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Court Rules
Judge

Judge Jennifer Choe-Groves

Individual Rules, Standing Orders & Policies

Rules last changed:
District of New Jersey

Limits & Logistics

Document Limits

Brief
5,500 wds
In Limine Request
3 pgs
In Limine Reply
1 pgs
Brief
12,500 wds
Motion in Limine
3 pgs
Concise Statement
1,750 wds

Courtesy Copies

Compendium

  • 2 copies

Courtesy copies

  • 2 copies
  • Upon request

Adjournments

  • it is hereby ORDERED that all requests to amend an existing Scheduling Order shall comply with the following procedures and requirements: 1. Any Party seeking an extension of a deadline should attempt to obtain consent to the requested extension from all other Parties to the case prior to filing a motion with the Court; 2. All motions requesting an extension should indicate the number of similar requests made by the moving Party and the reasons for the requested extension; 3. Extension requests should be limited to short periods to address unexpected conflicts; 4. The Party requesting the extension is responsible for ensuring that the requested deadlines do not fall on a weekend, holiday, or other date on which the Court will not be open for normal business; and
  • Extension of the Joint Claim Construction Brief deadline presumptively results in loss of the claim construction hearing date.

Request must include

Reason for RequestNumber of Previous Requests
  • Ideally, stipulations and requests for an extension of time should be filed with the Court at least three days in advance of the deadline the request concerns.
Reason for Request

Communication

Email

Chambers

steve_taronji@cit.uscourts.gov
Filters:

Page & Word Limits11 rules

Page LimitsMandatoryCivil cases

Opening briefs limited to 5,500 words; answering briefs limited to 8,250 words; reply briefs limited to 5,500 words; sur-reply briefs limited to 2,750 words; all briefs must use 14-point Times New Roman or similar typeface.

Opening brief
Up to 5,500 words
Answering brief
Up to 8,250 words
Reply brief
Up to 5,500 words
sur-reply brief
Up to 2,750 words
Format
14-point Times New Roman

Court's wording

its (their) opening brief, not to exceed 5,500 words, on [DATE]. The Defendant(s) shall serve, but not file, its (their) answering brief, not to exceed 8,250 words, on [DATE]. The Plaintiff(s) shall serve, but not file, its (their) reply brief, not to exceed 5,500 words, on [DATE]. The Defendant(s) shall serve, but not file, its (their) sur-reply brief, not to exceed 2,750 words, on [DATE]. The text for each brief shall be 14-point and in Times New Roman or a similar typeface.

NJ Scheduling Order ANDA patent cases · p. 13
|SectionClaim Construction Briefing
Page LimitsMandatoryCivil cases

each in limine request may be supported by a maximum of three pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one additional page in reply in support of its request.

In limine support
Up to 3 pages
In limine opposition
Up to 3 pages
Page LimitsMandatoryCivil cases

Opening brief capped at 5,500 words; answering brief at 8,250 words; reply brief at 5,500 words; sur-reply brief at 2,750 words.

Opening brief
Up to 5,500 words
Brief
Up to 8,250 words
Reply
Up to 5,500 words
sur-reply
Up to 2,750 words

Court's wording

The Plaintiff(s) shall serve, but not file, its opening brief, not to exceed 5,500 words, on [DATE]. The Defendant(s) shall serve, but not file, its answering brief, not to exceed 8,250 words, on [DATE]. The Plaintiff(s) shall serve, but not file, its reply brief, not to exceed 5,500 words, on [DATE]. The Defendant(s) shall serve, but not file, its sur-reply brief, not to exceed 2,750 words, on [DATE].

NJ Scheduling Order non-ANDA patent cases · p. 13
|SectionClaim Construction Briefing
Page LimitsMandatoryCivil cases

Testimony at claim construction hearing is prohibited unless prior approval is obtained by joint letter by the answering brief deadline; argument limited to three hours.

Court's wording

Absent prior approval of the Court (which, if it is sought, must be done by joint letter submission no later than the date on which answering claim construction briefs are due to be served), the parties shall not present testimony at the argument, and the argument shall not exceed a total of three hours in total.

NJ Scheduling Order non-ANDA patent cases · p. 16
|Section18. Hearing on Claim Construction.
Page LimitsMandatoryCivil cases

Each side is limited to 10,000 words for all opening briefs, 10,000 words for all answering briefs, and 5,000 words for all reply briefs for case dispositive motions.

Brief
Up to 10,000 words in total per side
Reply
Up to 5,000 words in total per side

Court's wording

Each Party is permitted to file as many case dispositive motions as desired, provided, however, that each SIDE will be limited to a combined total of 10,000 words for all opening briefs, a combined total of 10,000 words for all answering briefs, and a combined total of 5,000 words for all reply briefs, regardless of the number of case dispositive motions that are filed.

NJ Scheduling Order non-ANDA patent cases · p. 18
|SectionCase Dispositive and Daubert Motions
Page LimitsMandatoryCivil cases

If a Daubert motion is filed with a case dispositive motion, word limits increase to 12,500 words for opening briefs, 12,500 words for answering briefs, and 6,250 words for reply briefs per side.

