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`Alexis Adian Smith (SBN 274429)
`asmith@jonesday.com
`JONES DAY
`555 South Flower Street
`Fiftieth Floor
`Los Angeles, CA 90071
`Telephone: +1.213.489.3939
`Facsimile: +1.213.243.2539
`Attorneys for Defendant
`HIKVISION USA, INC.
`
`Gregory Dovel (SBN 135387)
`Email: greg@dovel.com
`Richard Lyon (SBN 229288)
`Email: rick@dovel.com
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone: 1.310.656.7066
`
`Attorneys for Plaintiff
`NETWORK-1 TECHNOLOGIES, INC.
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`NETWORK-1 TECHNOLOGIES,
`INC.,
`
`Plaintiff,
`
`v.
`HIKVISION USA, INC.,
`Defendant.
`
`Case No. 2:22-CV-08050 CJC(JDEx)
`FIFTH STIPULATION TO
`EXTEND TIME TO RESPOND TO
`INITIAL COMPLAINT
`Judge: Hon. Cormac J. Carney
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`Complaint Served: Nov. 7, 2022
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`Current Response Date: Mar. 27, 2023
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`New Response Date: Apr. 24, 2023
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`5th Stipulation to Extend Time to Respond to
`Initial Complaint 2:22-CV-08050 CJC (JDEx)
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`Case 2:22-cv-08050-CJC-JDE Document 20 Filed 03/23/23 Page 2 of 3 Page ID #:108
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`In accordance with Local Rule 8-3, Plaintiff Network-1 Technologies, Inc.
`and Defendant Hikvision USA, Inc., by and through their respective counsel,
`hereby stipulate to a fifth extension of time for Defendant to respond to Plaintiff’s
`Initial Complaint (“Complaint”). Defendant’s current extended deadline to respond
`to the Complaint is March 27, 2023.
`Good cause exists for this extension. Since the filing of the Complaint, the
`parties have been in communication exploring resolution and the parties continue to
`discuss resolution of this case. The parties are also conferring regarding
`Defendant’s anticipated motion to dismiss and are working to stipulate to permit
`Plaintiff to file an amended complaint prior to Defendant’s need to respond to the
`original Complaint. For those reasons, and also to conserve resources of both the
`Court and the parties, the parties stipulate to extend the date for Defendant to
`respond to the Complaint, and respectfully request that the Court enter an order so
`extending the response from March 27, 2023, to April 24, 2023.
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`- 2 -
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`5th Stipulation to Extend Time to Respond to
`Initial Complaint 2:22-CV-08050 CJC (JDEx)
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`Case 2:22-cv-08050-CJC-JDE Document 20 Filed 03/23/23 Page 3 of 3 Page ID #:109
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`Dated:
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`March 23, 2023
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`Dated:
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`March 23, 2023
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`Respectfully submitted,
`JONES DAY
`
`By: /s/ Alexis A. Smith
`Alexis Adian Smith
`Attorneys for Defendant
`HIKVISION USA, INC.
`
`Respectfully submitted,
`DOVEL & LUNER, LLP
`
`
`
`By: /s/ Richard Lyon
`Richard Lyon
`Attorneys for Plaintiff
`NETWORK-1 TECHNOLOGIES, INC.
`
`ATTESTATION
`In accordance with Local Rule 5-4.3.4(a)(2), I attest that concurrence in the
`filing of this document has been obtained from all other signatories listed and on
`whose behalf this filing is submitted.
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`/s/ Alexis A. Smith
`Alexis Adian Smith
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`- 3 -
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`5th Stipulation to Extend Time to Respond to
`Initial Complaint 2:22-CV-08050 CJC (JDEx)
`
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