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Case 2:22-cv-00263-JRG-RSP Document 36 Filed 12/16/22 Page 1 of 3 PageID #: 1028
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
` Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO. LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`
`
`
`Defendants.
`
`
`
`Civil Action No. 2:22-cv-263-JRG-RSP
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`
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`
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`
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`
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANTS
`TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF’S FIRST
`AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. hereby
`
`file this unopposed motion for an extension of time in which to answer, move, or otherwise respond
`
`to plaintiff AGIS Software Development LLC’s First Amended Complaint for Patent Infringement
`
`[Dkt. 29] filed December 5, 2022 after 5 p.m. CT, and respectfully show the Court:
`
`1. Defendants request a seven-day extension of time, from December 20, 2022, through
`
`and including December 27, 2022, to answer, move, or otherwise respond to plaintiff AGIS
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`Software Development LLC’s First Amended Complaint for Patent Infringement.
`
`2. Good cause exists for the requested extension in that Defendants’ counsel are
`
`committed to family and travel obligations for the holidays. Plaintiff does not oppose this motion,
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`and the parties have agreed to the extension of Defendants’ deadline to answer, move, or
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`otherwise respond.
`
`
`
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 36 Filed 12/16/22 Page 2 of 3 PageID #: 1029
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`3. Defendants are not seeking an extension for delay but rather to prepare its response
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`and so that justice will be done.
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`In view of the foregoing, Defendants respectfully request that the Court grant this
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`unopposed motion and extend the deadline to move, answer or otherwise respond to the
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`Complaint from December 20, 2022, through and including December 27, 2022.
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Melissa R. Smith
`Melissa R. Smith
`State Bar No. 24001351
`melissa@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, TX 75670
`Telephone: 903-934-8450
`Facsimile: 903-934-9257
`
`
`Neil P. Sirota
`neil.sirota@bakerbotts.com
`Margaret M. Welsh
`margaret.welsh@bakerbotts.com
`BAKER BOTTS L.L.P.
`30 Rockefeller Plaza
`New York, NY 10112-4498
`Phone: (212) 408-2500
`Fax: (212) 408-2501
`
`Counsel for Defendants Samsung
`Electronics Co., Ltd. and Samsung
`Electronics America, Inc.
`
`DATED: December 16, 2022
`
`
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`
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`- 2 -
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`

`

`Case 2:22-cv-00263-JRG-RSP Document 36 Filed 12/16/22 Page 3 of 3 PageID #: 1030
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`
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing document was filed electronically in
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`compliance with Local Rule CV-5(a). Plaintiff’s counsel of record were served with a true and
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`correct copy of the foregoing document by electronic mail on December 16, 2022.
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`
`
`/s/ Melissa R. Smith
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for Plaintiff and counsel for Defendants have complied with
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`Local Rule CV-7(h) by conferring, and Plaintiff is not opposed to Defendants filing this motion.
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`
`
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`
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`/s/ Melissa R. Smith
`Melissa R. Smith
`
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`- 3 -
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`

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