Not later than twenty-eight (28) days after service and filing of the Joint Claim Construction Chart, Joint
Claim Construction Worksheet and Joint Hearing Statement, the parties must complete all discovery,
including depositions of any percipient or expert witnesses that they intend to use in the Claim
Construction Hearing. Fed. R. Civ. P. 30 applies to depositions taken pursuant to Patent L.R. 4.3, except
as to experts. An expert witness identified in a party’s Joint Hearing Statement pursuant to Patent L.R.
4.2.c, may be deposed on claim construction issues. The identification of an expert witness in the Joint
Hearing Statement may be deemed good cause for a further deposition on all substantive issues.