`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`LEMAIRE ILLUMINATION TECHNOLOGIES, LLC
`
`Plaintiff,
`
`V.
`
`LG ELECTRONICS INC.,
`
`Defendant.
`
`Civil Action No. 2:1 7-CV-003 1 9-JRG
`The Hon, Rodney Gilstrap
`
`JURY TRIAL DEMANDED
`
`JOINT MOTION TO DISMISS
`
`Plaintiff Lemaire Illumination Technologies LLC and defendant LG Electronics Inc.
`
`("the parties"), stipulate that they have reached final agreement on settlement of their respective
`
`claims for relief asserted in this case. Based upon the agreei'nent, consent and approval of the
`
`parties, through their respective attorneys, further move the Court for entry of dismissal as
`
`follows:
`
`1 . All claims for relief asserted against LG Electronics Inc. by Lemaire Illumination
`
`Technologies LLC and all counterclaims asserted against Lemaire Illumination Technologies
`
`LLC by LG Electronics Inc. are to be dismissed, with prejudice.
`
`2. All attorneys' fees, costs of court and expenses shall be borne by each party
`
`incurring the sai'ne.
`
`EXHIBIT 4
`
`
`
`Case 2:17-cv-00319-JRG Document 30 Filed 10/16/17 Page 2 of 3 PagelD #: 228
`
`Dated: October 16, 2017
`
`Respectfully submitted,
`
`PLAINTIFF'S COUNSEL:
`
`/s/ Antonio S. Devora
`Katarzyna Brozynski
`kasia.brozysnki(24strasburger.com
`Texas State Bar No. 24036277
`STRASBURGER & PRICE, LLP
`901 Main Street, Suite 6000
`Dallas, Texas 75201
`(214) 651-4300 Telephone
`(214) 651-4330 Fax
`
`Antonio S. Devora
`Texas State Bar No. 24074133
`ai'itoiiiri.devora@strasburger.com
`Elizabeth F. Griffin
`Texas State Bar No. 24092450
`elizabeth.griff'in@strasburger.com
`STRASBURGER & PRICE, LLP
`2600 Dallas Parkway, Suite 600
`Frisco, Texas 75034
`(469) 287-3900 Telephone
`(469) 287-3999 Fax
`
`NI, WANG AND MASSAND, PLLC
`Neal G. Massand
`Texas Bar No. 24039038
`nmassand(2)nilawfirm.com
`8140 Walnut Hill Lane, Suite 500
`Dallas, TX, 75231
`(972) 331-4600 Telephone
`(972) 314-0900 Fax
`
`/s/ Joseph B. Warden
`Melissa R. Smith
`SBN 24001351
`Gillam & Smith LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: 903-934-8450
`Fax: 903-934-9257
`melissa(:gillamsmithlaw.com
`
`DEFENDANTS' COUNSEL:
`
`EXHIBIT 4
`
`
`
`Case 2:17-cv-00319-JRG Document 30 Filed 10/16/17 Page 3 of 3 PagelD #: 229
`
`Michael J. McKeon
`D.C. Bar No. 459780
`mckeon(2i:!f-r.com
`Scott A. Elengold (Pro Hac Vice)
`D.C. Bar No. 976559
`elengold(2jfr.com%
`Zachary A. Loney (Pro Hac Vice)
`D.C. Bar No. 1029748
`loiiey(24fr.coi'n
`Ryan M. Teel (Pro Hac Vice)
`D.C. Bar No. 1044020
`teel(2hfr.com
`FISH & RICHARDSON p.c.
`McPherson Building
`901 15th Street, N.W., 7th Floor
`Washington, D.C. 20005
`Telephone: (202) 783-5070
`Facsimile: (202) 783-2331
`
`Joseph B. Warden
`wardei'i@fr.coin
`FISH & RICHARDSON p.c.
`222 Delaware Avenue
`Wilmington, DE 19801
`
`Attorneys for Defendants
`LG ELECTRONICS INC.
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that counsel of record who are deemed to have consented to electronic
`service are being served with a copy of this docui'nent via the Court's CM/ECF system on October
`16, 2017, per Local Rule CV-5(a)(3).
`
`/s/ Melissa R. Smith
`
`EXHIBIT 4
`
`
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