Court's wording

In the event that a Party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert’s testimony, the total amount of words permitted for all case dispositive and Daubert motions shall be increased for each SIDE to 12,500 words for all opening briefs, a combined total of 12,500 words for all answering briefs, and a combined total of 6,250 words for all reply briefs.

NJ Scheduling Order non-ANDA patent cases · p. 18
|SectionCase Dispositive and Daubert Motions
Page LimitsMandatoryCivil cases

The concise statement in support of or in opposition to a motion for summary judgment shall be no longer than 1,750 words.

Concise statement
Up to 1,750 words
NJ Scheduling Order non-ANDA patent cases · p. 22
|Sectionh. Word Limits for Concise Statement
Page LimitsMandatoryCivil cases

Each Party shall be limited to three in limine requests, unless otherwise permitted by the Court.

Page LimitsMandatoryCivil cases

In limine requests and responses are limited to 3 pages of argument each; reply is limited to 1 page.

Opposition
Up to 3 pages

Court's wording

Each in limine request and any response shall contain the authorities relied upon; each in limine request may be supported by a maximum of three pages of argument and may be opposed by a maximum of three pages of argument, and the Party making the in limine request may add a maximum of one additional page in reply in support of its request.

Page LimitsImportantCivil cases

If more than one Party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three-page submission (and, for the moving parties, a single one-page reply).

Page LimitsMandatoryCivil cases

The Court will consider in limine requests on the papers (with moving parties a single one-page reply).

In limine reply
Up to 1 page

Document Format Requirements5 rules

FormattingMandatoryCivil cases

Joint Claim Construction Chart must be in Word format, 14-point Times New Roman, and emailed to chambers simultaneously with filing.

File type
Word
Font
Times New Roman
Font size
14 points
Applies to
  • Joint claim construction chart

Court's wording

The Joint Claim Construction Chart, in Word format, shall be e-mailed simultaneously with filing to steve_taronji@cit.uscourts.gov. The text for the Joint Claim Construction Chart shall be 14-point and in Times New Roman or a similar typeface.

FormattingMandatoryCivil cases

The parties shall submit simultaneously with filing each of the foregoing four documents in Word format to the Chambers of Judge Choe-Groves.

File type
Word

Formatting

  • Must be submitted to chambers simultaneously with filing
NJ Scheduling Order non-ANDA patent cases · p. 25
|SectionJury Instructions, Voir Dire, and Special Verdict Forms
FormattingImportantCivil cases

The text for the Joint Claim Construction Chart shall be 14-point and in Times New Roman or a similar typeface.

Font
Times New Roman
Font size
14 points

Formatting

  • Joint Claim Construction Chart must be in Word format (DOCX)
FormattingImportantCivil cases

The text for each brief shall be 14-point and in Times New Roman or a similar typeface.

Font
Times New Roman
Font size
14 points
FormattingImportantCivil cases

The text for each brief shall be 14-point and in Times New Roman or a similar typeface.

Font
Times New Roman
Font size
14 points
NJ Scheduling Order non-ANDA patent cases · p. 22
|Sectionh. Word Limits for Concise Statement

Document Filing Requirements34 rules

Filing RequirementsMandatoryCivil cases

Motions to amend scheduling orders must include a table of remaining events with current and requested deadlines.

Court's wording

5. All motions requesting an amendment to an existing scheduling order shall include a table reflecting all remaining events, the current deadlines for each of those events, and the requested new deadlines for each of those events. The table shall be formatted as follows:

Choe-Groves StandingOrder AmendingSchedule · p. 1
|SectionSTANDING ORDER REGARDING MOTIONS TO AMEND SCHEDULING ORDERS
Filing RequirementsMandatoryCivil cases

Should the Parties find it will be necessary to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the

NJ Scheduling Order ANDA patent cases · p. 10
|SectionApplication to Court for Protective Order
Filing RequirementsMandatoryCivil cases

Pinpoint citations required in all briefing, letters, and concise statements of facts; unsupported assertions will be ignored.

Court's wording

Pinpoint citations are required in all briefing, letters, and concise statements of facts. The Court will ignore any assertions of controverted facts and controverted legal principles not supported by a pinpoint citation to, as applicable: the record, an attachment or exhibit, and/or case law or appropriate legal authority.

Filing RequirementsMandatoryCivil cases

Each brief must include a certification of compliance with word count limitations.

Court's wording

Each brief must include a certification by counsel that the brief complies with the type and number limitations set forth above. The person who prepares the certification may rely on the word count of the word-processing system used to prepare the brief.

NJ Scheduling Order ANDA patent cases · p. 13
|SectionClaim Construction Briefing
Filing RequirementsMandatoryCivil cases

Parties must file a Joint Claim Construction Brief by the deadline, with specific structure combining positions on each claim term; extension of the deadline presumptively results in loss of the claim construction hearing date.

Court's wording

No later than [DATE], the parties shall file a Joint Claim Construction Brief. (Should the parties later stipulate or otherwise request to have this deadline extended, the parties will presumptively lose their claim construction hearing date upon the Court’s granting the extension.) The parties shall copy and paste their untitled briefs into one brief, with their positions on each claim term in sequential order, in substantially the form below.

