`14028
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`v.
`
`CHARTER COMMUNICATIONS, INC. et al.,
`
`Defendants.
`
`
`
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`v.
`
`COMCAST CABLE COMMUNICATIONS,
`LLC D/B/A XFINITY, et al.,
`
`Defendants.
`
`
`
`
`
`Lead Case No. 2:23-cv-00059-JRG-RSP
`Member Case No. 2:23-cv-00062-JRG-
`RSP
`
`JURY TRIAL DEMANDED
`
`
`TOUCHSTREAM’S UNOPPOSED MOTION FOR LEAVE TO FILE EXHIBITS THAT
`EXCEED PAGE LIMITS RELATED TO TOUCHSTREAM’S MOTION TO COMPEL
`ADDITIONAL DISCOVERY ON COMCAST’S SUPPLEMENTAL DISCLOSURES
`
`Plaintiffs Touchstream Technologies Inc. (“Touchstream,”) moves for leave to exceed the 5-
`
`page limit for attachments to discovery motions established by the Court’s Discovery Order.
`
`Touchstream Technologies, Inc. v. Altice USA Inc. et al., 2:23-cv-00060-JRG, Dkt. 72, ¶ 9(b) (former
`
`consolidated docket). Touchstream requests that the Court waive the five (5) page limit for the four
`
`(4) exhibits Touchstream anticipates attaching to its Motion to Compel Additional Discovery on
`
`Comcast’s Supplemental Disclosures. Good cause for this extension exists because multiple exhibits
`
`1
`
`
`
`Case 2:23-cv-00059-JRG-RSP Document 311 Filed 02/06/25 Page 2 of 3 PageID #:
`14029
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`
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`are needed to provide the full history of the dispute and provide the Court with the interrogatories and
`
`deposition testimony at issue. The parties have conferred and agree a 15-page limit is appropriate for
`
`this motion and response thereto.
`
`Date: February 6, 2025
`
`
`
`________
`
`Respectfully submitted,
`
`/s/ Ryan D. Dykal
`Lead Counsel
`
`Ryan D. Dykal (pro hac vice)
`Jordan T. Bergsten (pro hac vice)
`Mark Schafer (pro hac vice)
`Philip A. Eckert (pro hac vice)
`Anita Liu (TX State Bar No. 24134054)
`BOIES SCHILLER FLEXNER LLP
`1401 New York Ave, NW
`Washington, DC, DC 20005
`(t) 202-274-1109
`rdykal@bsfllp.com
`jbergsten@bsfllp.com
`mschafer@bsfllp.com
`peckert@bsfllp.com
`aliu@bsfllp.com
`
`John Michael Lyons (pro hac vice)
`Sabina Mariella (pro hac vice)
`Sophie Roytblat (pro hac vice)
`BOIES SCHILLER FLEXNER LLP
`55 Hudson Yards, 20th Floor
`New York, NY 10001
`jlyons@bsfllp.com
`smariella@bsfllp.com
`sroytblat@bsfllp.com
`
`Rachel Martin (pro hac vice)
`BOIES SCHILLER FLEXNER LLP
`333 Main Street
`Armonk, NY 10504
`rmartin@bsfllp.com
`
`Melissa Smith (TX State Bar No. 24001351)
`GILLAM & SMITH LLP
`303 S. Washington Ave.
`Marshall, TX 75670
`(t) 903-934-8450
`
`2
`
`
`
`Case 2:23-cv-00059-JRG-RSP Document 311 Filed 02/06/25 Page 3 of 3 PageID #:
`14030
`
`
`
`
`
`melissa@gillamsmithlaw.com
`
`Counsel for Plaintiff Touchstream Technologies, Inc.
`
`
`CERTIFICATE OF SERVICE
`
`I, Ryan D. Dykal, declare under penalty of perjury that a true and correct copy of the foregoing
`
`Motion to Compel was filed on February 6, 2025 by means of the U.S. District Court for the Eastern
`
`District of Texas’s Case Management/Electronic Case Filing (CM/ECF), which will send notification
`
`of such filing by electronic mail to all ECF participants.
`
`
`
`CERTIFICATE OF CONFERENCE
`
`By: /s/ Ryan D. Dykal
`Ryan D. Dykal
`
`Counsel for the parties complied with the meet and confer requirements of Local Rule CV7(h)
`
`and Comcast does not oppose Touchstream’s motion for leave to file excess pages.
`
`
`
`
`
`By: /s/ Ryan D. Dykal
`Ryan D. Dykal
`
`3
`
`
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