`
`David A. Ward
` New Jersey Bar No. 042381996
` dward@klugerhealey.com
`KLUGER HEALEY, LLC
`521 Newman Springs Road, Suite 23
`Lincroft, NJ 07738
`Telephone: (973) 307-0800
`Facsimile: (888) 635-1653
`
`M. Scott Fuller
` Texas Bar No. 24036607
` Georgia Bar No. 100968
` sfuller@ghiplaw.com
`Randall Garteiser
` Texas Bar No. 24038912
` California Bar No. 239829
` rgarteiser@ghiplaw.com
`GARTEISER HONEA, PLLC
`119 W. Ferguson Street
`Tyler, Texas 75702
`Telephone: (903) 705-7420
`Facsimile: (888) 908-4400
`
`ATTORNEYS FOR PLAINTIFF
`BETEIRO, LLC
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF NEW JERSEY
`
`
`
`
`Case No. 1:21-cv-020148-CPO-SAK
`
`Motion Date: November 7, 2022
`
`BETEIRO, LLC,
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`
`
`
`
`Plaintiff,
`
` v.
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`DRAFTKINGS, INC.,
`
`
`
`Defendant.
`
`REPLY IN SUPPORT OF MOTION FOR RECONSIDERATION AND RELIEF
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`REPLY IN SUPPORT OF MOTION FOR RECONSIDERATION AND RELIEF
`
`1
`
`
`
`Case 1:21-cv-20148-CPO-SAK Document 30 Filed 10/31/22 Page 2 of 2 PageID: 456
`
`Plaintiff Beteiro, LLC (“Plaintiff” or “Beteiro”) respectfully submits this Reply in Support of its
`
`Motion for Reconsideration and in accordance with Rules 59(e) and 60(b), where both rules provide an
`
`independent reason for this Court to correct its judgment. Indeed, even the Federal Circuit has delayed
`
`its review providing this Court first the opportunity to correct its own mistake.
`
`Plaintiff hereby incorporates and relies upon its concurrently filed Reply in related case Beteiro,
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`LLC v. PointsBet USA, Inc., Case 1:21-cv-20155-CPO-SAK (D.N.J. 2021) for its substantive arguments.
`
`
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`
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`Dated: October 31, 2022
`
`
`Respectfully Submitted
`
`
`
`
`
`/s/ David A, Ward
`David Ward
`KLUGER HEALEY, LLC
`
`M. Scott Fuller (Pro Hac Vice)
` Texas Bar No. 24036607
` sfuller@ghiplaw.com
`Randall Garteiser (Pro Hac Vice)
` Texas Bar No. 24038912
` rgarteiser@ghiplaw.com
`GARTEISER HONEA, PLLC
`119 W. Ferguson Street
`Tyler, Texas 75702
`Telephone: (903) 705-7420
`Facsimile: (888) 908-4400
`
`ATTORNEYS FOR PLAINTIFF
`BETEIRO, LLC
`
`
`
`
`
`REPLY IN SUPPORT OF MOTION FOR RECONSIDERATION AND RELIEF
`
`2
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`
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