`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`HOLOGIC, INC., a Delaware corporation; and
`CYTYC SURGICAL PRODUCTS, LLC, a
`Massachusetts limited liability company,
`
`C.A. No. 20-925-JFB-SRF
`
`Plaintiffs,
`
`v.
`
`MINERVA SURGICAL, INC., a Delaware
`corporation,
`
`DEFENDANT MINERVA SURGICAL, INC.’S MOTION FOR STAY
`
`Defendant Minerva Surgical, Inc. (“Defendant” or “Minerva”) hereby requests a stay of
`
`the above-captioned litigation pending exhaustion of the appeals in Hologic, Inc. et al v. Minerva
`
`Surgical, Inc., Civ. No. 15-1031 (D. Del.) (the “First Action”). The grounds for Defendant’s
`
`motion are set forth in a contemporaneously filed brief.
`
`Pursuant to D. Del. LR 7.1.1, on January 12, 2021 at 3:30 p.m., lead counsel and
`
`Delaware counsel for the parties met and conferred by telephone and made a good-faith effort to
`
`reach agreement on the matters set forth in this motion but were unable to agree. Plaintiffs
`
`oppose this motion.
`
`WHEREFORE, Defendants respectfully request the Court to enter the attached order
`
`granting this motion.
`
`
`
`Case 1:20-cv-00925-JFB-SRF Document 60 Filed 01/22/21 Page 2 of 2 PageID #: 1382
`
`Dated: January 22, 2021
`
`Respectfully submitted,
`
`WILSON SONSINI GOODRICH &
`ROSATI, P.C.
`
`
`/s/ Ian R. Liston
`Ian R. Liston (#5507)
`222 Delaware Avenue, Suite 800
`Wilmington, DE 19801
`(302) 304-7600
`iliston@wsgr.com
`
`Counsel for Defendant Minerva Surgical,
`Inc.
`
`Of Counsel:
`
`Vera M. Elson
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`(650) 493-9300
`velson@wsgr.com
`
`Edward G. Poplawski
`Olivia M. Kim
`Erik J. Carlson
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`633 West Fifth Street, 15th Floor
`Los Angeles, CA 90071
`(323) 210-2900
`epoplawski@wsgr.com
`okim@wsgr.com
`ecarlson@wsgr.com
`
`- 2 -
`
`
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