Synopsys, Inc. et al v. Bell Semiconductor, LLC
| Synopsys, Inc. and Cadence Design Systems, Inc. |
| Bell Semiconductor, LLC |
| United States International Trade Commission |
| 1:2022cv01512 |
| November 18, 2022 |
| US District Court for the District of Delaware |
| Colm F Connolly |
| Patent |
| 35 U.S.C. § 1 Patent Infringement |
| Plaintiff |
Docket Report
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This docket was last retrieved on December 6, 2023. A more recent docket listing may be available from PACER.
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Filing 35
NOTICE OF SERVICE of 1) Synopsys, Inc.'s Objections and Responses to Defendant's First Set of Request for Production (Nos. 1-3); and 2) Plaintiff Synopsys, Inc.'s Objections and Responses to Defendant Bell Semiconductor LLC's First Set of Interrogatories filed by Synopsys, Inc..(Vrana, Robert)
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Filing 34
NOTICE OF SERVICE of 1) Cadence Design Systems, Inc.'s Objections and Responses to Defendant's First Set of Interrogatories (Nos. 1-3) and 2) Cadence Design Systems, Inc.'s Objections and Responses to Defendant's First Set of Requests for Production (Nos. 1-3) filed by Cadence Design Systems, Inc..(Kraman, Pilar)
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Filing 33
OPENING BRIEF in Support re #32 MOTION to Dismiss for Lack of Jurisdiction Over the Subject Matter filed by Bell Semiconductor, LLC.Answering Brief/Response due date per Local Rules is 1/25/2023. (Attachments: #1 Exhibit A, #2 Exhibit B)(Farnan, Brian)
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Filing 32
MOTION to Dismiss for Lack of Jurisdiction Over the Subject Matter - filed by Bell Semiconductor, LLC. (Attachments: #1 Text of Proposed Order)(Farnan, Brian)
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Filing 31
STANDING ORDER REGARDING BRIEFING IN ALL CASES. Associated Cases: 1:22-cv-01569-CFC, 1:22-cv-01512-CFC(kmd)
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Filing 30
ORDER granting #24 MOTION to Intervene in Support of Defendant, for the Limited Purpose of Opposing in Part the Motion for Preliminary Injunction UNOPPOSED. Signed by Judge Colm F. Connolly on 12/20/2022. (nmf)
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SO ORDERED D.I. #26 Stipulation Regarding Response to the Complaint as well as Expedited Discovery and Briefing Schedule on the Motion for Preliminary Injunction, filed by Cadence Design Systems, Inc., Synopsys, Inc. Ordered by Judge Christopher J. Burke on 12/20/2022. (dlb)
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Filing 29
NOTICE OF SERVICE of (i) Defendant's Requests for Production for Cadence Design Systems, Inc. Relating to Plaintiffs' Motion for Preliminary Injunction; (ii) Defendant's Interrogatories for Cadence Design Systems, Inc. Relating to Plaintiffs' Motion for Preliminary Injunction; (iii) Defendant's Requests for Production from Synopsys, Inc. Relating to Plaintiffs' Motion for Preliminary Injunction; and (iv) Defendant's Interrogatories from Synopsys, Inc. Relating to Plaintiffs' Motion for Preliminary Injunction filed by Bell Semiconductor, LLC.(Farnan, Brian)
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Filing 28
NOTICE to Take Deposition of Henry Sheng on 2/2/2023 filed by Bell Semiconductor, LLC.(Farnan, Brian)
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Filing 27
NOTICE to Take Deposition of Kam Kittrell on 1/31/2023 filed by Bell Semiconductor, LLC.(Farnan, Brian)
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Filing 26
STIPULATION and [Proposed] Order Regarding Response to the Complaint as well as Expedited Discovery and Briefing Schedule on the Motion for Preliminary Injunction re 22 Oral Order,,,,,,,,,,,,,,,,, by Cadence Design Systems, Inc., Synopsys, Inc.. (Kraman, Pilar)
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Filing 25
NOTICE of Appearance by Sidney A Rosenzweig on behalf of United States International Trade Commission (Rosenzweig, Sidney)
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Filing 24
