Case 2:22-cv-00263-JRG-RSP Document 183 Filed 02/12/24 Page 1 of 5 PageID #: 18398
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`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:22-cv-00263-JRG-RSP
`§
`
`JURY TRIAL DEMANDED
`§
`§
`
`§
`§
`§
`§
`§
`§
`§
`
`JOINT MOTION TO EXTEND THE PARTIAL STAY OF ALL DEADLINES
`OF CLAIMS INVOLVING GOOGLE PRODUCTS
`
`Plaintiff AGIS Software Development LLC (“Plaintiff” or “AGIS”) and Defendants
`
`v.
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`ET AL.,
`
`Defendants.
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Defendants”
`
`or “Samsung) (Plaintiff and Defendants, collectively, the “Parties”) have met and conferred and
`
`jointly submit this request to extend the stay of all unreached case deadlines for the subset of claims
`
`and issues involving Google products.
`
`On January 15, 2024, the Court granted the Parties’ request for a partial stay of all
`
`unreached deadlines involving Google Products, including but not limited to Find My Device, in
`
`this matter until February 12, 2024 to allow the Parties to submit dismissal papers. Dkt. 176. The
`
`parties understand that AGIS and a third-party, Google LLC, have finalized a settlement agreement
`
`with respect to claims and issues involving Google products and expect to fully execute the
`
`agreement next week, and then file dismissal papers as to those claims by no later than February
`
`28, 2024. Accordingly, the Parties respectfully request an extension of the stay of these
`
`proceedings with respect to claims and issues involving Google products to continue through to
`
`February 28, 2024.
`
`
`
`
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:22-cv-00263-JRG-RSP
`§
`
`JURY TRIAL DEMANDED
`§
`§
`
`§
`§
`§
`§
`§
`§
`§
`
`JOINT MOTION TO EXTEND THE PARTIAL STAY OF ALL DEADLINES
`OF CLAIMS INVOLVING GOOGLE PRODUCTS
`
`Plaintiff AGIS Software Development LLC (“Plaintiff” or “AGIS”) and Defendants
`
`v.
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`ET AL.,
`
`Defendants.
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Defendants”
`
`or “Samsung) (Plaintiff and Defendants, collectively, the “Parties”) have met and conferred and
`
`jointly submit this request to extend the stay of all unreached case deadlines for the subset of claims
`
`and issues involving Google products.
`
`On January 15, 2024, the Court granted the Parties’ request for a partial stay of all
`
`unreached deadlines involving Google Products, including but not limited to Find My Device, in
`
`this matter until February 12, 2024 to allow the Parties to submit dismissal papers. Dkt. 176. The
`
`parties understand that AGIS and a third-party, Google LLC, have finalized a settlement agreement
`
`with respect to claims and issues involving Google products and expect to fully execute the
`
`agreement next week, and then file dismissal papers as to those claims by no later than February
`
`28, 2024. Accordingly, the Parties respectfully request an extension of the stay of these
`
`proceedings with respect to claims and issues involving Google products to continue through to
`
`February 28, 2024.
`
`
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 183 Filed 02/12/24 Page 2 of 5 PageID #: 18399
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`Accordingly, the Parties jointly move the Court to extend the stay of all deadlines in the
`
`case with respect to claims and issues involving Google products until February 28, 2024 to allow
`
`for execution of AGIS’s settlement agreement with Google LLC and for related dismissal papers
`
`to be submitted. This stay extension is not sought for the purpose of delay, but so that justice may
`
`be served.
`
`
`
`Dated: February 12, 2024
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Alfred R. Fabricant
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: ffabricant@fabricantllp.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Avenue,
`Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Justin Kurt Truelove
`State Bar No. 24013653
`Email: kurt@truelovelawfirm.com
`TRUELOVE LAW FIRM, PLLC
`100 West Houston Street
`Marshall, Texas 75670
`Telephone: (903) 938-8321
`Facsimile: (903) 215-8510
`
`ATTORNEYS FOR PLAINTIFF AGIS
`SOFTWARE DEVELOPMENT LLC
`
`
`
`
`
`2
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`Case 2:22-cv-00263-JRG-RSP Document 183 Filed 02/12/24 Page 3 of 5 PageID #: 18400
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`
`
`
` /s/ Mark Liang (with permission)
`Neil P. Sirota
`Email: neil.sirota@bakerbotts.com
`Margaret M. Welsh
`Email: margaret.welsh@bakerbotts.com
`Robert L. Maier
`NY Bar No. 4123246
`Email: Robert.maier@bakerbotts.com
`BAKER BOTTS L.L.P.
`30 Rockefeller Plaza
`New York, NY 10112-4498
`Telephone: (212) 408-2500
`Facsimile: (212) 408-2501
`
`Megan LaDriere White
`State Bar No. 24083348
`Email: megan.white@bakerbotts.com
`BAKER BOTTS L.L.P.
`2001 Ross Avenue, Suite 900
`Dallas, Texas 75201
`Telephone: (214) 953-6500
`Facsimile: (214) 953-6501
`
`Tom Gorham
`State Bar No. 24012715
`tom@gillamsmithlaw.com
`Melissa R. Smith
`State Bar No. 24001351
`melissa@gillamsmithlaw.com
`GILLAM & SMITH LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`Gregory Blake Thompson
`State Bar No. 24042033
`MANN | TINDEL | THOMPSON
`112 E. Line Street, Suite 304
`Tyler, Texas 75702
`(903) 657-8540
`(903) 657-6003 (fax)
`
`
`3
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`
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`Case 2:22-cv-00263-JRG-RSP Document 183 Filed 02/12/24 Page 4 of 5 PageID #: 18401
`
`Darin W. Snyder (pro hac vice)
`dsnyder@omm.com
`Mark Liang (pro hac vice)
`mliang@omm.com
`Bill Trac
`btrac@omm.com
`Sorin Zaharia
`zaharia@omm.com
`O’MELVENY & MYERS LLP
`Two Embarcadero Center, 28th Floor
`San Francisco, CA 94111
`Telephone: (415) 984-8700
`Facsimile: (415) 984-8701
`
`Stacy Yae (pro hac vice)
`syae@omm.com
`O’MELVENY & MYERS LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Telephone: (213) 430-6000
`Facsimile: (213) 430-6407
`
`Cason Cole
`State Bar No. 24109741
`ccole@omm.com
`Grant Gibson
`State Bar No. 24117859
`ggibson@omm.com
`O’MELVENY & MYERS LLP
`2501 North Harwood Street, Suite 1700
`Dallas, TX 75201-1663
`Telephone: (972) 360-1900
`Facsimile: (972) 360-1901
`
`
`ATTORNEYS FOR DEFENDANTS
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`
`
`4
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`Case 2:22-cv-00263-JRG-RSP Document 183 Filed 02/12/24 Page 5 of 5 PageID #: 18402
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that, on February 12, 2024, all counsel of record who are
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`deemed to have consented to electronic service are being served with a copy of this document via
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`the Court’s CM/ECF system per Local Rule CV-5(a)(3).
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`
`
`
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`
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`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that counsel for Plaintiff has met and conferred with
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`counsel for Defendants, and the parties have agreed to the proposed order submitted herewith.
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
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