American Patents LLC v. Mediatek, Inc. et al

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

Unopposed MOTION for Leave to File PLAINTIFF'S SUR-REPLY TO DEFENDANTS' CROSS-MOTION FOR ENTRY OF DEFENDANTS' PROPOSED PROTECTIVE ORDER 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., et al., JURY TRIAL DEMANDED Defendants. PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE SUR-REPLY TO DEFENDANTS' CROSS-MOTION FOR ENTRY OF DEFENDANTS' PROPOSED PROTECTIVE ORDER Pursuant to Local Rule CV-7(f)(1), Plaintiff American Patents respectfully requests leave to file a five-page sur-reply to Defendants' reply in support of their Cross-Motion for Entry of Defendants' Proposed Protective Order (Dkts. 140, 147). American Patents seeks leave to file this short sur-reply to address Defendants' misapplication of the burden to show good cause for entry of their proposed protective order, and Defendants' failure to meet their burden to show good cause. Pursuant to Local Rule CV-7(b), American Patents submits its proposed sur-reply as Exhibit A to this motion for leave. A proposed order is attached. Counsel for American Patents has conferred with counsel for Defendants, who confirmed that Defendants do not oppose American Patents' request for permission to file a five-page sur- reply. Accordingly, American Patents respectfully requests that the Court grant leave to file Plaintiff's sur-reply to Defendants' Cross-Motion for Entry of Defendants' Proposed Protective Order (Dkts. 140, 147). 1 Dated: September 9, 2019 Respectfully submitted, /s/ Larry D. Thompson, Jr. Matthew J. Antonelli (admission pending) Texas Bar No. 24068432 matt@ahtlawfirm.com Zachariah S. Harrington (lead attorney) Texas Bar No. 24057886 zac@ahtlawfirm.com Larry D. Thompson, Jr. 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 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 2