Exhibit B

Case 6:20-cv-00544-ADA Document 31-2 Filed 10/30/20 Page 1 of 4
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. 

HUAWEI TECHNOLOGIES CO., 

LTD. and HUAWEI 

TECHNOLOGIES USA INC.,

Defendants.

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CIVIL ACTION 6:20-cv-00533-ADA

CIVIL ACTION 6:20-cv-00534-ADA

CIVIL ACTION 6:20-cv-00535-ADA

CIVIL ACTION 6:20-cv-00536-ADA

CIVIL ACTION 6:20-cv-00537-ADA

CIVIL ACTION 6:20-cv-00538-ADA

CIVIL ACTION 6:20-cv-00539-ADA

CIVIL ACTION 6:20-cv-00540-ADA

CIVIL ACTION 6:20-cv-00541-ADA

CIVIL ACTION 6:20-cv-00542-ADA

CIVIL ACTION 6:20-cv-00543-ADA

CIVIL ACTION 6:20-cv-00544-ADA

[DRAFT] SCHEDULING ORDER

Deadline Item

October 9, 2020

Plaintiff serves preliminary3 infringement contentions in 

the form of a chart setting forth where in the accused 

product(s) each element of the asserted claim(s) are 

found. Plaintiff shall also identify the earliest priority 

date (i.e. the earliest date of invention) for each asserted 

claim and produce: (1) all documents evidencing 

conception and reduction to practice for each claimed 

invention, and (2) a copy of the file history for each patent 

in suit.

October 30, 2020 Deadline for Motions to Transfer, and deadline for parties 

to submit an agreed Scheduling Order.

3The parties may amend preliminary infringement contentions and preliminary invalidity

contentions without leave of court so long as counsel certifies that it undertook reasonable efforts

to prepare its preliminary contentions and the amendment is based on material identified after those

preliminary contentions were served and should do so seasonably upon identifying any such

material. Any amendment to add claims requires leave of court so that the Court can address any

scheduling issues.

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Case 6:20-cv-00544-ADA Document 31-2 Filed 10/30/20 Page 2 of 4
Deadline Item

December 7, 2020

Defendant serves preliminary invalidity contentions in the 

form of (1) a chart setting forth where in the prior art 

references each element of the asserted claim(s) are 

found, (2) an identification of any limitations the 

Defendant contends are indefinite or lack written 

description under section 112, and (3) an identification of 

any claims the Defendant contends are directed to 

ineligible subject matter under section 101. Defendant 

shall also produce (1) all prior art referenced in the 

invalidity contentions, (2) technical documents, including 

software where applicable, sufficient to show the 

operation of the accused product(s), and (3) summary, 

annual sales information for the accused product(s) for the 

two years preceding the filing of the complaint, unless the 

parties agree to some other timeframe.

December 21, 2020 Parties exchange claim terms for construction.

January 08, 2021 Parties exchange proposed claim constructions.

January 15, 2021

Parties disclose extrinsic evidence. The parties shall 

disclose any extrinsic evidence, including the identity of 

any expert witness they may rely upon with respect to 

claim construction or indefiniteness. With respect to any 

expert identified, the parties shall identify the scope of the 

topics for the witness’s expected testimony.4 With 

respect to items of extrinsic evidence, the parties shall 

identify each such item by production number or produce 

a copy of any such item if not previously produced. 

January 22, 2021 Deadline to meet and confer to narrow terms in dispute 

and exchange revised list of terms/constructions.

February 5, 2021 Plaintiff files Opening claim construction brief, including 

any arguments that any claim terms are indefinite.

March 5, 2021 Defendant files Responsive claim construction brief. 

March 19, 2021 Plaintiff files Reply claim construction brief.

4 Any party may utilize a rebuttal expert in response to a brief where expert testimony is relied upon by

the other party.

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Case 6:20-cv-00544-ADA Document 31-2 Filed 10/30/20 Page 3 of 4
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Deadline Item

April 2, 2021 Defendant files Sur-Reply claim construction brief.

April 5, 2021

Parties submit Joint Claim Construction Statement. 

See General Issues Note #8 regarding providing copies of 

the briefing to the Court and the technical adviser (if 

appointed).

April 9, 2021

Parties submit optional technical tutorials to the Court and 

technical adviser (if appointed). The parties shall also 

jointly submit, via USB drive, Box (not another cloud 

storage), or email to the law clerk, pdf versions of all asfiled briefing and exhibits.

April 15-16, 2021 Markman Hearing 

Case 6:20-cv-00544-ADA Document 31-2 Filed 10/30/20 Page 4 of 4