NJ Scheduling Order ANDA patent cases · p. 13
|SectionClaim Construction Briefing
Filing RequirementsMandatoryCivil cases

Declarations shall not contain legal argument or be used to circumvent the briefing word limitations imposed by this paragraph.

NJ Scheduling Order ANDA patent cases · p. 14
|SectionClaim Construction Briefing
Filing RequirementsMandatoryCivil cases

Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order.

Filing RequirementsMandatoryCivil cases

After the filing of Markman briefs, Judge Choe-Groves requires a joint claim construction chart that reflects the claim constructions on which the Parties disagree.

NJ Standing Order for Judge Choe-Groves · May 2026 · p. 1
|SectionIndividual Rules and Preferences
Filing RequirementsMandatoryCivil cases

After the filing of motions for summary judgment, Judge Choe-Groves requires a joint statement of undisputed material facts that reflects those facts on which the Parties agree.

NJ Standing Order for Judge Choe-Groves · May 2026 · p. 1
|SectionIndividual Rules and Preferences
Filing RequirementsMandatory

Submissions containing AI-drafted text must include an AI disclosure notice, accuracy certification, and confidentiality certification.

Document
Submission
Placement
Certificate section

Must include

  • AI disclosure

Court's wording

ORDERED that any submission in a case assigned to Judge Choe-Groves that contains text drafted with the assistance of a generative AI program on the basis of natural language prompts must be accompanied by: (1) A disclosure notice that identifies the program used, the manner in which it was used, and the specific portions of text that have been drafted; (2) A certification that counsel or the party has reviewed the included text and legal research for factual and legal accuracy; and (3) A certification that the use of such AI program has not resulted in the unauthorized disclosure of any confidential or business proprietary information;

Choe-Groves StandingOrder ArtificialIntelligence · Jul 2025 · p. 1
|SectionSTANDING ORDER ON THE USE OF ARTIFICIAL INTELLIGENCE
Filing RequirementsMandatoryCivil cases

Invalidity Contentions must identify prior art with details, provide anticipation/obviousness analysis, include a claim chart, and state invalidity grounds under sections 101, 112(a), and 112(b).

Court's wording

item offered for sale or publicly used or known, the date the offer or use took place or the information became known, and the identity of the person(s) or entity(ies) that made the use or made and received the offer, or the person(s) or entity(ies) that made the information known or to whom it was made known. For pre-AIA claims, prior art under 35 U.S.C. § 102(f) shall be identified by providing the name of the person(s) from whom and the circumstances under which the invention or any part of it was derived. For pre-AIA claims, prior art under 35 U.S.C. § 102(g) shall be identified by providing the identities of the person(s) or entity(ies) involved in and the circumstances surrounding the making of the invention before the patent applicant(s); b. Whether each item of prior art anticipates each asserted claim or renders it obvious. If obviousness is alleged, an explanation of why the prior art renders the asserted claim obvious, including an identification of any combinations of prior art showing obviousness; c. A chart identifying specifically where and how in each alleged item of prior art each limitation of each asserted claim is found, including, for each limitation that such Party contends is governed by 35 U.S.C. § 112(f), the identity of the structure(s), act(s), or material(s) in each item of prior art that performs the claimed function; and d. Any grounds of invalidity based on 35 U.S.C. § 101, indefiniteness under 35 U.S.C. § 112(b), or lack of enablement or insufficient written description under 35 U.S.C. § 112(a) of any of the asserted claims.

Filing RequirementsMandatoryCivil cases

6. Document Production Accompanying Invalidity Contentions. With the Invalidity Contentions, the Party opposing a claim of patent infringement shall produce or make available for inspection and copying: a. Source code1, specifications, schematics, flow charts, artwork, formulas, or other documentation sufficient to show the operation of any aspects or elements of an Accused Instrumentality identified by the patent claimant in its chart produced pursuant to paragraph 3(c) of this Order; b. A copy or sample of the prior art identified pursuant to paragraph 5(a) that does not appear in the file history of the patent(s) at issue. To the extent any such item is not in English, an English translation of the portion(s) relied upon shall be produced; 1 The parties may mutually agree on a later date for source code inspection, so long as the inspection is completed at least two (2) weeks prior to the due date for the final infringement contentions, set forth in the table at the conclusion of this Order.

NJ Scheduling Order non-ANDA patent cases · p. 8
|SectionDocument Production Accompanying Invalidity Contentions
Filing RequirementsMandatoryCivil cases

The parties’ Joint Claim Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s) in issue and should include each Party’s proposed construction of the disputed claim language with citation(s) only to the intrinsic evidence in support of their respective proposed constructions. A separate text-searchable PDF of each of the patent(s) in issue shall be submitted with this Joint Claim Construction Chart. In this joint submission, the parties shall not provide argument.

Filing RequirementsMandatoryCivil cases

Motion for Claim Construction must use specific language and contain no argument.

