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`John P. Schnurer, Bar No. 185725
`JSchnurer@perkinscoie.com
`Yun Louise Lu, Bar No. 253114
`LLu@perkinscoie.com
`Kyle R. Canavera Bar No. 314664
`KCanavera@perkinscoie.com
`PERKINS COIE LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130-2080
`Telephone: 858.720.5700
`Facsimile: 858.720.5799
`Attorneys for Defendants
`TCT Mobile (US) Inc. and Huizhou TCL Mobile
`Communication Co. Ltd.
`
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`ANCORA TECHNOLOGIES, INC.,
`Plaintiff,
`
`v.
`TCT MOBILE (US) INC. AND
`HUIZHOU TCL MOBILE
`COMMUNICATION CO. LTD.,
`Defendants.
`
`
`
`Case No. 8:19-CV-02192
`JOINT STIPULATION TO
`CONSOLIDATE
`Judge: Hon. Josephine L. Staton
`[Proposed Order Submitted Herewith]
`
`
`JOINT STIPULATION TO CONSOLIDATE
`Case No. 8:19-CV-02192
`
`
`
`
`
`
`
`
`
`Case 8:19-cv-02192-GW-AS Document 25 Filed 02/19/20 Page 2 of 3 Page ID #:217
`
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`JOINT STIPULATION
`Pursuant to Civil Local Rule 7-1, Plaintiff Ancora Technologies, Inc.
`
`(“Ancora”) and Defendants TCT Mobile (US) Inc. and Huizhou TCL Mobile
`Communication Co. Ltd. (“TCL”), by and through their respective counsel of record,
`hereby stipulate and request that the Court enter an order consolidating this case with
`co-pending case 2:20-cv-01252. In support of this request, the parties hereby state
`as follows:
`1. Ancora filed a complaint on August 27, 2019 and an amended complaint on
`September 12, 2019 in the Eastern District of Texas alleging TCL Corp., TCL
`Communication Ltd., TCL Communication Technology Holdings Ltd., TCT
`Mobile International Ltd., TCT Mobile, Inc., TCT Mobile (US) Inc., and TCT
`Mobile (US) Holdings Inc. infringe U.S. Patent No. 6,411,941 (’941 patent).
`Ancora Technologies, Inc. v. TCL Corp., No. 4:19-cv-00624 (E.D. Tex. Aug.
`27, 2019) (“Texas Lawsuit”).
`2. On November 12, 2019, TCL commenced the instant action against Ancora
`for declaratory judgment of noninfringement of the ’941 patent. Ancora
`Technologies, Inc. v. TCT Mobile (US) Inc., No. 8:19-cv-02192 (C.D. Cal.
`Nov. 12, 2019).
`3. On January 29, 2020, Ancora and TCL stipulated in this action to, inter alia,
`transfer the Texas Lawsuit to this Court for consolidation with this lawsuit.
`See Dkt. No. 22. On February 5, 2020, the Court granted the stipulation.
`Dkt. No. 23.
`4. On February 4, 2020, the parties jointly moved the Texas court to transfer the
`Texas Lawsuit to this Court on the basis of the parties’ stipulation. See Texas
`Lawsuit, Dkt. No. 26. On February 5, 2020, the Texas court granted the joint
`motion and transferred the Texas Lawsuit to this Court. See Texas Lawsuit,
`Dkt. No. 27.
`
`
`
`JOINT STIPULATION TO CONSOLIDATE
`Case No. 8:19-CV-02192
`
`
`
`-2-
`
`
`
`
`
`Case 8:19-cv-02192-GW-AS Document 25 Filed 02/19/20 Page 3 of 3 Page ID #:218
`
`
`5. At present, the instant lawsuit and the transferred Texas Lawsuit are both
`pending before the Court. See Ancora Technologies, Inc. v. TCL Corp., No.
`2:20-cv-01252 (C.D. Cal.) (“Second California Lawsuit”).
`6. On the basis of the foregoing, Ancora and TCL request that the Court issue an
`order consolidating the instant lawsuit (8:19-cv-02192) and the Second
`California Lawsuit (2:20-cv-01252). The parties are filing a similar stipulation
`in the Second California Lawsuit simultaneous with this filing.
`IT IS SO STIPULATED.
`
`
`DATED: February 19, 2020
`PERKINS COIE LLP
`By: /s/ John P. Schnurer
`John P. Schnurer, (SBN 185725)
`JSchnurer@perkinscoie.com
`Yun Louise Lu, (SBN 253114)
`LLu@perkinscoie.com
`Kyle R. Canavera (SBN 314664)
`KCanavera@perkinscoie.com
`Attorneys for Defendants
`TCT Mobile (US) Inc. and Huizhou TCL
`Mobile Communication Co. Ltd.
`
`DATED: February 19, 2020
`BROOKS KUSHMAN P.C.
`By: /s/ Marc Lorelli*
`Marc Lorelli (pro hac vice)
`mlorelli@brookskushman.com
`John S. LeRoy (pro hac vice)
`jleroy@brookskushman.com
`John P. Rondini (pro hac vice)
`jrondini@brookskushman.com
`Mark A. Cantor (pro hac vice)
`mcantor@brookskushman.com
`Attorneys for Plaintiff
`Ancora Technologies, Inc.
`
`
`
`
`
` *
`
` Pursuant to Local Rule 5-4.3.4(a)(2), the filing party attests that TCL’s counsel
`concurs in the content of this stipulation and has authorized its filing with his
`electronic signature.
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`JOINT STIPULATION TO CONSOLIDATE
`Case No. 8:19-CV-02192
`
`
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`-3-
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`
`
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