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Case 2:17-cv-04273-JVS-JCG Document 71-1 Filed 05/11/18 Page 1 of 3 Page ID #:954
`
`
`
`RUSS AUGUST & KABAT
`Brian D. Ledahl (SBN 186579)
`bledahl@raklaw.com
`Neil A. Rubin (SBN 250761)
`nrubin@raklaw.com
`Jacob R. Buczko (SBN 269408)
`jbuczko@raklaw.com
`Paul A. Kroeger (SBN 229074)
`pkroeger@raklaw.com
`Minna Chan (SBN 305941)
`mchan@raklaw.com
`12424 Wilshire Boulevard, 12FL
`Los Angeles, California 90025
`310/826-7474 – Telephone
`310/826-6991 – Facsimile
`
`Attorneys for Plaintiff
`Document Security Systems, Inc.
`
`
`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRICT OF CALIFORNIA
`
`
` Case No. 2:17-cv-04273-JVS-JCG
`
`[PROPOSED] ORDER GRANTING
`JOINT MOTION FOR DISMISSAL
`WITHOUT PREJUDICE OF
`WILLFUL INFRINGEMENT
`CLAIMS AGAINST DEFENDANTS
`EVERLIGHT ELECTRONICS CO.,
`LTD., AND EVERLIGHT
`AMERICAS, INC.
`
`DOCUMENT SECURITY SYSTEMS,
`INC.,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`EVERLIGHT ELECTRONICS CO.,
`LTD., and EVERLIGHT AMERICAS,
`INC.,
`
`
`Defendants.
`
`
`
`
`
`
`
`
`[PROPOSED] ORDER GRANTING JOINT MOTION FOR DISMISSAL WITHOUT
`PREJUDICE OF WILLFUL INFRINGEMENT CLAIMS AGAINST DEFENDANTS
`EVERLIGHT ELECTRONICS CO., LTD., AND EVERLIGHT AMERICAS, INC.
`
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`RUSS, AUGUST & KABAT
`
`

`

`Case 2:17-cv-04273-JVS-JCG Document 71-1 Filed 05/11/18 Page 2 of 3 Page ID #:955
`
`
`
`
`
`On this day, pursuant to Fed. R. Civ. P. 41(a)(2), Plaintiff Document Security
`
`Systems, Inc. (“DSS”) and Defendants Everlight Electronics Co., Ltd. and Everlight
`
`Americas, Inc. (“collectively, “Everlight”) jointly moved to dismiss DSS’s willful
`
`infringement claims against Everlight without prejudice to reinstate and with no
`
`award of fees or costs, pursuant to Everlight’s agreement that it will not assert that
`
`this dismissal precludes or otherwise bars any possible future willful infringement
`
`claims by DSS against Everlight, including willful infringement claims involving
`
`any of the same patents or claims underlying the instant action.
`
`
`
`The Court, having considered this request, hereby GRANTS the parties’ joint
`
`motion and ORDERS that DSS’s willful infringement claims be dismissed against
`
`Everlight without prejudice to reinstate and with no award of fees or costs. It is
`
`further ORDERED that this dismissal does not preclude or otherwise bar any
`
`possible future willful infringement claims by DSS against Everlight.
`
`IT IS SO ORDERED.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Hon. James V. Selna
`United States District Court Judge
`
`
`
`
`1
`
`[PROPOSED] ORDER GRANTING JOINT MOTION FOR DISMISSAL WITHOUT
`PREJUDICE OF WILLFUL INFRINGEMENT CLAIMS AGAINST DEFENDANTS
`EVERLIGHT ELECTRONICS CO., LTD., AND EVERLIGHT AMERICAS, INC.
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`RUSS, AUGUST & KABAT
`
`

`

`Case 2:17-cv-04273-JVS-JCG Document 71-1 Filed 05/11/18 Page 3 of 3 Page ID #:956
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was filed electronically
`
`in compliance with Local Rule CV-5(a). As such, this document was served on all
`
`counsel who have consented to electronic service on the date of filing.
`
`
`
`
`
`DATED: May 11, 2018
`
`
`By: /s/ Brian D. Ledahl
`Brian D. Ledahl
`
`
`
`
`
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`CERTIFICATE OF SERVICE
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`RUSS, AUGUST & KABAT
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`

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