Court's wording

Each Party shall file concurrently with the Joint Claim Construction Chart a “Motion for Claim Construction” that requests the Court to adopt the claim construction position(s) of that Party set forth in the Joint Claim Construction Chart. The motion shall not contain any argument and shall simply state that the Party “requests that the Court adopt the claim construction position[s] of [the Party] set forth in the Joint Claim Construction Chart (D.I.

Filing RequirementsMandatoryCivil cases

Each claim construction brief must include a certification of compliance with word count limitations.

Document
Brief
Placement
Certificate section

Court's wording

Each brief must include a certification by counsel that the brief complies with the type and number limitations set forth above. The person who prepares the certification may rely on the word count of the word-processing system used to prepare the brief.

Filing RequirementsMandatoryCivil cases

The Joint Claim Construction Brief and Joint Appendix shall comply with paragraph 10 of this Order.

Filing RequirementsMandatoryCivil cases

A letter must be filed with the Amended Joint Claim Construction Chart identifying participants, method, and duration of the meet and confer.

Court's wording

The parties shall file with the Amended Joint Claim Construction Chart a letter that identifies by name each individual who participated in the meet and confer, when and how (i.e., by telephone or in person) the meet and confer occurred, and how long it lasted.

NJ Scheduling Order non-ANDA patent cases · p. 16
|Section17. Meet and Confer Confirmation and Amended Claim Chart.
Filing RequirementsMandatoryCivil cases

Multiple summary judgment motions must be numbered in order of desired consideration; denial of one motion may halt review of subsequent motions.

Court's wording

A Party that files more than one summary judgment motion shall number each motion to make clear the order in which the Party wishes the Court to consider the motions in question. The first motion the Party wishes the Court to consider shall be designated #1, the second motion shall be designated #2, and so on. The Court will review the Party’s summary judgment motions in the order designated by the Party. If the Court decides to deny a motion filed by the Party, barring exceptional reasons determined sua sponte by the Court, the Court will not review any further summary judgment motions filed by the Party.

NJ Scheduling Order non-ANDA patent cases · p. 19
|Sectiond. Ranking of Summary Judgment Motions.
Filing RequirementsMandatoryCivil cases

Multiple Daubert motions must be numbered in order of desired consideration; denial may halt review of further motions; failure to cross-examine after denial may reduce trial time.

Court's wording

A Party that files more than one Daubert motion shall number each motion to make clear the order in which the Party wishes the Court to consider the motions in question. The first motion the Party wishes the Court to consider shall be designated #1, the second motion shall be designated #2, and so on. The Court will review the Party’s Daubert motions in the order designated by the Party. If the Court decides to deny a motion filed by the Party, barring exceptional reasons determined sua sponte by the Court, the Court will not review any further Daubert motions filed by the Party. If the Court denies a Daubert motion and the Party that brought the motion does not cross-examine the expert witness at trial about the matters raised in the Daubert motion, the Court will reduce by an appropriate amount the time allotted to that Party at trial.

NJ Scheduling Order non-ANDA patent cases · p. 20
|Sectione. Ranking of Daubert Motions.
Filing RequirementsMandatoryCivil cases

Each summary judgment motion must be accompanied by a separate concise statement of material facts.

Document
Summary judgment motion

Must include

  • Statement of facts

Court's wording

Any motion for summary judgment shall be accompanied by a separate concise statement detailing each material fact as to which the moving Party contends that there are no genuine issues to be tried that are essential for the Court’s determination of the summary judgment motion (not the entire case). A Party must submit a separate concise statement of facts for each summary judgment motion.

NJ Scheduling Order non-ANDA patent cases · p. 20
|Sectionf. Concise Statement of Facts Requirement.
Filing RequirementsMandatoryCivil cases

Affidavits or declarations setting forth facts and/or authenticating exhibits, as well as exhibits themselves, shall be attached only to the concise statement (i.e., not briefs).

NJ Scheduling Order non-ANDA patent cases · p. 22
|Sectioni. Affidavits and Declarations
Filing RequirementsMandatoryCivil cases

Each statement must include a certification by counsel that the statement complies with the type and number limitations set forth above.

NJ Scheduling Order non-ANDA patent cases · p. 22
|Sectionh. Word Limits for Concise Statement
Filing RequirementsMandatoryCivil cases

Motions in limine shall not be separately filed. All in limine requests and responses thereto shall be set forth in the proposed pretrial order.

Filing RequirementsImportantCivil cases

Proposed protective orders must include a specific paragraph about other proceedings.

Court's wording

Any proposed protective order must include the following paragraph: Other Proceedings. By entering this Order and limiting the disclosure of information in this case, the Court does not intend to preclude another court from finding that the information may be relevant and subject to disclosure in another case. Any person or party subject to this Order who becomes subject to a motion to disclose another party’s information designated as confidential pursuant to this Order shall promptly notify that party of the motion so that the party may have an opportunity to appear and be heard on whether that information should be disclosed.

NJ Scheduling Order ANDA patent cases · p. 11
|SectionParagraph after item 15
Filing RequirementsImportantCivil cases

The parties’ Joint Claim Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s) in issue and should include each party’s proposed construction of the disputed claim language with citation(s) only to the intrinsic evidence in support of their respective proposed constructions. A separate text-searchable PDF of each of the patent(s) in issue shall be submitted with this Joint Claim Construction Chart. In this joint submission, the parties shall not provide argument.

