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Case number 1:21-cv-00043

Koninklijke KPN N.V. v. Coolpad Technologies Inc. > Documents

Date Field Doc. No.Description (Pages)
Apr 14, 2023 91 Report to the Commissioner of Patents and Trademarks. (ntl) (Entered: 04/14/2023) (3)
Apr 13, 2023 90 STIPULATION of Dismissal by Koninklijke KPN N.V.. (Farnan, Brian) (Entered: 04/13/2023) (2)
Apr 10, 2023 89 ORAL ORDER: In light of the expiration of the stay of all deadlines on March 31, 2023, (D.I. 88), the Court hereby ORDERS that by no later than April 13, 2023, the parties shall submit a joint letter to the Court with an interim report on the nature of the matters in issue and the progress of the case to date. Thereafter, if the Court deems it necessary, it will schedule a status conference. Ordered by Judge Christopher J. Burke on 4/10/2023. (dlb) (Entered: 04/10/2023) (0)
Nov 14, 2022 N/A SO ORDERED (0)
Docket Text: SO ORDERED re D.I. [88] Stipulation filed by Koninklijke KPN N.V. Ordered by Judge Christopher J. Burke on 11/14/2022. (smg)
Nov 11, 2022 88 Stipulation (2)
Docket Text: STIPULATION to Stay by Koninklijke KPN N.V.. (Farnan, Brian)
Nov 7, 2022 N/A Oral Order (0)
Docket Text: ORAL ORDER: In light of the parties' representation that there are no claim construction issues in C.A. No. 21-43-GBW-CJB (the "Coolpad Action"), the Court hereby ORDERS that the Markman hearing set for November 28, 2022 will only take place with respect to C.A. No. 21-41-GBW-CJB. The Defendant in the Coolpad Action need not appear at the Markman hearing. Ordered by Judge Christopher J. Burke on 11/7/22. Associated Cases: 1:21-cv-00041-GBW-CJB, 1:21-cv-00043-GBW-CJB(mlc)
Oct 13, 2022 N/A Oral Order (0)
Docket Text: ORAL ORDER: The Court, having reviewed the parties' October 12, 2022 letter, (D.I. 83 in Civil Action No. 21-41-GBW-CJB; D.I. 84 in Civil Action No. 21-43-GBW-CJB), hereby ORDERS as follows with respect to the Markman hearing: (1) The Markman hearing is rescheduled to November 28, 2022 at 11:00am. The hearing will be held virtually over videoconference using the Microsoft Teams platform.; (2) By no later than November 16, 2022, the parties shall send an e-mail to the Court's Courtroom Deputy, Deborah Benyo, indicating the names and e-mail addresses of all individuals who will participate in the hearing.; (3) Twenty-four hours in advance of the hearing, each side shall: (a) submit two hard copies of its slide presentation to the Court; and (b) email its slide presentation to Ms. Benyo (copying the other side).; and (4) With respect to the order of the terms and which side will present argument first for each term, the Court ADOPTS the parties' proposal such that the parties will present the terms in the order that they appear in the parties' letter, with the Xiaomi Defendants presenting first on the first two terms and Plaintiff presenting first on the remainder of the terms. Ordered by Judge Christopher J. Burke on 10/13/2022. Associated Cases: 1:21-cv-00041-GBW-CJB, 1:21-cv-00043-GBW-CJB(smg)
Oct 12, 2022 83 Claim Construction Chart (8)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Farnan, Brian)
Oct 12, 2022 84 Letter (2)
Docket Text: Letter to The Honorable Christopher J. Burke from Brian E. Farnan regarding Claim Construction Meet and Confer. (Farnan, Brian)
Oct 12, 2022 85 Motion for Miscellaneous Relief (2)
Docket Text: MOTION for Claim Construction - filed by Koninklijke KPN N.V.. Motions referred to Christopher J. Burke.(Farnan, Brian)
Oct 4, 2022 82 Redacted Document (3)
Docket Text: REDACTED VERSION of [81] Stipulation by Koninklijke KPN N.V.. (Farnan, Brian)
Sep 27, 2022 N/A SO ORDERED (0)
Docket Text: SO ORDERED D.I. [81] Stipulation regarding Damages filed by Koninklijke KPN N.V. Ordered by Judge Christopher J. Burke on 9/27/22. (mlc)
Sep 13, 2022 N/A Oral Order (0)
Docket Text: ORAL ORDER: The Court, having reviewed the parties' June 10, 2022 letter regarding the Markman Hearing, (Civil Action No. 21-41-GBW-CJB, D.I. 58; Civil Action No. 21-43-GBW-CJB, D.I. 76), HEREBY ORDERS as follows: (1) A Markman Hearing is set for 11/2/2022 at 11:00 AM in Courtroom 2A before Judge Christopher J. Burke.; (2) The Court hereby ADOPTS the parties' proposal regarding time allocation. Each side will be allocated one hour and 30 minutes for argument.; (3) By October 12, 2022, the parties shall file a joint letter indicating the order in which they intend to present the claim terms at issue, including which side will present first for each term. In this letter, the parties should also let the Court know if there is joint agreement to conduct the Markman hearing via videoconference. If there is joint agreement, the Court will do so; if there is not joint agreement, then the hearing will go forward as an in-person hearing in Courtroom 2A.; (4) On or before October 12, 2022, Delaware and lead counsel for the parties shall meet and confer and file an amended joint claim construction chart that sets forth the terms/issues that remain in dispute. The meet and confer shall focus on an attempt to reach agreement on any remaining disputed terms/issues where possible and on an attempt to focus the dispute over the remaining terms/issues in light of the parties' claim construction briefing. In the joint letter that the parties submit by October 12, the parties shall also identify by name each individual who participated in this meet and confer, when and how that meet and confer occurred and how long it lasted. If no agreements on constructions have been reached or if no dispute has been narrowed on the meet and confer, the letter shall so state and the parties need not file an amended joint claim construction chart.; and (5) For administrative purposes, by no later than October 12, 2022, each party shall file a "Motion for Claim Construction" that requests the Court to adopt the claim construction position(s) of that party set forth in the Joint Claim Construction Chart and their briefing. The motion shall not contain any argument and shall simply state that the party "requests that the Court adopt the claim construction position[s] of [the party] set forth in the Joint Claim Construction Chart and its briefing."Ordered by Judge Christopher J. Burke on 9/13/22. Associated Cases: 1:21-cv-00041-GBW-CJB, 1:21-cv-00043-GBW-CJB(mlc)
