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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`TOUCHSTREAM TECHNOLOGIES,
`INC.
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`Plaintiff,
`
`v.
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`GOOGLE LLC
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`
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`Civil Action No. 6:21-cv-569-ADA
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`JURY TRIAL DEMANDED
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`Defendant.
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`CASE READINESS STATUS REPORT
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`Plaintiff Touchstream Technologies, Inc. (“Touchstream”) and defendant Google LLC
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`(“Google”) hereby provide the following status report.
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`FILING AND EXTENSIONS
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`Plaintiff’s complaint was filed on June 4, 2021. (Dkt. No. 1.) Defendant requested a single
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`unopposed extension of time of 45 days to respond to the complaint (Dkt. No. 9), which was granted
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`by this Court.
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`RESPONSE TO THE COMPLAINT
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`Defendant responded to the complaint on August 13, 2021, by filing a Motion to Dismiss
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`Touchstream’s Willful Infringement and Injunctive Relief Claims Under Rule 12(b)(6). (Dkt. No.
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`14.)
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`PENDING MOTIONS
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`The only currently pending motion is Defendant’s Motion to Dismiss Touchstream’s
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`Willful Infringement and Injunctive Relief Claims Under Rule 12(b)(6). (Dkt. No. 14.)
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`Case 6:21-cv-00569-ADA Document 17 Filed 08/20/21 Page 2 of 4
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`RELATED CASES IN THIS JUDICIAL DISTRICT
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`There are no related cases in the Western District of Texas.
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`IPR, CBM, AND OTHER PGR FILINGS
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`There are no known IPR, CBM, or other PGR filings.
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`NUMBER OF ASSERTED PATENTS AND CLAIMS
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`Plaintiff has asserted 3 patents. The asserted patents are United States Patent Nos. 8,356,251
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`(the “’251 patent”), 8,782,528 (the “’528 patent”), and 8,904,289 (the “’289 patent”). The deadline
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`for Plaintiff to serve its Preliminary Infringement Contentions, identifying its asserted claims, is
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`August 27, 2021.
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`APPOINTMENT OF TECHNICAL ADVISOR
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`The parties do not request that a technical advisor be appointed to the case to assist the Court
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`with claim construction or other technical issues.
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`MEET AND CONFER STATUS
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`Plaintiff and Defendant have met and conferred. The parties have no pre-Markman issues
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`to raise at the CMC.
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`Dated: August 20, 2021
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`Respectfully submitted,
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`/s/ Fiona A. Bell
`Fiona A. Bell (TX Bar No. 24052288)
`SHOOK, HARDY & BACON L.L.P.
`600 Travis Street, Suite 3400
`Houston, TX 77002
`(713) 227-2008
`Fax: 713-227-9508
`Email: fbell@shb.com
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`
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`Case 6:21-cv-00569-ADA Document 17 Filed 08/20/21 Page 3 of 4
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` Jordan T. Bergsten, pro hac vice
` Samuel J. Laroque, pro hac vice
` Ryan D. Dykal, pro hac vice
` Shook, Hardy & Bacon, LLP
` 2555 Grand Boulevard
` Kansas City, MO 64108
` (816) 474-6550
` Fax: (816) 421-5547
`Email: jbergsten@shb.com
`Email: slaroque@shb.com
`Email: rdykal@shb.com
`Counsel for Plaintiff
`Touchstream Technologies, Inc.
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`
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`/s/ Tharan Gregory Lanier
` Michael E. Jones
` Potter Minton PC
` 110 N College, Suite 500
` Tyler, TX 75702
` 903-597-8311
` Fax: 903-531-3939
` Email: mikejones@potterminton.com
`
` Evan M. McLean, pro hac vice
` Michael C. Hendershot, pro hac vice
` Tharan Gregory Lanier, pro hac vice
` Jones Day
` 1755 Embarcadero Road
` Palo Alto, CA 94303
` (650) 739-3939
` Fax: (650) 739-3900
` Email: emclean@jonesday.com
` Email: mhendershot@jonesday.com
` Email: tglanier@jonesday.com
`Counsel for Defendant Google LLC.
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`Case 6:21-cv-00569-ADA Document 17 Filed 08/20/21 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
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`that on the 20th day of August, 2021, I electronically filed the foregoing with the Clerk of Court
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`using the CM/ECF system, and all counsel of record who are deemed to have consented to
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`electronic service are being served with a copy of this document via the Court’s CM/ECF system.
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`Further, I hereby certify that I emailed counsel for Defendant and the Court
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`(TXWDml_LawClerks_JudgeAlbright@txwd.uscourts.gov) a courtesy copy of the foregoing.
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`/s/ Fiona A. Bell
`Fiona A. Bell
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