`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`UNILOC USA, INC. ET AL,
`Plaintiffs,
`v.
`
`MOTOROLA MOBILITY LLC,
`
`
`SNAP INC.,
`Defendants
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`2:16-cv-00992-JRG
`LEAD CASE
`
`2:16-cv-00696-JRG
`MEMBER CASE
`
`
`
`JOINT MOTION FOR EXTENSION
`
`
`
`Plaintiffs, Uniloc USA, Inc. and Uniloc Luxembourg, S.A. (together, “Uniloc”) and
`
`Defendant Snap Inc. file this Joint Motion for Extension and show as follows:
`
`1.
`
`Currently pending before the court are Snap Inc.’s motion to dismiss or transfer
`
`venue (Dkt. 35, Member Case) and motion to stay (Dkt. 150, Lead Case). Uniloc’s deadline to
`
`respond to both motions is Friday, June 16, 2017.
`
`2.
`
`On June 8, 2017, Uniloc noticed depositions of two Snap Inc. employees who
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`Uniloc believes have knowledge relevant to Snap Inc.’s motion to dismiss or transfer venue,
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`among other things. The depositions were noticed for June 21 and June 22.
`
`3.
`
`On June 13, 2017, this Court entered an order in Uniloc USA, Inc. v. Samsung
`
`Electronics America, Inc., Case No. 2:16-cv—00642-JRG (Dkt. No. 268) (E.D. Tex. June 13,
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`2017) dismissing all pending motions without prejudice and staying the case pending Inter Partes
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`Review (the “IPR”) of certain patents-in-suit, including patents-in-suit in this case.
`
`4.
`
`The parties are evaluating how to proceed in light of the June 13, 2017 order.
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`1
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`
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`Case 2:16-cv-00992-JRG Document 159 Filed 06/15/17 Page 2 of 3 PageID #: 1280
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`5.
`
`To avoid expense and burdening the court with what may become unnecessary
`
`motion practice, while the parties evaluate how to proceed in light of the June 13, 2017 order,
`
`Uniloc and Snap Inc. have agreed to (1) extend Uniloc’s deadline to respond to Snap Inc.’s pending
`
`motions (Dkt. Nos. 35 and 150) by two weeks; and (2) withdrawing Uniloc’s notices of depositions
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`without re-noticing them for at least two weeks.
`
`6.
`
`The parties have agreed to seek this extension not for delay but so that justice can
`
`be served.
`
`Therefore, the parties respectfully request that this Court extend Uniloc’s deadline to
`
`respond to Snap Inc.’s motion to dismiss or transfer venue (Dkt. 35, Member Case) and motion to
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`stay (Dkt. 150, Lead Case) to June 30, 2017.
`
`
`
`
`
`Dated: June 15, 2017
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Travis Richins
`James L. Etheridge
`Texas State Bar No. 24059147
`Ryan S. Loveless
`Texas State Bar No. 24036997
`Brett A. Mangrum
`Texas State Bar No. 24065671
`Travis Lee Richins
`Texas State Bar No. 24061296
`ETHERIDGE LAW GROUP, PLLC
`2600 E. Southlake Blvd., Suite 120 / 324
`Southlake, Texas 76092
`Telephone: (817) 470-7249
`Facsimile: (817) 887-5950
`Jim@EtheridgeLaw.com
`Ryan@EtheridgeLaw.com
`Brett@EtheridgeLaw.com
`Travis@EtheridgeLaw.com
`ATTORNEYS FOR UNILOC
`
`
`
`
`2
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`
`
`Case 2:16-cv-00992-JRG Document 159 Filed 06/15/17 Page 3 of 3 PageID #: 1281
`
`
`By: /s/ Reuben Chen __________
`Reuben H. Chen
`COOLEY LLP
`3175 Hanover Street
`Palo Alto, CA 94304
`Tel: (650) 843-5000
`Fax: (650) 843-7400
`rchen@cooley.com
`Deron R. Dacus
`Texas Bar No. 00790553
`THE DACUS FIRM, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, TX 75701
`Tel: (903) 705-1117
`Fax: (903) 705-1117
`ddacus@dacusfirm.com
`Attorneys for Defendant
`Snap Inc.
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
` I
`
` certify that on June 15, 2017 the foregoing document was served upon all counsel of
`record via the court’s electronic filing system in accordance with the Federal Rules of Civil
`Procedure.
`
`
`/s/ Travis Richins
`Travis Richins
`
`
`
`
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`CERTIFICATE OF CONFERENCE
`
`
`Counsel for Snap Inc. has indicated that Snap Inc. is unopposed to this motion.
`
`/s/ Travis Richins
`Travis Richins
`
`
`
`3
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`
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