Sep 12, 2022 N/A Order Referring Case to Magistrate Judge (0)
Docket Text: ORAL ORDER REFERRING CASE to Magistrate Judge Christopher J. Burke: IT IS HEREBY ORDERED that the above-captioned case is referred to Magistrate Judge Christopher J. Burke to hear and resolve all pre-trial matters up to and including expert discovery matters (but not including summary judgment motions, Daubert motions, pre-trial motions in limine or the pre-trial conference), subject to 28 U.S.C. § 636(b) and any further Order of the Court. ORDERED by Judge Gregory B. Williams on 9/12/22. Associated Cases: 1:21-cv-00041-GBW-CJB, 1:21-cv-00043-GBW-CJB (ntl)
Sep 7, 2022 N/A Case Assigned/Reassigned (0)
Docket Text: Case Reassigned to Judge Gregory B. Williams. Please include the initials of the Judge (GBW) after the case number on all documents filed. (smg)
Aug 8, 2022 N/A SO ORDERED (0)
Docket Text: SO ORDERED D.I. (78 in 1:21-cv-00043-VAC-CJB, 61 in 1:21-cv-00041-VAC-CJB) Stipulation to Amend Scheduling Order filed by Koninklijke KPN N.V. Ordered by Judge Christopher J. Burke on 8/5/2022. Associated Cases: 1:21-cv-00041-VAC-CJB, 1:21-cv-00043-VAC-CJB(dlb)
Aug 5, 2022 78 Stipulation (2)
Docket Text: STIPULATION to Amend Scheduling Order by Koninklijke KPN N.V.. (Farnan, Brian)
Jun 30, 2022 77 Notice of Change of Address (2)
Docket Text: NOTICE of Change of Address by Brian E. Farnan (Farnan, Brian)
Jun 10, 2022 75 Joint Claim Construction Brief (Main Document) (30)
Docket Text: JOINT CLAIM CONSTRUCTION BRIEF filed by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1)(Farnan, Brian)
Jun 10, 2022 75 Joint Claim Construction Brief (Exhibit 1) (15)
Docket Text: JOINT CLAIM CONSTRUCTION BRIEF filed by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1)(Farnan, Brian)
Jun 10, 2022 76 Letter (1)
Docket Text: Letter to The Honorable Christopher J. Burke from Brian E. Farnan regarding Markman Hearing. (Farnan, Brian)
Jun 8, 2022 N/A SO ORDERED (0)
Docket Text: SO ORDERED D.I. [74] Stipulation. As a result, the issue of the infringement of any claim of U.S. Patent No. 6,212,662 by Coolpads 662 Accused Products need not be tried and that further discovery as to infringement is unnecessary. Ordered by Judge Christopher J. Burke on 6/8/2022. (dlb)
Jun 8, 2022 74 Stipulation (3)
Docket Text: STIPULATION and [Proposed] Order Regarding Infringement by Koninklijke KPN N.V.. (Farnan, Brian)
Apr 20, 2022 N/A Case No Longer Referred to Mediation (0)
Docket Text: CASE NO LONGER REFERRED to Magistrate Judge Burke for the purpose of exploring ADR. Please see the Court's Standing Order No. 2022-2 dated March 14, 2022. (dlb)
Apr 13, 2022 72 VAC - Magistrate Non-consent - completed by the parties (1)
Docket Text: VAC Magistrate Non-Consent completed by the parties filed by Koninklijke KPN N.V.. (Farnan, Brian)
Apr 13, 2022 N/A Order Referring Case to Magistrate Judge (0)
Docket Text: ORAL ORDER: The parties having filed the appropriate form advising the Court that they do not unanimously consent to the jurisdiction of a Magistrate Judge, IT IS HEREBY ORDERED that, until further order of the Court, this case will remain assigned to the VAC (2022) docket. IT IS FURTHER ORDERED that this case is referred to Magistrate Judge Christopher J. Burke solely for the following purposes: (1) to adjudicate discovery (including fact and expert discovery) and protective order disputes; (2) to issue or modify a scheduling order; (3) to review stipulated orders and pro hac vice motions; and (4) to review requests for mediation in cases other than patent and securities cases. Issued by the Clerk of Court on 4/13/22. (etg)
Mar 31, 2022 71 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of Defendant's Responses and Objections to Koninklijke KPN N.V.'s Second Set of Interrogatories (No. 10) filed by Coolpad Technologies Inc..(Day, John)
Mar 30, 2022 N/A Case Assigned/Reassigned (0)
Docket Text: Case Reassigned to Vacant Judgeship (2022). Please include initials of VAC after the case number on all documents filed. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB(etg)
Mar 30, 2022 N/A Oral Order (0)
