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`REPLY IN SUPPORT OF MOTION TO STAY PROCEEDINGS AND DISMISS CUVTA CLAIM FOR LACK OF
`TRANSFER AND PROCEDURAL DEFECT
`Case No. 3:22-cv-01490-JST
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`Lauri Valjakka (Pro Se)
`Arinakatu 2 B38
`FI 53100 Lappeenranta
`Finland
`+358 50 467 0090
`lauri.valjakka@eezykeyz.fi
`
`Filed on behalf of Pro Se
`LAURI VALJAKKA
`
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
`LAURI VALJAKKA,
`Plaintiff,
`v.
`NETFLIX, INC.,
`Defendant.
` Case No. 4:22-cv-01490-JST
`
`REPLY IN SUPPORT OF MOTION TO
`STAY PROCEEDINGS AND DISMISS
`CUVTA CLAIM FOR LACK OF
`TRANSFER AND PROCEDURAL
`DEFECT AND [PROPOSED] ORDER
`
`
`Date: December 4, 2025
`Time: 2:00 p.m.
`Crtrm: 6 – 2nd Floor
`Judge: Hon. Jon S. Tigar
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`Case 4:22-cv-01490-JST Document 352 Filed 10/16/25 Page 1 of 4
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`REPLY IN SUPPORT OF MOTION TO STAY PROCEEDINGS AND DISMISS CUVTA CLAIM FOR LACK OF
`TRANSFER AND PROCEDURAL DEFECT
`Case No. 3:22-cv-01490-JST
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`I. INTRODUCTION
`Plaintiff respectfully submits this Reply in support of his Motion to Stay Proceedings. Netflix’s
`opposition mischaracterizes the Finnish Supreme Court proceeding and overstates authentication
`demands. The requested stay is narrow, time-limited, and designed to conserve judicial resources while
`a sovereign court resolves a dispositive ownership issue.
`II. THE FINNISH SUPREME COURT ORDER IS MATERIAL
`The Finnish Supreme Court has accepted review of ownership of the U.S. application. That
`proceeding is active and outcome-determinative. Its resolution will directly affect standing and
`ownership in this litigation. Proceeding here without awaiting that ruling risks inconsistent outcomes.
`III. RESPONSE TO NETFLIX’S OPPOSITION POINTS
`A. Relevance.
`Netflix argues the Finnish proceeding is irrelevant. In fact, it is central: ownership of the U.S.
`application is under judicial review abroad.
`B. Delay.
`Netflix claims Plaintiff seeks delay. Plaintiff has already filed Attachments 1–14 documenting
`the Finnish proceedings. A stay avoids duplicative litigation and waste.
`C. Authentication.
`Netflix demands full certified translations within seven days. That is impracticable. Plaintiff
`proposes a reasonable 7/21/35-day schedule, ensuring orderly authentication without prejudice.
`D. Witnesses.
`Netflix claims witnesses are unavailable. Its own Initial Disclosures (Exhibits A–C) show
`multiple witnesses remain available. Plaintiff’s references were only to highlight selective choices.
`E. Prejudice.
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`REPLY IN SUPPORT OF MOTION TO STAY PROCEEDINGS AND DISMISS CUVTA CLAIM FOR LACK OF
`TRANSFER AND PROCEDURAL DEFECT
`Case No. 3:22-cv-01490-JST
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` Netflix claims prejudice. The proposed stay is conditional, capped at twelve months, and
`subject to regular status reports. Netflix suffers no prejudice; the Court avoids inconsistent rulings.
`IV. RELIEF REQUESTED
` Plaintiff respectfully requests a conditional stay limited to ownership-related discovery and
`filings, subject to the simple authentication schedule below.
`V. SIMPLE AUTHENTICATION SCHEDULE
`• Within 7 days: Status declaration identifying Finnish document(s) and whether originals are in
`hand or requested.
`• Within 21 days: Filing of Finnish source document(s) under seal if available, or proof of
`registry request.
`• Within 35 days: Certified English translation of core pages, plus one authenticity declaration.
`• Every 60 days: Status reports while Finnish matter remains pending.
`• Duration: Stay not to exceed twelve months absent further order, terminating earlier upon
`dispositive Finnish ruling.
`VI. CONCLUSION
`The Finnish proceeding is active and material. A short, conditional stay preserves judicial
`economy, avoids duplication, and respects sovereign processes. Plaintiff respectfully requests entry of
`the proposed order.
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`Dated: October 16, 2025 Respectfully submitted,
`
`/s/ Lauri Valjakka
`Lauri Valjakka (pro se)
`Arinakatu 2 B38
`FI 53100 Lappeenranta
`Finland
`+358 50 467 0090
`lauri.valjakka@eezykeyz.fi
`
`LAURI VALJAKKA, Pro Se
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`REPLY IN SUPPORT OF MOTION TO STAY PROCEEDINGS AND DISMISS CUVTA CLAIM FOR LACK OF
`TRANSFER AND PROCEDURAL DEFECT
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`[PROPOSED] ORDER
`Having considered Plaintiff’s Motion to Stay, Defendant’s Opposition, and Plaintiff’s Reply, the
`Court finds good cause to grant a conditional stay.
`IT IS HEREBY ORDERED that:
`1. A conditional stay is GRANTED as to ownership-related discovery and filings, subject to the
`following schedule:
`o Within 7 days: Plaintiff files a status declaration.
`o Within 21 days: Plaintiff files Finnish source document(s) or proof of registry request.
`o Within 35 days: Plaintiff files certified English translation(s) and one authenticity
`declaration.
`o Plaintiff files status reports every 60 days while the Finnish matter remains pending.
`2. The stay shall not exceed twelve months absent further order and shall terminate earlier upon
`filing of a dispositive Finnish ruling.
`IT IS SO ORDERED.
`
`
`Date Hon. Jon S. Tigar United States District Judge
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