Ixi Mobile (R&D) Ltd. et al v. Apple, Inc.

Northern District of California, cand-4:2015-cv-03755

MOTION to Transfer Case Apple Inc.'s Notice of Motion to Transfer Venue Pursuant to 28 U.S.C. § 1404(a). Document filed by Apple, Inc.

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 14-cv-7954-RJS-DF IXI Mobile (R&D) Ltd. and IXI IP, LLC, JURY TRIAL DEMANDED Plaintiffs, - against - APPLE INC., Defendant. APPLE INC.'S NOTICE OF MOTION TO TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(a) PLEASE TAKE NOTICE that, upon the accompanying memorandum of law and supporting declarations and exhibits, and upon all the pleadings and prior proceedings had herein, Defendant Apple Inc. will move the Court before the Honorable Richard J. Sullivan, United States District Judge, at the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007, for an order pursuant to 28 U.S.C. § 1404(a) transferring the above-captioned case to the Northern District of California, and ordering such other and further relief as the Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that, opposition shall be served on or before February 17, 2015, and reply papers, if any, are to be served no later than February 20, 2015. Oral argument on this motion will be on a date and at a time designated by the Court. Dated: February 3, 2015 Respectfully submitted, By /s/ PATRICK E. KING PATRICK E. KING HARRISON J. FRAHN IV hfrahn@stblaw.com PATRICK E. KING pking@stblaw.com SIMPSON THACHER & BARTLETT LLP 2475 Hanover Street Palo Alto, California 94304 Telephone: (650) 251-5000 GREGORY T. CHUEBON gchuebon@stblaw.com SIMPSON THACHER & BARTLETT LLP 425 Lexington Avenue New York, NY 10017 Tel: (212) 455-2000 Attorneys for Defendant Apple Inc. 1