American Patents LLC v. Mediatek, Inc. et al

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

Unopposed MOTION for Leave to Exceed Page Limitation on AMERICAN PATENTS' OPPOSITION TO LENOVOS MOTION TO SEVER AND STAY PURSUANT TO THE CUSTOMER-SUIT EXCEPTION DOCTRINE 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, CIVIL ACTION NO. 6:18-CV-339-ADA v. PATENT CASE MEDIATEK INC., MEDIATEK USA INC., BROADCOM PTE. LTD., BROADCOM JURY TRIAL DEMANDED 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. PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO EXCEED PAGE LIMITS Plaintiff American Patents LLC hereby moves for leave to file its Opposition to Defendants Lenovo (Shanghai) Electronics Technology Co., Ltd. and Lenovo Group Ltd.'s Motion to Sever and Stay Pursuant to the Customer-Suit Exception Doctrine in excess of the page limit set by Local Rule CV-7(e)(3). Local Rule CV-7(e)(3) provides that responses to non- dispositive motions are limited to ten (10) pages. American Patents requests permission to exceed this page limit by up to five (5) pages. On March 13, 2019, the Lenovo Defendants filed a Motion to Sever and Stay Pursuant to the Customer-Suit Exception Doctrine. Additional pages are necessary to properly explain the Customer-Suit Exception doctrine and whether the doctrine applies to the Lenovo Defendants, and to properly address the Lenovo Defendants' arguments and the caselaw cited in their motion. 1 Plaintiff's counsel conferred with Defendants's counsel regarding whether Defendants opposed this Motion. Defendants indicated that they do not oppose this Motion, so long as the Court provides for an additional five (5) pages for Defendants' Reply as well. Accordingly, American Patents seeks leave to file a 15-page brief for its Opposition, and also requests the Court grant leave for Defendants to file a 10-page brief for their Reply. A proposed order is attached. Dated: March 27, 2019 Respectfully submitted, /s/ Michael D. Ellis Matthew J. Antonelli (admission pending) Texas Bar No. 24068432 matt@ahtlawfirm.com Zachariah S. Harrington (admission pending) Texas Bar No. 24057886 zac@ahtlawfirm.com Larry D. Thompson, Jr. (admission pending) Texas Bar No. 24051428 larry@ahtlawfirm.com Christopher Ryan Pinckney (admission pending) 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 Stafford Davis State Bar No. 24054605 sdavis@stafforddavisfirm.com Catherine Bartles Texas Bar No. 24104849 cbartles@stafforddavisfirm.com 2 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 Attorneys for American Patents LLC 3