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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF CONNECTICUT
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`LEGO SYSTEM A/S,
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`DEFENDANTS’ RESPONSE TO PLAINTIFF’S SECOND MOTION FOR
`LEAVE TO AMEND ITS COMPLAINT TO ADD ADDITIONAL DEFENDANTS.
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`Pursuant to Federal Rule of Civil Procedure Rule 12 and 15, Defendants Rubicon
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`Communications, LP DBA SmallWorks and SmallWorks, LLC (“Defendants”) hereby
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`respond to Plaintiff’s Second Motion for Leave to Amend its Complaint to Add Additional
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`Defendants (“Motion to Amend”). Attached are Defendants’ Memorandum of Law in
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`support of this Response (Ex. A), excerpts from the Deposition of James Thompson
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`(Ex. B – filed under seal), the Certificate of Formation of SmallWorks, LLC (Ex. C), the
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`Declaration of James Thompson (Ex. D), excerpts from the Deposition of Jamie
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`Thompson (Ex. E – filed under seal), and the Declaration of Jamie Thompson (Ex. F).
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`Defendants believe that it is not necessary to add Rubicon Communications LLC as a
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`party defendant, but in light of recent discovery, Defendants will not object to Plaintiff’s
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`Motion to Amend as it pertains to adding Rubicon Communications, LLC as an
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`additional defendant. For the reasons stated in the accompanying Memorandum of
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`Law, however, Defendants respectfully request that Plaintiff’s Motion to Amend be
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`denied as it pertains to adding Jamie and James Thompson as individual defendants.
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`CIVIL ACTION NO. 15-CV-00823-VLB
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`JURY TRIAL DEMANDED
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`FEBRUARY 24, 2017
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` Plaintiff/Counterclaim-Defendant,
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`V.
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` Defendants/Counterclaim Plaintiffs.
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`RUBICON COMMUNICATIONS, LP DBA
`SMALLWORKS AND SMALLWORKS,
`LLC,
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`Case 3:15-cv-00823-VLB Document 57 Filed 02/24/17 Page 2 of 2
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`DATED: February 24, 2017
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`Respectfully Submitted,
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`By: /s/ Ryan T. Beard__________
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`Eric B. Meyertons
` emeyertons@intprop.com
`Dwayne Goetzel
` dgoetzel@intprop.com
`Ryan T. Beard
` rbeard@intprop.com
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`MEYERTONS, HOOD, KIVLIN,
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` KOWERT & GOETZEL, P.C.
`1120 South Capital of Texas Hwy.
`Building 2, Suite 300
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`Austin, Texas 78746
`(512) 853-8800 (telephone)
`(512) 853-8801 (facsimile)
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`Stephen P. McNamara
`smcnamara@ssjr.com
`ST. ONGE STEWARD JOHNSTON & REENS LLC
`986 Bedford Street
`Stamford, Connecticut 06905-5619
`Telephone: (203) 541-4508
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`Attorneys for Defendant/Counterclaim-Plaintiff
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`CERTIFICATE OF SERVICE
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` I
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` hereby certify that on February 24, 2017, I electronically filed the foregoing pleading
`with the clerk of Court using the electronic case filing system of the Court.
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`/s/ Ryan T. Beard_____________________
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`Ryan T. Beard
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`-2-
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