Docket Text: ORAL ORDER: This case has been assigned to the District of Delaware's Vacant Judgeship ("VAC"). Detailed information relating to VAC cases may be found in the Court's Announcement of March 3, 2022 and Standing Order No. 2022-3 (March 16, 2022), which are available on the Court's website. Consistent with the foregoing Announcement and Standing Order, IT IS HEREBY ORDERED that: The parties shall file the "Notice of Consent or Absence of Consent to Proceed Before A United States Magistrate Judge," being docketed along with the instant Order, no later than fourteen (14) days after the date of this Order. IT IS FURTHER ORDERED that any order referring any part of this case to a Magistrate Judge is VACATED. Unless the parties consent to having a Magistrate Judge handle this case, a referral order will be entered to permit a Magistrate Judge (to be selected by the Court) to do only the following: (a) adjudicate discovery (including fact and expert discovery) and protective order disputes; (b) issue or modify a scheduling order; (c) review stipulated orders and pro hac vice motions; and (d) review requests for mediation in cases other than patent and securities cases. IT IS FURTHER ORDERED that any scheduling order that has been entered in this case is AMENDED such as follows: (a) the dates for any motions hearings are VACATED; and (b) the dates for any claim construction hearings are VACATED. Issued by the Clerk of Court on 3/30/22. Associated Cases: 1:21-cv-00041-VAC-CJB, 1:21-cv-00043-VAC-CJB(etg)
Mar 30, 2022 70 VAC Notice, Consent, Non-Consent, Magistrate Referral (1)
Docket Text: VAC Notice, Consent, Non-Consent, Magistrate Referral Associated Cases: 1:21-cv-00041-VAC-CJB, 1:21-cv-00043-VAC-CJB(etg)
Mar 23, 2022 66 Stipulation (2)
Docket Text: STIPULATION to Amend Claim Construction Schedule by Koninklijke KPN N.V.. (Farnan, Brian)
Mar 23, 2022 67 SO ORDERED (2)
Docket Text: SO ORDERED D.I. (47 in 1:21-cv-00041-LPS-CJB, 66 in 1:21-cv-00043-LPS-CJB) Stipulation to Amend Claim Construction Schedule filed by Koninklijke KPN N.V., ( Joint Claim Construction Brief due by 6/10/2022., A Markman Hearing is set for 6/21/2022 at 11:00 AM in Courtroom 2A before Judge Christopher J. Burke.) See stipulation for further deadlines. Ordered by Judge Christopher J. Burke on 3/23/2022. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB(mlc)
Mar 23, 2022 N/A Oral Order (0)
Docket Text: ORAL ORDER: The Court notes that to the extent that these cases are reassigned in the future to the VAC docket, if the parties thereafter all jointly consent to Judge Burke's jurisdiction over the cases, Judge Burke confirms that the current Markman dates (and other key dates in the schedule) will remain the same. Ordered by Judge Christopher J. Burke on 3/23/2022. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB(mlc)
Mar 14, 2022 N/A SO ORDERED (0)
Docket Text: SO ORDERED D.I. [64] MOTION for Pro Hac Vice Appearance of Attorney Jason Xu filed by Coolpad Technologies Inc. Ordered by Judge Christopher J. Burke on 3/14/2022. (dlb)
Mar 14, 2022 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Jason L. Xu for Coolpad Technologies Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (mpb)
Mar 11, 2022 65 Claim Construction Chart (Main Document) (10)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit A) (11)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit B) (15)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit C) (30)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit D) (19)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit E) (30)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit F) (30)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit G) (15)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit H) (30)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit I) (30)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit J) (14)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit K) (5)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 11, 2022 65 Claim Construction Chart (Exhibit L) (19)
Docket Text: CLAIM Construction Chart by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G, # (8) Exhibit H, # (9) Exhibit I, # (10) Exhibit J, # (11) Exhibit K, # (12) Exhibit L)(Farnan, Brian)
Mar 8, 2022 63 Notice (Other) (1)
Docket Text: NOTICE of Substitution of Counsel by Coolpad Technologies Inc. (Day, John)
Mar 8, 2022 64 Motion for Leave to Appear Pro Hac Vice (3)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Jason Xu - filed by Coolpad Technologies Inc.. Motions referred to Christopher J. Burke.(Day, John)
Mar 1, 2022 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Adam Tisdall for Koninklijke KPN N.V. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (mal)
Mar 1, 2022 62 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of (i) Plaintiff's Responses to Defendant's First Set of Interrogatories; (ii) Plaintiff's Responses and Objections to Defendant's First Set of Requests for Production; and (iii) Plaintiff's Second Set of Interrogatories to Coolpad filed by Koninklijke KPN N.V..(Farnan, Brian)
Feb 25, 2022 N/A SO ORDERED (0)
Docket Text: SO ORDERED D.I. [59] MOTION for Pro Hac Vice Appearance of Attorney Adam Tisdall filed by Koninklijke KPN N.V.. Ordered by Judge Christopher J. Burke on 2/25/2022. (dlb)
Feb 22, 2022 61 Order (1)
Docket Text: ORDER re [55] REPORT AND RECOMMENDATION is ADOPTED and [21] MOTION to Dismiss filed by Koninklijke KPN N.V. is DENIED. Signed by Judge Leonard P. Stark on 2/22/22. (ntl)
Feb 18, 2022 59 Motion for Leave to Appear Pro Hac Vice (3)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Adam Tisdall - filed by Koninklijke KPN N.V.. Motions referred to Christopher J. Burke.(Farnan, Brian)
Feb 18, 2022 60 Notice of Service (4)
Docket Text: NOTICE OF SERVICE of Defendants' Proposed Constructions for U.S. Patent No. 6,212,662 filed by Xiaomi Communications Co., Ltd., Xiaomi Corporation, Xiaomi Inc..(Tigan, Jeremy)
Jan 28, 2022 58 Notice of Service (4)
Docket Text: NOTICE OF SERVICE of Defendants' Proposed Terms for Construction From U.S. Patent No. 6,212,662 filed by Xiaomi Communications Co., Ltd., Xiaomi Corporation, Xiaomi Inc..(Tigan, Jeremy)
Jan 25, 2022 57 Answer to Counterclaim (15)