Filing RequirementsImportantCivil cases

Motion for Claim Construction must be filed concurrently, contain no argument, and state specific language.

Court's wording

Each party shall file concurrently with the Joint Claim Construction Chart a “Motion for Claim Construction” that requests the Court to adopt the claim construction position(s) of that party set forth in the Joint Claim Construction Chart. The motion shall not contain any argument and shall simply state that the party “requests that the Court adopt the claim construction position[s] of [the party] set forth in the Joint Claim Construction Chart (D.I. [ ]).”

Filing RequirementsImportantCivil cases

Parties must submit a joint letter by the date answering claim construction briefs are due to seek prior approval to present testimony at claim construction hearing.

Court's wording

Absent prior approval of the Court (which, if it is sought, must be done by joint letter submission no later than the date on which answering claim construction briefs are due to be served), the parties shall not present testimony at the argument, and the argument shall not exceed a total of three hours.

NJ Scheduling Order ANDA patent cases · p. 15
|SectionHearing on Claim Construction
Filing RequirementsImportantCivil cases

Parties must file a letter with the Amended Joint Claim Construction Chart identifying meet-and-confer participants, method, duration, and stating if no agreements reached.

Court's wording

The parties shall file with the Amended Joint Claim Construction Chart a letter that identifies by name each individual who participated in the meet and confer, when and how (i.e., by telephone or in person) the meet and confer occurred, and how long it lasted. If no agreements on constructions have been reached or if no dispute has been narrowed as a result of the meet and confer, the letter shall so state, and the parties need not file an Amended Joint Claim Construction Chart.

Filing RequirementsImportantCivil cases

Daubert motions must be numbered in order of preference.

Court's wording

A party that files more than one Daubert motion shall number each motion to make clear the order in which the party wishes the Court to consider the motions in question. The first motion the party wishes the Court to consider shall be designated #1, the second motion shall be designated #2, and so on.

Filing RequirementsImportantCivil cases

Each in limine request and any response shall contain the authorities relied upon

Filing RequirementsImportantCivil cases

Each party shall be limited to three in limine requests, unless otherwise permitted by the Court.

Filing RequirementsImportantCivil cases

Motions in limine shall comply with paragraph 14 of this Order.

Filing RequirementsImportantCivil cases

Declarations shall not contain legal argument or be used to circumvent the briefing word limitations imposed by this paragraph.

Filing RequirementsNoteCivil cases

The person who prepares the certification may rely on the word count of the word-processing system used to prepare the statement.

NJ Scheduling Order non-ANDA patent cases · p. 22
|Sectionh. Word Limits for Concise Statement

Filing & Service rules

Electronic Filing Rules

Compendiums of cases must not be filed electronically; a notice of service must be filed electronically.

Compendiums of cases shall not be filed electronically with the Court, but a notice of service of a compendium of cases shall be filed electronically with the Court.

Civil cases

Page 19 | 30

Compendiums of cases must not be filed electronically; only a notice of service of the compendium may be filed electronically.

Compendiums of cases shall not be filed electronically with the Court, but a notice of service of a compendium of cases shall be filed electronically with the Court.

Civil cases

Page 25 | Jury Instructions, Voir Dire, and Special Verdict Forms

The list of claim terms and proposed constructions must be exchanged but not filed with the Court.

On or before [DATE], the parties shall exchange a list of those claim term(s)/phrase(s) that they believe need construction and their proposed claim construction(s) of those term(s)/phrase(s). This document will not be filed with the Court.

Civil cases

Page 12 | Item 19

Filing Timing and Cure Windows

Joint proposed final pretrial order must be filed by 5:00 p.m. on the specified date.

The parties shall file a joint proposed final pretrial order no later than 5:00 p.m. on [DATE].

Civil cases

Page 18 | Pretrial Conference

When a case is to be tried to a jury, the parties should file (i) proposed voir dire, (ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict forms no later than 5:00 p.m. on [DATE] [21 days before the pretrial conference]. The parties shall submit simultaneously with filing each of the foregoing four documents in Word format to the Chambers of Judge Choe-Groves.

When a case is to be tried to a jury, the parties should file (i) proposed voir dire, (ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict forms no later than 5:00 p.m. on [DATE] [21 days before the pretrial conference]. The parties shall submit simultaneously with filing each of the foregoing four documents in Word format to the Chambers of Judge Choe-Groves.

Civil cases

Page 25 | Jury Instructions, Voir Dire, and Special Verdict Forms

Motion for Claim Construction must be filed concurrently with the Joint Claim Construction Chart.

Each Party shall file concurrently with the Joint Claim Construction Chart a “Motion for Claim Construction”

Civil cases

Page 13

Opening, answering, reply, and sur-reply claim construction briefs are served but not filed individually; they are later incorporated into the Joint Claim Construction Brief.

The Plaintiff(s) shall serve, but not file, its opening brief... The Defendant(s) shall serve, but not file, its answering brief... The Plaintiff(s) shall serve, but not file, its reply brief... The Defendant(s) shall serve, but not file, its sur-reply brief...

