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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION

WSOU INVESTMENTS, LLC D/B/A 

BRAZOS LICENSING AND 

DEVELOPMENT,

Plaintiff,

v. 

ZTE CORPORATION, 

Defendant.

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CIVIL ACTION 6:20-cv-00487-ADA

CIVIL ACTION 6:20-cv-00488-ADA

CIVIL ACTION 6:20-cv-00489-ADA

CIVIL ACTION 6:20-cv-00490-ADA

CIVIL ACTION 6:20-cv-00491-ADA

CIVIL ACTION 6:20-cv-00492-ADA

CIVIL ACTION 6:20-cv-00493-ADA

CIVIL ACTION 6:20-cv-00494-ADA

CIVIL ACTION 6:20-cv-00495-ADA

CIVIL ACTION 6:20-cv-00496-ADA

CIVIL ACTION 6:20-cv-00497-ADA

JOINT MOTION REGARDING EXTENSION OF DEADLINES

Plaintiff WSOU Investments, LLC d/b/a Brazos Licensing and Development (“WSOU”) 

and Defendant ZTE Corporation (“ZTE”), (collectively, the “Parties”), pursuant to the Court’s 

Standing Order Regarding Joint or Unopposed Request to Change Deadline, submit this Joint 

Motion to memorialize their agreement to extend case deadlines. The Parties have agreed to adjust 

the Scheduling Order, Dkt. 45, to afford the Parties more time for the purposes of completing 

depositions and discovery identified in the Court’s December 6, 2021, order; addressing any 

outstanding discovery disputes subject to the Local Civil Rules; and to reduce the number of claims 

and prior art references currently at issues. The Parties have jointly agreed to modify the schedule 

as follows:

Case 6:20-cv-00488-ADA Document 134 Filed 12/20/21 Page 1 of 4
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Event Original Deadline Proposed Extension

Close of Fact Discovery. December 17, 2021 June 17, 2022

Opening of Expert Reports. December 31, 2021 June 30, 2022

Rebuttal Expert Reports. January 21, 2022 July 21, 2022

Close of Expert Discovery. February 11, 2022 August 11, 2022

Deadline for the second of two meet and confers 

to discuss narrowing the number of specific 

claims asserted and specific prior art references 

to be asserted to triable limits. To the extent it 

helps the parties determine these limits, the

parties are encouraged to contact the Court’s 

Law Clerk for an estimate of the amount of trial 

time anticipated per side. The parties shall file a 

Joint Report within 5 business days regarding the 

results of the meet and confer.

February 18, 2022 August 18, 2022

Joint Report. February 23, 2022 August 25, 2022

Dispositive motion deadline and Daubert motion 

deadline.

February 25, 2022 August 25, 2022

Serve Pretrial Disclosures (jury instructions, 

exhibit lists, witness lists, discovery and 

deposition designations).

March 11, 2022 September 12, 2022

Serve objections to pretrial disclosures/rebuttal 

disclosures.

March 25, 2022 September 26, 2022

Serve objections to rebuttal disclosures and file 

motions in limine.

April 1, 2022 October 3, 2022

File Joint Pretrial Order and Pretrial 

Submissions (jury instructions, exhibit lists, 

witness lists, discovery and deposition 

designations); file oppositions to motions in 

limine.

April 8, 2022 October 10, 2022

File Notice of Request for Daily Transcript 

or Real Time Reporting. If a daily 

transcript or real time reporting of court 

proceedings is requested for trial, the party 

or parties making said request shall file a 

notice with the Court and e-mail the Court 

Reporter, Kristie Davis at

kmdaviscsr@yahoo.com.

Deadline to meet and confer regarding 

remaining objections and disputes on motions in 

limine.

April 15, 2022 October 17, 2022

File joint notice identifying remaining objections 

to pretrial disclosures and disputes on motion in 

limine.

April 26, 2022 October 26, 2022

(Proposed) Final Pretrial Conference. April 29, 2022 October 27, 2022

Case 6:20-cv-00488-ADA Document 134 Filed 12/20/21 Page 2 of 4
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(Proposed) Jury Selection / Trial. June 20, 2022 December 12, 2022

Dated: December 20, 2021

By: /s/ Mark D. Siegmund

Mark D. Siegmund

State Bar No. 24117055

mark@swclaw.com

STECKLER WAYNE COCHRAN

CHERRY, PLLC

8416 Old McGregor Rd.

Waco, Texas 76712

Telephone: (254) 651-3690

Facsimile: (254) 651-3689

James L. Etheridge

Texas State Bar No. 24059147

Ryan S. Loveless

Texas State Bar No. 24036997

Brett A. Mangrum

Texas Bar No. 24065671

Travis L. Richins

Texas State Bar No. 24061296

Jeff Huang

ETHERIDGE LAW GROUP, PLLC

2600 E. Southlake Blvd., Suite 120 / 324

Southlake, Texas 76092

Telephone: (817) 470-7249

Facsimile: (817) 887-5950

Jim@EtheridgeLaw.com

Ryan@EtheridgeLaw.com

Brett@EtheridgeLaw.com

Travis@EtheridgeLaw.com

Jeff@EtheridgeLaw.com

Attorneys for Plaintiff

By: /s/Lionel M. Lavenue 

Lionel M. Lavenue 

Virginia Bar No. 49,005

lionel.lavenue@finnegan.com

FINNEGAN, HENDERSON, 

FARABOW, GARRETT & DUNNER, 

LLP

1875 Explorer Street, Suite 800

Reston, VA 20190

Phone: (571) 203-2700

Fax: (202) 408-4400

Attorney for Defendant, 

ZTE Corporation

Case 6:20-cv-00488-ADA Document 134 Filed 12/20/21 Page 3 of 4
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CERTIFICATE OF SERVICE

I hereby certify that all counsel of record who are deemed to have consented to electronic 

service are being served with a copy of this filing via the Court’s CM/ECF system per Local 

Rule CV-5(a) on December 20, 2021. 

/s/ Mark D. Siegmund

Mark D. Siegmund

Case 6:20-cv-00488-ADA Document 134 Filed 12/20/21 Page 4 of 4