`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`WARD PARTICIPATIONS B.V.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO. LTD.
`and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Defendants.
`
`Civil Action No. 21-cv-00806-ADA
`
`The Honorable Judge Alan D. Albright
`
`JURY TRIAL DEMANDED
`
`STIPULATION FOR EXTENSION OF TIME TO MOVE,
`ANSWER, OR OTHERWISE RESPOND TO COMPLAINT
`
`Plaintiff, Ward Participations B.V. (“Ward Participations” or “Plaintiff”) and Defendants,
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`Samsung Electronics Co., Ltd. (“SEC”) and Samsung Electronics America, Inc. (“SEA”)
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`(collectively, “Defendants”), have stipulated to extend the time within which Defendants are
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`required to move, answer, or otherwise respond to Plaintiff’s complaint.
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`On August 4, 2021, Ward Participations filed a complaint alleging patent infringement by
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`SEC and SEA. (See Dkt. No. 1).
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`On August 13, 2021, Ward Participations served on SEA the summons and complaint.
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`Accordingly, SEA’s deadline to respond to the complaint is September 3, 2021.
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`SEA and SEC have agreed to waive service on SEC, a foreign entity, in exchange for an
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`extension of time for both SEA and SEC to respond to the complaint. The parties have stipulated
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`to extend the time for SEA and SEC to move, answer, or otherwise respond to the complaint
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`through and including January 18, 2022. The parties further agree that SEC is deemed to have
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`been served on August 13, 2021.
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`STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
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`Page 1
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`1
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`SAMSUNG 1023
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`
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`Case 6:21-cv-00806-ADA Document 7 Filed 08/23/21 Page 2 of 3
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`NOW, THEREFORE IT IS HEREBY STIPULATED by and between the parties, through
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`their respective counsel, that the deadline for Defendants, Samsung Electronics Co., Ltd. and
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`Samsung Electronics America, Inc., to move, answer, or otherwise respond to Plaintiff’s complaint
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`is extended to and including January 18, 2022.
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`Dated: August 23, 2021
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`Respectfully submitted,
`
`
`
`
`
`
`
`By: /s/ Erick S. Robinson
`Erick S. Robinson
`Texas Bar No. 24039142
`erobin@porterhedges.com
`Porter Hedges LLP
`1000 Main St., 36th Floor
`Houston, TX 77002
`Telephone: (713) 226-6615
`Mobile: (713) 498-6047
`Fax: (713) 583-9737
`
`By: /s/ David M. Hoffman
`David M. Hoffman
`Texas Bar No. 24046084
`hoffman@fr.com
`FISH & RICHARDSON P.C.
`111 Congress Avenue, Suite 810
`Austin, TX 78701
`Tel: (512) 472-5070
`Fax: (512) 320-8935
`
`COUNSEL FOR PLAINTIFF,
`WARD PARTICIPATIONS B.V.
`
`COUNSEL FOR DEFENDANTS,
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`
`STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
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`Page 2
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`2
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`Case 6:21-cv-00806-ADA Document 7 Filed 08/23/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing document was filed electronically in
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`compliance with Local Rule CV-5(a) on August 23, 2021, and was served via CM/ECF on all
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`counsel who are deemed to have consented to electronic service. Local Rule CV-5(b)(1).
`
`/s/ David M. Hoffman
`David M. Hoffman
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`STIPULATION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
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`Page 3
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`3
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