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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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`JURY TRIAL DEMANDED
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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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`PLAINTIFF BELL NORTHERN RESEARCH LLC AND TINNO MOBILE
`TECHNOLOGY CORP., SHENZHEN TINNO MOBILE CO. LTD., AND TINNO USA,
`INC.’S JOINT MOTION TO STAY ALL DEADLINES
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`Plaintiff Bell Northern Research, LLC (“BNR”) and Defendants Tinno Mobile Technology
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`Corp, Shenzhen Tinno Mobile Co., Ltd., and Tinno USA, Inc. (collectively, “Tinno”) have reached
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`an agreement. BNR and Tinno (the “Parties”) expect to jointly file a dismissal without prejudice
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`in approximately the next three weeks. Accordingly, the Parties respectfully request the Court
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`stay all pending deadlines between them up to and including March 24, 2023. The Parties request
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`this stay, not for purposes of any delay, but so that they may finalize and file dismissal papers
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`without incurring additional expenses.
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`Case 1:22-cv-22706-RNS Document 144 Entered on FLSD Docket 03/02/2023 Page 2 of 4
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`Dated: March 2, 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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`/s/ Jason Xu
`Jason Xu (admitted pro hac vice)
`Jason.Xu@rimonlaw.com
`RIMON LAW
`1990 K Street, Suite 420
`Washington, DC 20006
`Telephone: (202) 470-2141
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`Andrew J. Fuller, Esq.
`Florida Bar No. 1021164
`andrew.fuller@nelsonmullins.com
`NELSON MULLINS
`2 S. Biscayne Blvd., 21st Floor
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`2
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`Case 1:22-cv-22706-RNS Document 144 Entered on FLSD Docket 03/02/2023 Page 3 of 4
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`Miami, Florida 33131
`Telephone No. 305.373.9487
`Facsimile No. 305.373.9443
`vicki.mattison@nelsonmullins.com
`katie.bartoo@nelsonmullins.com
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`Attorneys for Defendants Tinno Mobile
`Technology Corp., Shenzhen Tinno Mobile
`Co. Ltd., Tinno USA, Inc.
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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 Bell Semic and Tinno
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`certify that counsel conferred on March 1, 2023 on all of the issues raised in this motion with
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`counsel for: HMD America, Inc., HMD Global Oy (collectively, “HMD”), Wingtech
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`Technology Co. Ltd., Wingtech International, Inc. (collectively, “Wingtech”), Best Buy Co.,
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`Inc., Best Buy Stores L.P. (collectively, “Best Buy”), Target Corp. (“Target”), and Walmart Inc.
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`(“Walmart”).
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`Counsel for HMD, Target, Best Buy, and Walmart indicated they do not oppose the
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`motion, “so long as BNR will not use the absence of Tinno from discovery or the case to
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`prejudice the other defendants.” Counsel for Wingtech indicated that they do not oppose the
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`motion.
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`The movants have conferred with all parties or non-parties who may be affected by the
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`relief requested.
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`/s/ Paul Richter
`Paul Richter
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`/s/ Jason Xu
`Jason Xu
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`3
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`Case 1:22-cv-22706-RNS Document 144 Entered on FLSD Docket 03/02/2023 Page 4 of 4
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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 March 2, 2023.
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`/s/ Jose I. Rojas
`Jose I. Rojas
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`4
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