`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`
`Case No: 1:22-cv-22706-RNS
`
`BELL NORTHERN RESEARCH, LLC,
`
`Plaintiff,
`
`v.
`
`HMD AMERICA, INC., HMD GLOBAL OY,
`SHENZHEN CHINO-E COMMUNICATION
`CO. LTD., WINGTECH TECHNOLOGY
`CO., LTD., WINGTECH
`INTERNATIONAL, INC., BEST BUY CO.,
`INC., BEST BUY STORES L.P., TARGET
`CORP., and WALMART INC.,
`
`Defendants.
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME
`TO SERVE NON- INFRINGMENT, UNENFORCEABILITY, AND INVALIDITY
`CONTENTIONS, AND MAKE ACCOMPANYING DOCUMENT PRODUCTION
`
`Defendants, WINGTECH TECHNOLOGY CO., LTD.
`
`and WINGTECH
`
`INTERNATIONAL, INC. (“WINGTECH” or “Defendants”), by and through its undersigned
`
`counsel and pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, hereby file this
`
`unopposed motion for extension of time and respectfully move the Court for an extension of the
`
`deadline to serve Non-Infringement, Unenforceability, and Invalidity Contentions and make
`
`accompanying document production under Amended Scheduling Order (ECF No. 174). In
`
`support thereof, the Defendant state as follows:
`
`1. Under the Amended Scheduling Order (ECF No. 174), the current deadline to
`
`serve Non-Infringement, Unenforceability, and Invalidity Contentions and make accompanying
`
`
`
`Case 1:22-cv-22706-RNS Document 181 Entered on FLSD Docket 06/09/2023 Page 2 of 4
`
`document production is June 9, 2023.
`
`2. WINGTECH has engaged new counsel who requires additional time to review the
`
`complaint, patents, and other relevant documents in this action as well as time to meet with the
`
`Plaintiff regarding possible resolution of this dispute.
`
`3. Undersigned counsel therefore respectfully requests a twenty one-day (21)
`
`extension of time up to and including Friday, June 30, 2023, in order to properly prepare and
`
`serve Non-Infringement, Unenforceability, and Invalidity Contentions and make accompanying
`
`document production.
`
`4.
`
`This motion is made in a good faith and not in effort to prejudice any party or
`
`delay this matter.
`
`WHEREFORE, Defendants, WINGTECH, respectfully request a 21-day extension of
`
`time through Friday, June 30, 2023 in order to serve Non-Infringement, Unenforceability, and
`
`Invalidity Contentions and make accompanying document production, and for such other and
`
`further relief this Court deems just and proper.
`
`Local Rule 7.1(a)(3) Certificate
`
`Counsel for Wingtech certifies that they have conferred with all parties or non-parties
`
`who may be affected by the relief sought in the motion in a good faith effort to resolve the
`
`issues raised in the motion. Counsel for the Plaintiff, Christopher Clayton, has indicated that
`
`Plaintiff does not oppose the relief sought herein.
`
`2
`
`
`
`Case 1:22-cv-22706-RNS Document 181 Entered on FLSD Docket 06/09/2023 Page 3 of 4
`
`Date: June 9, 2023
`
`Respectfully submitted,
`
`/s/ Andrew Jay Fuller, Esq.
`ANDREW J. FULLER, ESQ.
`Florida Bar No. 1021164
`NELSON MULLINS RILEY & SCARBOROUGH LLP
`2 South Biscayne Boulevard, 21st Floor
`Miami, FL 33131
`Telephone: (305) 373-9487
`Facsimile: (305) 373-9443
`andrew.fuller@nelsonmullins.com
`vicki.mattison@nelsonmullins.co
`
`David M. Airan (pro hac vice)
`Christopher Gass (pro hac vice)
`Nicole E. Kopinski (pro hac vice)
`LEYDIG, VOIT & MAYER, LTD.
`Two Prudential Plaza, Suite 4900
`180 North Stetson Avenue
`Chicago, IL 60601
`Telephone: (312) 616-5600
`Facsimile: (312) 616-5700
`cgass@leydig.com
`dairan@leydig.com
`nkopinski@leydig.com
`
`Attorneys for Defendants Wingtech Technology Co., Ltd.
`and Wingtech International, Inc.
`
`3
`
`
`
`Case 1:22-cv-22706-RNS Document 181 Entered on FLSD Docket 06/09/2023 Page 4 of 4
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that on this 9th day of June, 2023, I electronically filed the
`
`foregoing with the Clerk of Court of the United States District Court using the CM/ECF system
`
`which will send a notice of electronic filing to all counsel of record appearing on the Certificate
`
`of Service generated by the ECF system.
`
`/s/ Andrew J. Fuller, Esquire
`ANDREW J. FULLER, ESQ.
`Florida Bar No. 1021164
`andrew.fuller@nelsonmullins.com
`NELSON MULLINS
`Co-Counsel for Defendants Wingtech Technology Co.,
`Ltd. and Wingtech International, Inc.
`
`4
`
`
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