`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`MemoryWeb, LLC,
`
`Plaintiff
`
`v.
`
`Samsung Electronics Co., Ltd. (a Korean
`Company) and Samsung Electronics America,
`Inc.,
`
`Defendants
`
`Case No. 21-cv-411-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`CASE READINESS STATUS REPORT
`
`Plaintiff MemoryWeb, LLC and Defendants Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc. hereby provide the following status report in advance of the initial Case
`
`Management Conference (CMC).
`
`FILING AND EXTENSIONS
`
`Plaintiff’s Complaint was filed on April 26, 2021. There has been one extension with
`
`respect to Defendant Samsung Electronics America, Inc. for a total of 71 days.
`
`RESPONSE TO THE COMPLAINT
`
`
`
`Defendants filed their Answer to the Complaint on August 5, 2021.
`
`PENDING MOTIONS
`
`There are no pending motions at this time.
`
`RELATED CASES IN THIS JUDICIAL DISTRICT
`
`Both of the patents asserted in this case are also asserted in MemoryWeb, LLC v. Apple,
`
`Inc., Case No. 6:21-cv-00531-ADA, currently pending in this Judicial District.
`
`
`
`
`
`
`
`1
`
`MemoryWeb Ex. 2012
`Samsung v. MemoryWeb – IPR2022-00222
`
`
`
`Case 6:21-cv-00411-ADA Document 21 Filed 09/03/21 Page 2 of 3
`
`
`
`IPR, CBM, AND OTHER PGR FILINGS
`
`A petition seeking inter partes review of U.S. Pat. No. 10,621,228 (one of the asserted
`
`patents) was filed by non-party Unified Patents on the day of this filing, September 3, 2021, with
`
`the caption, Unified Patents, LLC v. MemoryWeb, LLC, IPR2021 -01413.
`
`NUMBER OF ASSERTED PATENTS AND CLAIMS
`
`Plaintiff has asserted two patents and a total of 34 claims.
`
`APPOINTMENT OF TECHNICAL ADVISER
`
`The Parties do not request a technical adviser to be appointed to the case to assist the Court
`
`with claim construction or other technical issues.
`
`MEET AND CONFER STATUS
`
`Plaintiff and Defendant conducted a meet and confer conference on September 3, 2021 and
`
`agreed to the following modifications to the schedule:
`
` Plaintiff to identify claims asserted: September 17, 2021;
`
` Plaintiff to serve preliminary infringement contentions: September 24, 2021; and
`
` Defendants to serve preliminary invalidity contentions: December 3, 2021.
`
`The parties have agreed to an overall case schedule that varies from the Default Schedule
`
`by at least four weeks. The proposed scheduling order will be submitted to the Court separately.
`
`
`Dated: September 3, 2021
`
`/s/ Allan A. Kassenoff___________
`
`Melissa R. Smith
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`Email: melissa@gillamsmithlaw.com
`
`
`
`
`Respectfully submitted,
`
`/s/ Arthur Gollwitzer III
`
`Arthur Gollwitzer III
` Texas Bar No. 24073336
`Jackson Walker LLP
`100 Congress Avenue, Suite 1100
`Austin, TX 78701
`Telephone: 512.236.2268
`Facsimile: 512.236.2002
`agollwitzer@jw.com
`
`2
`
`MemoryWeb Ex. 2012
`Samsung v. MemoryWeb – IPR2022-00222
`
`
`
`Case 6:21-cv-00411-ADA Document 21 Filed 09/03/21 Page 3 of 3
`
`
`
`
`Richard A. Edlin
`Allan A. Kassenoff
`Jeffrey R. Colin
`Vimal M. Kapadia
`GREENBERG TRAURIG, LLP
`MetLife Building, 200 Park Avenue
`New York, NY 10166
`Telephone: (212) 801-9200
`Facsimile: (212) 801-6400
`Email: edlinr@gtlaw.com
`Email: kassenoffa@gtlaw.com
`Email: colinj@gtlaw.com
`Email: kapadiav@gtlaw.com
`
`Attorneys for Defendants Samsung
`Electronics Co., Ltd., and Samsung
`Electronics America, Inc.
`
`
`
`
`
`Daniel J. Schwartz (pro hac vice)
`Zachary Sorman (pro hac vice)
`Angelo J. Christopher (pro hac vice)
`NIXON PEABODY LLP
`70 West Madison, Suite 3500
`Chicago, IL 60602-4224
`Tel: 312-977-4400
`djschwartz@nixonpeabody.com
`achristopher@nixonpeabody.com
`zsorman@nixonpeabody.com
`
`Attorneys for Plaintiff MemoryWeb, LLC
`
`3
`
`
`
`MemoryWeb Ex. 2012
`Samsung v. MemoryWeb – IPR2022-00222
`
`
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