Civil cases

Page 13 | Claim Construction Briefing

Service and Proof of Service Rules

Parties hiring own court reporter for in-person U.S. Court of International Trade hearings must provide transcript copy to court.

In such a case, the Parties shall provide a copy of the transcript to the court.

Civil cases

Page 2 | Transcripts

Courtesy Copy Requirements

Paper copies of filings are not required unless requested by the Court.

The Parties are not required to mail paper copies of documents to the Court unless requested.

Civil cases

Page 2 | Physical Copies of Filings

Paper copies of documents are not required unless specifically requested by the Court.

Hard Copies. The Parties are not required to mail paper copies of documents to the Court unless requested.

Civil cases

Page 11 | Item 18

Parties may submit two courtesy copies of a compendium of authorities with any briefing.

A party may submit with any briefing two courtesy copies of a compendium of the selected authorities on which the party would like the Court to focus.

Civil cases

Page 19 | 30

A party may submit two courtesy copies of a compendium of selected authorities with any briefing.

A Party may submit with any briefing two courtesy copies of a compendium of the selected authorities on which the party would like the Court to focus.

Civil cases

Page 24 | Compendium of Cases

Sealing & Redaction Procedures

Sealed filings do not require physical copies; a redacted version must be filed electronically within 7 days.

Papers Filed Under Seal. The parties need not file copies with the Clerk of Court for the U.S. District Court for the District of New Jersey. The parties are not required to physically deliver original and paper copies of sealed filings to the Court. A redacted version of any sealed document shall be filed electronically within seven days of the filing of the sealed document.

Civil cases

Page 11 | Item 17

Filing Bundling Requirements

Separate briefing on in limine requests is prohibited unless the Court permits otherwise.

No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.

Civil cases

Page 19 | 29

Parties must combine their served briefs into a single Joint Claim Construction Brief for filing.

The parties shall copy and paste their untitled briefs into one brief, with their positions on each claim term in sequential order, in substantially the form below.

Civil cases

Page 14

No separate briefing is allowed on in limine requests unless the Court permits otherwise.

No separate briefing shall be submitted on in limine requests, unless otherwise permitted by the Court.

Civil cases

Page 24 | Motions in Limine

Appendix materials must be submitted in a Joint Appendix.

If there are any materials that would be submitted in an appendix, the parties shall submit them in a Joint Appendix.

Civil cases

Page 14 | Claim Construction Briefing

If multiple parties support or oppose an in limine request, they must combine their arguments into a single three-page submission.

If more than one party is supporting or opposing an in limine request, such support or opposition shall be combined in a single three-page submission

Civil cases

Page 18 | Motions in Limine

Pre-Motion Conference Requirements

Daubert objections must be made by motion, with responses and replies due on specified dates.

To the extent any objection to expert testimony is made pursuant to the principles announced in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it shall be made by motion no later than [DATE]. Responses shall be filed no later than [DATE]. Replies shall be filed no later than [DATE].

Civil cases

Page 17 | Objections to Expert Testimony

Parties must meet and confer and file an Amended Joint Claim Construction Chart between four weeks and two weeks before the claim construction hearing.

On or before [DATE] [no earlier than four weeks before the claim construction hearing and no later than two weeks before the claim construction hearing], counsel for the parties shall meet and confer and thereafter file on [DATE], an Amended Joint Claim Construction Chart that sets forth the terms that remain in dispute.

Civil cases

Page 15 | 17. Meet and Confer Confirmation and Amended Claim Chart.

Should the Parties find it will be necessary to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the

Should the Parties find it will be necessary to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the

Civil cases

Page 10 | Application to Court for Protective Order

Adjournment & Extension Requirements

it is hereby ORDERED that all requests to amend an existing Scheduling Order shall comply with the following procedures and requirements: 1. Any Party seeking an extension of a deadline should attempt to obtain consent to the requested extension from all other Parties to the case prior to filing a motion with the Court; 2. All motions requesting an extension should indicate the number of similar requests made by the moving Party and the reasons for the requested extension; 3. Extension requests should be limited to short periods to address unexpected conflicts; 4. The Party requesting the extension is responsible for ensuring that the requested deadlines do not fall on a weekend, holiday, or other date on which the Court will not be open for normal business; and

it is hereby ORDERED that all requests to amend an existing Scheduling Order shall comply with the following procedures and requirements: 1. Any Party seeking an extension of a deadline should attempt to obtain consent to the requested extension from all other Parties to the case prior to filing a motion with the Court; 2. All motions requesting an extension should indicate the number of similar requests made by the moving Party and the reasons for the requested extension; 3. Extension requests should be limited to short periods to address unexpected conflicts; 4. The Party requesting the extension is responsible for ensuring that the requested deadlines do not fall on a weekend, holiday, or other date on which the Court will not be open for normal business; and

Civil cases

Page 1 | STANDING ORDER REGARDING MOTIONS TO AMEND SCHEDULING ORDERS

Extension of the Joint Claim Construction Brief deadline presumptively results in loss of the claim construction hearing date.

