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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 AND TO SERVE
`INVALIDITY CONTENTIONS
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`Defendants, Panasonic Corporation (hereinafter “PC”) and Panasonic Corporation
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`of North America (hereinafter “PCNA”) (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 second unopposed motion for an extension of time in which to answer or
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`otherwise respond to Plaintiff’s Complaint for Patent Infringement and respectfully show
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`the Court:
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`1.
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`The Panasonic Defendants are scheduled to answer or otherwise respond
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`to Plaintiff’s Complaint by January 16, 2024. Defendants respectfully move the Court
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`for a two-week extension of time through January 30, 2024 in which to answer or
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`otherwise respond to the complaint.
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`Case 2:22-cv-00443-JRG Document 40 Filed 01/12/24 Page 2 of 3 PageID #: 325
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`2.
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`In addition, the Panasonic Defendants’ current deadline to serve their
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`Invalidity Contentions is February 5, 2024. Defendants also respectfully move the Court
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`for a two-week extension of time through February 19, 2024 in which to serve their
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`Invalidity Contentions.
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`3.
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`Good cause exists for these extension requests. The extension of time will
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`give the Plaintiff and the Panasonic Defendants needed additional time to meet and
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`confer and to address the impact of the recent settlement between Plaintiff and Google
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`and corresponding stay. The extension will not affect any remaining deadlines or the trial
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`date. The parties, through counsel, have conferred regarding the subject matter of this
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`motion, and, as set forth in the above caption and certificate below, this motion is
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`unopposed.
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`Wherefore, Defendants, Panasonic Corporation and Panasonic Corporation of
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`North America, move for an extension of time in which to answer or otherwise respond
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`to Plaintiff’s Complaint through January 30, 2024 and to serve their Invalidity
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`Contentions on or before February 19, 2024.
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`Respectfully submitted,
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`DATED: January 12, 2024
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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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`ATTORNEYS FOR PANASONIC
`DEFENDANTS
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`2
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`Case 2:22-cv-00443-JRG Document 40 Filed 01/12/24 Page 3 of 3 PageID #: 326
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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 January 12, 2024.
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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 January 12, 2024, 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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