`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`GOOGLE LLC,
`
`
`Defendant.
`
`Civil Case No. 6:21-cv-569-ADA
`
`JURY TRIAL DEMANDED
`
`U.S. District Judge Alan Albright
`
`PLAINTIFF TOUCHSTREAM’S UNOPPOSED MOTION FOR ENTRY OF
`JUDGMENT ON VERDICT
`
`
`
`Pursuant to Rule 58 of the Federal Rules of Civil Procedure, Plaintiff Touchstream
`
`Technologies (“Touchstream”) respectfully moves the Court to enter judgment on the jury’s
`
`verdict (ECF No. 247). Judgment on the verdict should start the time for filing any post-trial
`
`motions or appeal, including but not limited to: renewed motions for judgment as a matter of law
`
`and/or new trial under Fed. R. Civ. P. 50(b) and 59; motions to amend the judgment; motion for
`
`entry of a permanent injunction and/or an ongoing royalty; a motion for the award of supplemental
`
`damages, prejudgment interest, and postjudgment interest; and any other motions for equitable
`
`relief that may be just and proper.
`
`Counsel for Touchstream has conferred with counsel for Google and this motion is
`
`unopposed. A proposed form of Judgment on the Jury Verdict is attached for the Court’s
`
`consideration.
`
`
`
`
`
`
`
`
`
`Case 6:21-cv-00569-ADA Document 255 Filed 08/23/23 Page 2 of 3
`
`
`
`Respectfully submitted,
`
`TOUCHSTREAM TECHNOLOGIES, INC.
`
` /s/ Ryan D. Dykal
`One of Its Attorneys
`
`Ryan D. Dykal (Pro Hac Vice)
`B. Trent Webb (Pro Hac Vice)
`Jordan T. Bergsten (Pro Hac Vice)
`Lauren E. Douville (Pro Hac Vice)
`Philip A. Eckert (Pro Hac Vice)
`Robert McClendon (Pro Hac Vice)
`SHOOK, HARDY & BACON L.L.P.
`2555 Grand Boulevard
`Kansas City, MO 64108
`(816) 474-6550
`Fax: (816) 421-5547
`rdykal@shb.com | bwebb@shb.com |
`jbergsten@shb.com | ldouville@shb.com
`peckert@shb.com | rmcclendon@shb.com
`
`
`Date: August 23, 2023
`
`
`By: Michael W. Gray (TX Bar No. 24094385)
`Andrew M. Long (TX Bar No. 24123079)
`Sharon A. Israel (TX Bar. No. 00789394)
`Robert H. Reckers (TX Bar No. 24039520)
`Kyle E. Friesen (TX Bar No. 24061954)
`SHOOK, HARDY & BACON L.L.P.
`600 Travis Street, Suite 3400
`Houston, TX 77002
`(713) 227-2008
`Fax: (713) 227-9508
`mgray@shb.com | amlong@shb.com
`sisrael@shb.com | rreckers@shb.com
`kfriesen@shb.com
`
`Gary M. Miller (Pro Hac Vice)
`Justin R. Donoho (Pro Hac Vice)
`Samuel G. Bernstein (Pro Hac Vice)
`SHOOK, HARDY & BACON L.L.P.
`111 S. Wacker Drive, Suite 4700
`Chicago, IL 60606
`(312) 704-7700
`Fax: (312) 558-1195
`gmiller@shb.com | jdonoho@shb.com |
`sbernstein@shb.com
`Counsel for Plaintiff Touchstream Technologies, Inc.
`
`
`
`
`
`2
`
`
`
`Case 6:21-cv-00569-ADA Document 255 Filed 08/23/23 Page 3 of 3
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on August 23, 2023, the foregoing was electronically
`
`filed with the Clerk of Court using the CM/ECF system, which will send a notification of such
`
`filing (“NEF”) to all counsel of record who have appeared in this case per Local Rule CV-5(b).
`
` /s/ Ryan D. Dykal
`Attorney for Plaintiff
`
`
`
`
`
`
`
`
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