Free Letter - District Court of Delaware - Delaware

Case 1:08-cv-00371-JJF Document 14 Filed 08/22/2008 Page 1 of 2
Chad Ni. Shandler
Director
302-651 -7836
Shand|er@r|f.com
August 22, 2008
VIA HAND DELIVERY AND ELECTRONIC FILING
The Honorable Joseph J. Farnan, Jr.
United States District Court
844 King Street
Wilmington, DE 19801
Re: St. Clair Intellectual Property Consultants, Inc. v.
General Imaging Co., et al, C.A. No. 08-371-JJF
Dear Judge F arnan:
Plaintiff St. Clair respectfully submits this letter in response to Defendants
Research in Motion Ltd.'s and Research in Motion Corp.'s (collectively, "RlM") August 20, 2008
letter (D.I. 12) that was submitted in support of General Imaging Co.’s letter request to postpone
the September ll, 2008 scheduling conference (D.l. 8).
As the Court is aware, St. Clair does not agree that the scheduling conference
should be postponed. The extension of time given as a courtesy to RIM to answer St. Clair's
complaint does not impede R]M's ability to discuss pretrial topics with the Court. Indeed, St.
Clair and R]l\/I have already started the process of preparing as outlined in the Court’s Order and
attached fonn. RJM participated in a Rule 26(f) meet and confer earlier this week and gave its
proposals for the pretrial schedule to St. Clair yesterday. St. Clair will continue to work with
RIM to prepare for the conference as required by this Court’s Order and the Federal Rules of
Civil Procedure.
RIM and St. Clair both have concrete proposals for each of the items set out in the
Court’s form order. There is no reason to delay discussion of these proposals with the Court
beyond September ll‘h.l
Respectfully submitted,
/s/ Chad M Shandler (#3 796)
Chad M. Shandler (#3796)
1 Notably, this Court has also set a September 11, 2008 date for the scheduling conference in a
related case entitled St. Clair Intellectual Property Consultants, Inc. v. FujiFil1n Holding Corp. et. al,
C.A. No. 08-373 JJF (D. Del.). St. Clair and Fuji have engaged in the Rule 26(i) meet and confer and are
in the process of preparing their Rule 26(i) report. St. Clair and Fuji will be fully prepared to discuss their
pretrial proposals at the September llm conference.
RLFI-3314319-1 ' ' '
One Rodney Square I 920 North King Street I Wilmington, DE 19801 I Phone: 302-651-7700 I Fax: 302-651-7701
wwwrlfcom

Case 1:08-cv-00371-JJF Document 14 Filed 08/22/2008 Page 2 of 2
The Honorable Joseph J. Farnan, Ir.
August 22, 2008
Page 2
CMS:ps
cc: Clerk of the Court (via e-tile) _
Jack B. Blumenfeld, Esq. (via e-mail)
Collins J. Seitz, Jr., Esq. (via e—mail) _
Run-3314819-1

Case 1:08-cv-00371-JJF

Document 14

Filed 08/22/2008

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Case 1:08-cv-00371-JJF

Document 14

Filed 08/22/2008

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