Plaintiff’s Proposal:
a. August 20, 2010 – fact discovery opens on all non-claim construction

e. 60 days after Court issues a claim construction order: All fact discovery must be
completed (including deposition of all fact witnesses).

Defendants Proposal:

a. September 17, 2010 – Fact discovery on liability issues begins.

(ii) Fact discovery on damages issues begins.
d. 60 days after Court issues a claim construction order: All fact discovery on liability
issues must be completed (including deposition of all fact witnesses on liability
issues).
e. 120 days after Court issues a claim construction order - All fact discovery on
damages/willfulness issues must be completed (including deposition of all fact
witnesses on damages/willfulness issues);

Other than liability issues, I do not see within their proposal details relating to All fact discovery.....

Gil could you comment on that difference?

doni