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`Case 6:19-cv-00385-ADA Document 21 Filed 10/28/19 Page 1 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Plaintiff,
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`ANCORA TECHNOLOGIES, INC.,
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`v.
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`LG ELECTRONICS INC. and LG
`ELECTRONICS U.S.A., INC.,
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`Defendants.
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`Plaintiff,
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`ANCORA TECHNOLOGIES, INC.,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`Defendants.
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`CIVIL ACTION NO. 6:19-CV-00384
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`JURY TRIAL DEMANDED
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`CIVIL ACTION NO. 6:19-CV-00385
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`JURY TRIAL DEMANDED
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`PLAINTIFF’S NOTICE OF READINESS
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`Plaintiff Ancora Technologies, Inc. (“Ancora”) submits this Notice of Readiness and
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`respectfully requests a joint case management conference in the above captioned matters.
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`On June 21, 2019, Ancora filed its Complaint against Samsung Electronics Co. Ltd. and
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`Samsung Electronics America, Inc. (collectively, “Samsung”) alleging infringement of U.S. Patent
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`No. 6,411,941 (“the ’941 Patent”). Samsung appeared through counsel and filed their Answer on
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`October 1, 2019.
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`Also on June 21, 2019, Ancora filed its Complaint against LG Electronics Inc. and LG
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`Electronics U.S.A., Inc. (collectively, “LG”) alleging infringement of the ’941 Patent. LG
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`appeared through counsel and filed their Answer on October 25, 2019.
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`Case 6:19-cv-00385-ADA Document 21 Filed 10/28/19 Page 2 of 4
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`The two matters involve the same plaintiff, Ancora, and the same patent. Accordingly, it
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`will be both in the interest of justice and more efficient for all parties involved to consolidate these
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`matters for claim construction, discovery, and any other pre-trial matters the Court deems fit to
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`address jointly between the two cases. Ancora thus respectfully requests a joint case management
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`conference with Samsung and LG within the next 30 days, if available.
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`Dated: October 28, 2019
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`Respectfully submitted,
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`By: /s/ Charles L. Ainsworth
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`Charles L. Ainsworth (Texas 00783521)
`Robert Christopher Bunt (Texas 00787165)
`PARKER, BUNT & AINSWORTH, P.C.
`1000 East Ferguson, Suite 418
`Tyler, Texas 75702
`Tel: (903) 531-3535
`charley@pbatyler.com
`rcbunt@pbatyler.com
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`
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`Lexie G. White (Texas 24048876)
`SUSMAN GODFREY LLP
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Tel: (713) 651-9366
`Fax: (713) 654-6666
`lwhite@susmangodfrey.com
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`Andres Healy (pro hac vice)
`SUSMAN GODFREY LLP
`1201 Third Avenue, Suite 3800
`Seattle, Washington 98101
`Tel: (206) 516-3880
`Fax: 206-516-3883
`ahealy@susmangodfrey.com
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`2
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`Case 6:19-cv-00385-ADA Document 21 Filed 10/28/19 Page 3 of 4
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`Zachary B. Savage (pro hac vice)
`SUSMAN GODFREY LLP
`1301 Avenue of the Americas, 32nd Floor
`New York, New York 10019
`Tel: (212) 336-8330
`Fax: (212) 336-8340
`zsavage@susmangodfrey.com
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`COUNSEL FOR PLAINTIFF ANCORA
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`Case 6:19-cv-00385-ADA Document 21 Filed 10/28/19 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 28th day of October 2019, I electronically filed the foregoing
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`with the Clerk of the Court using the CM/ECF system, which will send notification of such filing
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`to all counsel of record.
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`/s/ Charles L. Ainsworth
`Charles L. Ainsworth
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`4
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