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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
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`Case No. 1:22-cv-22706-RNS
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`BELL NORTHERN RESEARCH, LLC,
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`Plaintiff
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`v.
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`HMD AMERICA, INC.; HMD GLOBAL OY;
`SHENZHEN CHINO-E COMMUNICATION
`CO., LTD.; HON HAI PRECISION
`INDUSTRY CO., LTD; TINNO MOBILE
`TECHNOLOGY CORP.; SHENZHEN
`TINNO MOBILE CO., LTD.; TINNO USA,
`INC.; UNISOC TECHNOLOGIES CO., LTD.;
`SPREADTRUM COMMUNICATIONS USA,
`INC.; WINGTECH TECHNOLOGY CO.;
`LTD.; WINGTECH INTERNATIONAL,
`INC.; BEST BUY CO., INC.; BEST BUY
`STORES L.P.; TARGET CORP.; WALMART
`INC.
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`Defendants.
`_______________________________________/
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`JURY TRIAL DEMANDED
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`PLAINTIFF BELL NORTHERN RESEARCH LLC’S UNOPPOSED MOTION TO
`DISMISS WITHOUT PREJUDICE DEFENDANTS HON HAI PRECISION INDUSTRY
`CO. LTD AND SPREADTRUM COMMUNICATIONS USA, INC.
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`Plaintiff Bell Northern Research, LLC, pursuant to Fed. R. Civ. P. 41(a)(2), hereby
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`moves this Honorable Court to grant Plaintiff’s motion for an order dismissing all claims in this
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`action asserted against Defendants Hon Hai Precision Industry Co., Ltd. and Spreadtrum
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`Communications USA, Inc. without prejudice. Plaintiff submits that Defendants Hon Hai
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`Precision Industry Co., Ltd. and Spreadtrum Communications USA, Inc. have not pleaded any
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`counterclaims, and that the terms of this dismissal without prejudice are proper. Counsel for
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`Case 1:22-cv-22706-RNS Document 126 Entered on FLSD Docket 01/31/2023 Page 2 of 3
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`Plaintiff conferred with counsel for Defendants Hon Hai Precision Industry Co., Ltd. and
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`Spreadtrum Communications USA, Inc. who indicated that they did not oppose this motion.
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`Each Party to this case shall bear its own costs, expenses, and attorneys’ fees. A proposed order
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`of dismissal accompanies this Unopposed Motion to Dismiss.
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`Dated: January 31, 2023
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` Respectfully submitted,
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`/s/ Paul Richter
`Paul Richter (admitted pro hac vice)
`prichter@devlinlawfirm.com
`Christopher Clayton (admitted pro hac vice)
`cclayton@devlinlawfirm.com
`Adam Woodward
`awoodward@devlinlawfirm.com
`Florida Bar No. 1029147
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
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`Jose I. Rojas
`Florida Bar No. 331546
`jrojas@rojaslawfirm.com
`Alexander F. Rojas
`Florida Bar No. 124232
`arojas@rojaslawfirm.com
`ROJASLAW
`201 S. Biscayne Blvd., 28th Floor
`Miami, FL 33131
`Telephone: (305) 446-4000
`Facsimile: (305) 985-4146
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`Attorneys for Plaintiff Bell Northern
`Research, LLC
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`2
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`Case 1:22-cv-22706-RNS Document 126 Entered on FLSD Docket 01/31/2023 Page 3 of 3
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`CERTIFICATION OF PRE-FILING CONFERENCE
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`Pursuant to Local Rule 7.1(a)(3), the undersigned counsel for Plaintiff Bell Northern
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`Research, LLC certifies that Plaintiff’s counsel conferred with counsel for Defendants Hon Hai
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`Precision Industry Co. and Spreadtrum Communications USA, Inc. telephonically regarding the
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`issues raised in this Motion. Counsel for Defendants indicated that they did not oppose the
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`Motion.
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`/s/ Paul Richter
`Paul Richter
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who have consented to electronic service are
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`being served with a copy of this document on January 31, 2023.
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`/s/ Paul Richter
`Paul Richter
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`3
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