`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`NEODRON LTD.,
`
`Plaintiff,
`
`v.
`HP INC.,
`
`
`Defendant.
`
`
`
`
`
`Case No. 6:19-cv-00319-ADA
`
`STIPULATED MOTION TO DISMISS WITH PREJUDICE
`
`Pursuant to Rule 41 of the Federal Rules of Civil Procedure, the Parties move, stipulate
`
`and agree subject to and upon the Court’s approval that:
`
`(i)
`
`this action, including all claims and counterclaims that were or could have been
`
`brought in this action, shall be dismissed with prejudice, pursuant to the Settlement
`
`and License Agreement, whose terms shall remain confidential;
`
`(ii)
`
`this Court shall retain continuing jurisdiction over the parties and the subject matter
`
`to enforce the Settlement and License Agreement; and
`
`(iii)
`
` each of the Parties shall bear its own costs, expenses and attorneys’ fees in this
`
`action.
`
`
`
`
`
`
`
`Dated: August 20, 2020
`
`
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`
`By: /s/ Reza Mirzaie
`Reza Mirzaie (CA SBN 246953)
`Kent N. Shum (CA Bar No. 259189)
`Philip X. Wang (CA Bar No. 262239)
`C. Jay Chung (CA Bar No. 252794)
`Jonathan Ma (CA Bar No. 312773)
`Christian W. Conkle (CA Bar No. 306374)
`Kristopher R. Davis (CA Bar No. 329627)
`
`
`
`Case 6:19-cv-00319-ADA Document 21 Filed 08/20/20 Page 2 of 3
`
`Paul A. Kroeger (CA Bar No. 229074)
`Brian D. Ledahl (CA Bar No. 186579)
`RUSS, AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`Email: rmirzaie@raklaw.com
` kshum@raklaw.com
` pwang@raklaw.com
` jchung@raklaw.com
` jma@raklaw.com
` cconkle@raklaw.com
` kdavis@raklaw.com
` pkroeger@raklaw.com
` bledahl@raklaw.com
`
`Matthew D. Aichele (VA Bar No. 77821)
`Russ August & Kabat
`800 Main Avenue, SW, Suite 200
`Washington, DC 20024
`Telephone: (202) 664-0623
`Email: maichele@raklaw.com
`Attorneys for Plaintiff
`Neodron Ltd.
`
`By: /s/ John Michael Guaragna
`John Michael Guaragna
`DLA Piper LLP (US)
`401 Congress, Suite 2500
`Austin, Texas 78701
`Telephone: (512) 457-7125
`Facsimile: (512) 457-7001
`Email: john.guaragna@us.dlapiper.com
`
`Attorney for Defendant
`HP Inc.
`
`
`
`
`
`
`
`Case 6:19-cv-00319-ADA Document 21 Filed 08/20/20 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I certify that on August 20, 2020, a true and correct copy of foregoing document was
`
`electronically filed with the Court and served on all parties of record via the Court’s CM/ECF
`
`system.
`
`
`
`Lead Attorney
`John Michael Guaragna
`DLA Piper LLP (US)
`401 Congress, Suite 2500
`Austin, Texas 78701
`Telephone: (512) 457-7125
`Facsimile: (512) 457-7001
`Email: john.guaragna@dlapiper.com
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
`
`
`
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