2at the end of November and trial is nearly a year away), no Court-imposed deadlines need to bealtered, and any alleged prejudice to Qualcomm is
STATEMENT OF FACTSA.
Case Management Agreements and Deadlines.
In accordance with the Local Rule 3.05(c) for Middle District of Florida, the partiessubmitted a Joint Case Management Report to the Court on December 30, 2011. Dkt. 69. In theJoint Case Management Report the parties agreed that:If the party asserting patent infringement contends that an identical AccusedInstrumentality is contained in multiple products, then that AccusedInstrumentality is required to be charted only once with an accompanyingidentification of the products that allegedly contain that Accused Instrumentality;
. at 15. The Court’s Case Management and Scheduling Order, issued on February 13, 2012,and set March 2, 2012 as the deadline for ParkerVision’s ICs. Dkt. 84.
ParkerVision Diligently Sought Discovery Related to its InfringementContentions.
In early January 2012, shortly after the discovery period opened, ParkerVision servedQualcomm with its First Set of Interrogatories.
Ex. B. Interrogatory No. 2 asked:Separately for each product disclosed in response to Interrogatory 1, identifywhich products contain a receiver (or receiver function) that performs directconversion, i.e., conversion of a signal on a carrier frequency to baseband withoutconversion to an intermediate frequency, and for each identified product,describe, using the most accurate terms possible, the mechanism or circuitry thatperforms the direct conversion
. at 9. ParkerVision’s Interrogatory No. 2 was designed to determine the potential universe of Qualcomm products that contained the accused receiver functionality. Interrogatory No. 4asked:
Pursuant to Local Rule 3.05(c) for the Middle District of Florida, ParkerVision could not servediscovery on Qualcomm until after the parties had completed their case management meeting,which took place in late December 2011.
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