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Case 4:25-cv-01487-YGR Document 102
`
`Robert S. Hill (SBN 276056)
`HOLLAND & KNIGHT LLP
`robert.hill@hklaw.com
`
`David C. Schulte (SBN 24037456)
`Pro Hac Vice Admission
`david.schulte@hklaw.com
`
`Sara S. Staha (SBN 24088368)
`Pro Hac Vice Admission
`Sara.staha@hklaw.com
`
`Morgan J. Delabar (SBN 24116625)
`Pro Hac Vice Admission
`morgan.delabar@hklaw.com
`
`1722 Routh Street, Suite 1500
`Dallas, Texas 75201
`
`Telephone: 214-964-9421
`Facsimile: 214-964-9501
`
`Robert K. Jain (SBN 309728)
`HOLLAND & KNIGHT LLP
`robert.jain@hklaw.com
`
`98 San Jacinto Boulevard, Suite 1900
`Austin, Texas 78701
`
`Telephone: 512-647-4394
`
`Facsimile: 512-472-7473
`
`Filed 08/05/25
`
`Heidi L. Keefe
`hkeefe@cooley.com
`Reuben H. Chen
`rchen@cooley.com
`Alexandra Leeper
`aleeper@cooley.com
`Andrew C. Mace
`amace@cooley.com
`Matthew J. Brigham
`mbrigham@cooley.com
`COOLEY LLP
`
`3175 Hanover Street
`Palo Alto, CA 94304
`650-843-5000 (telephone)
`650-849-7400 (facsimile)
`
`Dustin M. Knight
`dknight@cooley.com
`COOLEY LLP
`
`1299 Pennsylvania Ave., NW, Suite 700
`
`Washington, DC 20004
`202-842-7800 (telephone)
`
`Page 1 of 9
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`Attorneys for Defendant —Google, LLC.,
`
`Attorneys for Plaintiff —Cellular South, Inc.
`See page below for additional counsel
`
`See page below for additional counsel
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`) Case Number: 4:25-cv-01487-YGR
`CELLULAR SOUTH, INC., )
`)
`Plaintiff{(s), )
`) HPROPOSED} JOINT CASE
`Vs. ) MANAGEMENT AND PRETRIAL
`) ORDER AS MODIFIED
`GOOGLE, LLC, )
`) Complaint Filed: May 9, 2024
`Defendant(s). )
`)
`IPR2025-00877
`Patent Owner Exhibit 2010
`
`Page 1 of 9
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`
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`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 2 of 9
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`Plaintiff Cellular South, Inc., (“CSI”) and Defendant Google, LLC (“Google”)
`(collectively “the Parties”) jointly submit this JOINT CASE MANAGEMENT AND PRETRIAL
`PROPOSED ORDER pursuant to the Court’s Directive in the Case Management Conference held
`on Monday, July 7, 2025, at 2:00 p.m. via ZOOM WEBINAR VIDEO CONFERENCE. (DKT
`71 and 100). The following case management deadlines are jointly proposed by the Parties and
`incorporate deadlines ordered by the Court in the Pre-Trial Schedule contained in DKT 96, with
`
`one exception:
`
`Event Proposed Deadline
`Initial Case Management Conference Monday, July 7, 2025
`Google to produce technical Wednesday, July 9, 2025
`documentation regarding accused
`products
`Deadline for Google to file Answer? Friday, July 11, 2025
`Google to make source code available for Wednesday, July 23, 2025
`inspection
`Patent L.R. 3-1 Amended Infringement Thursday, October 23, 2025
`Contentions
`Patent L.R. 3-2 Document Production Thursday, October 23, 2025
`Accompanying Amended Infringement
`Contentions
`Patent L.R. 3-3 Invalidity Contentions Thursday, November 20, 2025
`Patent L.R. 3-4 Document Production Thursday, November 20, 2025
`Accompanying Invalidity Contentions
`
`! The Parties note that DK'T 96 contains a February 26, 2026 date for disclosure of opening
`expert reports and a March 12, 2026 date for disclosure of rebuttal expert reports. The Parties
`understood these two dates to be contemplated as the dates for simultaneous filing of opening
`and rebuttal claim construction briefs, with expert deadlines to follow the Markman hearing.
`See DKT 100 at 4:24-5:3. This proposed schedule reflects the expert reports being due after
`this simultaneous claim construction brief filing and the Markman hearing.
`
`2 Google has agreed not to file a motion under Rule 12(b).
