Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 1 of 6 Page ID #:3498
`
`HUESTON HENNIGAN LLP
`Robert N. Klieger, State Bar No. 192962
`rklieger@hueston.com
`Vicki Chou, State Bar No. 248598
`vchou@hueston.com
`523 West 6th Street, Suite 400
`Los Angeles, CA 90014
`Telephone: (213) 788-4340
`Facsimile:
`(888) 775-0898
`Attorneys for Plaintiffs
`KRAFTON, INC, and KRAFTON AMERICAS,
`INC. (f/k/a PUBG SANTA MONICA, INC.)
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
`
`Case No. 2:22-cv-00209-GW-MRW
`JOINT STATUS REPORT IN
`ADVANCE OF APRIL 29, 2024
`STATUS CONFERENCE (ECF NO.
`178)
`Judge: Hon. George H. Wu
`Complaint Filed: January 10, 2022
`
`KRAFTON, INC. and KRAFTON
`AMERICAS, INC. (F/K/A PUBG
`SANTA MONICA, INC.),
`Plaintiffs,
`
`vs.
`APPLE INC., GOOGLE, LLC,
`YOUTUBE LLC, SEA LIMITED,
`MOCO STUDIOS PRIVATE
`LIMITED (F/K/A GARENA
`INTERNATIONAL | PRIVATE
`LIMITED), and GARENA ONLINE
`PRIVATE LIMITED,
`Defendants.
`
`REDACTED VERSION OF DOCUMENT TO BE FILED UNDER SEAL
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`JOINT STATUS REPORT IN ADVANCE OF CONFERENCE
`CASE NO. 2:22-cv-00209-GW-MRW
`
`
`
`HUESTON HENNIGAN LLP
`Robert N. Klieger, State Bar No. 192962
`rklieger@hueston.com
`Vicki Chou, State Bar No. 248598
`vchou@hueston.com
`523 West 6th Street, Suite 400
`Los Angeles, CA 90014
`Telephone: (213) 788-4340
`Facsimile:
`(888) 775-0898
`Attorneys for Plaintiffs
`KRAFTON, INC, and KRAFTON AMERICAS,
`INC. (f/k/a PUBG SANTA MONICA, INC.)
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
`
`Case No. 2:22-cv-00209-GW-MRW
`JOINT STATUS REPORT IN
`ADVANCE OF APRIL 29, 2024
`STATUS CONFERENCE (ECF NO.
`178)
`Judge: Hon. George H. Wu
`Complaint Filed: January 10, 2022
`
`KRAFTON, INC. and KRAFTON
`AMERICAS, INC. (F/K/A PUBG
`SANTA MONICA, INC.),
`Plaintiffs,
`
`vs.
`APPLE INC., GOOGLE, LLC,
`YOUTUBE LLC, SEA LIMITED,
`MOCO STUDIOS PRIVATE
`LIMITED (F/K/A GARENA
`INTERNATIONAL | PRIVATE
`LIMITED), and GARENA ONLINE
`PRIVATE LIMITED,
`Defendants.
`
`REDACTED VERSION OF DOCUMENT TO BE FILED UNDER SEAL
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`JOINT STATUS REPORT IN ADVANCE OF CONFERENCE
`CASE NO. 2:22-cv-00209-GW-MRW
`
`
`
`Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 2 of 6 Page ID #:3499
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`On March 26, 2024, the parties submitted a Joint Status Report providing a
`
`further update about the Singapore Arbitration Tribunal’s Final Award (“Final
`Award”) and requesting a continuance of the status conference. (ECF No. 177). On
`March 27, 2024, the Court directed the parties to file another Joint Status Report by
`April 24, 2024, and continued the scheduled March 28, 2024 Status Conference to
`April 29, 2024. (ECF No. 178). The Court also directed the parties to include a copy
`of the Final Award. (Id.) The parties respectfully submit the following Joint Status
`Report in compliance with the Court’s Order. The Final Award is filed under seal as
`Exhibit A to this Status Report.
`
`Plaintiffs’ Position:
`
`
`
`
`
`
`
` Consequently, while Plaintiffs have been carefully evaluating their
`options, they have not yet come to a final decision in how to proceed as there are many
`stakeholders involved. Plaintiffs believe they will be able to do so by the beginning
`of May.
`Given the foregoing, Plaintiffs respectfully request continuing the currently
`scheduled April 29, 2024 status conference by 24 days, until May 23, 2024, or as soon
`thereafter as the Court deems appropriate, so that the parties may confer and determine
`how to further proceed with this case in light of the Final Award. Plaintiffs also request
`filing a further Joint Status Report on May 17, 2024 ahead of that status conference.
