UNITED STATES DISTRICT COURT

FOR THE Northern District of Illinois − CM/ECF LIVE, Ver 6.3.3

Eastern Division

Inventus Power, Inc., et al.

Plaintiff,

v. Case No.: 1:20−cv−03375

Honorable Robert M. Dow Jr.

Shenzhen Ace Battery Co., Ltd., et al.

Defendant.

NOTIFICATION OF DOCKET ENTRY

This docket entry was made by the Clerk on Thursday, February 17, 2022:

 MINUTE entry before the Honorable Jeffrey Cummings: Telephonic status

hearing held regarding the jurisdictional discovery issues set forth in the parties' joint

status report [211] and defendant's motion to compel [209]. For the reasons discussed on

the record, the Court orders as follows: (1) By 2/21/22, Ace shall (a) update the previously

provided list of products to include the products listed on its website that it may not

produce; and (b) re−organize the product list by sorting the products into the product

categories reflected on Ace's website; (2) By 2/25/22, Inventus shall review the product

list and make an updated request for technical documents (technical product

specifications, schematics, and source code) for the appropriate subset of products at

issue. The parties shall then promptly meet and confer to discuss the logistics of producing

the source code on a device in the United States that both sides could examine; (3) As

discussed on the record, the parties shall continue to meet and confer regarding any

replacement search terms related to custodial documents for Ace employees and CEO and

those search terms shall be finalized amongst the parties by 2/24/22; (4) By 2/24/22, Ace

shall provide Inventus with five proposed search terms related to custodial documents for

Ace personnel responsible for customer communications; (5) By 2/28/22, Ace shall

provide Inventus with the hit counts for the eight previously agreed upon terms, plus

"lawsuit," for customer communication documents. The parties shall also meet and confer

to agree upon a more narrowed term to replace "secret;" (6) Counsel for Ace will confer

with Ace representatives to determine whether any additional responsive documents exist

related to Ace's participation in trade shows within the United States, including

presentation and marketing materials prepared by Ace to use at the trade shows. If no

additional trade show−related documents are discovered, Ace shall provide a sworn

certification that all responsive documents have been produced (See CSMC 2007−C4

Egizii Portfolio LLC v. Springfield Prairie Properties, LLC, No. 15−3195, 2018 WL

7859720, at *3 (C.D. Ill. Aug. 31, 2018) (requiring counsel to certify parties' compliance

with discovery order); Learning Resources, Inc. v. Playgo Toys Enterprises Ltd., No.

19−CV−00660, 2020 WL 2061536, at *3 (N.D. Ill. Apr. 29, 2020) (same, citing cases));

and (7) Ace shall work diligently to provide Inventus with any missing metadata discussed

on the record and is reminded that future electronic productions shall include metadata

where required by the parties' ESI protocol [93]. Defendant's motion to compel [209] is

denied without prejudice with leave to renew, if appropriate, following the parties' proper

Case: 1:20-cv-03375 Document #: 212 Filed: 02/17/22 Page 1 of 2 PageID #:5754
meet and confer efforts in accordance with Local Rule 37.2. By 3/11/22, the parties shall

file a joint status report confirming compliance with the above directives and setting forth

what jurisdictional discovery disputes, if any, remain. If necessary, the Court will set a

telephonic status hearing to resolve any remaining issues. Mailed notice (cc, )

ATTENTION: This notice is being sent pursuant to Rule 77(d) of the Federal Rules of

Civil Procedure or Rule 49(c) of the Federal Rules of Criminal Procedure. It was

generated by CM/ECF, the automated docketing system used to maintain the civil and

criminal dockets of this District. If a minute order or other document is enclosed, please

refer to it for additional information.

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Case: 1:20-cv-03375 Document #: 212 Filed: 02/17/22 Page 2 of 2 PageID #:5755