`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Plaintiff,
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`
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`v.
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`ZTE CORPORATION AND ZTE (TX),
`INC.,
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`
`
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`Defendant.
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`
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`Civil Action No. 2:17-CV-517-JRG
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`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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` UNOPPOSED MOTION TO EXTEND DEADLINE FOR PLAINTIFF AGIS
`SOFTWARE DEVELOPMENT LLC’S RESPONSE TO DEFENDANT
`ZTE (TX), INC.’S MOTION TO DISMISS PLAINTIFF’S COMPLAINT
`FOR FAILURE TO STATE A CLAIM AND IMPROPER VENUE
`OR IN THE ALTERNATIVE TO TRANSFER (D.E. 28)
`
`Plaintiff AGIS Software Development LLC (“Plaintiff”) hereby respectfully moves the
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`
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`Court to extend the deadline for Plaintiff to respond to Defendant ZTE (TX), Inc.’s
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`(“Defendant”) Motion to Dismiss Plaintiff’s Complaint for Failure to State a Claim and Improper
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`Venue or In the Alternative to Transfer (D.E. 28) by 14 days, from October 10, 2017 to October
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`24, 2017. Defendant does not oppose this extension.
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`
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`Plaintiff does not file this Unopposed Motion for the purposes of delay, but rather due to
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`other scheduling conflicts in the upcoming weeks, to allow Plaintiff to adequately address the
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`complexity of the issues associated with the pending Motion, and so that justice may be done.
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`1
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`Case 2:17-cv-00517-JRG Document 30 Filed 09/28/17 Page 2 of 3 PageID #: 232
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`Dated: September 28, 2017
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`BROWN RUDNICK LLP
`
`/s/ Alessandra C. Messing
`
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@brownrudnick.com
`Alessandra C. Messing
`NY Bar No. 5040019
`Email: amessing@brownrudnick.com
`John A. Rubino
`NY Bar No. 5020797
`Email: jrubino@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: (212) 209-4800
`Facsimile: (212) 209-4801
`
`
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`
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`ATTORNEYS FOR PLAINTIFF,
`AGIS SOFTWARE DEVELOPMENT LLC
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`2
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`Case 2:17-cv-00517-JRG Document 30 Filed 09/28/17 Page 3 of 3 PageID #: 233
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that, on September 28, 2017, all counsel of record who
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`are deemed to have consented to electronic service are being served with a copy of this document
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`via the Court's CM/ECF system per Local Rule CV-5(a)(3).
`
` /s/ Alessandra C. Messing
` Alessandra C. Messing
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`3
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