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`Page 2 of 9
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`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 3 of 9
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`Event
`
`Proposed Deadline
`
`Patent L.R. 4-1 Exchange Terms for
`Construction
`
`Thursday, December 11, 2025
`
`Patent L.R. 4-2 Exchange Preliminary
`Constructions and Extrinsic Evidence
`
`Thursday, January 8, 2026
`
`Patent L.R. 3-8 Damages Contentions
`
`Thursday, January 8, 2026
`
`Patent L.R. 4-3 Joint Claim Construction
`and Prehearing Statement
`
`Thursday, January 22, 2026
`
`Patent L.R. 3-9 Responsive Damages
`Contentions
`
`Thursday, February 5, 2025
`
`Patent L.R. 4-4 Completion of Claim
`Construction Discovery
`
`Thursday, February 5, 2026
`
`Deadline for Parties to Amend Pleadings
`to Add Parties or Claims, Absent Good
`Cause
`
`Thursday, February 5, 2026
`
`Patent L.R. 4-5(a) Opening Claim
`Construction Briefs
`
`Thursday, February 26, 2026
`
`Patent L.R. 4-5(b) Responsive Claim
`Construction Briefs
`
`Thursday, March 12, 2026
`
`Patent L.R. 3-10 Damages Contention
`Meeting and Certification Due
`
`Monday, April 6, 2026
`
`Parties to file amended, final joint claim
`construction statement
`
`Monday, April 6, 2026
`
`Written Technology Synopsis and
`Tutorial
`
`Wednesday, April 15, 2026 at 2:00 p.m.
`
`Patent L.R. 4-6 Claim Construction
`Hearing
`
`Wednesday, April 29, 2026 at 2:00 p.m.
`
`Patent L.R. 3-7 Disclosures
`
`30 days after the Court issues claim construction
`
`ruling
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`
`Page 3 of 9
`
`
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`
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`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 4 of 9
`
`Event
`
`Proposed Deadline
`
`Completion of Fact Discovery
`
`Thursday, June 11, 2026
`
`Deadline to file motions to compel
`
`Thursday, June 25, 2026
`
`Deadline for parties to meet and confer re
`narrowing the number of asserted
`claims/invalidity grounds
`
`Thursday June 25, 2026
`
`Opening Expert Report on Issues as to
`which Party Bears the Burden of Proof
`
`Thursday, July 16, 2026
`
`Responsive Expert Reports
`
`Thursday, August 20, 2026
`
`Completion of Expert Discovery
`
`Thursday, September 10, 2026
`
`Deadline to file letter requesting a pre-
`filing conference regarding motion for
`summary judgment
`
`Wednesday, September 16, 2026
`
`Pre-filing conference on motion for
`summary judgment
`
`Subject to court’s availability, Friday, September
`25,2026
`
`Deadline to File Summary Judgment &
`Daubert Motions
`
`Thursday, October 1, 2026
`
`Deadline to File Responsive Briefs to
`Summary Judgment & Daubert Motions
`
`Thursday, October 15, 2026
`
`Deadline to File Reply Briefs to Summary
`Judgment & Daubert Motions
`
`Thursday, October 22, 2026
`
`Summary Judgment & Daubert Hearing
`
`Subject to court’s availability, Tuesday,
`November 10, 2026 at 2:00 p.m.
`
`Exchange of deposition and discovery-
`response designations
`
`Thursday, December 10, 2026
`
`Exchange of exhibits and exhibit list
`
`Thursday, December 10, 2026
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`Page 4 of 9
`
`
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`
`
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`
`
`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 5 of 9
`
`Event Proposed Deadline
`
`Exchange Counter-Designations and Thursday, January 7, 2027
`Objections to Deposition and Discovery
`Response Designations
`
`Exchange objections to exhibit list Thursday, January 14, 2027
`Exchange witness lists Thursday, January 14, 2027
`Parties Exchange Motions in Limine Thursday, January 21, 2027
`Deadline to meet and confer regarding Tuesday, January 26, 2027
`
`Pretrial Conference Statement
`
`Deadline to file Joint Statement Friday, January 29, 2027
`confirming compliance with Pretrial meet
`and confer requirement
`
`Compliance Hearing Friday, February 5, 2027, at 9:01 a.m.
`
`Pretrial Statement Deadline Friday, February 12, 2027
`
`Joint Trial Readiness Binder Friday, February 19, 2027, by noon
`
`Pretrial Conference Friday, February 26, 2027 at 9:00 a.m.