Docket Text: ANSWER to [20] Amended Answer to Complaint, Counterclaim by Koninklijke KPN N.V..(Farnan, Brian)
Jan 21, 2022 56 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of Defendant's First Set of Interrogatories to Plaintiff Koninklijke KPN N.V. and Defendant's First Set of Requests for Production to Plaintiff Koninklijke KPN N.V. filed by Coolpad Technologies Inc..(Day, John)
Jan 11, 2022 N/A Report and Recommendations (0)
Docket Text: REPORT AND RECOMMENDATION: The Court, having reviewed Plaintiff's Motion to Dismiss Counterclaims III-V (the "claims") of Defendants' First Amended Counterclaims ("FAC"), (D.I. [21] ("Motion"); D.I. [22] at 3), and the briefing related thereto, (D.I. [22]; D.I. [25]; D.I. [28]), and having considered the relevant legal standards, see IOENGINE, LLC v. PayPal Holdings, Inc., Civil Action No. 18-452-WCB, 2019 WL 2121395, at *2 (D. Del. May 15, 2019), hereby recommends that, for the reasons that follow, the Motion be DENIED: (1) With regard to Plaintiff's assertion that the claims fail because Defendant does not sufficiently allege that the patent-in-suit is essential, (D.I. 22 at 6-8), the Court disagrees. Although at the case dispositive stage Defendant will need to prove essentiality by way of objective findings (i.e., whether practicing the relevant standards in fact leads to infringement of the patent), see 3G Licensing, S.A. v. Blackberry Ltd., Civil Action No. 17-82-LPS, D.I. 326 at 7 (D. Del. Oct. 2, 2020), at the pleading stage it need only point to facts that render it plausible that the patent is essential. And the Court does not see why Plaintiff's alleged repeated statements that it "belie[ved]" that the patent "may be" essential, or that the patent "is an essential patent" or that the patent "ha[s] been recognized as essential" cannot fit that bill; Plaintiff's statements in this regard are indeed facts plausibly suggesting that, later at the proof stage, Defendant may be able to show (based on objective evidence) that the patent actually is essential. (D.I. 20 at 11-12 at paras. 5-7; D.I. 23, ex. 2); (2) With respect to Plaintiff's assertion that the claims fail to plausibly establish a FRAND-related breach of contract, (D.I. 22 at 8-13), while the Court agrees that what is pleaded is not particularly robust, it concludes that Defendant has done just enough to get by. Here, the Court need only assess Defendant's theory that Plaintiff breached its FRAND obligations by demanding unfair or discriminatory royalties. Defendant alleges that Plaintiff did this when it provided proposed rates that were much higher than what other entities are paying pursuant to KPNs licensing agreements with them[.]" (D.I. 20 at 17 at para. 29) While it would have been better if the FAC included more details about these proposed rates or about the agreements with other entities, Rule 8 (not Rule 9(b)) applies here, and similar allegations to these have been found sufficient to state a FRAND-based breach claim. See Research In Motion Ltd. v. Motorola, Inc., 644 F. Supp. 2d 788, 797 (E.D. Tex. 2008); Apple, Inc. v. Motorola Mobility, No. 11-178-bbc, 2011 WL 7324582, at *11 (W.D. Wis. June 7, 2011).; and (3) As for Plaintiff's argument that Defendant failed to sufficiently identify a contractual provision that was breached, (D.I. 22 at 13-16), the Court is candidly not convinced that the breach claim could be solely based on Clause 6.1 of the ETSI IPR Policy alone, for reasons stated by Plaintiff. (D.I. 22 at 15-16; see also D.I. 23, ex. 4 at 34-35) But the Court does think that: (a) a plausible breach of Plaintiff's ETSI Declaration (which incorporates by reference Clause 6.1) could be asserted here (i.e., that to the extent that the patent is essential, Plaintiff had to be prepared to grant a license under FRAND terms, and that Plaintiff was not in fact prepared to do so), (D.I. 22 at 15; D.I. 25 at 16, 17; see also D.I. 23, ex. 2); and (b) the FAC can be read to actually assert such claims, (D.I. 20 at 15-16 at paras. 15, 18-19; id. at 20-22 at paras. 50, 56, 61) (*Objections to R&R due by 1/25/2022). Ordered by Judge Christopher J. Burke on 1/11/2022. (ceg)
Jan 3, 2022 54 Notice Requesting Removal of Co-Counsel (2)
Docket Text: NOTICE requesting Clerk to remove Edward J. Delman as co-counsel.. (Farnan, Brian)
Dec 15, 2021 53 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of KPN's Disclosure of Initial Infringement Contentions filed by Koninklijke KPN N.V..(Farnan, Brian)
Dec 8, 2021 52 Protective Order (30)
Docket Text: Stipulated Supplemental PROTECTIVE ORDER between non-party Qualcomm Inc., Plaintiff, and Defendants. Signed by Judge Christopher J. Burke on 12/8/2021. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB(dlb)
Dec 7, 2021 51 Proposed Order (30)
Docket Text: PROPOSED ORDER [Proposed] Stipulated Supplemental Protective Order Between Non Party Qualcomm Incorporated, Plaintiff, and Defendants by Koninklijke KPN N.V.. (Farnan, Brian)
Nov 15, 2021 50 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of Defendant Coolpad Technologies Inc.'s Core Technical Document Production and Sales Figures for Accused Products filed by Coolpad Technologies Inc..(Day, John)
Nov 12, 2021 49 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of (1) Defendant Coolpad Technologies Inc.'s Initial Disclosures Pursuant to Delaware Default Standard for Discovery Paragraph 3; (2) Defendant's Responses and Objections to Koninklijke KPN N.V.'s First Set of Interrogatories (Nos. 1-9); and (3) Defendant's Responses to Koninklijke KPN N.V.'s Requests for Production (Nos. 1-86) filed by Coolpad Technologies Inc..(Day, John)
