Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Exhibit A

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Exhibit A IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION MATCH GROUP, LLC § § Plaintiff, § § v. § No. 6:18-cv-00080-ADA § BUMBLE TRADING INC. § JURY TRIAL DEMANDED § Defendant. § § [PROPOSED] MODIFIED SCHEDULING ORDER The Court ORDERS that the following modified schedule will govern deadlines up to and including the Deadline to submit a proposed post-Markman schedule in this matter: Deadline Item February 15, 2019 Plaintiff shall produce (1) all documents evidencing conception and reduction to practice for each claimed invention, and (2) a copy of the file history for each patent in suit. March 22, 2019 Defendant serves preliminary1 invalidity contentions in the form of (1) a chart setting forth where in the prior art references each element of the asserted claim(s) are found, (2) an identification of any limitations the Defendant contends are indefinite or lack written description under section 112, and (3) an identification of any claims the Defendant contends are directed to ineligible subject matter under section 101. Defendant shall also produce (1) all prior art referenced in the invalidity contentions, (2) technical documents, including software where applicable, sufficient to show the operation of the accused product(s), and (3) summary, annual sales information for the accused product(s) for the prior two years, 1 The parties may amend preliminary infringement contentions and preliminary invalidity contentions without leave of court so long as counsel certifies that it undertook reasonable efforts to prepare its preliminary contentions and the amendment is based on material identified after those preliminary contentions were served and should do so seasonably upon identifying any such material. Any amendment to add claims requires leave of court so that the Court can address any scheduling issues. 1 unless the parties agree to some other timeframe. March 29, 2019 Parties exchange claim terms for construction April 4, 2019 Parties exchange proposed claim constructions and evidence April 8, 2019 Deadline to meet and confer to narrow terms in dispute and exchange revised list of terms/constructions April 15, 2019 Complete Claim Construction Discovery April 22, 2019 Parties file Opening claim construction briefs, including any arguments that any claim terms are indefinite. May 8, 2019 Parties file Responsive claim construction briefs. May 16, 2019 Parties file Reply claim construction briefs. May 17, 2019 Parties submit Joint Claim Construction Statement, optional tutorials, and consolidated briefing collated by Opening, Response, and Reply. May 23, 2019 Markman Hearing at 9:00 a.m. May 28, 2019 Deadline to submit proposed post-Markman schedule. SIGNED this ________ day of ____________________, 20____. ________________________________________ ALAN D. ALBRIGHT UNITED STATES DISTRICT JUDGE 2