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Case 2:16-cv-00741-RWS Document 376 Filed 05/14/20 Page 1 of 2 PageID #: 7806
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`UNILOC USA, INC., et al.,
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`Plaintiffs,
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`v.
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`BIG FISH, INC.,
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`Defendant.
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`Case No. 2:16-cv-00741-JRG
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`LEAD CASE
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`Case No. 2:16-cv-00858-JRG
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`JOINT MOTION TO STAY PROCEEDINGS
`PENDING FINALIZATION OF SETTLEMENT
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`Plaintiffs Uniloc USA, Inc., and Uniloc Luxembourg, S.A. (together “Uniloc”), and
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`Defendant, Big Fish Games, Inc. (“Big Fish Games”), jointly move to stay this action pending
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`finalization of settlement.
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`The parties will soon execute a written settlement agreement. To do so, the parties
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`respectfully request a stay of proceedings until Friday, June 12, 2020. The additional time will
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`permit the parties to avoid unnecessary expenses or burden to the Court. The parties submit that
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`good cause exists for granting this agreed motion, as set forth above. This motion is not filed for
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`purposes of delay, but so that justice may be served.
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`Accordingly, Uniloc and Big Fish respectfully request that the Court grant a stay of
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`proceedings between them, including all deadlines, until Friday, June 12, 2020. A proposed order
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`is attached.
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`3470880.v1
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`Case 2:16-cv-00741-RWS Document 376 Filed 05/14/20 Page 2 of 2 PageID #: 7807
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`Dated: May 14, 2020
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`Respectfully submitted,
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`/s/ Michael J. Ercolini
`Paul J. Hayes
`Kevin Gannon
`Michael J. Ercolini
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`Email: phayes@princelobel.com
`Email: kgannon@princelobel.com
`Email: mercolini@princelobel.com
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`Edward R. Nelson III
`ed@nelbum.com
`Texas State Bar No. 24061270
`NELSON BUMGARDNER PC
`3131 West 7th Street, Suite 300
`Fort Worth, TX 76107
`Tel: (817) 377-9111
`Fax: (817) 377-3485
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`ATTORNEYS FOR THE PLAINTIFFS
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`CERTIFICATE OF SERVICE
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`I certify that all counsel of record who have consented to electronic service are being
`served with a copy of this document via the Court’s CM/ECF system per Local Rule CV-5(a)(3)
`on May 14, 2020.
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`/s/ Michael J. Ercolini
`Michael J. Ercolini
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