`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`
`
`
`Case No. 2:21-CV-00225-JRG-RSP
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`
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`JURY TRIAL DEMANDED
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`
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`BRIGHT DATA LTD.
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`
`
`
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`Plaintiff,
`
`v.
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`NETNUT LTD.
`
`
`Defendant.
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`
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`
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`JOINT MOTION FOR EXTENSION OF DEADLINE FOR MEDIATION
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`Plaintiff Bright Data Ltd. (“Bright Data”) and Defendant NetNut Ltd. (“NetNut”)
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`(collectively the “Parties”) hereby respectfully, jointly move the Court for an extension of the
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`deadline for the Parties to complete mediation to January 31, 2022.
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`The Court ordered the Parties to mediate with the Hon. David Folsom no later than 45 days
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`from the date of the order, which would be January 1, 2022.1 See Dkt. No. 66. As the Parties had
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`previously mediated with the Hon. Jay Gandhi, the Court granted the Parties’ motion to continue
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`mediation with Judge Gandhi. See Dkt. No. 68. Based on their October 2021 mediation with
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`Judge Gandhi, the Parties have continued to work toward a business resolution to their dispute.
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`This includes an in-person meeting between both sides’ principals on December 13, 2021. In
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`addition to working toward a business resolution the Parties have contacted Judge Gandhi to set
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`an additional mediation date but do not yet have a date certain. Accordingly, the Parties
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`1 As January 1 is a Saturday, the current deadline falls on the following Monday, January 3,
`2022.
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`1
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`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2014
`1 of 3
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`
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`Case 2:21-cv-00225-JRG-RSP Document 79 Filed 12/22/21 Page 2 of 3 PageID #: 1186
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`respectfully request that the Court extend the deadline for the Parties to complete mediation to
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`January 31, 2022.
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`
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`Dated: December 22, 2021
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`By: /s/ J. Michael Woods
`
`Elizabeth L. DeRieux
`State Bar No. 05770585
`Capshaw DeRieux, LLP
`114 E. Commerce Ave.
`Gladewater, TX 75647
`Telephone: 903-845-5770
`ederieux@capshawlaw.com
`
`J. Mark Mann
`G. Blake Thompson
`Mann | Tindel | Thompson
`300 West Main
`Henderson, TX 75652
`mark@themannfirm.com
`blake@themannfirm.com
`Office 903-657-8540
`Marshall Office 903-472-4294
`Tyler Office 903-596-0900
`Waco Office 254-776-3336
`
`Korula T. Cherian
`Robert Harkins
`RuyakCherian LLP
`1936 University Ave, Ste. 350
`Berkeley, CA 94702
`sunnyc@ruyakcherian.com
`bobh@ruyakcherian.com
`
`Thomas Dunham
`Ronald Wielkopolski
`J. Michael Woods
`Colby A. Davis
`RuyakCherian LLP
`1901 L St. NW, Suite 700
`Washington, DC 20036
`tomd@ruyakcherian.com
`ronw@ruyakcherian.com
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`
`
`/s/ Eric H. Findlay (with permission)
`
`
`Eric H. Findlay (TX Bar No. 00789886)
`Debby Gunter (TX Bar No. 24012752)
`FINDLAY CRAFT, P.C.
`102 North College Avenue, Suite 900
`Tyler, Texas 75702
`Tel: (903) 534-1100
`Fax: (903) 534-1137
`Email: efindlay@findlaycraft.com
`Email: dgunter@findlaycraft.com
`
`Elliot C. Cook
`Finnegan, Henderson,
`Farabow, Garrett & Dunner,
`LLP
`1875 Explorer St., Suite 800
`Reston, VA 20190
`Tel: (571) 203-2738
`Fax: (202) 408-4400
`elliot.cook@finnegan.com
`
`Cory C. Bell
`Finnegan, Henderson,
`Farabow, Garrett & Dunner,
`LLP
`Two Seaport Lane
`Boston, MA 02210-2001
`Tel: (617) 646-1641
`Fax: (202) 408-4400
`cory.bell@finnegan.com
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`Attorneys For
`Defendant NetNut Ltd.
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`2
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`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2014
`2 of 3
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`
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`Case 2:21-cv-00225-JRG-RSP Document 79 Filed 12/22/21 Page 3 of 3 PageID #: 1187
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`michaelw@ruyakcherian.com
`colbyd@ruyakcherian.com
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`Attorneys for Plaintiff
`Bright Data Ltd.
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`
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`
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that the parties have complied with the meet and confer requirement in
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`Local Rule CV-7(h). On December 21, 2021, counsel for NetNut confirmed that NetNut joins
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`this motion.
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`/s/ J. Michael Woods
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who are deemed to have consented to electronic
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`service are being served this 22nd day of December, 2021, with a copy of this document via
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`CM/ECF.
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`
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`/s/ J. Michael Woods
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`3
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`NetNut Ltd. v. Bright Data Ltd.
`IPR2021-01492, EX. 2014
`3 of 3
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