`
`Trial Monday, March 15, 2027, at 8:30 a.m. (Jury
`Trial)
`
`Pursuant to the Court’s Pretrial Instructions in Civil Cases at Section 2, trial counsel
`shall meet and confer at least twenty-one (21) days in advance of the Pretrial Conference. The
`compliance hearing on Friday, February 5, 2027 at 9:01 a.m. is intended to confirm that counsel
`have reviewed the Court’s Pretrial Setting Instructions and are in compliance therewith. The
`compliance hearing shall be held in the Federal Courthouse, 1301 Clay Street, Oakland,
`California, in Courtroom 1. Five (5) business days prior to the date of the compliance hearing,
`the parties shall file a one-page JOINT STATEMENT confirming they have complied with this
`requirement or explaining their failure to comply. If compliance is complete, the parties need
`
`not appear and the compliance hearing will be taken off calendar. Telephonic appearances will
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`Page 5 of 9
`
`
`
`
`
`
`
`
`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 6 of 9
`
`be allowed if the parties have submitted a joint statement in a timely fashion. Failure to do so
`may result in sanctions.
`
`Parties are advised that while the Court set a trial date in this action, the trial date may
`be advanced if the calendar opens. Said trial date will not be sooner than eight (8) weeks after
`the close of discovery.
`
`Modification to the timing or extent of parties’ discovery obligations under Fed. R. Civ.
`P. 26 and other applicable rules may be done pursuant to a separate Court Order. The parties
`are directed to submit a JOINT proposed order to the Court within five (5) business days
`following the date of the Case Management Conference which sets forward the modifications.
`
`The parties must comply with both the Court’s Standing Order in Civil Cases and
`Standing Order for Pretrial Instructions in Civil Cases for additional deadlines and procedures.
`All Standing Orders are available on the Court’s website at
`
`http://www.cand.uscourts.gov/ygrorders.
`
`Dated: July 25, 2025 /s/ Robert S. Hill
`Counsel for plaintiff
`
`Dated: July 25, 2025 /s/ Heidi L. Keefe
`Counsel for defendant
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`Page 6 of 9
`
`
`
`
`
`
`
`
`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 7 of 9
`
`SIGNATURE ATTESTATION
`
`I hereby attest that signatories listed above, in the filing of this document has been obtained from
`
`each of the other signatories.
`
`Dated: July 25, 2025 Holland & Knight LLP
`
`By: /s/ Robert S. Hill
`Robert S. Hill (SBN 276056)
`
`Attorney for Plaintiff
`Cellular South, Inc
`
`IT IS SO ORDERED.
`Dated: 8/5/25
`
`f
`YY¥UNNE GONZALEZ(ROGERS()
`ed States District Court Judge
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`Page 7 of 9
`
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`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 8 of 9
`
`ADDITIONAL COUNSEL FOR
`
`ATTORNEYS FOR DEFENDANT
`
`PLAINTIFF CELLULAR SOUTH, INC. GOOGLE, LLC
`
`Jacob W.S. Schneider (SBN 675315)
`Jacob.schneider@hklaw.com
`Allison M. Lucier (SBN 569193)
`allison.lucier@hklaw.com
`HOLLAND & KNIGHT LLP
`
`10 St. James Avenue
`
`Boston, MA 02116
`
`Telephone: 617-523-2700
`
`Anthony J. Fuga (SBN 6301658)
`anthony.fuga@hklaw.com
`HOLLAND & KNIGHT LLP
`
`150 North Riverside Plaza, Suite 2700
`Chicago, IL 60606
`
`Telephone: (312) 263-3600
`Facsimile: (312) 578-6666
`
`Ashley Shively (SBN 264912)
`ashley.shively@hklaw.com
`HOLLAND & KNIGHT LLP
`560 Mission Street
`
`San Francisco, CA 94111
`415-743-6906
`
`Eamonn Gardner
`egardner@cooley.com
`COOLEY LLP
`
`1144 15th Street
`
`Suite 2300
`
`Denver, CO 80202-2686
`720-566-4000 (telephone)
`
`Attorneys for Defendant — Google, LLC
`
`Attorneys for Plaintiff —Cellular South, Inc.
`
`IPR2025-00877
`
`Patent Owner Exhibit 2010
`
`Page 8 of 9
`
`
`
`
`
`
`
`
`Case 4:25-cv-01487-YGR Document 102 Filed 08/05/25 Page 9 of 9
`
`IPR2025-00877
`Patent Owner Exhibit 2010
`Page 9 of 9
`
`
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`

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