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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)
`
`AMENDED DECLARATION OF
`RICHARD LYON IN SUPPORT OF
`JOINT AND UNOPPOSED
`MOTION TO CONTINUE THE
`HEARING ON DEFENDANT’S
`PARTIAL MOTION TO DISMISS
`AND CORRESPONDING REPLY
`BRIEF
`
`Judge: Hon. Cormac J. Carney
`
`
`
`
`Amended Declaration of Richard Lyon in
`Support of Joint and Unopposed Motion to
`Continue Hearing
`
`
`
`Case No. 2:22-CV-08050 CJC (JDEx)
`
`
`
`Case 2:22-cv-08050-CJC-JDE Document 32-2 Filed 05/22/23 Page 2 of 2 Page ID #:399
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`I, Richard Lyon, declare as follows:
`
`
`
`1.
`
` I am a partner at the law firm of Dovel & Luner, counsel for Plaintiff
`
`Network-1 Technologies. I submit this declaration in support of the joint and
`
`unopposed Motion to Continue the hearing on Defendant’s Partial Motion to
`
`Dismiss and corresponding Reply Brief, filed herewith. I know the facts stated
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`herein to be true based upon my own personal knowledge or upon my review of the
`
`records and files Dovel & Luner maintains in the regular course of its
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`representation of the plaintiff. If called and sworn as a witness, I could and would
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`testify competently thereto.
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`
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`2.
`
`Good cause exists to continue the hearing and deadline. This morning,
`
`the parties reached an agreement in principle to settle the case. Continuing the
`
`dates will allow the parties to conserve resources and draft a settlement agreement
`
`over the next three weeks.
`
`
`
`3. On May 22, 2023, Plaintiff’s counsel and counsel for Hikvision USA,
`
`Inc. consented to this motion.
`
`
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Executed on May 22, 2023 at Santa Monica, California
`
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`/s/ Richard Lyon
`Richard Lyon
`
`
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`
`
`
`
`
`
`Amended Declaration of Richard Lyon in
`Support of Joint and Unopposed Motion to
`Continue Hearing
`
`
`1
`
`Case No. 2:22-CV-08050 CJC (JDEx)
`
`
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