`
`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-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`JOINT MOTION FOR EXTENSION OF TIME TO FILE
`PROPOSED PROTECTIVE ORDER
`
`COME NOW, Plaintiffs Advanced Micro Devices, Inc. and ATI Technologies ULC
`
`(collectively, “AMD”) and Defendant Realtek Semiconductor Corp. (“Realtek”) and show the
`
`Court as follows:
`
`The current deadline for the Parties to submit a Proposed Protective Order with statement
`
`of disputed positions, and Initial and Additional Disclosures is September 2, 2022. The parties
`
`are proceeding to exchange Initial and Additional Disclosures today, September 2, 2022.
`
`The Parties have exchanged drafts of proposed protective order provisions but respectfully
`
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 57 Filed 09/02/22 Page 2 of 3 PageID #: 852
`
`request additional time to meet and confer and narrow any remaining differences and disputes.
`
`The Parties respectfully request a brief two (2) business day extension of this deadline up to and
`
`including September 7, 2022. The Parties will not request any further extensions on the submission
`
`of a proposed protective order and disputed portions thereof.
`
`Respectfully submitted,
`
`By: /s/ J. Mark Mann
`J. Mark Mann
`State Bar No. 12926150
`G. Blake Thompson
`State Bar No. 24042033
`MANN | TINDEL | THOMPSON
`201 E. Howard Street
`Henderson, Texas 75654
`Tel: (903) 657-8540
`Fax: (903) 657-6003
`Email: Mark@TheMannFirm.com
`Email: Blake@TheMannFirm.com
`
`Attorneys for Defendant Realtek
`Semiconductor Corp.
`
`Dated: September 2, 2022
`
`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
`Samuel F. Davenport
`William A. Meunier
`Marguerite McConihe
`Matthew A. Karambelas
`Catherin Xu
`Nana Liu
`Tianyi Tan
`MINTZ LEVIN COHN FERRIS
` GLOVSKY AND POPEO PC
`One Financial Center
`Boston, MA 02111
`617-542-6000
`
`Jonathan J. Engler
`MINTZ LEVIN COHN FERRIS
` GLOVSKY AND POPEO PC
`555 12th Street NW, Suite 1100
`Washington, DC 20004
`202-434-7446
`
`
`
`2
`
`
`
`
`Case 2:22-cv-00134-JRG-RSP Document 57 Filed 09/02/22 Page 3 of 3 PageID #: 853
`
`
`
`
`
`
`Attorneys for Plaintiffs ATI Technologies ULC
`and Advanced Micro Devices, Inc.
`
`
`
`CERTIFICATE OF CONFERENCE
`
`I hereby certify that counsel for the Parties met and conferred and this motion is joint.
`
`/s/ Eric H. Findlay
`Eric H. Findlay
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on September 2, 2022, the within document was filed with the Clerk
`
`of the Court using CM/ECF which will send notification of such filing to the attorneys of record
`
`in this case.
`
` /s/ Eric H. Findlay____
`Eric H. Findlay
`
`
`
`
`3
`
`
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