Should the parties later stipulate or otherwise request to have this deadline extended, the parties will presumptively lose their claim construction hearing date upon the Court’s granting the extension.

Civil cases

Page 14

Ideally, stipulations and requests for an extension of time should be filed with the Court at least three days in advance of the deadline the request concerns.

Ideally, stipulations and requests for an extension of time should be filed with the Court at least three days in advance of the deadline the request concerns.

Civil cases

Page 20 | 33

Chambers Communication Rules

Joint Claim Construction Chart must be emailed to steve_taronji@cit.uscourts.gov simultaneously with filing.

The Joint Claim Construction Chart, in Word format, shall be e-mailed simultaneously with filing to steve_taronji@cit.uscourts.gov.

Civil cases

Page 12 | Item 19

If the Parties seek a live transcript prepared by a court reporter for videoconferences, the Parties should reach out to the court at least two days in advance via email to Steve Taronji, Case Manager for Judge Choe-Groves, at steve_taronji@cit.uscourts.gov or by phone at (212) 264-1611, and the Court will request a court reporter to be provided by the District Court for the District of New Jersey (subject to availability).

If the Parties seek a live transcript prepared by a court reporter for videoconferences, the Parties should reach out to the court at least two days in advance via email to Steve Taronji, Case Manager for Judge Choe-Groves, at steve_taronji@cit.uscourts.gov or by phone at (212) 264-1611, and the Court will request a court reporter to be provided by the District Court for the District of New Jersey (subject to availability).

Civil cases

Page 2 | Transcripts

Joint Claim Construction Chart must be emailed to chambers in Word format simultaneously with filing.

The Joint Claim Construction Chart, in Word format, shall be e-mailed simultaneously with filing to steve_taronji@cit.uscourts.gov.

Civil cases

Page 13

Junior Lawyer Participation Incentives

The court encourages parties to give less-experienced lawyers familiar with the issues and record a more active role in oral arguments.

7. Opportunities for Junior Lawyers. The court encourages the parties to create opportunities for junior lawyers to take a more active role in oral arguments, particularly those junior lawyers who are familiar with the issues and the record, but who are not as experienced in arguing before a court.

Page 4 | Opportunities for Junior Lawyers

About United States District Judge Jennifer Choe-Groves
Common questions about Judge Jennifer Choe-Groves's rules

Are courtesy copies required for Judge Jennifer Choe-Groves?

Courtesy copies are required only when requested by chambers. Paper copies of filings are not required unless requested by the Court.

View ruleSource: page 2, section Physical Copies of Filings

Does Judge Jennifer Choe-Groves require a pre-motion conference or letter before filing a motion?

Daubert objections must be made by motion, with responses and replies due on specified dates.

View ruleSource: page 17, section Objections to Expert Testimony

What page or word limits apply to brief before Judge Jennifer Choe-Groves?

Judge Jennifer Choe-Groves' rule states these limits: attorney: 5500 words; attorney: 8250 words; attorney: 5500 words; attorney: 2750 words. Opening briefs limited to 5,500 words; answering briefs limited to 8,250 words; reply briefs limited to 5,500 words; sur-reply briefs limited to 2,750 words; all briefs must use 14-point Times New Roman or similar typeface.

View ruleSource: page 13, section Claim Construction Briefing

What page or word limits apply to in limine request before Judge Jennifer Choe-Groves?

Judge Jennifer Choe-Groves' rule states these limits: 3 pages; 3 pages; 1 pages. each in limine request may be supported by a maximum of three pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one additional page in reply in support of its request.

View ruleSource: page 18, section Motions in Limine

What formatting rules apply to filings before Judge Jennifer Choe-Groves?

Judge Jennifer Choe-Groves' formatting rule includes times new roman font, 14 point type and file format docx. Joint Claim Construction Chart must be in Word format, 14-point Times New Roman, and emailed to chambers simultaneously with filing.

View ruleSource: page 12, section Item 19

What must be included with motion filings before Judge Jennifer Choe-Groves?

Motions to amend scheduling orders must include a table of remaining events with current and requested deadlines.

View ruleSource: page 1, section STANDING ORDER REGARDING MOTIONS TO AMEND SCHEDULING ORDERS

What must be included with brief filings before Judge Jennifer Choe-Groves?

Pinpoint citations required in all briefing, letters, and concise statements of facts; unsupported assertions will be ignored.

View ruleSource: page 10, section Pinpoint Citations

How may parties contact Judge Jennifer Choe-Groves' chambers?

The rule lists email steve_taronji@cit.uscourts.gov. Joint Claim Construction Chart must be emailed to steve_taronji@cit.uscourts.gov simultaneously with filing.

View ruleSource: page 12, section Item 19

How does Judge Jennifer Choe-Groves handle sealed or redacted filings?

Process: file redacted on ecf. Sealed filings do not require physical copies; a redacted version must be filed electronically within 7 days.

View ruleSource: page 11, section Item 17

How do I request an adjournment or extension before Judge Jennifer Choe-Groves?

