`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Plaintiff,
`
`v.
`
`DODOTS LICENSING SOLUTIONS LLC,
`
`
`
`
`
`SAMSUNG ELECTRONICS CO.,
`LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., BEST BUY STORES,
`L.P., BESTBUY.COM, LLC, AND
`BEST BUY TEXAS.COM, LLC,
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case No. 6:22-cv-00535-ADA-DTG
`
`Defendants.
`
`DEFENDANTS’ UNOPPOSED MOTION FOR LEAVE
`TO EXTEND DEADLINE FOR MOTION TO TRANSFER VENUE
`
`Pursuant to Federal Rule of Civil Procedure 6(b) and this Court’s Standard Order
`
`Governing Proceedings 4.2 § VI, Defendants Samsung Electronics Co., Ltd. (“SEC”) and
`
`Samsung Electronics America, Inc. (“SEA”) (collectively, “Samsung”), Best Buy Stores, L.P.,
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`Bestbuy.com, LLC, and Best Buy Texas.com, LLC (collectively, “Best Buy”) (together,
`
`“Defendants”) hereby move to seek leave of Court to extend by one week the deadline to file
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`Defendants’ Motion to Transfer Venue. Counsel for Plaintiff has indicated that Plaintiff does not
`
`oppose this extension request.
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`Good cause supports the present motion. Plaintiff filed the parties’ Case Readiness Status
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`Report on November 29, 2022 in this case, see Dkt. 54, and on November 30, 2022 in the related
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`case DoDots Licensing Solutions LLC v. Apple Inc., No 6:22-cv-00533 (W.D. Tex. Nov. 30, 2022),
`
`Dkt. 54. These filings established the current Motion to Transfer Venue deadline of January 4,
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`2022. In the time since this deadline was set, Samsung has diligently attempted to identify the
`
`1
`
`
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`Case 6:22-cv-00535-ADA Document 56 Filed 12/29/22 Page 2 of 4
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`correct declarant or group of declarants to establish several facts in support of Defendants’ Motion
`
`to Transfer Venue. These efforts have been slowed due to one of Samsung’s intended declarants
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`separating from Samsung and alternative declarant unavailability during the winter holiday season.
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`Defendants therefore seek one additional week to file their Motion to Transfer Venue to ensure the
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`ability to secure the appropriate declarants.
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`This motion is not brought for the purpose of delay or any other improper purpose. Rather,
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`this motion is presented so that Defendants may fully brief and present the transfer facts for the
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`Court. The undersigned certifies that this extension does not change the date for any hearing, any
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`final submission to the Court related to a hearing, or the trial.
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`Accordingly, Defendants respectfully present this unopposed request for a one-week
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`extension up to and including January 11, 2023 to file its Motion to Transfer Venue.
`
`
`
`Dated: December 29, 2022
`
`Respectfully submitted,
`
`
`
`FISH & RICHARDSON P.C.
`
`By: /s/ David M. Hoffman
`
`David M. Hoffman
`TX Bar No. 24046084
`hoffman@fr.com
`111 Congress Avenue, Suite 810
`Austin, TX 78701
`Tel: (512) 472-5070
`Fax: (512) 320-8935
`
`Michael J. McKeon (pro hac vice pending)
`DC Bar No. 459780
`Adam R. Shartzer (admitted in W.D. Tex)
`DC Bar No. 994420
`shartzer@fr.com
`Michael J. Ballanco (pro hac vice pending)
`VA Bar No. 87293
`ballanco@fr.com
`Ben Christoff (pro hac vice pending)
`
`2
`
`
`
`Case 6:22-cv-00535-ADA Document 56 Filed 12/29/22 Page 3 of 4
`
`christoff@fr.com
`DC Bar No. 1025635
`Irene Hwang (pro hac vice pending)
`CA Bar No. 344798
`hwang@fr.com
`1000 Maine Avenue, SW, Suite 1000
`Washington, DC 20024
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`
`COUNSEL FOR DEFENDANTS,
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC.,
`BEST BUY STORES, L.P., BESTBUY.COM, LLC,
`AND BEST BUY TEXAS.COM, LLC
`
`
`
`
`
`
`
`3
`
`
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`Case 6:22-cv-00535-ADA Document 56 Filed 12/29/22 Page 4 of 4
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing document was filed electronically in
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`compliance with Local Rule CV-5(a) on December 29, 2022, and it was served via CM/ECF on
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`all counsel of record.
`
`
`
`
`
`
`/s/ David M. Hoffman
`David M. Hoffman
`
`4
`
`
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