Nov 11, 2021 48 Notice of Service (3)
Docket Text: NOTICE OF SERVICE of (i) Plaintiff's Initial Disclosures under Section 3 of the Default Standard for Discovery, Including Discovery of Electronically Stored Information and (ii) Plaintiff's Supplemental Rule 26 Disclosures filed by Koninklijke KPN N.V..(Farnan, Brian)
Oct 28, 2021 46 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of Defendant Coolpad Technologies Inc.'s Initial Disclosures filed by Coolpad Technologies Inc..(Mayo, Andrew)
Oct 28, 2021 47 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of Plaintiff's Rule 26 Initial Disclosures filed by Koninklijke KPN N.V..(Farnan, Brian)
Oct 26, 2021 45 Protective Order (18)
Docket Text: PROTECTIVE ORDER. Signed by Judge Christopher J. Burke on 10/25/2021. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(dlb)
Oct 25, 2021 44 Proposed Order (18)
Docket Text: PROPOSED ORDER Proposed Protective Order by Koninklijke KPN N.V.. (Farnan, Brian)
Oct 21, 2021 43 Notice (Other) (Main Document) (3)
Docket Text: NOTICE of Subpoenas to Qualcomm Incorporated and MediaTek USA Inc. by Koninklijke KPN N.V. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2)(Farnan, Brian)
Oct 21, 2021 43 Notice (Other) (Exhibit 1) (8)
Docket Text: NOTICE of Subpoenas to Qualcomm Incorporated and MediaTek USA Inc. by Koninklijke KPN N.V. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2)(Farnan, Brian)
Oct 21, 2021 43 Notice (Other) (Exhibit 2) (8)
Docket Text: NOTICE of Subpoenas to Qualcomm Incorporated and MediaTek USA Inc. by Koninklijke KPN N.V. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2)(Farnan, Brian)
Oct 19, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED D.I. [42] MOTION for Pro Hac Vice Appearance of Attorney Jasmine W. Zhu filed by Coolpad Technologies Inc. Ordered by Judge Christopher J. Burke on 10/19/2021. (dlb)
Oct 18, 2021 N/A Oral Order (0)
Docket Text: ORAL ORDER: If during the history of this case, Plaintiff(s) and Defendant(s) jointly wish to schedule a form of alternative dispute resolution ("ADR"), such as mediation, with Judge Burke, they should contact chambers by e-mail at Deborah_Benyo@ded.uscourts.gov or by phone. Additionally, if either side wishes to speak ex parte with Judge Burke regarding ADR matters, they may contact chambers via e-mail or by phone to arrange a time for a call. Ordered by Judge Christopher J. Burke on 10/18/2021. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(dlb)
Oct 18, 2021 N/A Oral Order (0)
Docket Text: ORAL ORDER: The Court denies without prejudice to refile upon payment of required fees D.I. [34] MOTION for Pro Hac Vice Appearance of Attorney Jasmine W. Zhu filed by Coolpad Technologies Inc. Ordered by Judge Christopher J. Burke on 10/18/2021. (dlb)
Oct 18, 2021 42 Motion for Leave to Appear Pro Hac Vice (3)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Jasmine W. Zhu - filed by Coolpad Technologies Inc.. Motions referred to Christopher J. Burke.(Mayo, Andrew)
Oct 15, 2021 39 Notice of Service (2)
Docket Text: NOTICE OF SERVICE of Plaintiff's Identification of Accused Products and Form of Damages filed by Koninklijke KPN N.V..(Farnan, Brian)
Oct 13, 2021 N/A Case Referred to Mediation (0)
Docket Text: CASE REFERRED to Magistrate Judge Christopher J. Burke for Mediation. Please see Standing Order dated January 20, 2016, regarding disclosure of confidential ADR communications. A link to the standing order is provided here for your convenience at https://www.ded.uscourts.gov/sites/ded/files/forms/StandingOrderforADR-Mediation.pdf Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(Taylor, Daniel)
Oct 13, 2021 37 Scheduling Order (15)
Docket Text: SCHEDULING ORDER: Case referred to the Magistrate Judge for the purpose of exploring ADR. Joinder of Parties due by 12/1/2021. Amended Pleadings due by 12/1/2021. Fact Discovery completed by 10/21/2022. Expert Discovery due by 2/3/2023. Dispositive Motions due by 3/3/2023. A Motion Hearing is set for 5/23/2023 at 11:00 AM before Judge Leonard P. Stark Joint Claim Construction Brief due by 5/27/2022. A Markman Hearing is set for 6/10/2022 at 11:00 AM before Judge Christopher J. Burke. A Pretrial Conference is set for 8/4/2023 at 09:00 AM before Judge Leonard P. Stark. A Jury Trial is set for 8/14/2023 at 09:00 AM before Judge Leonard P. Stark.. Signed by Judge Christopher J. Burke on 10/13/2021. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(mlc)
Oct 13, 2021 38 Transcript (21)
Docket Text: Official Transcript of Telephone Conference held on October 4, 2021 before Judge Christopher J. Burke. Court Reporter Brian Gaffigan, email: gaffigan@verizon.net. Transcript may be viewed at the court public terminal or ordered/purchased through the Court Reporter before the deadline for Release of Transcript Restriction. After that date, it may be obtained through PACER. Redaction Request due 11/3/2021. Redacted Transcript Deadline set for 11/15/2021. Release of Transcript Restriction set for 1/11/2022.(bpg)
Oct 12, 2021 35 Proposed Order (Main Document) (15)
Docket Text: PROPOSED ORDER Proposed Scheduling Order by Koninklijke KPN N.V.. (Attachments: # (1) Letter to The Honorable Christopher J. Burke)(Farnan, Brian)
Oct 12, 2021 35 Proposed Order (Letter to The Honorable Christopher J. Burke) (1)
Docket Text: PROPOSED ORDER Proposed Scheduling Order by Koninklijke KPN N.V.. (Attachments: # (1) Letter to The Honorable Christopher J. Burke)(Farnan, Brian)
Oct 12, 2021 36 Notice of Service (3)
