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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`UNILOC 2017, LLC
`Plaintiffs,
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`v.
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`SAMSUNG ELECTRONICS AMERICA
`INC. and SAMSUNG ELECTRONICS CO.
`LTD.,
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`Defendants.
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`Civil Action No. 2:18-cv-00508-JRG
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`UNOPPOSED MOTION FOR EXTENSION OF TIME TO MOVE, ANSWER OR
`OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT AND
`WAIVER OF FOREIGN SERVICE REQUIREMENT
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`Samsung Electronics Company, Ltd. and Samsung Electronics America, Inc., Defendants
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`herein, without waiving any defenses described or referred to in Rule 12 F.R.C.P., move the Court
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`to extend the time within which Defendants are required to move, answer or otherwise respond to
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`Plaintiff’s Complaint. In support of their Motion, Defendants state as follows:
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`1.
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`On November 17, 2018, Plaintiff filed its Complaint alleging patent infringement
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`against Samsung Electronics Company, Ltd. and Samsung Electronics America, Inc.
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`2.
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`On December 6, 2018, Defendant Samsung Electronics America, Inc. was served
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`with Plaintiff’s Complaint. Samsung Electronics Company, Ltd. has not yet been served.
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`3.
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`Counsel for Defendants has agreed to waive service under the Hague Convention
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`for Samsung Electronics Company, Ltd., a foreign entity, in exchange for a 60 day extension of
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`time for all defendants to answer or otherwise plead by February 25, 2019.
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`Case 2:18-cv-00508-JRG Document 9 Filed 12/12/18 Page 2 of 3 PageID #: 32
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`4.
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`Defendants’ agreement with Plaintiff should not be construed as a waiver of any
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`other rights or defenses, including, for instance, Defendants’ right to file counterclaims,
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`affirmative defenses, or to otherwise challenge the validity of the subject patents.
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`WHEREFORE, Defendants Samsung Electronics Company, Ltd. and Samsung Electronics
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`America, Inc., respectfully request that the time in which they are required to move, answer or
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`otherwise respond to Plaintiff’s Complaint for Patent Infringement be extended up to and including
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`February 25, 2019.
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`Dated: December 12, 2018
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`Respectfully submitted,
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`/s/ Melissa R. Smith
`Melissa R. Smith
`State Bar No. 24001351
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`Email: melissa@gillamsmithlaw.com
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`Attorney for Defendants
`Samsung Electronics Company, Ltd., and
`Samsung Electronics America, Inc.
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`Case 2:18-cv-00508-JRG Document 9 Filed 12/12/18 Page 3 of 3 PageID #: 33
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that counsel of record who are deemed to have consented
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`to electronic services are being served with a copy of this document via the Court’s CM/ECF
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`system per Local Rule CV-5(a)(3) on this the 12th day of December, 2018.
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` /s/ Melissa R. Smith
` Melissa R. Smith
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