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Case 6:11-cv-00096-LED Document 390 Filed 06/13/13 Page 1 of 3 PageID #: 10504
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`Plaintiff TracBeam, LLC (“TracBeam”), Defendants MetroPCS Communications, Inc.
`
`and MetroPCS Wireless Inc. (collectively, “MetroPCS”), and Plaintiff/Consolidated Defendant
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`TeleCommunication Systems, Inc. (“TCS”) respectfully move the Court to dismiss without
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`prejudice (1) TracBeam’s claims and counterclaims against MetroPCS and TCS and (2) the
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`claims and counterclaims asserted by TCS and MetroPCS against TracBeam in the above-
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`captioned cases.
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`
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`
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`CASE NO. 6:11-cv-96 (LED)
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`Jury Trial Demanded
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`
`
`CASE NO. 6:12-cv-58 (LED)
`
`Jury Trial Demanded
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`
`
`
`
` Plaintiff,
`
`
`vs.
`
`TRACBEAM, L.L.C.,
`
` Defendant.
`
`Joint Motion to Dismiss without prejudice claims and counterclaims between TracBeam,
`MetroPCS, and TCS
`
`
`
`TRACBEAM, L.L.C.,
`
`
`
` Plaintiff,
`
`
`vs.
`
`AT&T INC., et al,
`
` Defendant.
`
`TELECOMMUNICATION SYSTEMS,
`INC.,
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`
`
`
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`
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`T-Mobile / TCS / Ericsson EXHIBIT 1021
`T-Mobile / TCS / Ericsson v. TracBeam
`
`

`
`Case 6:11-cv-00096-LED Document 390 Filed 06/13/13 Page 2 of 3 PageID #: 10505
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`
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`The parties further move that each party shall bear its own costs, expenses, and attorneys’
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`
`
`
`
`
`
`Respectfully submitted,
`By: /s/ Jeff Eichmann
`John Jeffrey Eichmann
`(admitted to practice before the U.S. District
`Court for the Eastern District of Texas)
`CA State Bar No. 227472
`Email: jeff@dovellaw.com
` (admitted to practice before the U.S.
`District Court for the Eastern District of
`Texas)
`
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone: 310-656-7066
`Facsimile: 310-657-7069
`
`Attorneys for TracBeam, LLC
`
`
`
`
`
`/s/ E. Glenn Thames, Jr.
`E. Glenn Thames, Jr.
`E. Glenn Thames, Jr.
`Texas Bar No. 00785097
`glennthames@potterminton.com
`POTTER MINTON, P.C.
`110 N. College Avenue, Suite 500
`Tyler, Texas 75702
`Telephone: 903-597-8311
`Facsimile: 903-593-0846
`
`Edward A. Pennington (pro hac vice)
`Stephanie D. Scruggs (pro hac vice)
`Siddhesh V. Pandit (pro hac vice)
`SMITH, GAMBRELL & RUSSELL,
`LLP
`1055 Thomas Jefferson Street, N.W.
`Suite 400
`Washington, D.C. 20007
`Telephone: 202-263-4300
`Facsimile: 202-263-4348
`epennington@sgrlaw.com
`
` 2
`
`fees.
`
`Dated: June 13, 2013
`
`
`
`
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`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
`
`T-Mobile / TCS / Ericsson EXHIBIT 1021
`T-Mobile / TCS / Ericsson v. TracBeam
`
`

`
`Case 6:11-cv-00096-LED Document 390 Filed 06/13/13 Page 3 of 3 PageID #: 10506
`
`
`sscruggs@sgrlaw.com
`spandit@sgrlaw.com
`Attorneys for Defendants
`MetroPCS Communications, Inc. and
`MetroPCS Wireless, Inc.
`
`Attorneys for Consolidated Defendant
`TeleCommunication Systems, Inc.
`
`
` /s/ Jeff Eichmann
`John Jeffrey Eichmann
`
`
`
`
` 3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that counsel of record who are deemed to have consented to electronic
`service are being served this 13th day of June 2013, with a copy of this document via the Court’s
`CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by
`electronic mail, facsimile transmission and/or first class mail on this same date.
`
`T-Mobile / TCS / Ericsson EXHIBIT 1021
`T-Mobile / TCS / Ericsson v. TracBeam

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