`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
`
`UNILOC USA, INC. and
`UNILOC LUXEMBOURG, S.A
`
`Plaintiffs,
`
`
`
`v.
`
`LG ELECTRONICS, U.S.A., INC.,
`LG ELECTRONICS MOBILECOMM
`U.S.A., INC. and
`LG ELECTRONICS, INC.,
`
`
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Civil Action No. 3:18-cv-00559-M
`
`LG DEFENDANTS’ UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO
`RESPOND TO PLAINTFFS’ COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendants LG Electronics, Inc. (“LGEKR”), LG Electronics U.S.A., Inc. (“LGEUS”),
`
`and LG Electronics MobileComm U.S.A., Inc. (“LGEMU”), (collectively the “Defendants”)
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`with the agreement of Plaintiffs Uniloc USA, Inc. and Uniloc Luxembourg, S.A., hereby,
`
`without waiving any defenses described or referred to in Rule 12 F.R.C.P., move the Court to
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`extend the time for Defendants to move, answer or otherwise respond to Plaintiffs’ Complaint
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`for Patent Infringement (“Complaint”) to June 11, 2018, and in support thereof respectfully
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`indicate the following:
`
`1.
`
`2.
`
`Plaintiffs filed their Complaint on March 9, 2018.
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`LGEUS and LGEMU were served with a copy of the Complaint on or about
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`March 20, 2018. LGEKR is a foreign entity and has not yet been served.
`
`3.
`
`The parties have agreed, for purposes of this case only, that LGEKR will waive
`
`service of the Complaint under the Hague Convention in exchange for Plaintiffs’ agreement for
`
`Patent Owner EX2006
`LG Electronics v. Uniloc 2017 LLC
`IPR2019-01530
`
`
`
`
` Case 3:18-cv-00559-M Document 12 Filed 04/09/18 Page 2 of 3 PageID 44
`
`
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`an extension of time to/ June 11, 2018, for Defendants to answer or otherwise plead in response
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`to the Complaint.
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`4.
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`Defendants’ extension agreement with Plaintiffs is not to be construed as a waiver
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`of any other rights or defenses, including, by way of example, defenses described or referred to
`
`in Rule 12 F.R.C.P., and Defendants’ right to file counterclaims and/or affirmative defenses.
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`Wherefore, Defendants LGEUS, LGEMU, and LGEKR respectfully request that the
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`Court enter an order extending the deadline to June 11, 2018, for Defendants to move, answer or
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`otherwise respond to Plaintiffs’ Complaint for Patent Infringement.
`
`Date: April 9, 2018
`
`
`
`
`
`
`
` Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Vic Henry
`
`Vic H. Henry
`vhhenry@hoaf.com
`Texas Bar No. 09484250
`Lane Fletcher
`lanefletcher@hoaf.com
`Texas State Bar No. 07139300
`HENRY ODDO AUSTIN & FLETCHER
`a Professional Corporation
`1700 Pacific Avenue, Suite 2700
`Dallas, Texas 75201
`Telephone: (214) 658-1900
`Facsimile: (214) 658-1919
`
`ATTORNEYS FOR THE DEFENDANTS
`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC. and
`LG ELECTRONICS MOBILECOMM
`U.S.A., INC.
`
`
`
`2
`
`
`
`
` Case 3:18-cv-00559-M Document 12 Filed 04/09/18 Page 3 of 3 PageID 45
`
`
`
`CERTIFICATE OF CONFERENCE
`
`
`I hereby certify that on April 6, 2018, I spoke with Anthony Vecchione,
`
`counsel for Plaintiffs, regarding the matters addressed in this Motion and that the
`parties agree to the relief requested in this Motion.
`
`By: /s/ Vic Henry
`
`Vic Henry
`
`
`
`
`
`
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`CERTIFICATE OF SERVICE
`
`
`I hereby certify that on this 9th day of April 2018, a true and correct copy of
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`the foregoing instrument has been served via the Court’s ECF system on all
`counsel of record in accordance with the Federal Rules of Civil Procedure and via
`regular U.S. mail to the address listed in Plaintiffs’ Complaint for counsel not
`served via the Court’s ECF system.
`
`
`
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`
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`By: /s/ Lane Fletcher
`
`Lane Fletcher
`
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`
`3
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`
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