`
`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
`
`JOINT MOTION FOR EXTENSION OF TIME REGARDING CERTAIN DEADLINES
`
`Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies ULC (collectively,
`
`“AMD”) and Defendant Realtek Semiconductor Corp. (“Realtek”) respectfully request an
`
`extension of time as follows:
`
`I.
`
`On July 19, 2022, the Court held a scheduling conference for this case. The deadline for
`
`the Parties to file a Proposed Docket Control Order and Proposed Discovery Order is August 2,
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 41 Filed 08/02/22 Page 2 of 4 PageID #: 477
`
`2022. The deadline for the Parties to file a Proposed Protective Order and Comply with Paragraphs
`
`1 & 3 of the Discovery Order (Initial and Additional Disclosures) is August 9, 2022.
`
`II.
`
`The parties have conferred and agree to a fourteen (14) day extension for both deadlines
`
`indicated above. The deadline for the Parties to file a Proposed Docket Control Order and Proposed
`
`Discovery Order would be extended from August 2, 2022 up to and including August 16, 2022.
`
`The deadline for the Parties to file a Proposed Protective Order and Comply with Paragraphs 1 &
`
`3 of the Discovery Order (Initial and Additional Disclosures) would be extended from August 9,
`
`2022 up to and including August 23, 2022.
`
`Current Deadline New Deadline
`August 2, 2022
`August 16, 2022
`
`August 9, 2022
`
`August 23, 2022
`
`Description
`File Proposed Docket Control Order and Proposed
`Discovery Order
`File Proposed Protective Order and Comply with
`Paragraphs 1 & 3 of the Discovery Order (Initial
`and Additional Disclosures)
`
`
`III.
`
`The Parties submit that good cause exists for requesting these extensions. Realtek submits
`
`that (i) on August 1, 2022, the Court granted Plaintiffs’ Motion for Alternative Service on Realtek,
`
`and Plaintiffs served Realtek pursuant to the Court’s Order later the same day, and (ii) now that
`
`Realtek has been served, the extensions will allow the parties time to meet and confer regarding
`
`the Docket Control Order, Discovery Order, and other upcoming deadlines. AMD further submits
`
`that the extensions are appropriate in view of the pending Plaintiffs’ Motion for Discretionary Stay
`
`of Remainder of Action Pending Final Determination by the International Trade Commission of
`
`Investigation No. 337-TA-1318, Dkt. 37. Realtek will be filing its Opposition to AMD’s Motion
`
`2
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 41 Filed 08/02/22 Page 3 of 4 PageID #: 478
`
`for Discretionary Stay on August 5, 2022.The Parties do not file this Joint Motion for the purpose
`
`of delay, but rather to allow that justice be done.
`
`
`
`Dated: August 2, 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
`
`
`
`By: /s/ J. Mark Mann
`J. Mark Mann
`State Bar No. 12926150
`Mark@TheMannFirm.com
`
`3
`
`
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 41 Filed 08/02/22 Page 4 of 4 PageID #: 479
`
`G. Blake Thompson
`State Bar No. 24042033
`Blake@TheMannFirm.com
`MANN | TINDEL | THOMPSON
`201 E. Howard St.
`Henderson, Texas 75654
`(903) 657-8540
`(903) 657-6003 (fax)
`
`Attorneys for Defendant Realtek Semiconductor
`Corp.
`
`
`
`CERTIFICATE OF SERVICE
`
` The undersigned hereby certifies that on August 2, 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
`
`
`
`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 the parties jointly request the relief sought herein.
`
`
`
`/s/ Eric H. Findlay
` Eric H. Findlay
`
`
`
`
`
`4
`
`
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