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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.; TINNO MOBILE
`TECHNOLOGY CORP.; SHENZHEN
`TINNO MOBILE CO., LTD.; TINNO USA,
`INC.; UNISOC TECHNOLOGIES CO., LTD.;
`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 WINGTECH TECHNOLOGY CO.,
`LTD., AND WINGTECH INTERNATIONAL, INC.
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`Plaintiff Bell Northern Research, LLC (“BNR” or “Plaintiff”), pursuant to Fed. R. Civ. P.
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`41(a)(2), hereby moves this Honorable Court to grant its motion for an order dismissing all
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`claims in this action asserted against Defendants Wingtech Technology Co., Ltd., and Wingtech
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`International, Inc. (“Defendant” or “Wingtech”) without prejudice. BNR submits that Wingtech
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`has not pleaded any counterclaims, and that the terms of this dismissal without prejudice are
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`proper in that BNR and Wingtech have reached an agreement. BNR and Wingtech shall bear
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`their own costs, expenses, and attorneys’ fees. A proposed order of dismissal accompanies this
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`motion.
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`Case 1:22-cv-22706-RNS Document 219 Entered on FLSD Docket 08/11/2023 Page 2 of 3
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`Dated: August 11, 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 219 Entered on FLSD Docket 08/11/2023 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 on August 10, 2023 on all of the issues
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`raised in this motion with counsel for all of the Defendants in this action that have entered an
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`appearance, namely: HMD America, Inc., HMD Global Oy (collectively, “HMD”), Best Buy
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`Co., Inc., Best Buy Stores L.P. (collectively, “Best Buy”), Target Corp. (“Target”), Walmart Inc.
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`(“Walmart”), and Wingtech.
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`Counsel for HMD, Target, and Best Buy indicated they do not oppose this motion “so
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`long as BNR will not use the absence of [Wingtech] from discovery or the case to prejudice the
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`other defendants.” Counsel for Walmart indicated that they will not oppose the motion with the
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`same understanding. Wingtech does not oppose the motion.
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`The movant has 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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`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 August 11, 2023.
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`/s/ Jose I. Rojas
`Jose I. Rojas
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`3
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