Free Letter - District Court of Delaware - Delaware

Case 1 :08-cv-00340-JJF Document 22 Filed 07/14/2008 Page 1 of 3
tter
AI1€l01‘SOI1 Richard L. Horwitz
A -923 · Pam;
l Attorgley at Law
1313 North Market Street [email protected]
P.O. Box 95l 302 984-6027 Direct Phone
Wiimington, DE l9899-0951 302 65S—ll92 Fax
302 9846000
www.potteranderson.eom
July 14, zoos
Z VIA ELECTRONIC FILING
The Honorable Leonard P. Stark.
’ United States District Court
844 King Street
g Wilmington, Delaware 19801
Re: Symbol Technologies, Inc., v. Janam Technologies LLC
I C.A. No. 08-340-JJF
Dear Magistrate Stark:
E The enclosed chart shows a comparison ofthe parties' competing schedules for matters
{ leading up to the preliminary injunction hearing, as provided to the Court last week, on July 8.
Respectfully,
/s/ Richard L. Horwitz
Richard L. Horwitz
I RLH/msb
874057 /33146
Enclosure
cc: Clerk ofthe Court (via hand delivery)
Counsel of Record (via electronic mail)

Case 1:08-cv-00340-JJF Document 22 Filed 07/14/2008 Page 2 of 3
J COMPARISON OF
PLAINTIQFF SYMBOIJS AND DEFENDANT JANAIVPS
PROPOSED PRELIMINARY INJUNCTION
BRIEFING AND DISCOVERY SCHEDULES
, ACTION PLAINTIFF SYMBOL’S DEFENDANT .}'ANAM’S
; PROPOSED DATE PROPOSED DATE
Janam’s PI-related Discovery July 2, 2008 July 9, 2008
Requests to Symbol .
Served rm Jul 9, 2008 Served on Jul 9, 2008
Syrnbolfs PI—related Discovery July 15, 2008 not addressed in Janam’s
Requests to Janam proposal, but Symbol
Served on July 3, 2003 requests were served on July
3,20081
Symbol Serves its Discovery July 31, 2008 July 26, 2008 (Symbol shall
Responses and Objections also provide any documents
expressly identified in
opening brief that were not
included as exhibits)
Symbol Substantially July 31, 2008 August 5, 2008
A Completes its Production
Proposed Claim Constructions August 1, 2008 (parties September 23, 2008 (parties
for Pl Hearing identify terms requiring identify claim terms
construction for the PI requiring construction for the
hearing and only the party PI hearing)
identifying the term provides
a proposed construction) October 8, 2008 (both
Q parties provide proposed
constructions for the
i identified claim terms)
Parties submit a Joint Claim August 8, 2008 October 15, 2008
J Construction Statement to
Magistrate Judge Stark on
disputed terms
1 Janarn does not believe that these items need to be included inthe preliminary injunction
i scheduling order.

Case 1:08-cv-00340-JJF Document 22 Filed 07/14/2008 Page 3 of 3
ACTION PLAINTIFF SYMBOIJS DEFENDANT JANAM’S
PROPOSED DATE PROPOSED DATE
Janam Serves its Discovery August 14, 2008 not addressed in .lanam’s
Responses and Objections proposal, but Janam believes
it can meet the August 14,
Janam Substantially Completes August 14, 2008 2008 dates set forth in
’ its production Symbo1’s proposal (subject
to objections)
g Janam Completes its August 29, 2008 As soon as is practical
Depositions of Symbo1’s
Witnesses
Janam’s Opposition to September 19, 2008 October 24, 2008 (Janam
_ Symbol’s Pl Motion is Due shall produce any documents
expressly identified in
opposition papers but not
included as exhibits by
October 28, 2008)
Symbol Completes its October 17, 2008 As soon as practical after
Depositions of Ianaafs October 31, 2008
Witnesses
Symbolfs Reply to Ianamfs November 7, 2008 November 20, 2008
Opposition is Due
Janam Completes its November 26, 2008 December 5, 2008
Depositions of Symbol’s
Declarants in its Reply
Parties Exchange Exhibits and December 8, 2008 December 9, 2008
’ Demonstratives for the PI
y Hearing
t Pl Hearing December 11, 2008 December 11, 2008

Case 1:08-cv-00340-JJF

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Case 1:08-cv-00340-JJF

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