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`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.
`
`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.
`
`
`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)
`
`STIPULATION TO AMEND
`COMPLAINT
`
`Judge: Hon. Cormac J. Carney
`
`
`
`
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`Pursuant to Federal Rule of Civil Procedure 15(a)(2) and Local Rules 7-1 and
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`15-1, Plaintiff Network-1 Technologies, Inc. and Defendant Hikvision USA, Inc.,
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`by and through their respective counsel, hereby stipulate and agree as follows:
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`WHEREAS, Plaintiff served its initial Complaint in this action on November
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`Stipulation to Amend Complaint
`2:22-CV-08050 CJC (JDEx)
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`Case 2:22-cv-08050-CJC-JDE Document 23 Filed 04/18/23 Page 2 of 3 Page ID #:120
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`7, 2022;
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`WHEREAS, the Parties have met and conferred regarding the adequacy of
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`the Complaint under Rule 12;
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`WHEREAS, Plaintiff wishes to amend its Complaint in response to those
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`conferences;
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`WHEREAS, Plaintiff does not waive its right to subsequent amendment
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`under Rule 15(a)(1);
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`WHEREAS, Defendant agrees that it would be most efficient for Plaintiff to
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`serve its amended complaint prior to Defendant’s motion, answer, or other response
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`to any complaint in this action;
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`WHEREAS, Defendant’s stipulation is limited to the filing of an amended
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`complaint only, and does not impact any rights, claims, or defenses that Defendant
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`may have and otherwise has no substantive impact on Defendant’s arguments or
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`procedural posture in this case; and
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`THEREFORE, the Parties hereby stipulate under Rule 15(a)(2) that Plaintiff
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`may amend its Complaint at this time, provided that the amendment does not
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`impact Defendant’s rights, claims, or defenses or Defendant’s ability to respond by
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`way of appropriate motion (e.g., Rule 12 motion), and the amendment does not
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`impact Plaintiff’s right to later seek to further amend under Rule 15(a)(1).
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`Plaintiff’s proposed First Amended Complaint is submitted herewith as Exhibit A.
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`Rather than respond to the originally-filed Complaint, Defendant shall have 14 days
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`to respond to the First Amended Complaint once it is filed in accordance with the
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`proposed order.
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`- 2 -
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`Stipulation to Amend Complaint
` 2:22-CV-08050 CJC (JDEx)
`
`
`
`Case 2:22-cv-08050-CJC-JDE Document 23 Filed 04/18/23 Page 3 of 3 Page ID #:121
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`Dated:
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`April 18, 2023
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`Respectfully submitted,
`
`DOVEL & LUNER, LLP
`
`Dated:
`
`
`April 18, 2023
`
`By: /s/ Richard Lyon
`Richard Lyon
`
`Attorneys for Plaintiff
`NETWORK-1 TECHNOLOGIES, INC.
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`Respectfully submitted,
`
`JONES DAY
`
`By: /s/ Alexis Adian Smith
`Alexis Adian Smith
`
`Attorneys for Defendant
`HIKVISION USA, INC.
`
`
`
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`ATTESTATION
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`In accordance with Local Rule 5-4.3.4(a)(2), I attest that concurrence in the
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`filing of this document has been obtained from all other signatories listed and on
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`whose behalf this filing is submitted.
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` /s/ Richard Lyon
`Richard Lyon
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`- 3 -
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`Stipulation to Amend Complaint
` 2:22-CV-08050 CJC (JDEx)
`
`
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