`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`§
`§
`§ Case No. 2:16-cv-00992-JRG
`§
`
`LEAD CASE
`§
`§
`§ Case No. 2:16-cv-00990-JRG
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`UNILOC USA, INC., et al,
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`Plaintiffs,
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`
`v.
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`
`
`MOTOROLA MOBILITY LLC,
`KYOCERA INTERNATIONAL, INC.,
`
`Defendants.
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`
`
`JOINT MOTION TO CONTINUE THE STAY BETWEEN PLAINTIFFS AND
`DEFENDANT KYOCERA INTERNATIONAL, INC. PENDING FINALIZATION OF
`SETTLEMENT
`
`
`Plaintiffs Uniloc USA, Inc., and Uniloc Luxembourg, S.A. (together “Uniloc”), and
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`
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`Defendant Kyocera International, Inc. (“Kyocera”), hereby jointly file this Joint Motion to
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`Continue the Stay with respect to the stay currently in place between Uniloc and Kyocera
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`pending finalization of settlement.
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`
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`The parties have reached an agreement to settle the case, and are in the process of
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`finalizing payment under the written settlement agreement. The parties wish to conclude the
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`settlement without burdening the Court with any additional filings and without incurring
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`unnecessary expense. The parties believe that this can be accomplished within fourteen (14)
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`days.
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`Accordingly, Uniloc and Kyocera respectfully request that the Court grant a 14-day stay
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`of proceedings between them, including all deadlines, until June 29, 2017.
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`
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`The parties submit that good cause exists for granting this agreed motion, as set forth
`
`above. This motion is not filed for purposes of delay, but so that justice may be served.
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`A proposed order granting this Joint Motion is attached.
`
`
`
`Case 2:16-cv-00992-JRG Document 160 Filed 06/15/17 Page 2 of 3 PageID #: 1284
`
`
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`Wherefore, Plaintiffs Uniloc and Defendant Kyocera, jointly, respectfully request that the
`
`Court enter the proposed order submitted with this Motion as set forth above, and grant the
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`parties such other and further relief to which they are entitled.
`
`
`Date: June 15, 2017
`
`
`
`
`
`
`
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`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`/s/ Kevin Gannon
`Paul J. Hayes
`Kevin Gannon
`Aaron S. Jacobs
`Prince Lobel Tye LLP
`One International Place - Suite 3700
`Boston, MA 02110
`Tel: 617-456-8000
`Email: phayes@princelobel.com
`Email: kgannon@princelobel.com
`Email: ajacobs@princelobel.com
`
`Edward R. Nelson III
`ed@nelbum.com
`Texas State Bar No. 00797142
`Anthony M. Vecchione
`anthony@nelbum.com
`Texas State Bar No. 24061270
`NELSON BUMGARDNER PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`Phone: (817) 377-9111
`
`ATTORNEYS FOR THE PLAINTIFFS
`
`
`2
`
`
`
`Case 2:16-cv-00992-JRG Document 160 Filed 06/15/17 Page 3 of 3 PageID #: 1285
`
`
`
`
`
`
`
`/s/ Thomas W. Ritchie
`David L. Witcoff
`Lead Attorney
`Illinois State Bar No. 06183629
`dlwitcoff@jonesday.com
`Marc S. Blackman
`Illinois State Bar No. 06236719
`msblackman@jonesday.com
`Thomas W. Ritchie
`Illinois State Bar No. 06301954
`twritchie@jonesday.com
`JONES DAY
`77 West Wacker
`Chicago, Illinois 60601-1692
`Telephone: (312) 782-3939
`
`Attorneys for Defendant
`Kyocera International, Inc.
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`I hereby certify that all counsel of record who have consented to electronic service are
`being served with a copy of this document via the Court’s CM/ECF system per Local Rule CV-
`5(a)(3) on June 15, 2017.
`
`
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`/s/ Thomas W. Ritchie
`
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`3
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`
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