`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`v.
`
`HMD GLOBAL, et al.
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`v.
`
`ASUSTEK COMPUTER INC., et al.
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`v.
`
`PANASONIC CORPORATION, et al.
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`v.
`
`SONY CORPORATION, et al.
`
`
`
`
`
`Case No. 2:22-cv-00443-JRG
`(Lead Case)
`
`
`
`
`Case No. 2:22-cv-00440-JRG
`(Member Case)
`
`
`
`
`Case No. 2:22-cv-00447-JRG
`(Member Case)
`
`
`
`
`Case No. 2:22-cv-00448-JRG
`(Member Case)
`
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
`
`
`
`Defendant Sony Corporation, formerly known as Sony Mobile Communications, Inc.
`
`(“Sony”)1 hereby moves for an extension of time for Sony to respond to the Complaint filed by
`
`AGIS on November 18, 2022 (Dkt. No. 1).2
`
`
`1 While AGIS’s complaint identifies Sony Corporation and Sony Mobile Communications, Inc. as
`separate defendants, Sony Mobile Communications, Inc. and other Sony entities were integrated
`into one company named “Sony Corporation” as of April 1, 2021.
`2 Sony understands that corresponding motions are being filed in Civil Action Nos. 2-22-cv-00440
`(AGIS Software Development LLC v. ASUStek Computer Inc. et al); 22-cv-00443 (AGIS Software
`Development LLC v. HMD Global et al); and 2-22-cv-00447 (AGIS Software Development LLC
`v. Panasonic Corporation et al). These cases involve the same asserted patents and, as with the
`1
`
`
`
`
`
`Case 2:22-cv-00443-JRG Document 19 Filed 11/09/23 Page 2 of 3 PageID #: 180
`
`
`
`On January 25, 2023, the case was stayed pending a final determination in In the Matter of
`
`Certain Location-Sharing Systems, Related Software Components Thereof, and Products
`
`Containing Same (ITC Inv. No. 337-TA-1347) (Dkt. No. 13). On October 13, 2023, the parties
`
`filed a joint notice informing the Court of the termination of that investigation (Dkt. No. 14). On
`
`October 16, 2023, this Court lifted the stay and ordered Sony to answer or otherwise respond to
`
`the Complaint by November 15, 2023 (Dkt. No. 15).
`
`
`
`Sony—a foreign corporation organized under the laws of Japan—has not been served with
`
`AGIS’s Complaint. However, pursuant to an agreement between the parties, Sony accepted
`
`service on October 31, 2023 in exchange for a 60-day extension of time to respond from the
`
`November 15, 2023 date originally set by the Court. Accordingly, Sony respectfully requests that
`
`the Court move Sony’s deadline to answer or otherwise respond to the Complaint to January 16,
`
`2024. Counsel for AGIS confirmed that they do not oppose the requested relief.
`
` Respectfully submitted,
`
`
`
`
`
` By: /s/ G. Blake Thompson
`G. Blake Thompson
`State Bar No. 24042033
`Blake@TheMannFirm.com
`J. Mark Mann
`State Bar No. 12926150
`Mark@TheMannFirm.com
`MANN | TINDEL | THOMPSON
`112 E. Line Street, Suite 304
`Tyler, Texas 75702
`(903) 657-8540
`(903) 657-6003 (fax)
`
`Dated: November 9, 2023
`
`
`
`
`
`
`
`ATTORNEYS FOR SONY
`CORPORATION
`
`
`case against Sony, had been stayed pending the ITC investigation. If granted, the motions would
`result in the Sony, ASUStek, HMD, and Panasonic defendants all having response deadlines at
`approximately the same time in January.
`
`
`
`2
`
`
`
`Case 2:22-cv-00443-JRG Document 19 Filed 11/09/23 Page 3 of 3 PageID #: 181
`
`CERTIFICATE OF CONFERENCE
`
`I hereby certify that on November 9, 2023, counsel for Sony conferred via email with
`
`
`
`
`counsel for AGIS regarding the Motion. Based on that conference, the relief requested herein is
`
`unopposed.
`
`
`
`
`
`
`
` /s/ G. Blake Thompson
`G. Blake Thompson
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
`
`that, on November 9, 2023 all counsel of record who have appeared in this case are being served
`
`with a copy of the foregoing via the Court’s CM/ECF system.
`
` /s/ G. Blake Thompson
`G. Blake Thompson
`
`
`
`
`
`
`
`
`
`
`
`3
`
`
`
`
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