Admission by Motorola Inc..(Bowser, William) (Entered: 02/27/2006) 80 NOTICE OF SERVICE of Defendant's Response to Plaintiff J-Squared

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March 29, 2006 (Attachments: # 1 Exhibit A - Executed Subpoena) (Felice, David) (Entered: 04/21/2006) 04/24/2006 SO ORDERED, re 115 Joint MOTION for Extension of Time to submit Motorola's Expert Report filed by Motorola Inc. until 4/27/06. . Signed by Judge Sue L. Robinson on 4/24/06. (rld, ) (Entered: 04/24/2006) 117 MOTION to Consolidate Cases with GL Williams v. Motorola, C.A. No. 06-114-SLR - filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 04/24/2006) 118 MOTION to Amend/Correct [1] Complaint - filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Attachments: # 1 Exhibit 1 - Amended Complaint# 2 Exhibit 2-5# 3 Exhibit 6-10) (Felice, David) (Entered: 04/24/2006) 119 MOTION for Protective Order Precluding CertainDiscovery from ThirdParty GE Fanuc Automation, Inc. - filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Attachments: # 1 Text of Proposed Order Proposed Order# 2 Certification Pursuant to Rule 7.1.1# 3 Certification Pursuant to Rule 26(c)# 4 Exhibit 1# 5 Exhibit 2)(Felice, David) (Entered: 04/25/2006) 120 MOTION for Summary Judgment - filed by Motorola Inc.. (Bowser, William) (Entered: 05/01/2006) 121 OPENING BRIEF in Support re 120 MOTION for Summary Judgment filed by Motorola Inc..Answering Brief/Response due date per Local Rules is 5/15/2006. (Bowser, William) (Entered: 05/01/2006) 122 SEALED APPENDIX re 121 Opening Brief in Support by Motorola Inc.. (Bowser, William) (Entered: 05/01/2006) 123 NOTICE to Take Deposition of Wendy Vittori on Monday, May 8, 2006 at 11:00 a.m. by J-Squared Technologies (Oregon) Inc.. (Attachments: # 1 Certificate of Service)(Bellew, Sean) (Entered: 05/02/2006) 124 NOTICE OF SERVICE of Plaintiff J-Squared Technologies (Oregon), Inc.'s Amended Responses to Defendant Motorola, Inc.'s Second Set of Requests for Admission by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc..(Felice, David) (Entered: 05/02/2006) 125 NOTICE OF SERVICE of Plaintiff J-Squared Technologies, Inc.'s Responses to Defendant Motorola, Inc.'s Second Set of Requests for Admission by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc..(Felice, David) (Entered: 05/02/2006) 126 REDACTED VERSION of 122 Appendix by Motorola Inc.. (Attachments: # 1 Appendix Redacted# 2 Appendix Redacted# 3 Appendix Redacted# 4 Appendix Redacted# 5 Appendix Redacted# 6 Appendix Redacted# 7 Appendix Redacted# 8 Appendix Redacted) (Bowser, William) Modified on 5/8/2006 (fmt, ). (Entered: 05/04/2006) 127 AMENDED DOCUMENT by Motorola Inc.. Amendment to 126