MOTION to Intervene in Support of Defendant, for the Limited Purpose of Opposing in Part the Motion for Preliminary Injunction UNOPPOSED - filed by United States International Trade Commission. (Hatcher, Laura)
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Filing 23
Disclosure Statement pursuant to Rule 7.1: identifying Corporate Parent Hilco Patent Acquisition 56, LLC, Corporate Parent Hilco IP Merchant Capital, LLC, Corporate Parent Hilco, Inc. for Bell Semiconductor, LLC filed by Bell Semiconductor, LLC. (Farnan, Brian)
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Filing 22
ORAL ORDER: The Court, having reviewed Defendant's Emergency Motion for Extension of Time and to Order Briefing Schedule with Limited Discovery (the "Motion"), (D.I. 17), hereby ORDERS that the Motion is GRANTED-IN-PART and DENIED-IN-PART as follows: (1) With respect to Defendant's request that it be granted an extension until January 11, 2023 to answer or otherwise respond to Plaintiffs' Complaint, the Motion is GRANTED. Defendant has demonstrated good cause for its request in this regard -- in that the Complaint at issue is lengthy, it involves a large number of issues, and it requests significant relief. (D.I. 1) In light of that, and accounting for the upcoming holiday season, Defendant's request is well taken.; (2) With respect to whether the case schedule relating to Plaintiffs' Motion for Preliminary Injunction (the "PI Motion") should allow for some limited discovery by Defendant, the Motion is GRANTED-IN-PART. On the one hand, the Court thinks it can see how the PI Motion, even though it will probably largely turn on legal arguments, might also present some issues of fact that warrant tailored discovery (i.e., regarding Plaintiffs' defense/indemnity obligations, or whether this declaratory judgment action will actually resolve cases involving allegations of many different parties' alleged infringement of six patents). (D.I. 21 at 4; see also D.I. 9 at 14-16, 19) But on the other hand, Defendant did not provide a lot of detail about exactly (a) what particular discovery is required regarding (b) what specific issues that are relevant to the PI Motion. Defendant's failure to more specifically articulate the discovery it needs suggests that perhaps not very much process is actually required here. (See D.I. 18 at 6-7); see also, e.g., Park Lawn Corp. v. PlotBox, Inc., Civ. No. 20-1484-RGA, 2021 WL 3490020, at *2 (D. Del. Aug. 9, 2021) (denying a motion for expedited discovery, which was requested in order to help prepare for the filling of a preliminary injunction motion, where the plaintiff did not "file[] or serve[] its proposed discovery requests or identif[y] the three individuals it wishes to depose, which leaves the Court unable to evaluate the scope and, therefore, the reasonableness of the burden placed on [defendant]"). Under these circumstances, the Court ORDERS that some document discovery can occur, but will limit it such that Defendant may serve 3 interrogatories and 3 requests for production on each Plaintiff.; (3) As for the number of depositions that should be permitted, the Court ADOPTS Plaintiffs' proposal that Defendant may depose the two declarants (one per Plaintiff) to the PI Motion. While Defendant further sought to depose one corporate representative for each Plaintiff, it failed to sufficiently articulate in its briefing the need for that additional deposition (such as by explaining why it thinks that Plaintiffs' declarants will not likely be able to provide sufficient answers to Defendant's questions relevant to the PI Motion). See Park Lawn Corp., 2021 WL 3490020, at *2.; (4) With respect to the appropriate deadlines for discovery events and for completion of the briefing on the PI Motion, the Court ADOPTS Defendant's proposed dates. This should allow for sufficient time for the parties to actually be able to complete the necessary work without the need for further extensions.; (5) With respect to the issues of whether the depositions may be conducted via video platform and whether they should be limited to three hours on the record, the Court ORDERS that the parties shall further meet