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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

SISVEL INTERNATIONAL S.A., 

3G LICENSING S.A., and SISVEL S.p.A., 

 Plaintiffs, 

 v. 

BLU PRODUCTS, INC., 

 Defendant. 

Civil Action No. 1:20-cv-22050-DPG 

JOINT SCHEDULING REPORT PURSUANT TO LOCAL RULE 16.1(b)(2)

Plaintiffs Sisvel International S.A., 3G Licensing S.A., and Sisvel S.p.A. (“Sisvel” or 

“Plaintiffs”) and Defendant BLU Products, Inc. (“Blu” or “Defendants”), pursuant to Rule 

16.1(b)(2) of the Local Rules for the Southern District of Florida and the Court’s October 21, 2020 

Order (D.I. 19) hereby submit this Joint Scheduling Report. 

Information Required by Local Rule 16.1(b)(2) 

(A)Likelihood of settlement. 

Settlement is possible. The parties are attempting in good faith to resolve this matter 

and will notify the Court if they do so. 

(B) Likelihood of appearance in the action of additional parties. 

The parties do not anticipate the appearance of any additional parties in this litigation. 

(C)Proposed limits on time. 

On November 2, 2020, Sisvel filed a Proposed Amended Scheduling Order in the 

related litigation Sisvel International S.A. et al. v. HMD America, Inc. et al., 1:20-cv-22051 (S.D. 

Fla.), D.I. 34. The parties in this case agreed to follow the same schedule, which is attached as the 

Proposed Scheduling Order. 

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In addition to the deadlines set by the Court’s Order, the parties agree to exchange 

initial disclosures pursuant to Fed. R. Civ. P. 26 on November 30, 2020. 

(D)Proposals for the formulation and simplification of issues, including the 

elimination of frivolous claims or defenses and the number and timing of motions 

for summary judgment or partial summary judgment. 

The parties do not have any proposals for the formulation and simplification of any 

issues at this time. As the case progresses, the parties will in good faith confer to discuss proposals 

for the formulation and simplification of the issues in this case. 

(E) The necessity or desirability of amendments to the pleadings. 

Plaintiffs do not anticipate that any amendments to the Complaint will be necessary. 

(F) The possibility of obtaining admissions of fact and of documents, electronically 

stored information or things which will avoid unnecessary proof, stipulations 

regarding authenticity of documents, electronically stored information or things, 

and the need for advance rulings from the Court on admissibility of evidence. 

Through the discovery process it is expected that the parties will work together in good 

faith to obtain admissions and stipulations that will avoid unnecessary proof at trial. In particular 

the parties have discussed the use of Requests for Admission to address this issue. 

(G)Suggestions for the avoidance of unnecessary proof and cumulative evidence. 

Through the discovery process the parties have agreed to avoid the production of 

unnecessary proof and cumulative evidence. To the extent one party believes that the evidence is 

unnecessary or cumulative, the parties have agreed to work together in good faith to address these 

situations. 

(H)Suggestions on the advisability of referring matters to a Magistrate Judge or 

master. 

The parties consent to referring discovery dispute related matters to the Magistrate 

Judge. The parties do not consent to referring any matters to a master at this time. 

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(I) A preliminary estimate of the time required for trial. 

The parties estimate that the time required for trial will be ten days. 

(J) Requested date or dates for conferences before trial, a final pretrial conference, 

and trial. 

At this time, the parties have no additional requested dates for conferences before trial, 

a final pretrial conference, or trial beyond the dates included in the Joint Scheduling Report. 

(K)Any key issues about: 

(i) Disclosure, discovery, or preservation of electronically stored information, 

including the form or forms in which it should be produced; 

The parties will negotiate in good faith an Electronically Stored Information agreement 

to address the disclosure of electronically stored information. 

(ii) Claims of privilege or of protection as trial-preparation materials, 

including – if the parties agree on a procedure to assert those claims after 

production – whether to ask the court to include their agreement in an 

order under Federal Rule of Evidence 502; and 

The parties will negotiate in good faith an agreed protective order to address issues of 

privilege. 

(iii) When the parties have agreed to use the ESI Checklist available on the 

Court’s website (www.flsd.uscourts.gov), matters enumerated on the ESI 

checklist. 

The parties will consider whether to use the ESI Checklist as part of their negotiations 

over an Electronically Stored Information agreement. 

[Signature follows on next page] 

Case 1:20-cv-22050-DPG Document 21 Entered on FLSD Docket 11/12/2020 Page 3 of 4
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Dated: November 12, 2020 

/s/ Jorge Espinosa 

Jorge Espinosa, Esq. 

Florida Bar No: 799032 

Jorge.espinosa@gray-robinson.com

Francesca Russo, Esq. 

Florida Bar No.: 174912 

Francesca.russo@gray-robinson.com

Robert R. Jimenez, Esq. 

Florida bar No. 72020 

Robert.jimenez@gray-robinson.com

GRAYROBINSON, P.A. 

333 S.E. 2nd Ave., Suite 3200 

Miami, FL 33131 

Tel: 305-416-6880 

Fax: 305-416-6887 

OF COUNSEL 

Neil A. Benchell

nbenchell@devlinlawfirm.com

tdevlin@devlinlawfirm.com

DEVLIN LAW FIRM LLC 

1526 Gilpin Avenue 

Wilmington, DE 19806 

Tel: 302-449-9010 

Attorneys for Plaintiffs 

Sisvel International S.A., 

3G Licensing S.A., and SISVEL S.p.A. 

/s/ Bernard L. Egozi

Bernard L. Egozi, Esq. 

Florida Bar No. 152544 

begozi@egozilaw.com 

Yanina Zilberman, Esq. 

Florida Bar No. 105665 

yanina@egozilaw.com

EGOZI & BENNETT, PA 

2999 NE 191st Street, Suite 407 

Aventura, Florida 33180 

Tel. 305.931.3000 

Fax: 305.931.9343 

Attorneys for Defendant BLU Products, Inc.

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