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Hitoneout....it looks to me that HDC is presenting

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LocWolf   Saturday, 08/01/20 08:41:05 AM
Re: Hitoneout post# 15026
Post # of 15149 
Hitoneout....it looks to me that HDC is presenting "Exceptional Circumstances Warrant".
I believe our case hinges strongly on this area to allow the discovery HDC is after.

The Local Rules state:

Except with regard to discovery necessary for claim construction, all other
discovery is stayed until after the Markman Hearing. Notwithstanding this
general stay of discovery, the Court will permit limited discovery by
agreement of the parties, or upon request, where exceptional circumstances warrant.
________________________________

Here is one big reason why we need this granted...... 151. As Defendant Intel is in the sole
and complete possession of its relevant source code, algorithms, etc., with such information not
publicly available, Plaintiff HDC respectfully requests early, limited discovery to confirm which
Intel products and uses by Intel infringe

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