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 re 1 Complaint by Qualcomm Incorporated, Qualcomm Technologies, Inc.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION AMERICAN PATENTS LLC, Plaintiff, v. MEDIATEK, INC., MEDIATEK USA INC., Civil Action No. 6:18-cv-00339-ADA BROADCOM PTE. LTD., BROADCOM CORPORATION, LENOVO (SHANGHAI) 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 SECOND EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendants Qualcomm Incorporated and Qualcomm Technologies, Inc. (hereinafter "the Qualcomm Defendants") move the Court to extend the time with which the Qualcomm Defendants are required to move, answer, or otherwise respond to Plaintiff American Patents LLC's Original Complaint for Patent Infringement (the "Complaint"). In support of this Motion, the Qualcomm Defendants state as follows: 1. On November 14, 2018, Plaintiff filed its Complaint alleging patent infringement against the Qualcomm Defendants and a number of other entities. 2. On December 10, 2018, the Court granted Plaintiff's Agreed Motion for Extension of Time to Answer or Otherwise Respond to Plaintiff's Complaint which extended the time with which the Qualcomm Defendants are required to move, answer, or otherwise respond to the Complaint to January 9, 2019 (Dkt. No. 25.) 3. The parties seek to further extend the Qualcomm Defendants' response US_ACTIVE-144373154.3-OMOHAMME deadline from January 9, 2019 to February 10, 2019. The extension is sought not for purposes of delay but for good cause, including that the Qualcomm Defendants need additional time to review the Complaint, investigate the allegations and issues contained therein (including the asserted patents), and prepare a response. In addition, Plaintiff has agreed to extend the responsive pleading deadline for other entities named as defendants in the action to February 10, 2019. 4. Counsel for the Qualcomm Defendants has conferred with counsel for Plaintiff, and the parties are agreed to the requested extension. 5. WHEREFORE, Defendants Qualcomm Incorporated and Qualcomm Technologies, Inc. respectfully request that the time in which the Qualcomm Defendants are required to move, answer, or otherwise respond to Plaintiff's Original Complaint for Patent Infringement be extended to and include February 10, 2019. Dated: January 9, 2019 Respectfully submitted, /s/ Megan Hudgeons_____________________ Jeff Layne, Texas Bar No. 00791083 Megan Hudgeons, Texas Bar No. 24001645 REED SMITH LLP 111 Congress Avenue Suite 400 Austin, TX 78701 Telephone: +1 512 623 1821 Facsimile: +1 512 623 1802 Email: jlayne@reedsmith.com Email: mhudgeons@reedsmith.com Attorneys for Qualcomm Incorporated and Qualcomm Technologies, Inc. -2- CERTIFICATE OF SERVICE I certify that on January 9, 2019, a true and correct copy of the foregoing document was served on all counsel of record via ECF. /s/ Megan Hudgeons Megan Hudgeons -3-