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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
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`CASE NO. 1:22-cv-22706-RNS
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`Plaintiff,
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`BELL NORTHERN RESEARCH, LLC,
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`v.
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`HMD AMERICA, INC., HMD GLOBAL OY,
`SHENZHEN CHINO-E COMMUNICATION CO.
`LTD., HON HAI PRECISION INDUSTRY CO.,
`LTD, TINNO MOBILE TECHNOLOGY CORP.,
`SHENZHEN TINNO MOBILE CO., LTD., TINNO
`USA, INC., UNISOC TECHNOLOGIES CO. LTD.,
`SPREADTRUM COMMUNICATIONS USA, INC.,
`WINGTECH TECHNOLOGY CO. LTD.,
`WINGTECH INTERNATIONAL, INC., HUAQIN
`CO. LTD., BEST BUY CO., INC., BEST BUY
`STORES L.P., TARGET CORP., WALMART INC.,
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`Defendants.
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`___________________________________________/
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`NOTICE OF INTENT TO FILE OPPOSITION TO PLAINTIFF’S MOTION FOR
`ALTERNATIVE SERVICE
`Defendant Huaqin Co. Ltd., through undersigned counsel, hereby files this notice that it
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`intends to submit a response in opposition to Plaintiff Bell Northern Research, LLC’s (“BNR”)
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`motion for leave to effect alternative service (ECF No. 71) within the timeframe applicable under
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`the Local Rules (or as otherwise ordered by the Court). Huaqin files this notice in an abundance
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`of caution because on a prior occasion, in a related case that BNR later dismissed, BNR filed an
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`ex parte motion for alternative service regarding Huaqin that was granted and that, we submit,
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`failed to properly set out grounds for alternative service where, as here, the defendant is located in
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`Case 1:22-cv-22706-RNS Document 72 Entered on FLSD Docket 11/21/2022 Page 2 of 2
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`a country that has signed onto the Hague Service Convention. See Bell Northern Research, LLC v.
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`hmd America, Inc., Case No. 22-cv-21035-RNS (S. D. Fla.) (ECF Nos. 44, 45).
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`As a result, Huaqin intends to file an opposition to the motion for alternative service and it
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`respectfully requests that the Court not rule on the Plaintiff’s motion until Huaqin has filed its
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`response in opposition within the timeframe permitted under the Local Rules.
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`Date: November 21, 2022
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`Respectfully Submitted,
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`MARCUS NEIMAN
`RASHBAUM & PINEIRO LLP
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`By: /s/ Michael A. Pineiro
`Michael A. Pineiro
`Fla. Bar No. 41897
`mpineiro@mnrlawfirm.com
`One Biscayne Tower
`2 South Biscayne Boulevard, Suite 2530
`Miami, Florida 33131
`Telephone: (305) 400-4260
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`Counsel for Defendant Huaqin Co. Ltd.
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`CERTIFICATE OF SERVICE
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`I hereby certify that on November 21, 2022, a true and correct copy of the foregoing Notice
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`of Appearance was served via CM/ECF on all counsel or parties of record on the Service List.
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`/s/ Michael A. Pineiro
`By:
` Michael A. Pineiro
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