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`IN THE 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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`v.
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`FITBIT, INC.,
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`Defendant.
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`Civil Action No. 1:19-cv-11586-FDS
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`JOINT MOTION TO EXTEND DEADLINE TO FILE STATUS REPORT
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`Plaintiff Philips North America LLC (“Philips”) and Defendant Fitbit, Inc. (“Fitbit”)
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`respectfully jointly move the Court to extend the deadline to file their status report. On April 8,
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`2020, the Court ordered that if the Court were to deny Fitbit’s Motion to Dismiss, then parties
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`were to file a status report seven days after the issuance of that order. See Dkt. #61. On August
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`10, 2021, the Court denied Fitbit’s Motion to Dismiss. See Dkt. # 219. On August 17, 2021 the
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`parties jointly filed a motion requesting an extension to file the status report to August 24, 2021.
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`See Dkt. #221. The parties have met and conferred, and believe that they would benefit from
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`some additional time to meet and confer before providing the Court the status report. The parties
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`therefore request an extension to August 27, 2021 to file their status report.
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`Therefore, Philips and Fitbit respectfully request that the Court grant the parties’
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`joint motion.
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`Case 1:19-cv-11586-FDS Document 223 Filed 08/24/21 Page 2 of 3
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`Dated: August 24, 2021
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`Respectfully submitted,
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`PHILIPS NORTH AMERICA LLC,
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`FITBIT, INC.
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`By its attorneys,
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`/s/ Ruben J. Rodrigues
`Ruben Rodrigues (BBO 676,573)
`Lucas I. Silva (BBO 673,935)
`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
`rrodrigues@foley.com
`lsilva@foley.com
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`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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`By Its Attorneys,
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`/s/ Karim Z. Oussayef
`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
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`Ameet A. Modi (pro hac vice)
`amodi@desmaraisllp.com
`Emily H. Chen (pro hac vice)
`echen@desmaraisllp.com
`DESMARAIS LLP
`101 California Street
`San Francisco, CA 94111
`Telephone: (415) 573-1900
`Facsimile: (415) 573-1901
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`Gregory F. Corbett (BBO # 646394)
`Elizabeth A. DiMarco (BBO#681921)
`WOLF, GREENFIELD & SACKS, P.C. 600
`Atlantic Avenue
`Boston, MA 02110
`Telephone: (617) 646-8000
`Facsimile: (617) 646-8646
`gcorbett@wolfgreenfield.com
`edimarco@wolfgreenfield.com
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`Case 1:19-cv-11586-FDS Document 223 Filed 08/24/21 Page 3 of 3
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`LOCAL RULE 7.1(a)(2) CERTIFICATION
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`I, Karim Z. Oussayef, counsel for Defendant, hereby certifies that counsel for Defendant met
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`and conferred with counsel for Plaintiff on August 24, 2021, wherein counsel for Plaintiff stated that
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`they agree to this extension request.
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`/s/ Karim Z. Oussayef
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`CERTIFICATE OF SERVICE
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`I certify that this document is being filed through the Court’s electronic filing system, which
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`serves counsel for other parties who are registered participants as identified on the Notice of Electronic
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`Filing (NEF). Any counsel for other parties who are not registered participants are being served by
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`first class mail on the date of electronic filing.
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`/s/ Elizabeth A. DiMarco
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