Sep.20.2016 04:37 PM
`Case 1:16-cv-04586-LTS Document 12 Filed 09/22/16 Page 1 of 1
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`Case 1:16-cv-04586-L TS Document 11
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`Filed 09/20/lJ'ie 1 of 1
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`September 20,2016
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`ELECTRO:\ICALLY FILED
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`Bon. Laura Taylor Swain
`United States District Judge
`United States Courthouse
`500 Pearl Street
`New York. New York 10007-1312
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`ME~~O ENDORSED
`
`RE: Broadsigu International, LLC v. T-Rcx Property AB. 16-cv-4586 (LTSl (HBP)
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`Dear Judge Swain:
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`We represent Plaintiff Broadsign Inten1ational, LLC ("Broadsign") in the above-referenced action. We are
`writing to advise the Court that, despite its best efforts, Broadsign has been unable to serve the Summons and
`Complaint on Defendant T .Rex Property AB ("T-Rex") and, for that reason, will be unable to submit an
`agreed upon Preliminary Pre-Trial Statement as required by Your Honor's hutial Conference Order entered
`July 26, 2016 (Dkt. 9).
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`T"Rex is a prolific non-practicing entity that has filed approximately 59 patent infringement actions
`throughout the United States since 2012, five ofthoso cases in this very District, Shortly after filing the
`Complaint, we spoke with T-Rex's counsel and asked ifT-Rex would accept service or agree to waive service
`in accordance with Fed. R. Civ. P. 4 (d). T-Rex refused. We have consulted counsel in Sweden and are now
`in the process of serving T-Rex in accordance with the provisions of the Hagtte Convention. For these
`reasons, Broadsign requests additional time to comply with the Cowt's Initial Pre~ Trial Conference Order.
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`Respectfully submitted,
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`The Coun has scheduled an initial confercmce Oil October 6, 2016 at 11:45 AM. Broadsign also requests that
`the conference be adjourned without date until the Summons and Complaint have been served.
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`cc: VIa Facsimile- Chambers of Judge Swain (212) 805-0426
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`6256.5604 vI· WorkSitcUS·033387/000 I
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`SO ORDE,BE~·
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