`
`UNITED STATES DISTRICT COURT
`IN THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` C.A. No. 6:19-cv-00318-ADA
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`
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`Plaintiff,
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`NEODRON LTD.,
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`v.
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`DELL TECHNOLOGIES, INC.,
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`Defendant.
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`JOINT MOTION TO DISMISS WITH PREJUDICE
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`WHEREAS, Plaintiff Neodron Ltd., (“Plaintiff”) and Defendant Dell Technologies, Inc.,
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`(“Defendant”) have resolved Plaintiff’s claims for relief against Defendant and Defendant’s
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`counterclaims for relief against Plaintiff asserted in this case.
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`NOW, THEREFORE, Plaintiff and Defendant through their attorneys of record, request
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`this Court to dismiss Plaintiff’s claims for relief against Defendant with prejudice and Defendant’s
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`claims, defenses or counterclaims for relief against Plaintiff with prejudice, and with all attorneys’
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`fees, costs of court and expenses borne by the party incurring same.
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`Dated: January 4, 2021
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`Respectfully Submitted,
`
`
`By: /s/ Reza Mirzaie
`
`Reza Mirzaie (CA SBN 246953)
`rmirzaie @ raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`Email: bledahl@raklaw.com
`Paul A. Kroeger (CA SBN 229074)
`pkroeger@raklaw.com
`Philip X. Wang (CA SBN 262239)
`pwang@raklaw.com
`Kent N. Shum (CA SBN 259189)
`
`
`
`Case 6:19-cv-00318-ADA Document 24 Filed 01/04/21 Page 2 of 3
`
`Email: kshum@raklaw.com
`Christian W. Conkle (CA SBN 306374)
`Email: cconkle@raklaw.com
`Kristopher R. Davis (SBN 329627)
`Email: kdavis@raklaw.com
`Jonathan Ma (SBN 312773)
`jma@raklaw.com
`Jay Chung (SBN 252794)
`jchung@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`
`Matthew D. Aichele (VA SBN 77821)
`Email: maichele@raklaw.com
`RUSS AUGUST & KABAT
`800 Maine Avenue, SW, Suite 200
`Washington, DC 20024
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`
`Attorneys for Plaintiff Neodron Ltd
`
`
`By: /s/ Brady Cox______
`Brady Cox
`Email: brady.cox@alston.com
`ALSTON & BIRD LLP
`2200 Ross Avenue, Suite 2300
`Dallas, Texas 75201
`Phone: (214) 922-3400
`Fax: (214) 922-3899
`
`Jeffrey T. Lindgren
`Richard C. Vasquez
`VASQUEZ BENISEK &
`LINDGREN LLP
`1550 Parkside Drive, Suite 130
`Walnut Creek, CA 94596
`925-627-4250
`Fax: 925-403-0900
`Email: jlindgren@vbllaw.com
`Email: rvasquez@vbllaw.com
`Attorneys for Defendant Dell Technologies,
`Inc.
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`- 2 -
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`Case 6:19-cv-00318-ADA Document 24 Filed 01/04/21 Page 3 of 3
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`
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`CERTIFICATE OF CONFERENCE
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`Neodron certifies that counsel for Neodron and counsel for Defendant met and
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`conferred concerning the substance of this Joint Motion to Dismiss with Prejudice and the
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`relief requested on January 2, 2021 Defendant agrees with the Joint Motion and the relief
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`requested.
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`
`
`/s/_Reza Mirzaie _____________
`Reza Mirzaie
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`CERTIFICATE OF SERVICE
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`I hereby certify that the counsel of record who are deemed to have consented to
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`electronic service are being served on January 4, 2021 with a copy of this document via
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`the Court’s ECF system.
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`/s/ Reza Mirzaie____________
`Reza Mirzaie
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`
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`3
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`
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