throbber
Case 6:20-cv-00505-ADA Document 44 Filed 02/16/21 Page 1 of 2
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`NEONODE SMARTPHONE LLC,
`
`
`
`
`
`APPLE INC.,
`
`
`v.
`
`Plaintiff,
`
`
`
`
`
`
`
`
`Defendants.
`
`Civil Action No. 6:20-cv-00505-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`APPLE INC.’S RESPONSE TO NEONODE SMARTPHONE LLC’S MOTION FOR
`ISSUANCE OF LETTER OF REQUEST
`
`Defendant Apple Inc. (“Apple”) hereby responds to Plaintiff Neonode Smartphone
`
`LLC’s (“Neonode Smartphone”) Motion for Issuance of Letter of Request to Examine Persons,
`
`Inspect Documents and Inspect Property Pursuant to the Hague Convention on the Taking of
`
`Evidence Abroad in Civil or Commercial Matters (“Motion”) (Dkt. No. 43).
`
`Apple does not oppose Neonode Smartphone’s Motion, though notes that Neonode
`
`Smartphone failed to wait for Apple’s response during the meet and confer process as required
`
`by the Local Rules in this District before filing its allegedly opposed Motion. See Local Rule
`
`CV-7-2(i) (“The court may refuse to hear or may deny a nondispositive motion unless the movant
`
`advises the court within the body of the motion that counsel for the parties have first conferred
`
`in a good-faith attempt to resolve the matter by agreement and, further, certifies the specific
`
`reason that no agreement could be made.”); see also Attachment A (parties’ correspondence
`
`related to the Motion); Dkt. No. 43.
`
`
`
`
`
`
`
`
`1
`
`

`

`Case 6:20-cv-00505-ADA Document 44 Filed 02/16/21 Page 2 of 2
`
`Date: February 16, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`Respectfully submitted,
`
`FISH & RICHARDSON P.C.
`
`/s/ Betty Chen
`Benjamin C. Elacqua
`Texas Bar Number 24055443
`elacqua@fr.com
`Kathryn A. Quisenberry
`Texas Bar Number 24105639
`quisenberry@fr.com
`FISH & RICHARDSON P.C.
`1221 McKinney Street, Suite 2800
`Houston, TX 77010
`Telephone: 713-654-5300
`Facsimile: 713-652-0109
`
`Betty Chen
`Texas Bar Number 24056720
`bchen@fr.com
`FISH & RICHARDSON P.C.
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`Telephone: 650-839-5070
`Facsimile: 650-839-5071
`
`
`COUNSEL FOR DEFENDANT APPLE INC.
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`
`document has been served on February 16, 2021 to all counsel of record who are deemed to have
`
`consented to electronic service via the Court’s CM/ECF system per Local Rule CV-5(b)(1).
`
`
`
`
`
`
`
`/s/ Betty Chen
`Betty Chen
`
`
`
`
`
`2
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket