`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
` NEODRON LTD.,
`
`Plaintiff,
`
`Case No. 6-21-CV-00547-ADA
`
`v.
`
`JURY TRIAL DEMANDED
`
`STMICROELECTRONICS N.V.;
`STMICROELECTRONICS, INC.;
`STMICROELECTRONICS (NORTH
`AMERICA) HOLDING, INC.,
`
`Defendants.
`
`JOINT MOTION TO DISMISS
`
`Plaintiff Neodron Ltd. (“Plaintiff”) has resolved the claims for relief it asserted in this case
`
`against Defendants STMicroelectronics, Inc., STMicroelectronics (North America) Holdings, Inc.,
`
`and STMicroelectronics N.V. (collectively, “Defendants”).
`
`NOW, THEREFORE,
`
`Plaintiff
`
`and Defendants
`
`STMicroelectronics,
`
`Inc.
`
`STMicroelectronics (North America) Holdings, Inc., through their attorneys of record, request this
`
`Court to dismiss Plaintiff’s claims for relief against all Defendants with prejudice, and with all
`
`attorneys’ fees, costs of court and expenses borne by the party incurring same.
`
`November 4, 2021
`
`/s/ Reza Mirzaie
`
`Reza Mirzaie (CA SBN 246953)
`Email: rmirzaie@raklaw.com
`Philip X. Wang (CA SBN 262239)
`Email: pwang@raklaw.com
`Kristopher Davis (CA SBN 329627)
`Email: kdavis@raklaw.com
`
`Respectfully submitted,
`
` /s/ Justin S. Cohen
`
`Bruce S. Sostek
`Justin S. Cohen
`Richard L. Wynne, Jr.
`Nadia E. Haghighatian
`HOLLAND & KNIGHT LLP
`One Arts Plaza
`
`1
`
`
`
`Case 6:21-cv-00547-ADA Document 24 Filed 11/04/21 Page 2 of 3
`
`
`
`Christian W. Conkle (CA SBN 306374)
`Email: cconkle@raklaw.com
`Jonathan Ma (CA SBN 312773)
`Email: jma@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`
`
`
`
`
`ATTORNEY FOR PLAINTIFF
`
`
`
`
`NEODRON LTD.
`
`
`
`
`1722 Routh St., Suite 1500
`Dallas, Texas 75201
`Telephone: 214.969.1386
`
`Max Ciccarelli
`CICCARELLI LAW FIRM LLC
`750 N. St. Paul St., Suite 200
`Dallas, Texas 75201
`Telephone 214.444.8869
`
`
`
`
`
`
`
`
`
`
`ATTORNEY FOR DEFENDANTS
`
`STMICROELECTRONICS INC. and
`STMICROELECTRONICS (NORTH
`AMERICA) HOLDING, INC.
`
`
`
`2
`
`
`
`Case 6:21-cv-00547-ADA Document 24 Filed 11/04/21 Page 3 of 3
`
`CERTIFICATE OF CONFERENCE
`
`In accordance with Local Rule CV-7(G), I hereby certify that I met and conferred with
`
`counsel for Defendants, regarding the relief sought in this motion by email on November 4, 2021.
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
`ATTESTATION OF CONCURRENCE
`
`I hereby attest that concurrence in the filing of the document has been obtained from each
`
`of the other signatories, which shall serve in lieu of their signatures on the document.
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the counsel of record who are deemed to have consented to
`
`electronic service are being served on November 4, 2021 with a copy of this document via the
`
`Court’s ECF system.
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
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.
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.
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
