`
`Justin T. Quinn
`ROBINSON MILLER LLC
`One Newark Center, 19th Floor
`Newark, New Jersey 07102
`973-690-5400
`jquinn@rwmlegal.com
`
`Attorneys for Defendants
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`
`WAG Acquisition, L.L.C.,
`
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`Multi Media, L.L.C., et al.,
`
`
`
`
`
`
`
`Defendants.
`
`WAG Acquisition, L.L.C.,
`
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`Data Conversions, Inc., et al.,
`
`
`
`
`
`
`
`Defendants.
`
`Civil Action No. 2:14-cv-02340
`(ES)(MAH)
`
`Hearing Date: August 21, 2017
`
`NOTICE OF JOINT MOTION
`TO DISMISS OR, IN THE
`ALTERNATIVE, MOTION TO
`TRANSFER VENUE
`
`
`
`Civil Action No. 2:14-cv-02345
`(ES)(MAH)
`
`
`
`
`
`
`Case 2:14-cv-02340-ES-MAH Document 153 Filed 07/28/17 Page 2 of 4 PageID: 2921
`
`
`
`Civil Action No. 2:14-cv-02674
`(ES)(MAH)
`
`
`
`
`
`
`Civil Action No. 2:14-cv-02832
`(ES) (MAH)
`
`
`
`
`Civil Action No. 2:14-cv-03456
`(ES)(MAH)
`
`
`
`Civil Action No.2:14-cv-04531
`(ES)(MAH)
`
`WAG Acquisition, L.L.C.,
`
`
`
`Plaintiff,
`
`v.
`
`Flying Crocodile, Inc., et al.,
`
`
`
`
`
`
`
`Defendants.
`
`WAG Acquisition, L.L.C.,
`
`
`
`Plaintiff,
`
`v.
`
`Gattyán Group S.à r.l., et al.,
`
`
`
`
`
`
`
`Defendants.
`
`WAG Acquisition, L.L.C.,
`
`
`
`Plaintiff,
`
`v.
`
`FriendFinder Networks Inc., et al.,
`
`
`
`
`
`
`
`Defendants.
`
`WAG Acquisition, L.L.C.,
`
`
`
`Plaintiff,
`
`v.
`
`Vubeology, Inc., et al.,
`
`
`
`
`
`
`
`Defendants.
`
`
`
`Case 2:14-cv-02340-ES-MAH Document 153 Filed 07/28/17 Page 3 of 4 PageID: 2922
`
`
`
`Civil Action No.2:15-cv-03581
`(ES)(MAH)
`
`WAG Acquisition, L.L.C.,
`
`
`
`Plaintiff,
`
`v.
`
`WebPower, Inc., d/b/a WP Associates
`
`et al.,
`
`
`
`
`
`
`
`Defendants.
`
`
`TO:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`William T. Walsh, Clerk
`United States District Court
`District of New Jersey
`Martin Luther King Building
`& U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07102
`
`Ronald Abramson, Esq.
`Lewis Baach Kaufmann Middlemiss PLLC
`The Chrysler Building
`405 Lexington Avenue, 62nd Floor
`New York, New York 10174
`
`PLEASE TAKE NOTICE that Defendants FriendFinder Networks Inc.,
`
`Streamray Inc., Multi Media, LLC, WMM, LLC, WMM Holdings, LLC,
`
`WebPower, Inc., Accretive Technology Group, Inc., ICF Technology, Inc., Riser
`
`Apps LLC, Vubeology, Inc., Duodecad IT Services Luxembourg S.à r.l., and Docler
`
`Media LLC (collectively, “Defendants”), by and through their respective attorneys,
`
`hereby move for an Order dismissing the above-captioned matters or, in the
`
`alternative, transferring them to their proper venues in light of the Supreme Court’s
`
`
`
`Case 2:14-cv-02340-ES-MAH Document 153 Filed 07/28/17 Page 4 of 4 PageID: 2923
`
`decision in TC Heartland, and pursuant to Fed. R. Civ. P. 12(b)(3) and 28
`
`U.S.C. §§ 1400(b), 1406.
`
`
`
`PLEASE TAKE FURTHER NOTICE that, in support of this joint motion,
`
`Defendants will rely upon the accompanying memorandum of law, the attendant
`
`party Declarations, and all other pleadings and memoranda on file in this matter.
`
`
`
`PLEASE TAKE FURTHER NOTICE that a proposed form of Order is
`
`submitted herewith.
`
`
`
`PLEASE TAKE FURTHER NOTICE that a Certification attesting to the
`
`date and manner of service also is submitted herewith.
`
`PLEASE TAKE FURTHER NOTICE that oral argument is requested.
`
`
`
`
`
`Dated: July 28, 2017
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`s/ Justin T. Quinn
`Justin T. Quinn
`ROBINSON MILLER LLC
`One Newark Center
`Newark, NJ 07102
`Telephone No.: (973) 690-5400
`Facsimile No.: (973) 466-2760
`JQuinn@rwmlegal.com
`
`Attorneys for Defendants FriendFinder Networks
`Inc., Streamray Inc., Multi Media, LLC, WMM, LLC
`WMM Holdings, LLC, WebPower, Accretive
`Technology Group, Inc., ICF Technology Group,
`Inc., Riser Apps, LLC, Duodecad IT Services
`Luxembourg S.à r.l. and Docler Media LLC
`
`
`
`
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