IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

BELL NORTHERN RESEARCH, LLC,

Plaintiff,

v.

T-MOBILE USA, INC. and T-MOBILE 

US, INC.,

Defendants.

Civil Action No. 4:23-cv-910-ALM

JURY TRIAL DEMANDED 

PROPOSED SCHEDULING ORDER

Court’s 

Proposed 

Deadlines

Agreed Proposed 

Deadlines

Description

(10 days after

Mgmt. Conf. 

(“CMC”))

Thursday, 

March 28, 2024

Thursday, 

April 18, 2024 P.R. 3-1 Disclosure of Asserted Claims and 

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

production) to be served.

(5 weeks after 

CMC)

Monday, 

April 22, 2024

Monday,

 April 22, 2024

Join Additional Parties 

(5 weeks after 

CMC)

Monday,

April 22, 2024

Monday,

May 13, 2024

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.

(No later than 

45 days after 

CMC)

Thursday,

May 2, 2024

Monday, 

May 20, 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).

Case 4:23-cv-00910-ALM Document 17-1 Filed 02/26/24 Page 1 of 6 PageID #: 307
Court’s 

Proposed 

Deadlines

Agreed Proposed 

Deadlines

Description

(7 weeks after 

CMC)

Monday, 

May 6, 2024

Monday,

May 6, 2024 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).

(No later than 

65 days after 

CMC)

Wednesday, 

May 22, 2024

Monday, 

June 3, 2024 Parties to exchange preliminary proposed claim 

construction and extrinsic evidence supporting same. 

(P.R. 4-2).

(13 weeks after 

CMC)

Monday, 

June 17, 2014

Monday,

June 17, 2024 Parties’ Final Amended Pleadings. (A motion for 

leave is required.)

(No later than 

95 days after 

CMC)

Friday,

June 21, 2024

Friday,

June 21, 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.

(16 weeks after 

CMC)

Monday, 

July 8, 2024

Monday,

July 8, 2024

Respond to Amended Pleadings.

(No later than 

125 days after 

CMC)

Sunday, 

July 21, 2024

Monday,

July 22, 2024

Completion date for discovery on claim construction. 

(P.R. 4-4).

(No later than 

140 days after 

CMC)

Monday, 

August 5, 2024

Monday, 

August 5, 2024 Opening claim construction brief. 

(P.R. 4-5(a)).

Case 4:23-cv-00910-ALM Document 17-1 Filed 02/26/24 Page 2 of 6 PageID #: 308
Court’s 

Proposed 

Deadlines

Agreed Proposed 

Deadlines

Description

(No later than 2 

weeks after 

claim 

construction 

(“CC”) brief)

Monday, 

August 19, 2024

Monday, 

August 19, 2024

Responsive claim construction brief. 

(P.R. 4-5(b)).

(No later than 7 

days after 

responsive CC 

brief)

Monday,

August 26, 2024

Monday, 

August 26, 2024

Reply claim construction brief. 

(P.R. 4-5(c)).

(4 weeks before 

CC hearing)

Monday, 

August 12, 2024

Monday, 

August 12, 2024

Submit technology synopsis/tutorial (both hard copy 

and disk).

(At least 10 days 

before CC 

hearing)

Friday,

August 30, 2024

Friday, 

August 30, 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.

Claim 

Construction 

Hearing

Monday,

September 9, 

2024 

Monday, 

September 9, 2024 Claim Construction hearing Monday, September 9, 

2024, at 10:00 a.m. at the United States Courthouse, 

7940 Preston Road, Plano, TX 75024.

Case 4:23-cv-00910-ALM Document 17-1 Filed 02/26/24 Page 3 of 6 PageID #: 309
Court’s 

Proposed 

Deadlines

Agreed Proposed 

Deadlines

Description

(5 weeks after 

CC hearing)

Monday,

October 14, 

2024

Tuesday, 

October 15, 2024

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.

Monday, 

October 28, 2024

Fact Discovery Deadline. All fact discovery must 

be served in time to be completed by this date. 

(9 weeks after 

CC hearing)

Monday,

November 11, 

2024

Monday, November 

4, 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).

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

Opinions).

(11 weeks after 

CC hearing)

Monday,

November 25, 

2024

Monday, 

November 25, 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).

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.

Monday, 

December 9, 2024

Expert Discovery Deadline. All expert discovery 

must be served in time to be completed by this 

date.

(13 weeks after 

CC hearing and 

no later than 

110 days prior 

to the filing of 

the Joint Final 

PTO)

Monday,

Monday, 

December 9, 2024

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).

Case 4:23-cv-00910-ALM Document 17-1 Filed 02/26/24 Page 4 of 6 PageID #: 310
Court’s 

Proposed 

Deadlines

Agreed Proposed 

Deadlines

Description

December 9, 

2024

(5 weeks before 

final pretrial 

conference 

“PTC”)

Friday,

March 21, 2025

Friday,

March 21, 2025

Notice of intent to offer certified records.

(5 weeks before 

PTC)

Friday,

March 21, 2025

 Friday, 

 March 21, 2025

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).

(30 days before 

PTC)

Wednesday, 

March 26, 2025

Wednesday, 

March 26, 2025

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.

(4 weeks before 

PTC)

Friday,

March 28, 2025

Friday, 

March 28, 2025

Deposition Designation due. 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 

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, the applicable Federal Rules of Civil 

Procedure, and the Court’s rulings on objections.

Case 4:23-cv-00910-ALM Document 17-1 Filed 02/26/24 Page 5 of 6 PageID #: 311
Court’s 

Proposed 

Deadlines

Agreed Proposed 

Deadlines

Description

(2 weeks before 

PTC)

Friday,

April 11, 2025

Response 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.

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.

Friday,

April 25, 2025

Friday,

April 25, 2025

Final Pretrial Conference at 9:00 a.m. at the Paul 

Brown United States Courthouse, 101 E. Pecan Street, 

Sherman, Texas 75090.

To be

determined

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

United States Courthouse, 101 E. Pecan Street, 

Sherman, Texas 75090.

Case 4:23-cv-00910-ALM Document 17-1 Filed 02/26/24 Page 6 of 6 PageID #: 312