`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Civil Action No. 2:15-cv-1381
`JRG/RSP
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`RYUJIN FUJINOMAKI, Pro Se
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`Plaintiff,
`
`vs.
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`GOOGLE INC., SAMSUNG ELECTRONICS
`CO.LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., SAMSUNG
`TELECOMMUNICATIONS AMERICA,
`LLC., MOTOROLA MOBILITY
`HOLDINGS, INC., MOTOROLA
`MOBILITY LLC, LG ELECTRONICS INC.,
`LG ELECTRONICS MOBILECOMM
`U.S.A., INC., LG ELECTRONICS U.S.A.,
`INC., AUSTEK COMPUTER INC., ASUS
`COMPUTER INTERNATIONAL, INC., and
`HUAWEI TECHNOLOGIES CO., LTD.
`Defendants.
`
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`UNOPPOSED MOTION OF HUAWEI TECHNOLOGIES CO., LTD., FOR EXTENSION
`OF TIME TO RESPOND TO COMPLAINT FOR PATENT INFRINGEMENT
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`Defendants Huawei Technologies Co., Ltd. (“Defendant”), without waiving any defenses
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`described or referenced in Federal Rule of Civil Procedure 12, file this unopposed Motion for
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`Extension of Time to Respond to Ryujin Fujinomaki’s Complaint for Patent Infringement.
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`Plaintiff filed his Complaint on July 31, 2015, naming Huawei Technologies Co. Ltd. as a
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`defendant. Defendant Huawei Technologies Co., Ltd. is a Chinese entity wholly located in China.
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`Defendant Huawei Technologies Co. Ltd. agreed to waive service via The Hague Convention in
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`exchange for an extension of time to respond to the Complaint. Specifically, Defendant requests an
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`extension of time to November 23, 2015 to answer, move, or otherwise respond to the Complaint.
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`Plaintiff does not oppose this Motion.
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`For the foregoing reasons, Defendant respectfully requests that this Court grant an extension
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`SAMSUNG, ET AL. V. FUJINOMAKI
`FUJINOMAKI EX2003 - 1
`Huawei's Motion for Extension of Time
`IPR2017-01017
`
`
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`Case 2:15-cv-01381-JRG-RSP Document 23 Filed 10/16/15 Page 2 of 2 PageID #: 498
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`of time until and including November 23, 2015, for Defendant to respond to the Complaint for Patent
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`Infringement.
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`Respectfully submitted,
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`
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`
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`/s/ K.D. Shull
`K.D. Shull
`Texas Bar No. 24033067
`Huawei Technologies USA Inc.
`5700 Tennyson Parkway, Suite 500
`Plano, TX 75024
`Telephone: 214-919-6001
`E-mail: kd.shull@huawei.com
`
`ATTORNEY FOR DEFENDANT
`HUAWEI TECHNOLOGIES CO., LTD.
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`CERTIFICATE OF SERVICE
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`
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`The undersigned certifies that the foregoing document was filed electronically in compliance with
`Local Rule CV-5(a). All other counsel of record not deemed to have consented to electronic service
`were served with a true and correct copy of the foregoing by electronic mail on this the 19th day of
`September, 2015.
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`
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`/s/ K.D. Shull
`K.D. Shull
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`SAMSUNG, ET AL. V. FUJINOMAKI
`FUJINOMAKI EX2003 - 2
`Huawei's Motion for Extension of Time
`IPR2017-01017
`
`
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