Taken from JOINT CASE MANAGEMENT
CONFERENCE STATEMENT (yesterday’s pacer) re; Acer/Barco/HTC

Hope I captured the main scheduling issues of this statement…if not corrections welcome.

With regards to the ‘749 patent, Plaintiffs have already admitted that the
disputed claim terms from the original claim language remain unchanged. Defendants do not
believe that any further claim construction is needed for either patent. To the extent Plaintiffs
propose supplemental terms for construction, it should not consume an additional seven months before reaching a Markman hearing, as Plaintiffs propose.

Defendants instead suggest the following scheduling efficiencies……… result in a Markman hearing three months from now in September, 2011

Defendants request that the Court schedule the Markman hearing as soon as possible after
the close of claim construction briefing.
2. Request for Additional Depositions
Discovery issues are complex in these cases, and Defendants do not believe that adequate
discovery can be completed of the three parties and numerous third party suppliers of
microprocessors and intermediary hard drives, within the limit of ten depositions as provided for
in the Federal Rules of Civil Procedure. Defendants accordingly seek an order from the Court
allowing the number of depositions to be extended beyond the default ten fact witness depositions in each of the three cases, to allow Defendants to also take an additional thirty third party depositions across all three cases.

Looks like we are asking for thirty depositions. Is this unusual or ?? Ron or anyone else with a legal background please comment on the Joint Case Management Conference if you have read the Pacer. Tks.