`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`Plaintiff,
`
`Case No. 6:19-cv-00398-ADA
`
`NEODRON LTD.,
`
`
`
`
`
`
`
`
`
`
`
`v.
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`JURY TRIAL DEMANDED
`
`LENOVO GROUP LTD., LENOVO (UNITED
`STATES) INC., and MOTOROLA MOBILITY
`LLC,
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`
`
`
`
`
`
`
`
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`Defendants.
`
`
`
`
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`NOTICE OF DISMISSAL WITHOUT PREJUDICE
`
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`Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), Plaintiff Neodron Ltd., hereby dismisses without
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`prejudice all claims in this action against Lenovo Group Ltd., Lenovo (United States) Inc., and
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`Motorola Mobility LLC, with each party to bear its own costs, expenses, and attorneys’ fees.
`
`
`
`Dated: September 6, 2019
`
`
`/s/ Reza Mirzaie
`
` Reza Mirzaie (CA SBN 246953)
`Email: rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`Email: mfenster@raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`Email: bledahl@raklaw.com
`Paul A. Kroeger (CA SBN 229074)
`Email: pkroeger@raklaw
`Philip X. Wang (CA SBN 262239)
`pwang@raklaw.com
`Neil A. Rubin (CA SBN 250761)
`Email: nrubin@raklaw.com
`Amy E. Hayden (CA SBN 287026)
`Email: ahayden@raklaw.com
`Shani Williams (SBN 274509)
`Email: swilliams@raklaw.com
`
` 1
`
`
`
`Case 6:19-cv-00398-ADA Document 25 Filed 09/06/19 Page 2 of 3
`
`Kristopher R. Davis (IL SBN 6296190)
`Email: kdavis@raklaw.com
`Christian W. Conkle (CA SBN 306374)
`Email: cconkle@raklaw.com
`Kent N. Shum (CA SBN 259189)
`Email: kshum@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`
`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.
`
`
`
`
`2
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`
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`Case 6:19-cv-00398-ADA Document 25 Filed 09/06/19 Page 3 of 3
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that all counsel of record who are deemed to have
`
`consented to electronic service are being served with a copy of this document via electronic mail
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`per Local Rule CV-5(a)(3) on September 6, 2019.
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
` 1
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`
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