`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`NORTHSTAR SYSTEMS LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`VOLKSWAGEN AG,
`
`
`Defendant.
`
`
`
`NORTHSTAR SYSTEMS LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`BAYERISCHE MOTOREN WERKE AG,
`
`
`Defendant.
`
`
`
`
`
`
`Case No. 2:22-cv-00486-JRG (Lead Case)
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`Case No. 2:22-cv-00496-JRG (Member Case)
`
`JURY TRIAL DEMANDED
`
`
`JOINT MOTION FOR EXTENSION OF TIME FOR PLAINTIFF
` NORTHSTAR SYSTEMS LLC TO COMPLY WITH P.R. 3-1 & 3-2
`(INFRINGEMENTCONTENTIONS) AND FOR DEFENDANT
`BAYERISCHE MOTOREN WERKE AG TO COMPLY
`WITH P.R. 3-3 & 3-4 (INVALIDITY CONTENTIONS)
`
`
`
`
`Plaintiff NorthStar Systems LLC (“NorthStar” or “Plaintiff”) and Defendant Bayerische
`
`Motoren Werke AG (“Defendant” or “BMW”) (the “Parties”) submit this joint motion for an
`
`extension of time for NorthStar to comply with P.R. 3-1 and 3-2 (Infringement Contentions) from
`
`July 6, 2023, up to and including July 20, 2023; and for an extension of time for BMW to comply
`
`with P.R. 3-3 and 3-4 (Invalidity Contentions) from August 31, 2023, up to an including
`
`September 14, 2023. The Parties do not file this Joint Motion for the purpose of delay, but rather
`
`
`
`Case 2:22-cv-00486-JRG Document 30 Filed 06/27/23 Page 2 of 4 PageID #: 213
`
`to allow the Parties to adequately address the issues associated with the pending Contentions, and
`
`in order that justice be done.
`
`Dated: June 27, 2023
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Vincent J. Rubino, III
`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
`
`John Andrew Rubino
`NY Bar No. 5020797
`Email: jarubino@rubinoip.com
`Michael Mondelli III
`NY Bar No. 5805114
`Email: mmondelli@rubinoip.com
`RUBINO IP
`51 J.F.K. Parkway
`Short Hills, New Jersey 07078
`Telephone: (201) 341-9445
`Facsimile (973) 535-0921
`
`Justin Kurt Truelove
`Texas Bar No. 24013653
`Email: kurt@truelovelawfirm.com
`TRUELOVE LAW FIRM, PLLC
`100 West Houston Street
`Marshall, Texas 75670
`Telephone: (903) 938-8321
`Facsimile: (903) 215-8510
`
`ATTORNEYS FOR PLAINTIFF
`NORTHSTAR SYSTEMS LLC
`
`
`
`
`
`Case 2:22-cv-00486-JRG Document 30 Filed 06/27/23 Page 3 of 4 PageID #: 214
`
`/s/ Lionel M. Lavenue (with permission)
`Lionel M. Lavenue
`Virginia Bar No. 49,005
`Email: lionel.lavenue@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`1875 Explorer Street, Suite 800
`Reston, VA 20190
`Telephone: (571) 203-2700
`Facsimile: (202) 408-4400
`
`ATTORNEY FOR DEFENDANT
`BAYERISCHE MOTOREN WERKE AG
`
`
`
`
`
`
`
`Case 2:22-cv-00486-JRG Document 30 Filed 06/27/23 Page 4 of 4 PageID #: 215
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on June 27, 2023, all counsel of record who are
`
`deemed to have consented to electronic service are being served with a copy of this document via
`
`the Court’s CM/ECF system per Local Rule CV-5(a)(3).
`
`/s/ Vincent J. Rubino, III
` Vincent J. Rubino
`
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that counsel for Plaintiff has met and conferred with
`
`counsel for Defendants, and all parties have agreed to the proposed order submitted herewith.
`
`
`
`/s/ Vincent J. Rubino, III
` Vincent J. Rubino
`
`
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