`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`ADVANCED MICRO DEVICES, INC.; and ATI
`TECHNOLOGIES ULC,
`
`Plaintiffs,
`
`v.
`
`TCL INDUSTRIES HOLDINGS CO., LTD.; TCL
`INDUSTRIES HOLDINGS (H.K.) LIMITED;
`TCL ELECTRONICS HOLDINGS LIMITED;
`TCL TECHNOLOGY GROUP CORPORATION;
`TTE CORPORATION; TCL HOLDINGS (BVI)
`LIMITED; TCL KING ELECTRICAL
`APPLIANCES (HUIZHOU) CO. LTD.;
`SHENZHEN TCL NEW TECHNOLOGIES CO.,
`LTD.; TCL MOKA INTERNATIONAL
`LIMITED; TCL SMART DEVICE (VIETNAM)
`CO., LTD; MANUFACTURAS AVANZADAS
`SA DE CV; TCL ELECTRONICS MEXICO, S
`DE RL DE CV; TCL OVERSEAS MARKETING
`LTD.; and REALTEK SEMICONDUCTOR
`CORP.,
`
`Defendants.
`
`
`
`C. A. NO. 2:22-CV-00134
`
`JURY TRIAL DEMANDED
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME FOR
`PLAINTIFFS ADVANCED MICRO DEVICES, INC. AND ATI TECHNOLOGIES ULC
`TO COMPLY WITH P. R. 3-1 & 3-2 (INFRINGEMENT CONTENTIONS) AND FOR
`DEFENDANT REALTEK SEMICONDUCTOR CORP. TO COMPLY WITH P. R. 3-3 &
`3-4 (INVALIDITY CONTENTIONS) AND STANDING ORDER REGARDING
`SUBJECT-MATTER ELIGIBILITY CONTENTIONS
`
`Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies ULC (collectively,
`
`“AMD”) respectfully request an extension of time as follows:
`
`
`
`
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 32 Filed 07/15/22 Page 2 of 4 PageID #: 298
`
`I.
`
`On July 7, 2022, the Court granted the Parties’ Joint Motion for Extend Deadlines to
`
`Comply with Infringement Contentions, Invalidity Contentions, and Subject-Matter Eligibility
`
`Contentions (Dkt. No. 24), (Dkt. No. 29). The Parties have since met and conferred on an
`
`additional extension.
`
`II.
`
`AMD hereby respectfully moves the Court that the time to comply with P. R. 3-1 & 3-2
`
`(Infringement Contentions) be extended from July 15, 2022 up to and including July 26, 2022.
`
`The deadline for Realtek to comply with P. R. 3-3 & 3-4 (Invalidity Contentions) and to comply
`
`with the Standing Order Regarding Subject-Matter Eligibility Contentions would be extended from
`
`September 9, 2022 up to and including September 20, 2022.
`
`Current Deadline New Deadline
`July 15, 2022
`July 26, 2022
`
`September 9, 2022
`
`September 9, 2022
`
`Description
`Comply with P.R. 3-1 & 3-2 (Infringement
`Contentions)
`September 20, 2022 Comply with P.R. 3-3 & 3-4
`Contentions)
`September 20, 2022 Comply with Standing Order Regarding Subject-
`Matter Eligibility Contentions
`
`
`(Invalidity
`
`III.
`
`Plaintiffs have conferred with counsel for Realtek, and counsel is unopposed to the
`
`extension. Plaintiffs do not file this Motion for the purpose of delay, but rather to allow the Parties
`
`to adequately address the issues associated with the pending contentions, related issues, and in
`
`order that justice be done.
`
`
`
`2
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 32 Filed 07/15/22 Page 3 of 4 PageID #: 299
`
`Dated: July 15, 2022
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`By: /s/ Eric H. Findlay
`Eric H. Findlay
`State Bar No. 00789886
`Brian Craft
`State Bar No. 04972020
`FINDLAY CRAFT, P.C.
`102 N. College Ave. Suite 900
`Tyler, Texas 75702
`Tel: (903) 534-1100
`Fax: (903) 534-1137
`Email: efindlay@findlaycraft.com
`Email: bcraft@findlaycraft.com
`
`Michael T. Renaud
`James M. Wodarski
`Michael J. McNamara
`Adam S. Rizk
`William Meunier
`Marguerite McConihe
`Matthew A. Karambelas
`Catherine Xu
`Tianyi Tan
`MINTZ LEVIN COHN FERRIS
` GLOVSKY AND POPEO PC
`One Financial Center
`Boston, MA 02111
`617-542-6000
`
`Attorneys for Plaintiffs
`Advanced Micro Devices, Inc. and ATI
`Technologies ULC
`
`
`CERTIFICATE OF SERVICE
`
` The undersigned hereby certifies that on July 15, 2022, all counsel of record who are
`
`
`
`
`
`deemed to 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).
`
`/s/ Eric H. Findlay
` Eric H. Findlay
`
`
`
`3
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 32 Filed 07/15/22 Page 4 of 4 PageID #: 300
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that all counsel of record have met and conferred in
`
`accordance with Local Rule CV-7(h) and Plaintiffs’ motion is unopposed.
`
`
`
`/s/ Eric H. Findlay
` Eric H. Findlay
`
`
`
`
`
`4
`
`
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