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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`PHILIPS NORTH AMERICA LLC,
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`Plaintiff,
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`Defendant.
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`v.
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`FITBIT, INC.,
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`Civil Action No. 1:19-cv-11586-IT
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`JURY TRIAL DEMANDED
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`JOINT MOTION OF THE PARTIES TO EXTEND PLAINTIFF’S DEADLINE TO FILE
`OPPOSITION TO DEFENDANT’S MOTION TO COMPEL AND FOR LEAVE FOR
`DEFENDANT TO FILE REPLY BRIEF
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`Plaintiff Philips North American LLC (“Philips”) and Fitbit, Inc. (“Fitbit”) respectfully
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`jointly move the Court to extend the deadline for Philips to submit an opposition to Fitbit’s Motion
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`to Compel (Dkt # 198) and to extend the deadline for Fitbit to reply to said opposition. Fitbit’s
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`Motion to Compel was filed on June 18, 2021, and, under Local Rule 7.1(b)(2), the deadline for
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`Philips to submit an opposition is July 2, 2021. After meeting and conferring with regard to this
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`deadline, the parties jointly request that the Court extend said deadline by two weeks to July 16,
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`2021. The parties further jointly request that the Court grant leave under Local Rule 7.1(b)(3) for
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`Fitbit to file a reply brief no longer than ten (10) pages by July 30, 2021.1
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`Therefore, Philips and Fitbit respectfully request that the Court grant the parties’ joint
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`motion.
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`1 Philips reserves the right to request leave to file a sur-reply, if necessary, upon review of any reply filed by Fitbit.
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`4812-5965-1312.1
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`Case 1:19-cv-11586-FDS Document 206 Filed 06/29/21 Page 2 of 3
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`Dated: June 29, 2021
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`Respectfully Submitted,
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` /s/ Ruben Rodriques
`Lucas I. Silva (BBO 673,935)
`Ruben J. Rodrigues (BBO 676,573)
`John Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
`lsilva@foley.com
`rrodrigues@foley.com
`jcuster@foley.com
`
`
`Eley O. Thompson (pro hac vice)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
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`Counsel for Plaintiff
`Philips North America LLC
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`/s/ David J. Shaw_______________
`David J. Shaw (pro hac vice)
`dshaw@desmaraisllp.com
`DESMARAIS LLP
`1701 Pennsylvania Ave., NW, Suite 200
`Washington, D.C. 20006
`Telephone: (202) 451-4900
`Facsimile: (202) 451-4901
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`Karim Z. Oussayef (pro hac vice)
`koussayef@desmaraisllp.com
`Leslie M. Spencer (pro hac vice)
`lspencer@desmaraisllp.com
`Brian D. Matty (pro hac vice)
`bmatty@desmaraisllp.com
`DESMARAIS LLP
`230 Park Avenue
`New York, NY 10169
`Telephone: (212) 351-3400
`Facsimile: (212) 351-3401
`
`Ameet A. Modi (pro hac vice)
`amodi@desmaraisllp.com
`DESMARAIS LLP
`101 California Street
`San Francisco, CA 94111
`Telephone: (415) 573-1900
`Facsimile: (415) 573-1901
`
`Gregory F. Corbett (BBO # 646394)
`WOLF, GREENFIELD & SACKS, P.C.
`600 Atlantic Avenue
`Boston, MA 02110
`Telephone: (617) 646-8000
`Facsimile: (617) 646-8646
`E-mail: gcorbett@wolfgreenfield.com
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`Attorneys for Fitbit, Inc.
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`4812-5965-1312.1
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`2
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`Case 1:19-cv-11586-FDS Document 206 Filed 06/29/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on June 29, 2021 a copy of the foregoing document
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`was filed with the Court through the ECF system and that a copy will be electronically served on
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`registered participants as identified on the Notice of Electronic Filing.
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`4812-5965-1312.1
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`By: /s/Ruben J. Rodrigues
` Ruben J. Rodrigues
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`3
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