`//
`//
`
`- 2 -
`JOINT STATUS REPORT IN ADVANCE OF CONFERENCE
`CASE NO. 2:22-cv-00209-GW-MRW
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`
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`Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 3 of 6 Page ID #:3500
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`CowmOnANWnNn&WoNO—
`
`NoNoNoi)NoNoNoi)No——————————CO~nNnN£&WoNo—oS\OCO~nNnN&WoNo—oS
`
`
`
`Garena Defendants’ Position:
`
`Plaintiffs have requested a further limited continuance to determine whether and
`
`howto proceed with the case.
`
`The Garena Defendants believe further delay is not warranted, as the Award was
`
`issued almost 6 weeks ago, and that the Court’s guidance will help move the case
`
`towards resolution. As such the Garena Defendants request the status conference be
`
`held on April 29 as scheduled.
`
`
`
`
`Google Defendants’ Position
`
`Google LLC and its wholly-owned subsidiary, YouTube, LLC (collectively,
`
`“Google”) take no position on Plaintiffs’ request for a 24-day continuance of the
`
`currently scheduled April 29, 2024 status conference. Google does, however, agree
`
`_3-
`JOINT STATUS REPORT IN ADVANCE OF CONFERENCE
`CASE NO. 2:22-cv-00209-GW-MRW
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`Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 4 of 6 Page ID #:3501
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`with the Garena Defendants
`
`
`Accordingly, Google respectfully submits that Plaintiffs should dismiss the current
`Complaint (Dkt. 1) with prejudice in its entirety. Nonetheless, if Plaintiffs need
`additional time to reach this conclusion, Google has no objection to a further
`continuance of the status conference.
`Apple’s Position
`Apple takes no position on Plaintiffs’ request for a continuance of the status
`conference, but also agrees that Plaintiffs should dismiss the complaint with prejudice
`in its entirety
`
`Dated: April 24, 2024
`
`Respectfully submitted,
`HUESTON HENNIGAN LLP
`
`By:
`
`Vicki Chou
`Attorneys for Plaintiffs
`KRAFTON, INC, and KRAFTON
`AMERICAS, INC (f/k/a PUBG
`SANTA MONICA, INC.)
`
`MAYER BROWN LLP
`
`By: /s/ A. John Mancini
`A. John P. Mancini (pro hac vice)
`jmancini@mayerbrown.com
`Paul M. Fakler (pro hac vice)
`pfakler@mayerbrown.com
`Sara A. Slavin (pro hac vice)
`sslavin@mayerbrown.com
`1221 Avenue of the Americas
`New York, NY 10020
`Telephone: (212) 506-2500
`John Nadolenco (SBN: 181128)
`jnadolenco@mayerbrown.com
`350 S. Grand Ave., 25th Floor
`Los Angeles, CA 90071
`- 4 -
`JOINT STATUS REPORT IN ADVANCE OF CONFERENCE
`CASE NO. 2:22-cv-00209-GW-MRW
`
`
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`Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 5 of 6 Page ID #:3502
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`Telephone: (213) 229-9500
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`Attorneys for Defendants
`GOOGLE LLC AND ITS WHOLLY-
`OWNED SUBSIDIARY, YOUTUBE,
`LLC
`
`DAVIS WRIGHT TREMAINE LLP
`
`
`By: /s/ Nicolas A. Jampol
`Nicolas A. Jampol (SBN: 244867)
`nicolasjampol@dwt.com
`865 S. Figueroa Street, 24th Floor
`Los Angeles, CA 900017
`Telephone: (213) 633-6800
`Attorney for Defendant
`Apple Inc.
`
`LEX LUMINA PLLC
`
`
`By: /s/ Mark Lemley
`Mark Lemley
`mlemley@lex-lumina.com
`745 Fifth Avenue, Suite 500
`New York, NY 10151
`Telephone: (646) 898-2055
`Attorney for Defendant
`Garena Online Private Limited
`
`
`
`
`
`
`
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`- 5 -
`JOINT STATUS REPORT IN ADVANCE OF CONFERENCE
`CASE NO. 2:22-cv-00209-GW-MRW
`
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`Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 6 of 6 Page ID #:3503
`Case 2:22-cv-00209-GW-MRW Document 181 Filed 04/24/24 Page 6of6 Page ID #:3503
`
`EXHIBIT A
`EXHIBIT A
`DOCUMENT PROPOSED TO BE
`DOCUMENT PROPOSED TO BE
`FILED UNDER SEAL IN ITS ENTIRETY
`FILED UNDER SEALIN ITS ENTIRETY
`
`
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