N.D. Ohio L. P. R. 2.1

(a) Planning Meeting. The parties shall confer no less than ten days before the Case

Management Conference to discuss and address in the Joint Planning Report the topics set forth in

Fed. R. Civ. P. 26(f) and LR 16.3(b)(3), as well as the following topics:

(1) Any modification to the deadlines set by these Local Patent Rules;

(2) Any anticipated motions that might affect the deadlines set by these Local Patent

Rules, including motions for preliminary injunction and to add or substitute parties,

and a proposed briefing schedule;

(3) Any issues that might be the proper subject of an early motion for summary

judgment or partial summary judgment;

(4) The field of the claimed invention(s), claims asserted, number of claim terms to be

construed, and the allegedly infringing activity or product;

(5) Any modification to the limits on interrogatories and/or depositions set forth in the

Federal Rules of Civil Procedure;

(6) Any deviations from the form Patent Protective Order set forth in Appendix A to

these Local Patent Rules;

(7) The format of the Claim Construction Hearing, including whether the Court will hear

live testimony, the order of presentation, and the estimated length of the hearing;

(8) Whether the parties will agree to the electronic exchange of pleadings, notices,

discovery, and other mandated disclosures not otherwise served electronically via the

Court’s electronic filing system;

(9) The susceptibility of this action to resolution by Alternative Dispute Resolution; and

(10) The appointment of a Special Master.

Local Patent Rules - Northern District of Ohio

(b) Joint Planning Report. No later than five days before the Case Management

Conference, the plaintiff, on behalf of all parties, must file with the Court a Joint Planning Report in

the form provided in Appendix B to these Local Patent Rules or in any other form ordered by the

Court. Statements made by the parties in the Joint Planning Report will be used for case

management purposes only and shall not be used to limit or otherwise restrict a party’s ability to

seek relief from the Court at a later date with respect to issues addressed or not addressed in the

Joint Planning Report.

(c) Case Management Conference.

(1) Agenda. The general agenda for the Case Management Conference is set by

LR 16.3(b). The parties also should be prepared to discuss with the Court all of the

matters addressed in the parties’ Joint Planning Report, including the status of

settlement discussions and the utilization of Alternative Dispute Resolution methods

under L.R. 16.4-16.10.

(2) Technology At Issue. Each party should be prepared to discuss the

technology at issue during the Case Management Conference. This includes the

general technology at issue, the patent(s) in suit, and each accused apparatus,

product, device, process, method, act, or other instrumentality of each opposing party

that is accused of infringing (each, an “Accused Instrumentality”). In addition to the

foregoing, each party opposing a claim of infringement is expected to bring a sample

or representation (e.g., photographs, video, specifications, etc.) of each Accused

Instrumentality.

(3) Master. The parties should be prepared to discuss with the Court whether

they would consent to the appointment of a master (a Magistrate Judge or otherwise)

who would provide assistance to the parties and the Court. Cases for which a master

is appointed shall be considered for expedited treatment.

(4) Attendance by Parties. All parties, lead counsel, and a representative with

full authority for settlement purposes shall attend the Case Management Conference.

“Parties” means either the named individuals or, in the case of a corporation or

similar legal entity, a person familiar with the facts of the case, including the

patented technology or allegedly infringing technology.