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

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

MOTION to Expedite Hearing Date of Case Management Conference filed by IXI IP,LLC, IXI Mobile (R&D) Ltd.

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1 John V. Picone III, Bar No. 187226 jpicone@hopkinscarley.com 2 Jennifer S. Coleman, Bar No. 213210 jcoleman@hopkinscarley.com 3 Aleksandr Korzh, Bar No. 286613 akorzh@hopkinscarley.com 4 HOPKINS & CARLEY A Law Corporation 5 The Letitia Building 70 South First Street 6 San Jose, CA 95113-2406 7 mailing address: P.O. Box 1469 8 San Jose, CA 95109-1469 Telephone: (408) 286-9800 9 Facsimile: (408) 998-4790 10 Attorneys for Plaintiffs IXI MOBILE (R&D) LTD. and IXI IP, LLC 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 IXI MOBILE (R&D) LTD. and IXI IP, CASE NO. 3:15-CV-03752-HSG 14 LLC, 15 Plaintiffs, 16 v. 17 SAMSUNG ELECTRONICS CO., et al., 18 Defendants. IXI MOBILE (R&D) LTD. and IXI IP, CASE NO. 3:15-CV-03754-HSG 19 LLC, (RELATED CASE) 20 Plaintiffs, 21 v. 22 BLACKBERRY CORPORATION, et al., 23 Defendants. IXI MOBILE (R&D) LTD. and IXI IP, CASE NO. 4:15-CV-03755-HSG 24 LLC, (RELATED CASE) 25 Plaintiffs, UNOPPOSED ADMINISTRATIVE MOTION OF IXI MOBILE (R&D) LTD. AND IXI IP, 26 v. LLC TO ADVANCE HEARING DATE OF 27 APPLE, INC. CASE MANAGEMENT CONFERENCE 28 Defendant. H OPKINS & C ARLEY 626\1255216.3 ATTO RNEY S AT LAW SAN JO SE NOTICE OF ADMINISTRATIVE MOTION AND ADMINISTRATIVE MOTION BY IXI MOBILE (R&D) LTD. AND IXI IP, LLC TO ADVANCE HEARING DATE OF CASE MANAGEMENT CONFERENCE 1 Pursuant to Local Rule 7-11(a), plaintiffs IXI MOBILE (R&D) LTD. and IXI IP, LLC 2 (collectively, "IXI") submit this Administrative Motion to request that the Court modify its 3 previous notices and advance the pending Case Management Conference related to these three 4 related cases from November 17, 2015 at 2:00 p.m. to November 3, 2015 at 2:00 p.m. 5 IXI originally commenced these three related actions in the Southern District of New 6 York beginning in June, 2014. More specifically, IXI commenced (1) the action against the 7 Samsung defendants on June 17, 2104; (2) the action against the Blackberry defendants on June 8 18, 2014; and (3) the action against Apple on October 2, 2104. The three matters were ultimately 9 accepted as related for pre-trial purposes. On December 12, 2104, the Court presiding over these 10 matters issued a Case Management Plan and Scheduling Order (Dkt. No. 38). 11 In accordance with the Case Management Plan and Scheduling Order, IXI and the 12 Defendants have begun pre-trial discovery and related procedures. The parties submitted a Joint 13 Claim Construction Statement on June 8, 2015; and IXI filed its opening Claim Construction 14 brief on July 8, 2015. On August 8, 2015, before Defendants' filed a Claim Construction brief, 15 the Court issued an Order granting Defendants' Motion to Transfer these cases to this Court. 16 These matters were then transferred to this Court on August 17, 2105. On September 2, 2015, 17 IXI filed an unopposed administrative motion to relate the three actions, which this Court granted 18 on September 9, 2015. Subsequently, this Court issued Orders scheduling a Case Management 19 Conference for the three cases for November 17, 2015 at 2:00 p.m. 20 For the reasons set out above and for the convenience of the parties, IXI respectfully 21 requests that the Case Management Conference for the Actions be advanced to November 3, 2015 22 at 2:00 p.m. so that the Actions can proceed in this Court in a timely and efficient manner. 23 Dated: September 25, 2015 HOPKINS & CARLEY A Law Corporation 24 By: /s/ Jennifer S. Coleman 25 John V. Picone III Jennifer S. Coleman 26 Aleksandr Korzh Attorneys for Plaintiffs 27 IXI MOBILE (R&D) LTD. and IXI IP, LLC 28 H OPKINS & C ARLEY -2- 626\1255216.3 ATTO RNEY S AT LAW SAN JO SE NOTICE OF ADMINISTRATIVE MOTION AND ADMINISTRATIVE MOTION BY IXI MOBILE (R&D) LTD. AND IXI IP, LLC TO ADVANCE HEARING DATE OF CASE MANAGEMENT CONFERENCE