Ixi Mobile (R&D) Ltd. et al v. Apple, Inc.

Northern District of California, cand-4:2015-cv-03755

LETTER addressed to Judge Richard J. Sullivan from Thomas S. Biemer, Esquire dated June 4, 2015 re: Claim Construction Technology Tutorial. Document filed by IXI IP,LLC, IXI Mobile (R&D) Ltd.

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DIRECT DIAL NUMBER: Thomas S. Biemer (215) 575-7025 tbiemer@dilworthlaw.com June 4, 2015 VIA ECF Honorable Richard J. Sullivan Courtroom: 905 Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: Claim Construction Technology Tutorial Dear Judge Sullivan: I write on behalf of Plaintiffs IXI IP, LLC and IXI Mobile (R&D) Ltd. and Defendants BlackBerry Limited, BlackBerry Corporation, Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Samsung Telecommunications America, LLC, and Apple Inc. in the cases captioned IXI Mobile (R&D) Ltd. et al. v. Samsung Elec. Co., Ltd., No. 14- cv-4355(RJS), IXI Mobile (R&D) Ltd. et al. v. Blackberry Ltd., et al., No. 14-cv-4428(RJS), and IXI Mobile (R&D) Ltd. et al. v. Apple Inc., No. 14-cv-7954(RJS). The claim construction process in these cases is beginning, with the Joint Claim Term Chart due on June 8, 2015, and briefing to be completed by August 14, 2015. As a reminder, the Court has yet to instruct the parties as to whether it desires technology tutorials in advance of the Claim Construction Hearing. At a high level, the technology generally involves systems, devices, and methods for improving communications and network services between wide area networks and wireless local area networks. The parties believe that some explanation of the patented technologies could assist the Court in its understanding of the disputed claim terms in the context of claimed inventions. Procedurally, the parties believe that counsel for each party should present a technical tutorial, which may include, for example, a video or slideshow, at the beginning of the Claim Construction Hearing. Because of some of the complexities inherent in the accused technology, the Court may also wish to consider whether it wants to appoint a technical advisor or special master. 1500 Market Street · Suite 3500E · Philadelphia, PA 19102-2101 · 215-575-7000 · fax 215-575-7200 Cherry Hill NJ · Harrisburg, PA · Red Bank. NJ · Washington, DC · Wilmington, DE · New York, NY Judge Sullivan June 4, 2015 Page 2 Please advise whether the Court would like the parties to present technical tutorials. Some tutorials, such as video presentations, can be quite time consuming to create and the parties would like to get started as soon as possible if the Court desires such a presentation. Thank you for your guidance on this matter. Respectfully, /s/Thomas S. Biemer Thomas S. Biemer cc: Counsel of Record 1500 Market Street · Suite 3500E · Philadelphia, PA 19102-2101 · 215-575-7000 · fax 215-575-7200 Cherry Hill NJ · Harrisburg, PA · Red Bank. NJ · Washington, DC · Wilmington, DE · New York, NY