It is not going to happen...

Unrestricted discovery is the rule, and Featherstone's proposal of "Metered" discovery is a trick to restrict EDID'S ability to present its case on issues that are essence of the law suit.

For example, EDIG needs to identify all the "Accused products", that NOKIA makes which use FLASH in their operation; what is the technology used in such products and how did Nokia came upon it, and for how long they have been using it...

This knowledge is essential to calculating the nature and the extent of the "Infringment" by Nokia. What Featherstone is proposing is absurd. He wants an ORDER first, issued by the Court on theoretical grounds as to what would constitute and "Infringement" of EDIG patents, and then he will reveal how many products he thinks fit the mold described in the ORDER...

EDIG'S position has always been that if you have a product that used an SD card and you take that card out of the product and it does not work, then that products infringes on its patents...

Featherstone's slight of hand trickery would destroy that position. He would essentially shift the burden to EDIG to prove separately each prodct's infringment based on a pre defined "infringment" pronouncement by the Court not based on any evidentiary basis for lack of production of such evidence by defendants to plaintiff ahead of the ruling ...

IT IS NOT GOING TO HAPPEN THAT WAY, PERIOD...

Gil...