`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`GESTURE TECHNOLOGY PARTNERS,
`LLC
`
`Plaintiff,
`
`v.
`
`HUAWEI DEVICE CO., LTD., HUAWEI
`DEVICE USA INC.,
`Defendants.
`
`CIVIL ACTION NO. 2:21-CV-00040-JRG
`
`RENEWED JOINT MOTION
`TO STAY CERTAIN DEADLINES AND NOTICE OF PARTIAL SETTLEMENT
`
`Plaintiff Gesture Technology Partners, LLC (“Plaintiff”) and Defendants Huawei Device
`
`Co., Ltd. and Huawei Device USA Inc. (“Defendants”), by and through their undersigned attorneys,
`
`hereby file this Renewed Joint Motion to Stay All Deadlines and Notice of Settlement between
`
`Plaintiff and Defendants.
`
`Plaintiff and Defendants previously filed a Joint Motion to Stay Certain Deadlines and Notice
`
`of Partial Settlement on October 19, 2021. Dkt. 101. The Court granted that motion on October 29,
`
`2021, and ordered the parties to submit dismissal papers no later than November 29, 2021. Dkt. 109.
`
`Dismissal of this case is partially based on a settlement between Plaintiff and Defendants. Plaintiff
`
`and Defendants require additional time to finalize a settlement agreement between them, given the
`
`scope of that agreement and the presence of signatories in China.
`
`The parties wish to conclude the settlement without burdening the Court with additional
`
`filings and without incurring unnecessary expense. Plaintiff and Defendants anticipate they will be
`
`able to submit dismissal papers on December 6, 2021. Accordingly, the parties respectfully request
`
`
`
`Case 2:21-cv-00040-JRG Document 132 Filed 11/29/21 Page 2 of 4 PageID #: 3799
`
`that the Court grant a stay of all proceedings between Plaintiff and Defendants, including all pending
`
`deadlines between the parties until December 6, 2021
`
`The parties submit that good cause exists for granting this renewed and agreed motion, as set
`
`forth above. This motion is not filed for purposes of delay, but so that justice may be served.
`
`Wherefore, the parties respectfully request that the Court enter the proposed order submitted with
`
`this joint motion as set forth above and grant the parties such order and further relief to which they
`
`are entitled.
`
`Dated: November 29, 2021
`
`
`
` Respectfully submitted,
`
`By: /s/ Fred I. Williams
`Fred I. Williams
`Texas State Bar No. 00794855
`Michael Simons
`Texas State Bar No. 24008042
`Robert Daniel Garza
`Texas State Bar No. 24097730
`Robert Rhodes
`Texas State Bar No. 24116958
`WILLIAMS SIMONS & LANDIS PLLC
`The Littlefield Building
`601 Congress Avenue, Suite 600
`Austin, TX 78701
`Tel: 512-543-1354
`fwilliams@wsltrial.com
`msimons@wsltrial.com
`dgarza@wsltrial.com
`rrhodes@wsltrial.com
`
`Todd E. Landis
`State Bar No. 24030226
`WILLIAMS SIMONS & LANDIS PLLC
`2633 McKinney Ave., Suite 130 #366
`Dallas, TX 75204
`Tel: 512-543-1357
`tlandis@wsltrial.com
`
`By: /s/ Mark Mann
`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
`
`Kent E. Baldauf, Jr.
`kbaldaufjr@webblaw.com
`Bryan P. Clark
`bclark@webblaw.com
`THE WEBB LAW FIRM
`420 Ft. Duquesne Blvd., Suite 1200
`Pittsburgh, PA 15222
`Tel: 412-471-8815
`
`Matthew S. Warren
`Erika Warren
`Jennifer A. Kash
`WARREN LEX LLP
`2261 Market Street, No. 606
`
`
`
`Case 2:21-cv-00040-JRG Document 132 Filed 11/29/21 Page 3 of 4 PageID #: 3800
`
`John Wittenzellner
`Pennsylvania State Bar No. 308996
`WILLIAMS SIMONS & LANDIS PLLC
`1735 Market Street, Suite A #453
`Philadelphia, PA 19103
`Tel: 512-543-1373
`johnw@wsltrial.com
`
`Attorneys for Plaintiff
`Gesture Technology Partners, LLC
`
`San Francisco, California 94114
`Tel: 415-895-2940
`21-040@cases.warrenlex.com
`
`Attorneys for Defendants Huawei Device
`Co., Ltd., and Huawei Device USA, Inc.
`
`
`
`Case 2:21-cv-00040-JRG Document 132 Filed 11/29/21 Page 4 of 4 PageID #: 3801
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on November 29, 2021, the undersigned caused a
`
`copy of the foregoing document to be served on all counsel of record via the Court’s CM/ECF
`
`system, pursuant to the Federal Rules of Civil Procedure.
`
`/s/ Fred I. Williams
`Fred I. Williams
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that counsel for Gesture Technology Partners, LLC and
`
`counsel for Huawei Device Co., Ltd. and Huawei Device USA, Inc. met and conferred, and all
`
`parties agree to filing the foregoing document as a joint motion.
`
`/s/ Fred I. Williams
`Fred I. Williams
`
`
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