Exhibit A

Case 4:23-cv-01147-ALM Document 21-1 Filed 05/22/24 Page 1 of 8 PageID #: 395
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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

R2 Solutions LLC,

 Plaintiff,

v.

Databricks, Inc., 

 Defendant.

Civil Action No. 4:23-cv-01147-ALM

Jury Trial Demanded

Case 4:23-cv-01147-ALM Document 21-1 Filed 05/22/24 Page 2 of 8 PageID #: 396
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SCHEDULING ORDER

It is hereby ORDERED, after consultation with the parties, that the following scheduling 

will apply in this case:

Model Order Date Proposed Date Event

June 11, 2024 at 

10:00 a.m. 

Case Management Conference at Paul Brown 

United States Courthouse, 101 E. Pecan Street, 

Sherman, Texas. Counsel for each party, with 

authority to bind their respective clients, and all 

unrepresented parties, shall be present. 

Continuance of the management conference will 

not be allowed absent a showing of good cause. 

June 21, 2024

[10 days after Mgmt. 

Conf.] 

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

Infringement Contentions (and P.R. 3-2 document 

production) to be served.

July 16, 2024

[5 weeks after 

Mgmt. Conf.] 

Join Additional Parties.

TBD at Mgmt. 

Conf. 

Mediation. The Court will discuss appointing a 

mediator at the Scheduling Conference. 

July 16, 2024

[5 weeks after 

Mgmt. Conf.]

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

document production) to be served. To extent not 

already required to be disclosed, exchange 

Mandatory Disclosures on all issues, including 

damages.

July 16, 2024

[5 weeks after 

Mgmt. Conf.]

Parties to exchange Initial Disclosures under 

FRCP 26(a).

July 26, 2024

[No later than 45 

days after Mgmt. 

Conf.] 

Parties to exchange proposed terms for 

construction and identify any claim element 

governed by 35 U.S.C. § 112, ¶ 6 (P.R. 4-1). 

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Model Order Date Proposed Date Event

July 30, 2024

[7 weeks after 

Mgmt. Conf.] 

Privilege Logs to be exchanged by parties (or a 

letter to the Court stating that there are no 

disputes as to claims of privileged documents).

August 15, 2024

[No later than 65 

days after Mgmt. 

Conf.] 

Parties to exchange preliminary proposed claim 

construction and extrinsic evidence supporting 

same (P.R. 4-2). 

September 10, 2024

[13 weeks after 

Mgmt. Conf.] 

Parties’ Final Amended Pleadings (a motion for 

leave is required).

September 13, 2024

[No later than 95 

days after Mgmt. 

Conf.] 

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.

October 1, 2024

[16 weeks after 

Mgmt. Conf.] 

Respond to Amended Pleadings.

October 14, 2024

[No later than 125 

days after Mgmt. 

Conf.] 

Completion date for discovery on claim 

construction (P.R. 4-4). 

October 29, 2024

[No later than 140 

days after Mgmt. 

Conf.] 

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

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Model Order Date Proposed Date Event

November 4, 2024

[4 weeks before 

claim construction 

hearing] 

Submit technology synopsis/tutorial (both hard 

and electronic copies).

November 12, 2024

[No later than 2 

weeks after claim 

construction brief]

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

November 19, 2024

[No later than 7 days 

after response]

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

November 22, 2024

[At least 10 days 

before claim 

construction 

hearing] 

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.

December 9, 2024 Deadline for substantial completion of document 

production. 

December 2, 2024 

at 1:30 p.m. 

December 9, 2024 at 

1:30 p.m. 

Proposed Claim Construction Hearing at the 

Paul Brown United States Courthouse, 101 E. 

Pecan Street, Sherman, Texas 75090. 

January 6, 2025 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.

January 20, 2025 Fact Discovery Deadline and Deadline to File 

Motions to Compel related to Fact Discovery. All 

discovery must be served in time to be completed 

by this date. 

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Model Order Date Proposed Date Event

February 3, 2025

[9 weeks after claim 

construction 

hearing]

January 27, 2025 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).

February 3, 2025

[9 weeks after claim 

construction 

hearing] 

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

Willfulness Opinions).

February 17, 2025

[11 weeks after 

claim construction 

hearing] 

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). 

Note: Objections to any expert, including 

Daubert motions, shall be filed within 3 weeks 

after the expert’s Report has been disclosed. 

Such objections and motions are limited to ten 

pages each.

March 3, 2025

[13 weeks after 

claim construction 

hearing]

Expert Discovery Deadline.

March 3, 2025

[13 weeks after 

claim construction 

hearing (no later 

than 110 days prior 

to the filing of the 

Joint Final PTO)]

March 13, 2025 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).

June 16, 2025

[5 weeks before 

final pretrial 

conference]

Notice of intent to offer certified records.

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Model Order Date Proposed Date Event

June 16, 2025

[5 weeks before 

final pretrial 

conference]

Counsel and unrepresented parties are each 

responsible for contacting opposing counsel and 

unrepresented parties to determine how they will 

prepare the Joint Final Pretrial Order

(See www.txed.uscourts.gov) and Proposed Jury 

Instructions and Verdict Form (or Proposed 

Findings of Fact and Conclusions of Law in 

nonjury cases). 

June 23, 2025

[4 weeks before 

final pretrial 

conference]

Serve Pretrial Disclosures (Witness List, 

Deposition Designations, Exhibit Lists, and 

Video Deposition Designation) by the Party with 

the Burden of Proof. Each party who proposes to 

offer a deposition 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 request 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 an initial Video Deposition 

Designation is responsible for preparation of the 

final edited video in accordance with all parties’ 

designations, the applicable Federal Rules of 

Civil Procedure, and the Court’s rulings on 

objections. 

July 7, 2025 Serve Objections to Pretrial Disclosures; and 

Serve Rebuttal Pretrial Disclosures.

July 14, 2023 Serve Objections to Rebuttal Pretrial Disclosures.

June 20, 2025

[30 days before final 

pretrial conference]

Motions in limine due.

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. 

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Model Order Date Proposed Date Event

July 7, 2025

[2 weeks before 

final pretrial conf]

Responses to motions in limine due.

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 the final pretrial 

conference.

File Proposed Jury Instructions/Form of Verdict 

(or Proposed Findings of Fact and Conclusions of 

Law).

If Parties will be requesting daily copy of the 

transcript during trial, they must notify the 

Court’s court reporter, Chris Bickham, 

Chris_Bickham@txed.uscourts.gov, by this date. 

July 21, 2025 at 

1:30 p.m. 

Final Pretrial Conference at the Paul Brown 

United States Courthouse, 101 E. Pecan Street, 

Sherman, Texas 75090. 

TBD – 10:00 a.m. Jury Selection and Trial at the at the Paul 

Brown United States Courthouse, 101 E. Pecan 

Street, Sherman, Texas 75090. 

Case 4:23-cv-01147-ALM Document 21-1 Filed 05/22/24 Page 8 of 8 PageID #: 402