`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 22-311-WCB
`
`JURY TRIAL DEMANDED
`
`))))))))))
`
`IMPOSSIBLE FOODS INC.,
`
`Plaintiff,
`
`v.
`
`MOTIF FOODWORKS, INC. and
`GINKGO BIOWORKS, INC.,
`
`Defendants.
`
`PLAINTIFF IMPOSSIBLE FOODS INC.’S MOTION FOR LEAVE TO AMEND ITS
`IDENTIFICATION OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`REGARDING THE YEAST PATENTS
`
`Pursuant to the Court’s prior guidance that Impossible Food Inc. (“Impossible”) could
`
`move to amend its identification of asserted claims for good cause (D.I. 161 at 2), Impossible
`
`hereby moves for Leave to Amend its Identification of Asserted Claims and Infringement
`
`Contentions Regarding the Yeast Patents. The grounds for this Motion are set forth in
`
`Impossible’s Opening Brief in Support of this Motion.
`
`Pursuant to Rule 7.1.1 of the Local Rules of the United States District Court for the District
`
`of Delaware, Counsel for Plaintiff hereby certifies that a reasonable effort has been made to reach
`
`agreement between the parties on this Motion. Counsel for the parties, including Delaware
`
`counsel, met and conferred, and the parties were unable to reach agreement.
`
`
`
`Case 1:22-cv-00311-WCB Document 526 Filed 06/05/24 Page 2 of 2 PageID #: 28169
`
`Respectfully submitted,
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Andrew M. Moshos
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`amoshos@potteranderson.com
`
`Attorneys for Plaintiff Impossible Foods Inc.
`
`OF COUNSEL:
`
`Wendy L. Devine
`Kristina M. Hanson
`Shannon P. Gillespie McComb
`Jessica Ramsey
`Joyce K. Yao
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`Tel: (415) 947-2000
`
`Matthew R. Reed
`Jeffrey Nall
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`Tel: (650) 493-9300
`
`Lori P. Westin
`Natalie J. Morgan
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`12235 El Camino Real
`San Diego, CA 92130
`Tel: (858) 350-2300
`
`Michael T. Rosato
`Sonja R. Gerrard
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104
`Tel: (206) 883-2529
`
`Matthew Macdonald
`WILSON SONSINI GOODRICH &
`ROSATI, P.C.
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`Tel: (323) 210-2953
`
`Dated: June 5, 2024
` 11391525 / 20200.00002
`
`2
`
`
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