`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`NEODRON LTD.,
`
`Plaintiff,
`
`v.
`
`LENOVO GROUP LTD. and LENOVO
`(UNITED STATES) INC.,
`
`
`Case No. 6:19-cv-00320-ADA
`
`
`
`
`
`Defendants.
`
`JOINT MOTION TO DISMISS WITH PREJUDICE
`
`WHEREAS, Plaintiff Neodron Ltd., (“Plaintiff”) and Defendant Lenovo Group Ltd.,1 and
`
`
`
`
`
`
`Lenovo (United States) Inc., (“Defendants”) have resolved Plaintiff’s claims for relief against
`
`Defendant asserted in this case.
`
`NOW, THEREFORE, Plaintiff and Defendants through their attorneys of record, request
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`this Court to dismiss Plaintiff’s claims for relief against Defendants with prejudice, and with all
`
`attorneys’ fees, costs of court and expenses borne by the party incurring same.
`
`Dated: January 4, 2021
`
`
`
`Respectfully Submitted,
`
`
`By: /s/ Reza Mirzaie
`
`Reza Mirzaie (CA SBN 246953)
`rmirzaie @ raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`Email: bledahl@raklaw.com
`
`
`1 Although Plaintiffs did not serve Lenovo Group Ltd. in this action, the parties agree that any
`claims as to Lenovo Group Ltd. should be dismissed with prejudice.
`
`
`
`Case 6:19-cv-00320-ADA Document 27 Filed 01/04/21 Page 2 of 3
`
`Paul A. Kroeger (CA SBN 229074)
`pkroeger@raklaw.com
`Philip X. Wang (CA SBN 262239)
`pwang@raklaw.com
`Kent N. Shum (CA SBN 259189)
`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/ Lionel M. Lavenue
`Lionel M. Lavenue
`FINNEGAN HENDERSON FARABOW
`GARRETT & DUNNER LLP
`11955 Freedom Drive, Suite 800
`Reston, VA 20190
`Email: lionel.lavenue@finnegan.com
`
`Attorney for Defendants Lenovo Group
`Ltd. and Lenovo (United States)
`
`
`
`
`
`- 2 -
`
`
`
`
`
`Case 6:19-cv-00320-ADA Document 27 Filed 01/04/21 Page 3 of 3
`
`
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`CERTIFICATE OF CONFERENCE
`
`Neodron certifies that counsel for Neodron and counsel for Defendant met and conferred
`
`concerning the substance of this Joint Motion to Dismiss with Prejudice and the relief requested on
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`December 31, 2021. Defendant agrees with the Joint Motion and the relief requested.
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
`CERTIFICATE OF SERVICE
`
`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 the
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`Court’s ECF system.
`
`
`
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
`
`
`
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