`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`
`
`John P. Schnurer, Bar No. 185725
`JSchnurer@perkinscoie.com
`Yun (Louise) Lu, Bar No. 253114
`LLu@perkinscoie.com
`Kyle R. Canavera Bar No. 314664
`KCanavera@perkinscoie.com
`PERKINS COIE LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130-2080
`Telephone: 858.720.5700
`Facsimile: 858.720.5799
`
`Attorneys for Defendants
`TCT Mobile (US) Inc., Huizhou TCL Mobile
`Communication Co., Ltd., and Shenzhen TCL Creative
`Cloud Technology Co., Ltd.
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`ANCORA TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`vs.
`
`TCT MOBILE (US) INC., HUIZHOU
`TCL MOBILE COMMUNICATION
`CO. LTD., and SHENZHEN TCL
`CREATIVE CLOUD TECHNOLOGY
`CO., LTD.,
`
`Defendants.
`
`TCL’S NOTICE OF MOTION
`AND MOTION TO STAY
`
`
`
`
`
`
`Case No. 8:19-CV-02192-GW-ASx
`(LEAD CASE)
`
`Case No. 2:20-cv-01252-GW-ASx
`(CONSOLIDATED CASE)
`
`Judge: Hon. George H. Wu
`Judge: Hon. Alka Sagar
`
`TCL’S NOTICE OF MOTION
`AND MOTION TO STAY
`
`Case No. 8:19-CV-02192-GW-ASx
`
`
`
`Case 8:19-cv-02192-GW-AS Document 59 Filed 10/14/20 Page 2 of 2 Page ID #:1365
`
`
`PLEASE TAKE NOTICE that on November 12, 2020, at 8:30 a.m., or as
`
`soon as the matter may be heard, in this Court, located at United States Courthouse,
`
`350 West 1st Street, Los Angeles, CA, 90012, Courtroom 9D, 9th Floor,
`
`Defendants (“TCL”) will and hereby do move to stay this case pending inter partes
`
`review proceedings by the Patent Office.
`
`This motion is based upon this notice, the accompanying memorandum of
`
`points and authorities, the declaration of Kyle R. Canavera (and accompanying
`
`exhibits), the proposed order, and upon such other and further matters, papers, and
`
`arguments as may be submitted to the Court.
`
`This motion is made following the conference of counsel pursuant to L.R.
`
`7-3, which took place on September 25, 2020.
`
`Dated: October 14, 2020
`
`Respectfully submitted,
`
`/s/ Kyle R. Canavera
`John P. Schnurer, Bar No. 185725
`JSchnurer@perkinscoie.com
`Yun (Louise) Lu, Bar No. 253114
`LLu@perkinscoie.com
`Kyle R. Canavera, CA Bar No. 314664
`KCanavera@perkinscoie.com
`PERKINS COIE LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130-2080
`Tel.: 858.720.5700
`Fax.: 858.720.5799
`
`
`Attorneys for Defendants
`TCT Mobile (US) Inc., Huizhou TCL Mobile
`Communication Co., Ltd., and Shenzhen TCL
`Creative Cloud Technology Co., Ltd.
`
`-1-
`
`Case No. 8:19-CV-02192-GW-ASx
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`
`
`TCL’S NOTICE OF MOTION
`AND MOTION TO STAY
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
