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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`SEAGEN INC.,
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`CIVIL ACTION NO. 2:20-cv-00337
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`Plaintiff,
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`v.
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`JURY TRIAL DEMANDED
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`DAIICHI SANKYO CO., LTD.,
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`Defendant.
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`UNOPPOSED MOTION FOR ORAL HEARING
`REGARDING MOTION TO COMPEL DAIICHI SANKYO CO., LTD.’S DISCOVERY
`RESPONSES AND PRODUCTION (DKT. 58)
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`Plaintiff Seagen Inc. respectfully requests a hearing on its Motion to Compel Daiichi
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`Sankyo Co., Ltd.’s Discovery Responses and Production (Dkt. 58).
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`The Court granted Plaintiff’s motion to expedite briefing on the Motion to Compel in light
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`of Defendant’s pending Motion to Dismiss for Lack of Subject Matter Jurisdiction and Lack of
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`Personal Jurisdiction (Dkt. 22) and Motion to Transfer on the Basis of Inconvenience under 28
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`U.S.C. § 1404 to the District of Delaware (Dkt. 24). The Order directed Defendants to file a
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`response to the Motion to Compel on or before February 26, 2021, without an allowance for a
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`reply or surreply. The Motion to Compel is now fully briefed. (Dkts. 58 & 60.).
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`Accordingly, Plaintiff requests a hearing on its Motion to Compel. Plaintiff has conferred
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`with Defendant—and while Defendant does not join in this request, it does not oppose it either.1
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`1 Although Defendant does not oppose Plaintiff’s Motion for a Hearing on its Motion to Compel,
`Defendant maintains its position that this Court lacks subject matter and personal jurisdiction, and
`therefore the Court does not possess the jurisdiction to preside over Plaintiff’s motion. (See Dkt.
`No. 22.) Further, as the Plaintiff’s Motion to Compel requests additional jurisdictional and venue
`discovery that it seeks for use in supplementing its responses to the Defendant’s Motion to Dismiss
`(Dk. 22) and Motion to Transfer (Dkt. 24), these three motions are connected and thus would
`benefit from being heard collectively at one hearing.
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`Case 2:20-cv-00337-JRG Document 71 Filed 04/13/21 Page 2 of 3 PageID #: 2443
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`Dated: April 13, 2021
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`Respectfully submitted,
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`/s/ Melissa R. Smith
`Michael A. Jacobs
`MJacobs@mofo.com
`Matthew A. Chivvis
`MChivvis@mofo.com
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, CA 94105
`Telephone: 415.268.7000
`Facsimile: 415.268.7522
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`Bryan Wilson
`BWilson@mofo.com
`Pieter S. de Ganon
`PdeGanon@mofo.com
`MORRISON & FOERSTER LLP
`755 Page Mill Road
`Palo Alto, California 94304-1018
`Telephone: 650.813.5600
`Facsimile: 650.494.0792
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`Melissa R. Smith
`State Bar No. 24001351
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`melissa@gillamsmithlaw.com
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`Of Counsel:
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`T. John Ward, Jr.
`Texas State Bar No. 00794818
`jw@wsfirm.com
`Charles Everingham IV
`Texas State Bar No. 00787447
`ce@wsfirm.com
`Andrea L. Fair
`Texas State Bar No. 24078488
`andrea@wsfirm.com
`WARD, SMITH & HILL, PLLC
`1507 Bill Owens Parkway
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`2
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`Case 2:20-cv-00337-JRG Document 71 Filed 04/13/21 Page 3 of 3 PageID #: 2444
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`Longview, Texas 75604
`Telephone: 903.757.6400
`Facsimile: 903.757.2323
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`Attorneys for Plaintiff Seagen Inc.
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`CERTIFICATE OF SERVICE
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`I hereby certify that counsel of record who are deemed to have consented to electronic
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`service are being served this 13th day of April, 2021, with a copy of this document via the Court’s
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`CM/ECF system per Local Rule CV-5(a)(3).
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`/s/ Melissa R. Smith
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that the Parties have met and conferred regarding this Motion on April 12,
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`2021. This motion is unopposed.
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`/s/ Melissa R. Smith
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