Case 2:21-cv-00040-JRG-RSP Document 238 Filed 03/14/22 Page 1 of 5 PageID #: 10532
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`GESTURE TECHNOLOGY PARTNERS,
`LLC,
`
`Plaintiff
`
`JURY TRIAL DEMANDED
`
`v.
`HUAWEI DEVICE CO., LTD., AND
`HUAWEI DEVICE USA, INC.,
`
`Defendants.
`
`C.A. NO. 2:21-cv-00040-JRG
`LEAD CONSOLIDATED CASE
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Defendants.
`
`C.A. NO. 2:21-cv-00041-JRG
`
`JOINT MOTION TO EXTEND THE STAY OF ALL DEADLINES
`
`Plaintiff Gesture Technology Partners, LLC (“GTP”) and Defendants Samsung Electronics
`
`Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”) (altogether, “Parties”)
`
`file this Joint Motion to Extend the Stay of All Deadlines.
`
`On February 9, 2022, the Parties filed a Joint Motion to Stay All Deadlines and Notice of
`
`Settlement. Dkt. 235. The Parties informed the Court that they reached a settlement in principle
`
`and are in the process of finalizing the documents pertaining to the settlement. At the time, the
`
`Parties anticipated that they would be able to submit dismissal papers before March 11, 2022. The
`
`Court granted the Parties’ motion and ordered that all deadlines are stayed through March 11,
`
`2022. Dkt. 236. The Court further ordered that absent a showing of good cause, the Parties will
`
`submit dismissal papers no later than March 11, 2022. Id.
`
`The Parties file the present joint motion to respectfully request an extension of the stay of
`
`all deadlines for five (5) days. The Parties remain committed to their settlement in principle, and
`
`1
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`GESTURE TECHNOLOGY PARTNERS,
`LLC,
`
`Plaintiff
`
`JURY TRIAL DEMANDED
`
`v.
`HUAWEI DEVICE CO., LTD., AND
`HUAWEI DEVICE USA, INC.,
`
`Defendants.
`
`C.A. NO. 2:21-cv-00040-JRG
`LEAD CONSOLIDATED CASE
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Defendants.
`
`C.A. NO. 2:21-cv-00041-JRG
`
`JOINT MOTION TO EXTEND THE STAY OF ALL DEADLINES
`
`Plaintiff Gesture Technology Partners, LLC (“GTP”) and Defendants Samsung Electronics
`
`Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”) (altogether, “Parties”)
`
`file this Joint Motion to Extend the Stay of All Deadlines.
`
`On February 9, 2022, the Parties filed a Joint Motion to Stay All Deadlines and Notice of
`
`Settlement. Dkt. 235. The Parties informed the Court that they reached a settlement in principle
`
`and are in the process of finalizing the documents pertaining to the settlement. At the time, the
`
`Parties anticipated that they would be able to submit dismissal papers before March 11, 2022. The
`
`Court granted the Parties’ motion and ordered that all deadlines are stayed through March 11,
`
`2022. Dkt. 236. The Court further ordered that absent a showing of good cause, the Parties will
`
`submit dismissal papers no later than March 11, 2022. Id.
`
`The Parties file the present joint motion to respectfully request an extension of the stay of
`
`all deadlines for five (5) days. The Parties remain committed to their settlement in principle, and
`
`1
`
`
`
`Case 2:21-cv-00040-JRG-RSP Document 238 Filed 03/14/22 Page 2 of 5 PageID #: 10533
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`are actively working to finalize the documents pertaining to the settlement. The Parties submit
`
`that good cause exists for granting this joint motion, as this joint motion is not filed for purposes
`
`of delay, but so that justice may be served in the most efficient manner and without wasting judicial
`
`or party resources. Accordingly, the Parties respectfully request that the Court enter the proposed
`
`order submitted with this joint motion.
`
`Dated: March 11, 2022
`
`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
`327 Congress Ave., Suite 490
`Austin, TX 78701
`Tel: 512-543-1354
`fwilliams@wsltrial.com
`msimons@wsltrial.com
`dgarza@wsltrial.com
`rrhodes@wsltria.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
`
`John Wittenzellner
`Pennsylvania State Bar No. 308996
`WILLIAMS SIMONS & LANDIS PLLC
`1735 Market Street, Suite A #453
`Philadelphia, PA 19103
`
`2
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`Case 2:21-cv-00040-JRG-RSP Document 238 Filed 03/14/22 Page 3 of 5 PageID #: 10534
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`Tel: 512-543-1373
`johnw@wsltrial.com
`
`Kevin S. Kudlac
`Texas Bar No. 00790089
`Kudlac PLLC
`1916 Wimberly Lane
`Austin, TX 78735
`Tel: 512-656-5743
`kevin@kudlacIP.com
`Attorneys for Plaintiff
`Gesture Technology Partners, LLC
`
`/s/ Christopher W. Kennerly
`Christopher W. Kennerly (TX Bar No. 00795077)
`chriskennerly@paulhastings.com
`Radhesh Devendran (pro hac vice)
`radheshdevendran@paulhastings.com
`Boris S. Lubarsky (pro hac vice)
`borislubarsky@paulhastings.com
`David M. Fox (pro hac vice)
`davidfox@paulhastings.com
`PAUL HASTINGS LLP
`1117 S. California Avenue
`Palo Alto, CA 94304
`Telephone: (650) 320-1800
`Facsimile: (650) 320-1900
`
`Allan M. Soobert
`allansoobert@paulhastings.com
`PAUL HASTINGS LLP
`2050 M Street NW
`Washington, D.C. 20036
`Telephone: 202-551-1700
`Facsimile: 202-551-1705
`
`Elizabeth L. Brann
`elizabethbrann@paulhastings.com
`PAUL HASTINGS LLP
`4747 Executive Drive, 12th Floor
`San Diego, CA 92121
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
`
`Robert Laurenzi
`robertlaurenzi@paulhastings.com
`
`3
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`Case 2:21-cv-00040-JRG-RSP Document 238 Filed 03/14/22 Page 4 of 5 PageID #: 10535
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`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 318-6000
`Facsimile: (212) 319-4090
`
`Harry Lee Gillam, Jr. (TX Bar No. 07921800)
`gil@gillamsmithlaw.com
`Melissa R. Smith (TX Bar No. 24001351)
`melissa@gillamsmithlaw.com
`James Travis Underwood (TX Bar No. 24102587)
`travis@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 S. Washington Ave.
`Marshall, TX 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`
`Attorneys for Defendants Samsung Electronics Co.,
`Ltd and Samsung Electronics America, Inc.
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`4
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`Case 2:21-cv-00040-JRG-RSP Document 238 Filed 03/14/22 Page 5 of 5 PageID #: 10536
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that due to the CM/ECF outage on March 11, 2022, the
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`undersigned caused a copy of the foregoing document to be served on all counsel of record on
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`March 14, 2022, via the Court’s CM/ECF system, pursuant to the Federal Rules of Civil Procedure.
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`/s/ Melissa R. Smith
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`5
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