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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
`ARENDI S.A.R.L.,
`
`
`Plaintiff,
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`
`v.
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`GOOGLE LLC,
`
`
`Defendant.
`
`C.A. No. 13-919-LPS
`
`))))))))))
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`MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
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`Plaintiff Arendi S.A.R.L. (“Plaintiff”) respectfully moves for leave to file an Amended
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`Complaint against Defendant Google LLC (“Defendant”), pursuant to Federal Rules of Civil
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`Procedure 15(a)(2) and 15(d). The proposed Amended Complaint is attached as Exhibit 1, and a
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`black-lined version indicating changes introduced by the Amended Complaint is attached as
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`Exhibit 2. The grounds for this amendment are set forth in the accompanying opening letter brief
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`filed by Plaintiff.
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`
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`Pursuant to D. Del. LR 7.1.1, counsel for Plaintiff has conferred with counsel for
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`Defendant regarding the filing of this Motion. Defendant opposes the Motion.
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`
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`Case 1:13-cv-00919-LPS Document 89 Filed 11/19/18 Page 2 of 2 PageID #: 903
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`
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`Dated: November 19, 2018
`
`Of Counsel:
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`John P. Lahad
`Susman Godfrey LLP
`1000 Louisiana Street
`Suite 5100
`Houston, TX 77002
`P 713-653-7859
`jlahad@susmangodfrey.com
`
`Stephen D. Susman
`Seth Ard
`Susman Godfrey LLP
`1301 Avenue of the Americas
`32nd Floor
`New York, NY 10019-6023
`P 212-471-8354
`ssusman@susmangodfrey.com
`sard@susmangodfrey.com
`
`
`
`
`SMITH, KATZENSTEIN & JENKINS, LLP
`
`/s/ Eve H. Ormerod
`Neal C. Belgam (No. 2721)
`Eve H. Ormerod (No. 5369)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`eormerod@skjlaw.com
`
`
`Attorneys for Plaintiff
`
`
`2
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`
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