`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Luminati Networks Ltd.,
`
`Plaintiff,
`
`v.
`
`Teso LT, UAB, Oxysales, UAB, and
`Metacluster LT, UAB,
`
`Defendants.
`
`
`
`Civil Action No.
`
`2:19-cv-00395-JRG
`
`UNOPPOSED MOTION TO EXTEND DEADLINE TO
`
`ANSWER OR OTHERWISE RESPOND TO COMPLAINT AND
`
`SET BRIEFING SCHEDULE ON MOTION TO DISMISS
`
`Defendants Teso LT, UAB (“Teso”), Oxysales, UAB (“Oxysales”), and Metacluster
`
`LT, UAB (“Metacluster”) (collectively, “Defendants”) file this Unopposed Motion to Ex-
`
`tend Deadline to Answer or Otherwise Respond to Complaint and Set Briefing Schedule on
`
`Motion to Dismiss, and respectfully show as follows:
`
`The Lithuanian Central Authority delivered a copy of the Complaint to Metacluster
`
`on February 18, 2020, to Teso on February 21, 2020, and to Oxysales on March 8, 2020.
`
`There is a disagreement betweenthe parties as to whetherthis service was effective under
`
`the Hague Convention, but Defendants agree to accept service of the Complaint and Plain-
`
`tiff Luminati Networks Ltd. (“Luminati”) agrees to an extension of the deadline for De-
`
`fendants to answer or otherwise respond to the Complaint, and a briefing schedule with
`
`respect to Defendants’ anticipated motion to dismiss.
`
`Code200, UAB,etal. v. Bright Data Ltd.
`IPR2022-00861, EX. 2001
`1 0f4
`
`
`
`Case 2:19-cv-00395-JRG Document 13 Filed 03/05/20 Page 2 of 4 PageID #: 401
`
`Luminati and Defendants have agreed on the following schedule and, as such, the
`
`parties respectfully request that the Court enter an Order memorializing it:
`
`(cid:131)
`
`(cid:131)
`
`(cid:131)
`
`(cid:131)
`
`Deadline for Defendants to Answer or Otherwise Respond to the Complaint:
`March 24, 2020;
`
`Luminati’s Response to Any Motion to Dismiss: 21 days after any motion to
`dismiss is filed;
`
`Defendants’ Reply In Support of Any Motion to Dismiss: 14 days after Lumi-
`nati’s Response is filed; and
`
`Luminati’s Sur-Reply: 14 days after Defendants’ Reply is filed.
`
`With respect to the contemplated motion to dismiss to be filed on or before March
`
`24, 2020, Defendants have agreed to file one motion to dismiss on all Defendants’ behalves.
`
`
`
`2
`
`Code200, UAB, et al. v. Bright Data Ltd.
`IPR2022-00861, EX. 2001
`2 of 4
`
`
`
`Case 2:19-cv-00395-JRG Document 13 Filed 03/05/20 Page 3 of 4 PagelD #: 402
`
`Dated: March 5, 2020
`
`Respectfully submitted,
`
`Atte
`
`MICHAEL C. SMITH
`Texas State Bar No. 18650410
`michaelsmith@siebman.com
`SIEBMAN, FORREST,
`BURG & SMITH LLP
`113 East Austin Street
`Marshall, Texas 75671
`Telephone:(903) 938-8900
`Telecopier: (972) 767-4620
`
`STEVEN CALLAHAN
`
`Texas State Bar No. 24053122
`scallahan@ccrglaw.com
`CRAIG TOLLIVER
`Texas State Bar No. 24028049
`ctolliver@ccrglaw.com
`GEORGET. “JORDE” SCOTT
`Texas State Bar No. 24061276
`jscott@ccrglaw.com
`CHARHON CALLAHAN
`ROBSON & GARZA, PLLC
`3333 Lee Parkway, Suite 460
`Dallas, Texas 75219
`Telephone:(214) 521-6400
`Telecopier: (214) 764-8392
`
`Counselfor Defendants Teso LT, UAB,
`Oxysales, UAB, and Metacluster LT, UAB
`
`Code200, UAB,et al. v. Bright Data Ltd.
`IPR2022-00861, EX. 2001
`3 of 4
`
`
`
`Case 2:19-cv-00395-JRG Document 13 Filed 03/05/20 Page 4 of 4 PagelD #: 403
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned certifies that, on March 5, 2020, he met and conferred with Lumi-
`nati’s counsel Ronald Wielkopolski, Esq., and that Luminati is not opposedto the relief
`requested in the foregoing motion.
`
`Ar
`
`STEVEN CALLAHAN
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was filed electronically in
`compliance with Local Rule CV-5(a) on March 5, 2020. As such, this document was served
`on all counsel who are deemed to have consented to electronic service. Local Rule CV-
`5(a)(3)(A).
`
`A+ (Ct
`
`STEVEN CALLAHAN
`
`Code200, UAB,et al. v. Bright Data Ltd.
`IPR2022-00861, EX. 2001
`4o0f4
`
`
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