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Exhibit T to Motorola's Response to Plaintiffs' Motion for Protective Order# 21 Exhibit U to Motorola's Response to Plaintiffs' Motion for Protective Order# 22 Exhibit V to Motorola's Response to Plaintiffs' Motion for Protective Order# 23 Exhibit W to Motorola's Response to Plaintiffs' Motion for Protective Order)(Bowser, William) Modified on 5/15/2006 (fmt, ). (Entered: 05/11/2006) 05/11/2006 130 RESPONSE to Motion re 117 MOTION to Consolidate Cases with GL Williams v. Motorola, C.A. No. 06-114-SLR filed by Motorola Inc.. (Attachments: # 1 Exhibit A to Motorola's Response to Plaintiffs' Motion to Consolidate# 2 Exhibit B to Motorola's Response to Plaintiffs' Motion to Consolidate)(Bowser, William) (Entered: 05/11/2006) 131 RESPONSE to Motion re 118 MOTION to Amend/Correct [1] Complaint filed by Motorola Inc.. (Attachments: # 1 Exhibit A to Motorola's Response to Plaintiffs' Motion to Amend# 2 Exhibit B to Motorola's Response to Plaintiffs' Motion to Amend# 3 Exhibit C to Motorola's Response to Plaintiffs' Motion to Amend# 4 Exhibit D to Motorola's Response to Plaintiffs' Motion to Amend# 5 Exhibit E to Motorola's Response to Plaintiffs' Motion to Amend# 6 Exhibit F to Motorola's Response to Plaintiffs' Motion to Amend# 7 Exhibit G to Motorola's Response to Plaintiffs' Motion to Amend# 8 Exhibit H to Motorola's Response to Plaintiffs' Motion to Amend# 9 Exhibit I to Motorola's Response to Plaintiffs' Motion to Amend# 10 Exhibit J to Motorola's Response to Plaintiffs' Motion to Amend# 11 Exhibit K to Motorola's Response to Plaintiffs' Motion to Amend# 12 Exhibit L to Motorola's Response to Plaintiffs' Motion to Amend# 13 Exhibit M to Motorola's Response to Plaintiffs' Motion to Amend (Redacted)# 14 Exhibit N to Motorola's Response to Plaintiffs' Motion to Amend (Redacted)# 15 Exhibit O to Motorola's Response to Plaintiffs' Motion to Amend# 16 Exhibit P to Motorola's Response to Plaintiffs' Motion to Amend# 17 Exhibit Q to Motorola's Response to Plaintiffs' Motion to Amend# 18 Exhibit R to Motorola's Response to Plaintiffs' Motion to Amend)(Bowser, William) (Entered: 05/11/2006) 132 SEALED EXHIBITS A, C, D, F, G, H, J, K, L AND P to 129 Response to Motion by Motorola Inc. (fmt, ) (Entered: 05/15/2006) 133 SEALED EXHIBITS I, M, N, Q, and R to 131 Response to Motion by Motorola Inc.. (fmt, ) (Entered: 05/15/2006) 134 SUBPOENA Returned Executed as to Paul W. Pocalyko, CPA, Parente Randolph on 05/15/06 (Bowser, William) Modified on 5/15/2006 (fmt, ). (Entered: 05/15/2006) 135 Supplemental RESPONSE to Motion re 118 MOTION to Amend/Correct [1] Complaint filed by Motorola Inc.. (Bowser, William) (Entered: 05/17/2006) 136 First MOTION to Strike Portions of Plaintiffs' Expert Report - filed by Motorola Inc.. (Attachments: # 1 Certificate of Compliance)(Bowser, William) Modified on 5/22/2006 (fmt, ). (Entered: 05/22/2006)

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137 SEALED EXHIBITS re 136 First MOTION to Strike Portions of Plaintiffs' Expert Report by Motorola Inc.. (fmt, ) (Entered: 05/22/2006) CORRECTING ENTRY: the Sealed Exhibits attached to D.I. 136 have been deleted from the entry and docketed as D.I. 137 (fmt, ) (Entered: 05/22/2006) 138 REDACTED VERSION of 137 Exhibit to a Document Motorola's Exhibits in Support of Its Motion to Strike by Motorola Inc.. (Attachments: # 1 Exhibit s A through E# 2 Exhibit F# 3 Exhibit G# 4 Exhibit s H through M# 5 Exhibit N)(Bowser, William) (Entered: 05/22/2006) 139 REPLY to Response to Motion re 119 MOTION for Protective Order Precluding CertainDiscovery from Third-Party GE Fanuc Automation, Inc. filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 05/22/2006) 140 REPLY to Response to Motion re 117 MOTION to Consolidate Cases with GL Williams v. Motorola, C.A. No. 06-114-SLR filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 05/22/2006) 141 REPLY to Response to Motion re 118 MOTION to Amend/Correct [1] Complaint filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 05/22/2006) 142 REQUEST for Oral Argument by Motorola Inc. re 120 MOTION for Summary Judgment, 118 MOTION to Amend/Correct [1] Complaint, 119 MOTION for Protective Order Precluding CertainDiscovery from Third-Party GE Fanuc Automation, Inc., 117 MOTION to Consolidate Cases with GL Williams v. Motorola, C.A. No. 06-114-SLR. (Bowser, William) (Entered: 05/24/2006) 143 Second STIPULATION TO EXTEND TIME Answering and Reply Briefs on Motion for Summary Judgment to June 6 and June 22, 2006 filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 05/30/2006) SO ORDERED, re 143 Second STIPULATION TO EXTEND TIME Answering and Reply Briefs on Motion for Summary Judgment to June 6 and June 22, 2006 filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc. Set Briefing Schedule: Answering Brief due 6/6/2006.Reply Brief due 6/22/2006. Signed by Judge Sue L. Robinson on 5/30/06. (rld, ) (Entered: 05/30/2006) 144 Third STIPULATION TO EXTEND TIME Deadline for Answering Brief to June 8, 2006 - filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 06/06/2006) SO ORDERED, re 144 Third STIPULATION TO EXTEND TIME Deadline for Answering Brief to June 8, 2006 filed by J-Squared Technologies Inc.,, J-Squared Technologies (Oregon) Inc., . Signed by