and confer, in order to try to reach agreement. The Court does not have enough information about these issues to provide a ruling, and the parties really should be able to come to a joint resolution as to these matters.; (6) With regard to Defendant's request to file a sur-reply with respect to the PI Motion, the Court DENIES the request at this time. Defendant did not provide a sufficient explanation as to why there would be a need to deviate from the typical briefing regime here.; and (7) By no later than December 16, 2022, the parties shall submit a revised proposed scheduling order regarding the PI Motion, which incorporates the Court's decisions herein. Ordered by Judge Christopher J. Burke on 12/14/2022. (dlb)
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Filing 21
REPLY BRIEF re #17 Emergency MOTION for Extension of Time and to Order Briefing Schedule With Limited Discovery filed by Bell Semiconductor, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Certificate of Compliance)(Farnan, Michael)
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Filing 20
ORAL ORDER: The Court, having reviewed Defendant"s Emergency Motion for Extension of Time and to Order Briefing Schedule with Limited Discovery, (D.I. 17), hereby ORDERS that by no later than close of business on December 13, 2022, Defendant shall file a reply brief of no more than 4 double-spaced pages. Ordered by Judge Christopher J. Burke on 12/12/2022. (dlb) Modified on 12/12/2022 (dlb).
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Filing 19
NOTICE of Intent to file a Motion to Intervene by United States International Trade Commission re #8 MOTION for Preliminary Injunction (Hatcher, Laura)
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Filing 18
RESPONSE to Motion re #17 Emergency MOTION for Extension of Time and to Order Briefing Schedule With Limited Discovery filed by Cadence Design Systems, Inc., Synopsys, Inc.. (Attachments: #1 Exhibit 1-4)(Kraman, Pilar)
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ORAL ORDER REFERRING MOTION to Magistrate Judge Burke: #17 Emergency MOTION for Extension of Time and to Order Briefing Schedule With Limited Discovery filed by Bell Semiconductor, LLC. Ordered by Judge Colm F. Connolly on 12/12/2022. Motion referred to Magistrate Judge Christopher J. Burke.(nmf)
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Pro Hac Vice Attorney Ashley N. Moore and Richard A. Kamprath for Bell Semiconductor, LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (mpb)
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Pro Hac Vice Attorney Kyle Ryman and David Sochia for Bell Semiconductor, LLC added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (mpb)
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Filing 17
Emergency MOTION for Extension of Time and to Order Briefing Schedule With Limited Discovery - filed by Bell Semiconductor, LLC. (Attachments: #1 Exhibit A - Proposed Order, #2 Exhibit B, #3 Certificate of Compliance, #4 Rule 7.1.1 Certification)(Farnan, Brian)
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Filing 16
MOTION for Pro Hac Vice Appearance of Attorney Richard A. Kamprath, Ashley N. Moore, David Sochia, and Kyle Ryman - filed by Bell Semiconductor, LLC. (Farnan, Brian)
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SO ORDERED, re #16 MOTION for Pro Hac Vice Appearance of Attorney Richard A. Kamprath, Ashley N. Moore, David Sochia, and Kyle Ryman, filed by Bell Semiconductor, LLC. Ordered by Judge Colm F. Connolly on 12/9/2022. (kmd)
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Pro Hac Vice Attorney Aliza George Carrano,Barrington E. Dyer, Krista S. Schwartz, and Shaimaa Hussein for Synopsys, Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (mkr)
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Pro Hac Vice Attorney Matthew M. Wolf, Jeffrey A. Miller, Joseph B. Palmieri, Kurt Riester, Jennifer A. Sklenar, and Lindsay Strong for Cadence Design Systems, Inc. added for electronic noticing. Pursuant to Local Rule 83.5 (d)., Delaware counsel shall be the registered users of CM/ECF and shall be required to file all papers. (mkr)
