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`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
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`Plaintiff,
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`v.
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`PHILIPS NORTH AMERICA LLC,
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`FITBIT LLC,
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`Defendant.
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`C.A. No. 1:19-cv-11586-FDS
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`JOINT MOTION TO EXTEND DEADLINE TO FILE OPPOSITIONS
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`Plaintiff Philips North America LLC (“Philips”) and Defendant Fitbit LLC (“Fitbit”)
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`respectfully jointly move the Court to extend the deadline to file Oppositions to the Motions for
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`Summary Judgment filed on March 2, 2022. On March 2, 2022, Fitbit and Philips filed their
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`respective motions requesting summary judgement (Dkt. Nos. 329, 331, 333, 335, and 336). Per
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`Local Rule 56.1, oppositions to motions for summary judgment must be filed within 21 days after
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`the motion is served setting the deadline for Oppositions to the aforementioned motions as March
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`23, 2022. The parties have met and conferred and, due to the amount of briefing involved in the
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`summary judgment motions, request a seven day extension to March 30, 2022 to file their
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`respective Oppositions.
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`This joint motion is supported by good cause. Specifically the extension will allow for
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`adequate time to prepare and file Oppositions to the summary judgment motions. Further, the
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`extension will not impact any other deadlines in this matter and will not cause prejudice or delay
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`in this action as no hearing date has yet been set for these motions. Further, all parties have agreed
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`to this extension request.
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`Case 1:19-cv-11586-FDS Document 358 Filed 03/17/22 Page 2 of 4
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`Therefore, for good cause shown, the parties respectfully request that the Court extend
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`the deadline to file Oppositions to Dkt. Nos. 329, 331, 333, 335, and 336 to March 30, 2022.
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`Dated: March 17, 2022
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`Respectfully submitted,
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`PHILIPS NORTH AMERICA LLC,
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`By its attorneys,
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`/s/ John W. Custer
`Ruben Rodrigues (BBO 676,573)
`Lucas I. Silva (BBO 673,935)
`John W. Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
`rrodrigues@foley.com
`lsilva@foley.com
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`Eley O. Thompson (pro hac vice)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
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`FITBIT LLC,
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`By Its Attorneys,
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`/s/ David J. Shaw
`David J. Shaw (pro hac vice)
`dshaw@desmaraisllp.com
`DESMARAIS LLP
`1701 Pennsylvania Ave., NW, Suite 200
`Washington, D.C. 20006
`Telephone: (202) 451-4900
`Facsimile: (202) 451-4901
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`Karim Z. Oussayef (pro hac vice)
`koussayef@desmaraisllp.com
`Leslie M. Spencer (pro hac vice)
`lspencer@desmaraisllp.com
`Brian D. Matty (pro hac vice)
`bmatty@desmaraisllp.com
`Henry L. Ard (pro hac vice)
`hard@desmaraisllp.com
`DESMARAIS LLP
`230 Park Avenue
`New York, NY 10169
`Telephone: (212) 351-3400
`Facsimile: (212) 351-3401
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`Ameet A. Modi (pro hac vice)
`amodi@desmaraisllp.com
`DESMARAIS LLP
`101 California Street
`San Francisco, CA 94111
`Telephone: (415) 573-1900
`Facsimile: (415) 573-1901
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`2
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`Case 1:19-cv-11586-FDS Document 358 Filed 03/17/22 Page 3 of 4
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`Gregory F. Corbett (BBO # 646394)
`Elizabeth A. DiMarco (BBO#681921)
`WOLF, GREENFIELD & SACKS, P.C. 600
`Atlantic Avenue
`Boston, MA 02110
`Telephone: (617) 646-8000
`Facsimile: (617) 646-8646
`gcorbett@wolfgreenfield.com
`edimarco@wolfgreenfield.com
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`Case 1:19-cv-11586-FDS Document 358 Filed 03/17/22 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing document was filed with
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`the Court through the ECF system and that a copy will be electronically served on registered
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`participants as identified on the Notice of Electronic Filing.
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`/s/ John W. Custer
`John W. Custer
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