EXHIBIT A

Case 4:23-cv-00609-SDJ Document 20-1 Filed 11/08/23 Page 1 of 5 PageID #: 229
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

Civil Action No. 4:23-cv-00070 SDJ

[PROPOSED] SCHEDULING ORDER

Pursuant to the Court’s Order Governing Proceedings (Dkt. No. 15) and the E.D. Tex. 

Patent Rules, it is hereby ORDERED that the parties shall adhere to the following Schedule. 

Dates in bold typeface (or written by hand and underlined) may not be changed without the 

consent of the Court. 

Deadline or Event Joint 

Proposal 

Based on 

Court’s 

Pretrial Date

Joint Proposal 

Based on one 

month extension to 

Court’s Pretrial 

Date

(same dates unless 

otherwise noted)

Mediation (to be discussed at case management conference)

P.R. 3-1 Disclosure of Asserted Claims and Infringement 

Contentions (and P.R. 3-2 document production) to be 

served.

11/30/2023

Join additional parties. 12/27/2023

P.R. 3-3 Invalidity Contentions (and P.R. 3-4 Document 

production) to be served. To the extent not already required 

to be disclosed, exchange Mandatory Disclosures on all 

issues, including damages.

1/15/2024

Parties to exchange proposed terms for construction and 

identify any claim element governed by 35 U.S.C. § 112, ¶ 6 

(P.R. 4-1).

1/22/2024

Privilege logs to be exchanged by parties (or a letter to the 1/22/2024

BELL SEMICONDUCTOR, LLC,

Plaintiff,

v.

AMS SENSORS USA, INC. and AMSOSRAM AG,

Defendants.

Case 4:23-cv-00609-SDJ Document 20-1 Filed 11/08/23 Page 2 of 5 PageID #: 230
Court stating that there are no disputes as to claims of 

privileged documents).

Parties to exchange preliminary proposed claim construction 

and extrinsic evidence supporting same. (P.R. 4-2).

1/29/2024

Parties’ Final Amended Pleadings. 2/19/2024

Joint Claim Construction and Prehearing Statement to be 

filed. (P.R. 4-3). Provide an estimate of how many pages are 

needed to brief the disputed claims.

2/23/2024

Respond to Amended Pleadings. 3/12/2024

Completion date for discovery on claim construction. (P.R. 

4-4).

3/24/2024

Opening claim construction brief. (P.R. 4-5(a)). 4/5/2024

Responsive claim construction brief. (P.R. 4-5(b)). 4/19/2024

Reply claim construction brief. (P.R. 4-5(c)). 4/26/2024

Submit technology synopsis/tutorial (both hard copy and 

disk).

4/11/2024

Parties to file joint claim construction and chart. (P.R. 4-

5(d)). Parties shall work together to agree on as many claim 

terms as possible.

4/29/2024

Claim Construction Hearing at 10:00 a.m. at the United 

States Courthouse, 7940 Preston Road, Plano, TX 75024.

Thursday, 

May 9, 2024

Fact Discovery Deadline. Deadline for Initial Mandatory

Disclosure of all persons, documents, data compilations and 

tangible things, which are relevant to a claim or defense of 

any party and which has not previously been disclosed. This 

deadline is not an extension of earlier deadlines set out in this 

Court’s order or the Patent Rules, nor an excuse to delay 

disclosure of information. It is a “catchall” deadline for 

provision of all remaining information which may be 

relevant to a claim or defense of any party at trial.

6/13/2024

Parties shall notify the Court of the name, address, and 

telephone number of the agreed-upon mediator, or request 

that the Court select a mediator, if they are unable to agree 

on one.

6/20/2024

Parties with burden of proof to designate Expert Witnesses 

other than claims construction experts and provide their 

expert witness reports, to include for ALL experts all 

information set out in Rule 26(a)(2)(B).

7/11/2024

Comply with P.R. 3-7 (Designation of Willfulness

Opinions).

7/11/2024

Parties to Designate Expert Witnesses on issues for which 

the parties do not bear the burden of proof, and provide their 

expert witness report, to include for ALL experts all 

information set out in Rule 26(2)(B).

7/25/2024

Mediation deadline. 8/1/2024

Expert Discovery deadline. 8/8/2024

Case 4:23-cv-00609-SDJ Document 20-1 Filed 11/08/23 Page 3 of 5 PageID #: 231
File objections to any expert, including Daubert motions. 

Such objections and motions are limited to ten pages each.

File Dispositive Motions and any other motions that may 

require a hearing. Regardless of how many dispositive 

motions a party files, each party is limited to a total of sixty 

pages for such motions. Each individual motion shall comply 

with Local Rule CV-7.

Responses to motions shall be due in accordance with 

Local Rule CV-7(e).

8/18/2024

Meet and confer with counsel and unrepresented parties to 

determine how the parties will prepare the Joint Final Pretrial 

Order, and Proposed Jury Instructions and Verdict Form. 

12/2/2024 1/2/2025

Motions in limine due. 12/6/2024 1/6/2025

File Joint Final Pretrial Order. 

Exchange Exhibits and deliver copies to the Court. At this 

date, all that is required to be submitted to the Court is a 

hyperlinked exhibit list on disk (2 copies) and no hard 

copies.

12/6/2024 1/6/2025

Video Deposition Designation due. Each party who proposes 

to offer a deposition by video shall serve on all other parties 

a disclosure identifying the line and page numbers to be 

offered. All other parties will have seven calendar days to 

serve a response with any objections and requesting cross 

examination line and page numbers to be included. Counsel 

must consult on any objections and only those which cannot 

be resolved shall be presented to the Court. The party who 

filed the initial Video Deposition Designation is responsible 

for preparation of the final edited video in accordance with 

all parties’ designations and the Court’s rulings on 

objections.

12/9/2024 1/9/2025

Response to motions in limine due. 12/23/2024 1/23/2025

File objections to witnesses, deposition extracts, and 

exhibits, listed in pre-trial order. (This does not extend the 

deadline to object to expert witnesses.) If numerous 

objections are filed, the Court may set a hearing prior to 

docket call.

12/23/2024 1/23/2025

File Proposed Jury Instructions/Form of Verdict (or Proposed 

Findings of Fact and Conclusions of Law).

12/23/2024 1/23/2025

File Proposed Voir Dire Questions. 12/23/2024 1/23/2025

Final Pretrial Conference at 1:30 p.m. at the United States 

Courthouse located at 7940 Preston Road, Plano, TX 75024.

January 6, 

2025 

TBD by Court or 

February 6, 2025 

10:00 a.m. Jury Selection and Trial at the United States 

Courthouse located at 7940 Preston Road, Plano, TX 75024.

To be 

determined 

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