Docket Text: NOTICE OF SERVICE of (i) Plaintiff's First Set of Interrogatories to Coolpad and Bullitt and (ii) Plaintiff's First Set of Requests for Production to Coolpad and Bullitt filed by Koninklijke KPN N.V..(Farnan, Brian)
Oct 4, 2021 N/A Scheduling Conference (0)
Docket Text: Minute Entry for proceedings held before Judge Christopher J. Burke - Rule 16 Teleconference/Case Management Conference held on 10/4/2021. The Court ordered the parties to submit a revised joint scheduling order by no later than the close of business on October 12, 2021. (Clerk: Bryant-Alvarez) Appearances: B. Farnan and A. Healy for Plaintiff; J. Tigan, B. Cangro, J. Day, J. Zhu, and E. Fenton for Defendants. (Court Reporter Brian Gaffigan.) Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(dlb)
Sep 17, 2021 34 Motion for Leave to Appear Pro Hac Vice (3)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Jasmine W. Zhu - filed by Coolpad Technologies Inc.. Motions referred to Christopher J. Burke.(Mayo, Andrew)
Sep 14, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Yufeng Ma for Coolpad Technologies Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (twk)
Sep 13, 2021 N/A Remark re Newer Attorneys (0)
Docket Text: REMARK: The parties should be aware that the Court encourages the participation of newer attorneys in courtroom proceedings and at oral argument. Please see the Court's Standing Order Regarding Courtroom Opportunities for Newer Attorneys, a link to which is provided here for the parties' convenience:http://www.ded.uscourts.gov/sites/ded/files/forms/StandingOrder2017.pdf Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(dlb)
Sep 10, 2021 N/A Order Setting Scheduling Conference (0)
Docket Text: Order Setting Telephonic Scheduling Conference: The Court, having been recently referred this case, has reviewed the parties' August 23, 2021 Proposed Scheduling Order in which the parties have disputes. NOW THEREFORE, a Case Management/Scheduling Teleconference is set for October 4, 2021 at 2:00 PM before Judge Christopher J. Burke. By no later than September 30, 2021, the parties shall jointly provide the Court's Courtroom Deputy, Ms. Benyo, with a dial-in number via e-mail to use for the call. Ordered by Judge Christopher J. Burke on 9/10/2021. Associated Cases: 1:21-cv-00041-LPS-CJB, 1:21-cv-00043-LPS-CJB, 1:21-cv-00044-LPS-CJB(dlb)
Sep 9, 2021 N/A Motions Referred (0)
Docket Text: MOTION REFERRED: [21] MOTION to Dismiss for Failure to State a Claim , [15] MOTION to Dismiss Counterclaims Motion referred to Christopher J. Burke.(dlb)
Sep 9, 2021 N/A Order Referring Case to Magistrate Judge (0)
Docket Text: ORAL ORDER: IT IS HEREBY ORDERED that this case is referred to Magistrate Judge Christopher J. Burke to hear and resolve all pre-trial matters up to and including expert discovery matters (but not including summary judgment motions, Daubert motions, pre-trial motions in limine or the pre-trial conference), subject to 28 U.S.C. § 636(b) and any further Order of the Court. ORDERED by Judge Leonard P. Stark on 9/9/21. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS (ntl)
Aug 23, 2021 31 Proposed Order (Main Document) (18)
Docket Text: PROPOSED ORDER Proposed Scheduling Order re (30 in 1:21-cv-00043-LPS, 14 in 1:21-cv-00041-LPS, 19 in 1:21-cv-00044-LPS) Order,, by Koninklijke KPN N.V.. (Attachments: # (1) Letter to the Honorable Leonard P. Stark)(Farnan, Brian)
Aug 23, 2021 31 Proposed Order (Letter to the Honorable Leonard P. Stark) (1)
Docket Text: PROPOSED ORDER Proposed Scheduling Order re (30 in 1:21-cv-00043-LPS, 14 in 1:21-cv-00041-LPS, 19 in 1:21-cv-00044-LPS) Order,, by Koninklijke KPN N.V.. (Attachments: # (1) Letter to the Honorable Leonard P. Stark)(Farnan, Brian)
Aug 9, 2021 N/A Order (0)
Docket Text: ORAL ORDER: IT IS HEREBY ORDERED that the parties shall confer regarding proposed dates in the scheduling order and shall submit a proposal, including a proposal for the length and timing of trial, to the Court no later than August 23, 2021. The parties are to review the Court's form scheduling order, which is posted at http://www.ded.uscourts.gov (see Chambers, Judge Stark, New Patent Procedures). ORDERED by Judge Leonard P. Stark on 8/9/21. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS (ntl)
Aug 6, 2021 29 Letter (1)
Docket Text: Letter to The Honorable Leonard P. Stark from Brian E. Farnan regarding Request for Scheduling Conference. (Farnan, Brian)
Jul 1, 2021 28 Reply Brief (15)
Docket Text: REPLY BRIEF re [21] MOTION to Dismiss for Failure to State a Claim filed by Koninklijke KPN N.V.. (Farnan, Michael)
Jun 29, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re [27] STIPULATION TO EXTEND TIME for Plaintiff to file its reply brief in support of its Partial Motion to Dismiss Coolpad's First Amended Counterclaims to 7/1/2021 filed by Koninklijke KPN N.V. Signed by Judge Leonard P. Stark on 6/29/21. (ntl)
Jun 24, 2021 27 Stipulation to EXTEND Time (1)
Docket Text: STIPULATION TO EXTEND TIME for Plaintiff to file its reply brief in support of its Partial Motion to Dismiss Coolpad's First Amended Counterclaims to 7/1/2021 - filed by Koninklijke KPN N.V.. (Farnan, Brian)
Jun 23, 2021 26 Redacted Document (Main Document) (27)
Docket Text: REDACTED VERSION of [25] Answering Brief in Opposition, by Coolpad Technologies Inc.. (Attachments: # (1) Exhibit A-D)(Day, John)
Jun 23, 2021 26 Redacted Document (Exhibit A-D) (30)
Docket Text: REDACTED VERSION of [25] Answering Brief in Opposition, by Coolpad Technologies Inc.. (Attachments: # (1) Exhibit A-D)(Day, John)
Jun 22, 2021 N/A CORRECTING ENTRY: (0)
