American Patents LLC v. Mediatek, Inc. et al

Western District of Texas, txwd-6:2018-cv-00339

Agreed MOTION for Extension of Time to File Answer or Otherwise Respond to Plaintiff's Complaint as to Broadcom Defendants by American Patents LLC.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION AMERICAN PATENTS LLC, Plaintiff, v. MEDIATEK, INC., MEDIATEK USA INC., BROADCOM PTE. LTD., BROADCOM CORPORATION, LENOVO (SHANGHAI) CIVIL ACTION NO. 6:18-CV-00339-ADA ELECTRONICS TECHNOLOGY CO. LTD., LENOVO GROUP LTD., NXP SEMICONDUCTORS N.V., NXP B.V., NXP USA, INC., QUALCOMM INCORPORATED AND QUALCOMM TECHNOLOGIES, INC., Defendants. AGREED MOTION FOR EXTENSION OF TIME FOR BROADCOM DEFENDANTS TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S ORIGINAL COMPLAINT Plaintiff American Patents LLC respectfully moves the Court to extend the deadline for Defendants Broadcom Corporation and Broadcom PTE. Ltd. (hereinafter "the Broadcom Defendants") to move, answer, or otherwise respond to Plaintiff's Original Complaint for Patent Infringement (the "Complaint"). In support of this Motion, Plaintiff states as follows: 1. On November 14, 2018, Plaintiff filed its Complaint alleging patent infringement against the Broadcom Defendants and a number of other entities. The deadline for the Broadcom Defendants to answer, move, or otherwise respond to the Complaint is currently December 10, 2018. 2. The parties seek to extend the Broadcom Defendants' response deadline to February 8, 2019. The extension is sought not for purposes of delay but for good cause, including that the Broadcom Defendants need additional time to review the Complaint, investigate the allegations and issues contained therein (including the asserted patents), and prepare a response. -1- 3. Counsel for Plaintiff has conferred with counsel for the Broadcom Defendants, and the parties are agreed to the requested extension. The Broadcom Defendants have also agreed to waive any objections to the absence of summons or to service (including objections based on a failure to execute service under the Hague Convention) in exchange for the requested extension of time for the Broadcom Defendants to answer or otherwise plead by February 8, 2019. 4. Therefore, Plaintiff respectfully requests that this Court enter an Order extending the deadline for the Broadcom Defendants to answer, move, or otherwise respond to the Complaint until February 8, 2019. -2- Dated: December 7, 2018 Respectfully submitted, By: /s/ Stafford Davis Stafford Davis State Bar No. 24054605 sdavis@stafforddavisfirm.com Catherine Bartles(not yet admitted) Texas Bar No. 24104849 cbartles@stafforddavisfirm.com THE STAFFORD DAVIS FIRM The People's Petroleum Building 102 North College Avenue, 13th Floor Tyler, Texas 75702 (903) 593-7000 (903) 705-7369 fax Zachariah S. Harrington (not yet admitted) Texas Bar No. 24057886 zac@ahtlawfirm.com Matthew J. Antonelli (not yet admitted) Texas Bar No. 24068432 matt@ahtlawfirm.com Larry D. Thompson, Jr. (not yet admitted) Texas Bar No. 24051428 larry@ahtlawfirm.com Christopher Ryan Pinckney (not yet admitted) Texas Bar No. 24067819 ryan@ahtlawfirm.com Michael D. Ellis Texas Bar No. 24081586 michael@ahtlawfirm.com ANTONELLI, HARRINGTON & THOMPSON LLP 4306 Yoakum Blvd., Ste. 450 Houston, TX 77006 (713) 581-3000 Attorneys for American Patents LLC -3- CERTIFICATE OF SERVICE I certify that on December 7, 2018, a true and correct copy of the foregoing document was served on all counsel of record via ECF. /s/ Stafford Davis Stafford Davis -4-