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Filing 15
MOTION for Pro Hac Vice Appearance of Attorney Krista S. Schwartz, Barrington Dyer, Shaimaa M. Hussein, and Aliza George Carrano - filed by Synopsys, Inc.. (Vrana, Robert)
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Filing 14
MOTION for Pro Hac Vice Appearance of Attorney Jeffrey A. Miller, Joseph Palmieri, Matthew M. Wolf, Jennifer Sklenar, Kurt Riester, and Lindsay Strong - filed by Cadence Design Systems, Inc.. (Stombaugh, Alexis)
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SO ORDERED, re #14 MOTION for Pro Hac Vice Appearance of Attorney Jeffrey A. Miller, Joseph Palmieri, Matthew M. Wolf, Jennifer Sklenar, Kurt Riester, and Lindsay Strong, filed by Cadence Design Systems, Inc. Ordered by Judge Colm F. Connolly on 11/29/2022. (kmd)
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SO ORDERED, re #15 MOTION for Pro Hac Vice Appearance of Attorney Krista S. Schwartz, Barrington Dyer, Shaimaa M. Hussein, and Aliza George Carrano, filed by Synopsys, Inc. Ordered by Judge Colm F. Connolly on 11/29/2022. (kmd)
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Filing 13
Letter to The Honorable Colm F. Connolly from Pilar G. Kraman regarding Request for Teleconference on the Motion for Preliminary Injunction - re #8 MOTION for Preliminary Injunction . (Kraman, Pilar)
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Filing 12
DECLARATION re #8 MOTION for Preliminary Injunction [Declaration of Kam Kittrell] by Cadence Design Systems, Inc., Synopsys, Inc.. (Kraman, Pilar)
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Filing 11
DECLARATION re #8 MOTION for Preliminary Injunction [Declaration of Henry Sheng] by Cadence Design Systems, Inc., Synopsys, Inc.. (Kraman, Pilar)
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Filing 10
DECLARATION re #8 MOTION for Preliminary Injunction [Declaration of Pilar G. Kraman] by Cadence Design Systems, Inc., Synopsys, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9)(Kraman, Pilar)
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Filing 9
OPENING BRIEF in Support re #8 MOTION for Preliminary Injunction filed by Cadence Design Systems, Inc., Synopsys, Inc..Answering Brief/Response due date per Local Rules is 12/12/2022. (Attachments: #1 Certification)(Kraman, Pilar)
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Filing 8
MOTION for Preliminary Injunction - filed by Cadence Design Systems, Inc., Synopsys, Inc.. (Attachments: #1 Text of Proposed Order)(Kraman, Pilar)
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Case Assigned to Judge Colm F. Connolly. Please include the initials of the Judge (CFC) after the case number on all documents filed. (rjb)
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Filing 7
SUMMONS Returned Executed by Cadence Design Systems, Inc..Bell Semiconductor, LLC served on 11/21/2022, answer due 12/12/2022. (Stombaugh, Alexis)
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Filing 6
Summons Issued as to Bell Semiconductor, LLC on 11/18/2022. (mpb)
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Filing 5
Disclosure Statement pursuant to Rule 7.1: No Parents or Affiliates Listed filed by Synopsys, Inc.. (mpb)
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Filing 4
Disclosure Statement pursuant to Rule 7.1: Other Affiliate BlackRock Inc. for Cadence Design Systems, Inc. filed by Cadence Design Systems, Inc. (mpb)
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Filing 3
Report to the Commissioner of Patents and Trademarks for Patent/Trademark Number(s) SEE ATTACHED. (mpb)
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Filing 2
Notice, Consent and Referral forms re: U.S. Magistrate Judge jurisdiction. (mpb)
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Filing 1
COMPLAINT filed with Jury Demand against Bell Semiconductor, LLC ( Filing fee $ 402, receipt number ADEDC-4008931.) - filed by Synopsys, Inc., Cadence Design Systems, Inc.. (Attachments: #1 Exhibit A-N, #2 Civil Cover Sheet)(mpb)
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