Docket Text: CORRECTING ENTRY: Exhibits at D.I. [25] replaced per counsel's request. (kmd)
Jun 4, 2021 21 Motion to Dismiss for Failure to State a Claim (2)
Docket Text: MOTION to Dismiss for Failure to State a Claim - filed by Koninklijke KPN N.V.. (Farnan, Brian)
Jun 4, 2021 22 Opening Brief in Support (21)
Docket Text: OPENING BRIEF in Support re [21] MOTION to Dismiss for Failure to State a Claim filed by Koninklijke KPN N.V..Answering Brief/Response due date per Local Rules is 6/18/2021. (Farnan, Brian)
Jun 4, 2021 24 Redacted Document (Main Document) (2)
Docket Text: REDACTED VERSION of [23] Declaration by Koninklijke KPN N.V.. (Attachments: # (1) Exhibits 1-5)(Farnan, Brian)
Jun 4, 2021 24 Redacted Document (Exhibits 1-5) (30)
Docket Text: REDACTED VERSION of [23] Declaration by Koninklijke KPN N.V.. (Attachments: # (1) Exhibits 1-5)(Farnan, Brian)
May 24, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Russell Rennie for Koninklijke KPN N.V. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS. (kmd)
May 21, 2021 20 Amended Answer to Complaint (26)
Docket Text: AMENDED ANSWER to [13] Answer to Complaint, Counterclaim, Amended COUNTERCLAIM against All Plaintiffs by Coolpad Technologies Inc.. (Mayo, Andrew)
May 20, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re (19 in 1:21-cv-00043-LPS, 9 in 1:21-cv-00041-LPS, 15 in 1:21-cv-00046-LPS, 17 in 1:21-cv-00044-LPS, 13 in 1:21-cv-00045-LPS) MOTION for Pro Hac Vice Appearance of Attorney Russell Rennie filed by Koninklijke KPN N.V. Signed by Judge Leonard P. Stark on 5/20/21. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS (ntl)
May 20, 2021 19 Motion for Leave to Appear Pro Hac Vice (3)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Russell Rennie - filed by Koninklijke KPN N.V.. (Farnan, Brian)
May 13, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re [18] STIPULATION TO EXTEND TIME for Defendant to respond to Plaintiff's Motion to Dismiss Counterclaims to May 21, 2021 filed by Coolpad Technologies Inc. Signed by Judge Leonard P. Stark on 5/13/21. (ntl)
May 12, 2021 18 Stipulation to EXTEND Time (1)
Docket Text: STIPULATION TO EXTEND TIME for Defendant to respond to Plaintiff's Motion to Dismiss Counterclaims to May 21, 2021 - filed by Coolpad Technologies Inc.. (Mayo, Andrew)
Apr 30, 2021 15 Motion for Miscellaneous Relief (Main Document) (2)
Docket Text: MOTION to Dismiss Counterclaims - filed by Koninklijke KPN N.V.. (Attachments: # (1) Text of Proposed Order)(Farnan, Brian)
Apr 30, 2021 15 Motion for Miscellaneous Relief (Text of Proposed Order) (1)
Docket Text: MOTION to Dismiss Counterclaims - filed by Koninklijke KPN N.V.. (Attachments: # (1) Text of Proposed Order)(Farnan, Brian)
Apr 30, 2021 16 Opening Brief in Support (18)
Docket Text: OPENING BRIEF in Support re [15] MOTION to Dismiss Counterclaims filed by Koninklijke KPN N.V..Answering Brief/Response due date per Local Rules is 5/14/2021. (Farnan, Brian)
Apr 30, 2021 17 Declaration (Main Document) (2)
Docket Text: DECLARATION re [16] Opening Brief in Support of Tamar Lusztig by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Farnan, Brian)
Apr 30, 2021 17 Declaration (Exhibit 1) (24)
Docket Text: DECLARATION re [16] Opening Brief in Support of Tamar Lusztig by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Farnan, Brian)
Apr 30, 2021 17 Declaration (Exhibit 2) (3)
Docket Text: DECLARATION re [16] Opening Brief in Support of Tamar Lusztig by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Farnan, Brian)
Apr 30, 2021 17 Declaration (Exhibit 3) (30)
Docket Text: DECLARATION re [16] Opening Brief in Support of Tamar Lusztig by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Farnan, Brian)
Apr 30, 2021 17 Declaration (Exhibit 4) (30)
Docket Text: DECLARATION re [16] Opening Brief in Support of Tamar Lusztig by Koninklijke KPN N.V.. (Attachments: # (1) Exhibit 1, # (2) Exhibit 2, # (3) Exhibit 3, # (4) Exhibit 4)(Farnan, Brian)
Apr 13, 2021 14 Disclosure Statement (1)
Docket Text: Disclosure Statement pursuant to Rule 7.1: identifying Other Affiliate Yulong Infotech, Inc., Other Affiliate Coolpad Group Limited for Coolpad Technologies Inc. filed by Coolpad Technologies Inc.. (Day, John)
Apr 12, 2021 13 Answer to Complaint (19)
Docket Text: ANSWER to [1] Complaint, with Jury Demand , COUNTERCLAIM against Koninklijke KPN N.V. by Coolpad Technologies Inc..(Day, John)
Mar 15, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Timothy Vann Pearce, Jr for Coolpad Technologies Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (kmd)
Mar 10, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re [12] MOTION for Pro Hac Vice Appearance of Attorney T. Vann Pearce, Jr. and Yufeng Ma filed by Coolpad Technologies Inc. Signed by Judge Leonard P. Stark on 3/10/21. (ntl)
Mar 10, 2021 12 Motion for Leave to Appear Pro Hac Vice (4)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney T. Vann Pearce, Jr. and Yufeng Ma - filed by Coolpad Technologies Inc.. (Day, John)
Mar 9, 2021 11 Order (2)
Docket Text: ORDER re [10] MOTION to Compel (Unopposed) filed by Coolpad Technologies Inc. Signed by Judge Leonard P. Stark on 3/9/21. (ntl)
Feb 24, 2021 10 Motion to Compel (Main Document) (2)
Docket Text: MOTION to Compel (Unopposed) - filed by Coolpad Technologies Inc.. (Attachments: # (1) Text of Proposed Order)(Day, John)
Feb 24, 2021 10 Motion to Compel (Text of Proposed Order) (2)
Docket Text: MOTION to Compel (Unopposed) - filed by Coolpad Technologies Inc.. (Attachments: # (1) Text of Proposed Order)(Day, John)
