Neodron LTD v. Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.

Western District of Texas, txwd-6:2019-cv-00323

Unopposed MOTION for Extension of Time to File Answer re [1] Complaint, by Samsung Electronics America, Inc., Samsung Electronics Co., Ltd.

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION NEODRON LTD., Plaintiff, v. Civil Action No. 6:19-cv-00323-ADA SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS AMERICA, INC. Defendants, DEFENDANTS SAMSUNG ELECTRONICS CO., LTD AND SAMSUNG ELECTRONICS AMERICA INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively "Samsung") file this unopposed motion for extension of time to answer or otherwise respond to Plaintiff Neodron Ltd's ("Plaintiff") Complaint (Dkt. No. 1). Plaintiff filed its Complaint on May 21, 2019 (Dkt. No. 1). Plaintiff filed an executed summons with the Court on June 13, 2019, indicating service occurred on June 5, 2019 (Dkt. No. 12). Assuming that service was proper, Samsung's deadline to respond would be June 26, 2019. Samsung has retained O'Melveny & Myers LLP as counsel. The undersigned counsel for Samsung conferred with Plaintiff's counsel on June 17, 2019 to request a 30-day courtesy extension of Samsung's time to answer or otherwise respond to Plaintiff's Complaint, and Plaintiff's counsel confirmed that they do not oppose the requested extension. 1 Samsung therefore respectfully requests and extension of time up to and including July 26, 2019, to answer or otherwise respond to the Complaint. No prior extension of time has been requested. Accordingly Samsung respectfully requests that the Court issue the attached proposed order extending Samsung's time to answer or otherwise respond to Plaintiff's complaint to July 26, 2019. Dated: June 18, 2019 Respectfully submitted, /s/ Ryan K. Yagura Ryan K. Yagura (Tex. Bar No. 24075933) ryagura@omm.com O'MELVENY & MYERS LLP 400 S. Hope Street Los Angeles, CA 90071 Telephone: 213-430-6000 Facsimile: 213-430-6407 Counsel for Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. . 2 CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(b)(1) on June 18, 2019. /s/ Ryan K. Yagura 3