`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS Software Development, LLC
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`
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`Plaintiff,
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`v.
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`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`(DONGGUAN) CO., LTD.
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`Defendants.
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`
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`CIVIL ACTION NO. 2:17-cv-513-JRG
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`JURY TRIAL DEMANDED
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`UNOPPOSED SECOND MOTION FOR FURTHER EXTENSION OF TIME
`FOR DEFENDANTS TO ANSWER OR OTHERWISE RESPOND
`TO PLAINTIFF’S FIRST AMENDED COMPLAINT
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`Defendants Huawei Device USA, Inc., Huawei Device Co., Ltd., and Huawei Device
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`(Dongguan) Co., Ltd. (collectively, “Defendants” or “Huawei”) hereby file this unopposed
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`second motion for a further extension of time to answer, move, or otherwise respond to Plaintiff
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`AGIS Software Development, LLC’s (“AGIS”) First Amended Complaint. Huawei Device
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`USA, Inc. was first served with the original complaint on July 17, 2017. (D.I. 6.) Then, on
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`August 17, 2017, AGIS filed the First Amended Complaint to replace the foreign Huawei
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`defendants identified in the original complaint with Huawei Device Co., Ltd. and Huawei Device
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`(Dongguan) Co., Ltd. (D.I. 20.) On August 24, 2017, Huawei Device Co., Ltd. and Huawei
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`Device (Dongguan) Co., Ltd. both agreed to waive service of the First Amended Complaint.
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`(D.I. 22, 23.) On August 23, 2017, Defendants filed their unopposed first Motion for Extension
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`of time (D.I. 21), which the Court granted on September 11, 2017 (D.I. 24), extending the time to
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`answer to September 28, 2017. Defendants, therefore, request the court further extend the
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`deadline an additional two weeks’ time to October 12, 2017, in order to provide Defendants’
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`1
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`Case 2:17-cv-00513-JRG Document 27 Filed 09/25/17 Page 2 of 2 PageID #: 364
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`counsel the additional opportunity to investigate the relevant facts and evaluate the precedential
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`law in a manner that allows Defendants to narrow the issues in dispute, to the extent possible,
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`and to prepare a response that will focus the issues and arguments necessary to be addressed in
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`this proceeding. This Motion is made for good cause, and not for delay or tactical advantage.
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`Counsel for Huawei have conferred with counsel for AGIS, and AGIS does not oppose the
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`requested extension.
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`Dated: September 25, 2017
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`Respectfully submitted by:
`
`/s/ J. Mark Mann
`J. Mark Mann
`SBN: 12926150
`mark@themannfirm.com
`G. Blake Thompson
`SBN: 24042033
`blake@themannfirm.com
`MANN TINDEL THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`Tel: 903-657-8540
`Fax: 903-657-6003
`
`COUNSEL FOR DEFENDANTS
`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI
`DEVICE (DONGGUAN) CO., LTD.
`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on September 25, 2017, a true and correct copy of
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`the foregoing was served to the parties counsel of record via electronic mail pursuant to Local
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`Rule CV-5(d).
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`/s/ J. Mark Mann
`J. Mark Mann
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`2
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