Feb 23, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Tamar E. Lusztig for Koninklijke KPN N.V. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS. (kmd)
Feb 17, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Edward J. Delman for Koninklijke KPN N.V. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS.(kmd)
Feb 17, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re (10 in 1:21-cv-00045-LPS, 9 in 1:21-cv-00046-LPS, 10 in 1:21-cv-00044-LPS, 7 in 1:21-cv-00041-LPS, 9 in 1:21-cv-00043-LPS) MOTION for Pro Hac Vice Appearance of Attorney Tamar Lusztig filed by Koninklijke KPN N.V. Signed by Judge Leonard P. Stark on 2/17/21. Associated Cases: 1:21-cv-00041-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS (ntl)
Feb 17, 2021 9 Motion for Leave to Appear Pro Hac Vice (3)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Tamar Lusztig - filed by Koninklijke KPN N.V.. (Farnan, Brian)
Feb 12, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re (8 in 1:21-cv-00046-LPS, 9 in 1:21-cv-00044-LPS, 8 in 1:21-cv-00043-LPS, 9 in 1:21-cv-00045-LPS) MOTION for Pro Hac Vice Appearance of Attorney Edward J. Delman filed by Koninklijke KPN N.V. Signed by Judge Leonard P. Stark on 2/12/21. Associated Cases: 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS (ntl)
Feb 11, 2021 8 Motion for Leave to Appear Pro Hac Vice (4)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Edward J. Delman - filed by Koninklijke KPN N.V.. (Farnan, Brian)
Feb 10, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re [7] STIPULATION TO EXTEND TIME to move, answer, or otherwise respond to the Complaint to April 12, 2021 filed by Coolpad Technologies Inc. Signed by Judge Leonard P. Stark on 2/10/21. (ntl)
Feb 9, 2021 7 Stipulation to EXTEND Time (1)
Docket Text: STIPULATION TO EXTEND TIME to move, answer, or otherwise respond to the Complaint to April 12, 2021 - filed by Coolpad Technologies Inc.. (Mayo, Andrew)
Feb 5, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorneys Alexandra G. White an dTom DelRosario for Koninklijke KPN N.V. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. Associated Cases: 1:21-cv-00042-LPS, 1:21-cv-00043-LPS, 1:21-cv-00044-LPS, 1:21-cv-00045-LPS, 1:21-cv-00046-LPS.(kmd)
Feb 5, 2021 N/A Add Attorneys Pro Hac Vice (0)
Docket Text: Pro Hac Vice Attorney Andres C. Healy for Koninklijke KPN N.V. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. Associated Cases: 1:21-cv-00041-LPS et al.(kmd)
Jan 29, 2021 N/A SO ORDERED (0)
Docket Text: SO ORDERED, re (5 in 1:21-cv-00041-LPS, 6 in 1:21-cv-00046-LPS, 6 in 1:21-cv-00043-LPS, 6 in 1:21-cv-00042-LPS, 6 in 1:21-cv-00044-LPS, 6 in 1:21-cv-00045-LPS) MOTION for Pro Hac Vice Appearance of Attorney Alexandra G. White, Andres C. Healy, and Tom DelRosario filed by Koninklijke KPN N.V. Signed by Judge Leonard P. Stark on 1/29/21. Associated Cases: 1:21-cv-00041-LPS et al. (ntl)
Jan 28, 2021 6 Motion for Leave to Appear Pro Hac Vice (6)
Docket Text: MOTION for Pro Hac Vice Appearance of Attorney Alexandra G. White, Andres C. Healy, and Tom DelRosario - filed by Koninklijke KPN N.V.. (Farnan, Brian)
Jan 21, 2021 5 Summons Returned Executed (2)
Docket Text: SUMMONS Returned Executed by Koninklijke KPN N.V.. Coolpad Technologies Inc. served on 1/19/2021, answer due 2/9/2021. (Farnan, Brian)
Jan 20, 2021 N/A Case Assigned/Reassigned (0)
Docket Text: Case Assigned to Judge Leonard P. Stark. Please include the initials of the Judge (LPS) after the case number on all documents filed. Associated Cases: 1:21-cv-00041-LPS through 1:21-cv-00046-LPS (rjb)
Jan 19, 2021 4 Disclosure Statement (3)
Docket Text: Disclosure Statement pursuant to Rule 7.1: identifying Other Affiliate Capital Research and Management Company, Other Affiliate America Movil, S.A.B. de C.V. for Koninklijke KPN N.V. filed by Koninklijke KPN N.V.. (Farnan, Brian)
Jan 15, 2021 1 Complaint* (1)
Jan 15, 2021 N/A No Summons Issued (0)
Docket Text: No Summons Issued. (sam)
Jan 15, 2021 1 Complaint (Main Document) (12)
Docket Text: COMPLAINT for Infringement of Patent- filed with Jury Demand against Coolpad Technologies Inc. - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3466656.) - filed by Koninklijke KPN N.V. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Civil Cover Sheet)(sam)
Jan 15, 2021 1 Complaint (Exhibit A) (11)
Docket Text: COMPLAINT for Infringement of Patent- filed with Jury Demand against Coolpad Technologies Inc. - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3466656.) - filed by Koninklijke KPN N.V. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Civil Cover Sheet)(sam)
Jan 15, 2021 1 Complaint (Exhibit B) (30)
Docket Text: COMPLAINT for Infringement of Patent- filed with Jury Demand against Coolpad Technologies Inc. - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3466656.) - filed by Koninklijke KPN N.V. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Civil Cover Sheet)(sam)
Jan 15, 2021 1 Complaint (Civil Cover Sheet) (1)
Docket Text: COMPLAINT for Infringement of Patent- filed with Jury Demand against Coolpad Technologies Inc. - Magistrate Consent Notice to Pltf. ( Filing fee $ 402, receipt number ADEDC-3466656.) - filed by Koninklijke KPN N.V. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Civil Cover Sheet)(sam)
Jan 15, 2021 2 Magistrate Consent Forms (3)
Docket Text: Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (sam)
Jan 15, 2021 3 Patent/Trademark Report to Commissioner (1)
Docket Text: Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) US 6,212,662 B1. (sam)
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