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`Plaintiff,
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`v.
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`VOLKSWAGEN AG,
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`Defendant.
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`NORTHSTAR SYSTEMS LLC,
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`Plaintiff,
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`v.
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`BAYERISCHE MOTOREN WERKE AG,
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`Defendant.
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`
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`Case No. 2:22-cv-00486-JRG (Lead Case)
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`JURY TRIAL DEMANDED
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`
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`Case No. 2:22-cv-00496-JRG (Member Case)
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`JURY TRIAL DEMANDED
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`Case 2:22-cv-00486-JRG Document 67 Filed 09/01/23 Page 1 of 3 PageID #: 831
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`DEFENDANT BAYERISCHE MOTOREN WERKE AG’s
`MOTION TO AMEND THE DOCKET CONTROL ORDER
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`Defendant Bayerische Motoren Werke AG (“BMW AG”) respectfully moves to amend
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`the Docket Control Order (Dkt. 57) for it to serve its Subject Matter Eligibility Contentions and
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`Invalidity Contentions from September 14, 2023, to October 2, 2023.
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`Plaintiff does not oppose the requested relief. BMW AG does not file this Motion for the
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`purpose of delay, but rather to allow the BMW AG to adequately address the issues associated
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`with the pending Contentions, to align BMW AG’s deadline for contentions with the VW
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`deadline for simplicity, and in order that justice be done.
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`
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`Case 2:22-cv-00486-JRG Document 67 Filed 09/01/23 Page 2 of 3 PageID #: 832
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`BMW AG respectfully requests that the Court entered the Amended Docket Control
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`Order attached hereto as Exhibit A.
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`Dated: September 1, 2023
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`Respectfully submitted,
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`
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
`Virginia Bar No. 49,005
`lionel.lavenue@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`1875 Explorer Street, Suite 800
`Reston, VA 20190
`Phone: (571) 203-2700
`Fax: (202) 408-4400
`
`ATTORNEY FOR DEFENDANT
`BAYERISCHE MOTOREN WERKE AG
`
`
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`Case 2:22-cv-00486-JRG Document 67 Filed 09/01/23 Page 3 of 3 PageID #: 833
`
`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for Defendant Bayerische Motoren Werke AG has met and
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`conferred with Counsel for Plaintiff and Defendant Volkswagen AG to the relief requested.
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`Plaintiff and Defendant Volkswagen AG do not oppose this motion.
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`
`
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
`
`CERTIFICATE OF SERVICE
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`
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` I hereby certify that on September 1, 2023, I electronically filed the foregoing MOTION TO
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`AMEND THE DOCKET CONTROL ORDER with the Clerk of the Court using the CM/ECF
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`system which will send notification of such filing via electronic mail to all counsel of record.
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
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