The request must include reason for request and number of previous requests. it is hereby ORDERED that all requests to amend an existing Scheduling Order shall comply with the following procedures and requirements: 1. Any Party seeking an extension of a deadline should attempt to obtain consent to the requested extension from all other Parties to the case prior to filing a motion with the Court; 2.

View ruleSource: page 1, section STANDING ORDER REGARDING MOTIONS TO AMEND SCHEDULING ORDERS

Does Judge Jennifer Choe-Groves require motion papers to be bundled?

Separate briefing on in limine requests is prohibited unless the Court permits otherwise.

View ruleSource: page 19, section 29

Is electronic filing required before Judge Jennifer Choe-Groves?

No. Electronic filing is prohibited for the covered filings. Compendiums of cases must not be filed electronically; a notice of service must be filed electronically.

View ruleSource: page 19, section 30

When is a filing treated as filed before Judge Jennifer Choe-Groves?

The rule states a 5:00 PM filing cutoff. Joint proposed final pretrial order must be filed by 5:00 p.m. on the specified date.

View ruleSource: page 18, section Pretrial Conference

What rule applies to serving the court before Judge Jennifer Choe-Groves?

Details: recipient: the court. Parties hiring own court reporter for in-person U.S. Court of International Trade hearings must provide transcript copy to court.

View ruleSource: page 2, section Transcripts

Does Judge Jennifer Choe-Groves encourage junior lawyer participation?

Yes. Judge Jennifer Choe-Groves's rules include a junior lawyer participation incentive. The court encourages parties to give less-experienced lawyers familiar with the issues and record a more active role in oral arguments.

View ruleSource: page 4, section Opportunities for Junior Lawyers
Complete rules summary for Judge Jennifer Choe-Groves

it is hereby ORDERED that all requests to amend an existing Scheduling Order shall comply with the following procedures and requirements: 1. Any Party seeking an extension of a deadline should attempt to obtain consent to the requested extension from all other Parties to the case prior to filing a motion with the Court; 2. All motions requesting an extension should indicate the number of similar requests made by the moving Party and the reasons for the requested extension; 3. Extension requests should be limited to short periods to address unexpected conflicts; 4. The Party requesting the extension is responsible for ensuring that the requested deadlines do not fall on a weekend, holiday, or other date on which the Court will not be open for normal business; and

Motions to amend scheduling orders must include a table of remaining events with current and requested deadlines.

Proposed protective orders must include a specific paragraph about other proceedings.

Pinpoint citations required in all briefing, letters, and concise statements of facts; unsupported assertions will be ignored.

Each in limine request and response must contain the authorities relied upon.

Joint Claim Construction Chart must be emailed to steve_taronji@cit.uscourts.gov simultaneously with filing.

Sealed filings do not require physical copies; a redacted version must be filed electronically within 7 days.

Paper copies of documents are not required unless specifically requested by the Court.

The parties’ Joint Claim Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s) in issue and should include each party’s proposed construction of the disputed claim language with citation(s) only to the intrinsic evidence in support of their respective proposed constructions. A separate text-searchable PDF of each of the patent(s) in issue shall be submitted with this Joint Claim Construction Chart. In this joint submission, the parties shall not provide argument.

Motion for Claim Construction must be filed concurrently, contain no argument, and state specific language.

Opening briefs limited to 5,500 words; answering briefs limited to 8,250 words; reply briefs limited to 5,500 words; sur-reply briefs limited to 2,750 words; all briefs must use 14-point Times New Roman or similar typeface.

Parties must submit a joint letter by the date answering claim construction briefs are due to seek prior approval to present testimony at claim construction hearing.

Declarations must not contain legal argument or circumvent word limits.

Appendix materials must be submitted in a Joint Appendix.

each in limine request may be supported by a maximum of three pages of argument and may be opposed by a maximum of three pages of argument, and the party making the in limine request may add a maximum of one additional page in reply in support of its request.

Joint proposed final pretrial order must be filed by 5:00 p.m. on the specified date.

Motions in limine must not be filed separately; all requests and responses must be included in the proposed pretrial order.

Separate briefing on in limine requests is prohibited unless the Court permits otherwise.

Parties may submit two courtesy copies of a compendium of authorities with any briefing.

Joint Claim Construction Chart must be in Word format, 14-point Times New Roman, and emailed to chambers simultaneously with filing.

Should the Parties find it will be necessary to apply to the Court for a protective order specifying terms and conditions for the disclosure of confidential information, counsel should confer and attempt to reach an agreement on a proposed form of order and submit it to the

Each brief must include a certification of compliance with word count limitations.

If multiple parties support or oppose an in limine request, they must combine their arguments into a single three-page submission.

Daubert motions must be numbered in order of preference.

Daubert objections must be made by motion, with responses and replies due on specified dates.

Parties must file a Joint Claim Construction Brief by the deadline, with specific structure combining positions on each claim term; extension of the deadline presumptively results in loss of the claim construction hearing date.

Compendiums of cases must not be filed electronically; a notice of service must be filed electronically.

Each party is limited to three in limine requests.

Parties must file a letter with the Amended Joint Claim Construction Chart identifying meet-and-confer participants, method, duration, and stating if no agreements reached.

Motions in limine must comply with paragraph 14 of this Order.

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