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Case 2:24-cv-00215-RWS-RSP Document 12 Filed 04/04/24 Page 1 of 4 PageID #: 72
`
`
`SLYDE ANALYTICS LLC,
`
`
`
`
`v.
`
`Plaintiff,
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION

`

`Case No. 2:24-cv-00215-RWS-RSP

`
`JURY TRIAL DEMANDED


`







`
`
`
`GARMIN LTD. and GARMIN
`CORPORATION,
`
`
`Defendants.
`
`
`
`MOTION FOR ISSUANCE OF LETTERS ROGATORY FOR SERVICE OF PROCESS
`ON DEFENDANT GARMIN CORPORATION
`
`Pursuant to Federal Rules of Civil Procedure 4(h)(2) and 4(f)(2)(B), Plaintiff Slyde
`
`
`
`Analytics LLC (“Slyde” or “Plaintiff”) respectfully requests that this Court issue a Request for
`
`Judicial Assistance (“Letters Rogatory”) (attached as Exhibit A), addressed to the appropriate
`
`judicial authority in Taiwan, requesting that the Taiwanese authority assists in effecting service of
`
`process upon Defendant Garmin Corporation (“Garmin Corp.” or “Defendant”).
`
`Slyde filed its Complaint (Dkt. No. 1) on March 27, 2024. This Court issued a Summons
`
`as to Garmin Corp. on March 28, 2024 (Dkt. No. 11). Upon information and belief, Garmin Corp.
`
`is a publicly-listed company with an address of No. 68, Zhangshu 2nd Road, Xizhi District, New
`
`Taipei City, 221, Taiwan. Accordingly, Slyde respectfully requests that this Court issue Letters
`
`Rogatory seeking the assistance of the Taiwanese authority in effecting service of the Complaint
`
`and Summons upon Garmin Corp.
`
`Slyde respectfully requests that the Court return (a) the original copy of the signed and
`
`issued Letters Rogatory, and (b) two certified copies, to the undersigned counsel. The United
`
`

`

`Case 2:24-cv-00215-RWS-RSP Document 12 Filed 04/04/24 Page 2 of 4 PageID #: 73
`
`States Department of State will oversee transmission of the Letters Rogatory to Taiwan through
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`diplomatic channels as provided in 28 U.S.C. § 1781(a)(2). Slyde will reimburse this Court for
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`any expenses incurred in connection with the issuance and return of the Letters Rogatory. Slyde
`
`has retained the services of Process Service Network, 27201 Tourney Road, Suite 223, Valencia,
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`CA 91355, to ensure delivery of the materials and fee in accordance with U.S. and Taiwanese
`
`procedures.
`
`Dated: April 4, 2024
`
`
`
`
`
`
`
`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, NJ 07078
`Telephone: (973) 535-0920
`Facsimile: (973) 535-0921
`
`
`
`
`
`2
`
`

`

`Case 2:24-cv-00215-RWS-RSP Document 12 Filed 04/04/24 Page 3 of 4 PageID #: 74
`Case 2:24-cv-00215-RWS-RSP Document 12 Filed 04/04/24 Page 3 of 4PagelD #: 74
`
`ATTORNEYS FOR PLAINTIFF
`ATTORNEYS FOR PLAINTIFF
`SLYDE ANALYTICS LLC
`SLYDE ANALYTICS LLC
`
`
`3
`
`

`

`Case 2:24-cv-00215-RWS-RSP Document 12 Filed 04/04/24 Page 4 of 4 PageID #: 75
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`
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that, on April 4, 2024, all counsel of record who are
`
`deemed to 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).
`
` /s/ Vincent J. Rubino, III
` Vincent J. Rubino, III
`
`

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