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Case 2:14-cv-00111-AJS Document 352 Filed 04/28/15 Page 1 of 2
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
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`DRONE TECHNOLOGIES, INC.,
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` Plaintiff,
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`
`
`
`v.
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`
`PARROT S.A. and PARROT, INC.
`
` Defendants.
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`Civil Action No. 2:14-cv-00111
`
`Judge Arthur J. Schwab
`
`JURY TRIAL DEMANDED
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`ELECTRONICALLY FILED
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`
`DEFENDANTS PARROT S.A. AND PARROT, INC.’S
`MOTION FOR JUDGMENT AS A MATTER OF LAW
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`
`
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`Pursuant to Federal Rule of Civil Procedure 50(a), Defendants Parrot S.A. and Parrot, Inc.
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`(collectively, “Defendants” or “Parrot”) ask this Court to enter judgment as a matter of law in
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`favor of Parrot. This motion incorporates by reference the oral motion under FRCP 50(a) made
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`by counsel James E. Hopenfeld on the record at the end of Plaintiff’s case-in-chief on April 28,
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`2015. In addition, this motion asks this Court to enter judgment as a matter of law that the issue
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`of “future” ongoing royalties is speculative and has not been proven. This motion is supported
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`by the attached Memorandum.
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`Dated: April 28, 2015
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`Respectfully submitted,
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`
`
`/s/ Eric G. Soller
`Eric G. Soller, Esquire
`PA I.D. #65560
`EGS@Pietragallo.com
`Firm I.D. #834
`One Oxford Centre, 38th Floor
`301 Grant Street
`Pittsburgh, PA 15219
`Phone: (412) 263-1836
`Fax: (412) 263-4242
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`
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`COUNSEL FOR DEFENDANTS
`PARROT S.A. AND PARROT, INC.
`
`
`
`James E. Hopenfeld (pro hac vice)
`Attorney-in-Charge
`CA Bar No. 190268
`Hopenfeld@oshaliang.com
`Tammy J. Terry (pro hac vice)
`Texas Bar No. 24045660
`Terry@oshaliang.com
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, TX 77010-1034
`Phone: (713) 228-8600
`Fax: (713) 228-8778
`
`

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`Case 2:14-cv-00111-AJS Document 352 Filed 04/28/15 Page 2 of 2
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`
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`CERTIFICATE OF SERVICE
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`I certify that on April 28, 2015, the foregoing document, Defendants Parrot S.A. and
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`Parrot, Inc.’s Motion for Judgment as a Matter of Law, was filed electronically with the
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`Clerk of the Court using the CM/ECF system, which will send notification of such filing to all
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`counsel of record via email as follows:
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`Richard T. Ting, Esquire
`John C. Thomas III, Esquire
`Charles H. Dougherty, Jr, Esquire
`Gene A. Tabachnick, Esquire
`Clay P. Hughes, Esquire
`Beck & Thomas, P.C.
`1575 McFarland Road
`Suite 100
`Pittsburgh, PA 15216
`412-343-9700
`Fax: 412-343-5787
`Email: rting@beckthomas.com
`jthomas@beckthomas.com
`cdougherty@beckthomas.com
`gtabachnick@beckthomas.com
`chughes@beckthomas.com
`
`By:
`
`
` /s/ Eric G. Soller
`Counsel for Defendants

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