`
`
`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 AMEND THE DOCKET CONTROL ORDER
`
`Plaintiff AGIS Software Development LLC (“AGIS” or “Plaintiff”) and Defendants
`
`v.
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`ET AL.,
`
`Defendants.
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Samsung”
`
`or “Defendants”) (collectively, the “Parties”) respectfully move the Court for a one-week
`
`extension of the deadlines listed in the Docket Control Order (Dkt. 28):
`
`Event
`
`Current Deadline
`
`Requested Deadline
`
`Comply with P.R. 4-3 (Joint
`Claim Construction Statement)
`Comply with P.R. 4-4 (Deadline
`to Complete Claim Construction
`Discovery)
`
`
`
`June 9, 2023
`
`July 7, 2023
`
`June 16, 2023
`
`July 14, 2023
`
`Pursuant to the Court’s Docket Control Order (Dkt. No. 28), the current deadline for the
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`parties to submit their P.R. 4-3 (Joint Claim Construction Statement) is June 9, 2023 and the
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`deadline for claim construction discovery pursuant to P.R. 4-4 is July 7, 2023. The Parties seek a
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`one-week extension until June 16, 2023 and July 14, 2023, respectively, for these deadlines. The
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`Parties have exchanged proposed disputed claim terms, have met and conferred, and have made
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`significant progress toward agreeing on disputed terms. The Parties are continuing to confer in an
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`
`
`
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`Case 2:22-cv-00263-JRG-RSP Document 65 Filed 06/08/23 Page 2 of 4 PageID #: 2314
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`attempt to come to an agreement on all disputed claim terms. The Parties believe a brief extension
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`would help in resolving the remaining disputes.
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`WHEREFORE, Plaintiff and Defendants jointly request that the Court enter an order
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`extending the above deadlines from June 9, 2023 up to and including June 16, 2023, and July 7,
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`2023 up to and including July 14, 2023.
`
`
`Dated: June 8, 2023
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`
`
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`
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`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
`
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`ATTORNEYS FOR PLAINTIFF AGIS
`SOFTWARE DEVELOPMENT LLC
`
`
`
`
`2
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 65 Filed 06/08/23 Page 3 of 4 PageID #: 2315
`
`
`
` /s/ Neil P. Sirota (with permission)
`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
`Telephone: (212) 408-2500
`Facsimile: (212) 408-2501
`
`Melissa R. Smith
`State Bar No. 24001351
`Tom Gorham
`State Bar No. 24012715
`tom@gillamsmithlaw.com
`melissa@gillamsmithlaw.com
`GILLAM & SMITH LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`ATTORNEYS FOR DEFENDANTS
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`
`3
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 65 Filed 06/08/23 Page 4 of 4 PageID #: 2316
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on June 8, 2023, 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).
`
`
`
`
`
`
`
`/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 all parties have agreed to the proposed order submitted herewith.
`
`
`
`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`
`
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`
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