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Judge Sue L. Robinson on 6/7/06. (fmt, ) (Entered: 06/07/2006) 06/08/2006 145 ANSWERING BRIEF in Opposition re 120 MOTION for Summary Judgment filed by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc..Reply Brief due date per Local Rules is 6/15/2006. (Felice, David) (Entered: 06/08/2006) 146 SEALED EXHIBIT re 145 Answering Brief in Opposition by J-Squared Technologies Inc., J-Squared Technologies (Oregon) Inc.. (Felice, David) (Entered: 06/08/2006) (Court only) ***Deadlines terminated. (rld, ) (Entered: 06/09/2006) 147 Discovery Dispute Resolution between counsel and Chief Judge Robinson dated June 7, 2006. (rld, ) (Entered: 06/09/2006) 148 NOTICE of Appearance by Sean J. Bellew on behalf of all plaintiffs (Attachments: # 1 Certificate of Service)(Bellew, Sean) (Entered: 06/16/2006) (Court only) ***Attorney Sean J. Bellew for J-Squared Technologies Inc. and J-Squared Technologies (Oregon) Inc. added. (fmt, ) (Entered: 06/16/2006) 149 REDACTED VERSION of 146 Exhibit to a Document /Public Version Exhibits to Plaitniffs' Answering Brief in Opposition to Defendant's Motion for Summary Judgment by J-Squared Technologies Inc., JSquared Technologies (Oregon) Inc.. (Felice, David) (Entered: 06/20/2006) 150 Joint STIPULATION TO EXTEND TIME for Filing of Defendant's Reply Brief in Support of Its Motion for Summary Judgment to June 29, 2006 - filed by Motorola Inc.. (Bowser, William) (Entered: 06/22/2006) SO ORDERED, re 150 Joint STIPULATION TO EXTEND TIME for Filing of Defendant's Reply Brief in Support of Its Motion for Summary Judgment to June 29, 2006 filed by Motorola Inc.,, Set Briefing Schedule: Reply Brief due 6/29/2006. Signed by Judge Sue L. Robinson on 6/22/06. (rld, ) (Entered: 06/22/2006) 151 Order Setting Teleconference: Telephone Conference set for 6/29/2006 11:00 AM before Honorable Mary Pat Thynge. Signed by Judge Mary Pat Thynge on 6/23/2006. (cab, ) (Entered: 06/23/2006) 152 REPLY BRIEF re 120 MOTION for Summary Judgment filed by Motorola Inc.. (Bowser, William) (Entered: 06/29/2006) 153 SEALED APPENDIX re 152 Reply Brief by Motorola Inc.. (Bowser, William) (Entered: 06/29/2006) 154 Joint STIPULATION TO EXTEND TIME Plaintiffs' Answering Brief and Defendant's Reply Brief to Answering Brief: June 30, 2006; Reply Brief: July 14, 2006 - filed by Motorola Inc.. (Bowser, William) (Entered: 06/30/2006)

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