`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 12-574-LPS
`(consolidated)
`
`JURY TRIAL DEMANDED
`
`)))))))))))))
`
`)))))))))
`
`ROBERT BOSCH LLC,
`
`Plaintiff,
`
`v.
`
`ALBEREE PRODUCTS, INC.,
`API KOREA CO., LTD.,
`SAVER AUTOMOTIVE PRODUCTS, INC.,
`and COSTCO WHOLESALE CORPORATION,
`
`Defendants.
`
`COSTCO WHOLESALE CORPORATION,
`
`Third-Party Plaintiff,
`
`v.
`
`ROBERT BOSCH GMBH,
`
`Third-Party Defendant.
`
`SPECIALLY APPEARING THIRD-PARTY DEFENDANT
`ROBERT BOSCH GMBH’S MOTION TO DISMISS
`
`Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12(b)(5), third-party Defendant
`
`Robert Bosch GmbH (“Bosch GmbH”), by its specially appearing counsel, respectfully submits
`
`this motion to dismiss Costco Wholesale Corporation’s (“Costco”) claims against it asserted in
`
`Costco’s Answer and Counterclaims (D.I. 244) for lack of personal jurisdiction over Bosch
`
`GmbH and improper service. The grounds for this motion are set forth in the accompanying
`
`brief filed contemporaneously herewith.
`
`
`
`Case 1:12-cv-00574-LPS Document 263 Filed 12/04/15 Page 2 of 2 PageID #: 9196
`
`Respectfully submitted,
`
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ David E. Moore
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byrne (#4446)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`sobyrne@potteranderson.com
`
`Attorneys for Plaintiff Robert Bosch LLC
`
`OF COUNSEL:
`
`Mark A. Hannemann
`SHEARMAN & STERLING LLP
`599 Lexington Ave
`New York, NY 10022
`Tel.: (212) 848-4000
`
`Rose Cordero Prey
`Ksenia Takhistova
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004
`Tel.: (212) 425-7200
`
`Dated: December 4, 2015
`1210938 / 39026
`
`2
`
`
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