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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT LLC, §
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`HMD GLOBAL, et al.
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`________________________________________________________________________
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`AGIS SOFTWARE DEVELOPMENT LLC, §
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`PANASONIC CORPORATION, et al.
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`Case No. 2:22-cv-00443-JRG
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` (Lead Case)
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`Case No. 2:22-cv-00447-JRG
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`UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER
`OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT
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`Defendants, Panasonic Holdings Corporation (named in Plaintiff’s Complaint as
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`“Panasonic Corporation”) (hereinafter “PHC”) and Panasonic Corporation of North
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`America
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`(hereinafter “PCNA”)
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`(collectively “the Panasonic Defendants” or
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`“Defendants”), without waiving any defenses set forth in Federal Rule Civil Procedure
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`12, file this unopposed motion for an extension of time in which to answer or otherwise
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`respond to Plaintiff’s Complaint for Patent Infringement and respectfully show the Court:
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`1.
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`The Court has ordered the Panasonic Defendants to answer or otherwise
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`respond to Plaintiff’s Complaint by November 16, 2023. Defendants respectfully move
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`the Court for a sixty-day extension of time through January 15, 2024 in which to answer
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`or otherwise respond to the complaint. Good cause exists for this extension.
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`2.
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`Neither of the Panasonic Defendants has been served with process in this
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`action. PHC is a corporation organized and existing under the laws of Japan and is a
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`member of the Hague Convention. In consideration for the additional time requested,
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`1
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`Case 2:22-cv-00443-JRG Document 20 Filed 11/09/23 Page 2 of 3 PageID #: 185
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`PHC has agreed to waive the normal legal requirement of being served pursuant to the
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`provisions of the Hague Convention and respond to the complaint on or before January
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`15, 2024. PCNA has agreed to waive service in consideration for the same extension
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`through January 15, 2024. Answering or responding to the complaint on the same date
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`will facilitate judicial economy and efficiency.
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`3.
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` Plaintiff alleges infringement of five patents. The additional time will
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`assist the Panasonic Defendants in properly preparing their defenses herein. As set forth
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`in the above caption, this motion is unopposed.
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`Wherefore, Defendants, Panasonic Holdings Corporation (named in Plaintiff’s
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`Complaint as “Panasonic Corporation”) and Panasonic Corporation of North America
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`move for an extension of time in which to answer or otherwise respond to Plaintiff’s
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`Complaint through January 15, 2024.
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`Respectfully submitted,
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`DATED: November 9, 2023
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`/s/ Trey Yarbrough
`Trey Yarbrough
`Bar No. 22133500
`trey@yw-lawfirm.com
`YARBROUGH WILCOX, PLLC
`100 E. Ferguson, Suite 1015
`Tyler, Texas 75702
`903-595-3111 office
`903-595-0191 fax
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`ATTORNEY FOR DEFENDANTS
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`Case 2:22-cv-00443-JRG Document 20 Filed 11/09/23 Page 3 of 3 PageID #: 186
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who are deemed to
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`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) on November 9, 2023.
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`/s/ Trey Yarbrough
`Trey Yarbrough
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`CERTIFICATE OF CONFERENCE
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`This is to certify that counsel for the Defendants and counsel for the Plaintiff
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`conferred regarding the subject matter of this motion on October 27, 2023, and the
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`foregoing motion is unopposed.
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` /s/ Trey Yarbrough
` Trey Yarbrough
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`3
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