GeoVector Corporation v. Samsung Electronics Co. Ltd. et al

Filing 25

STIPULATION AND ORDER EXTENDING TIME as to 14 MOTION to Dismiss First Amended Complaint. Response due by 9/23/2016. Reply due by 10/7/2016. (Hearing remains set for 10/19/2016.) Signed by Judge William H. Orrick on 09/16/2016. (jmdS, COURT STAFF) (Filed on 9/16/2016)

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Jack Russo (Cal. Bar No. 96068)
Christopher Sargent (Cal. Bar No. 246285)
COMPUTERLAW GROUP LLP
401 Florence Street
Palo Alto, CA 94301
[phone]
[phone] fax
[e-mail]
[e-mail]
Attorneys for Plaintiff
GEOVECTOR CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

Computerlaw Group LLP
www.computerlaw.comsm

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GEOVECTOR CORPORATION, a California
corporation,
Plaintiff;
v.
SAMSUNG INTERNATIONAL, INC., a New
Jersey corporation;
SAMSUNG ELECTRONICS CO., LTD., a
Korean corporation;
SAMSUNG ELECTRONICS AMERICA, INC.,
a New York corporation;
SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC, a Delaware limited
liability company; and
SAMSUNG RESEARCH AMERICA, INC., a
California corporation,

Case No. 3:16-cv-02463-WHO
STIPULATION AND ORDER EXTENDING TIME
TO FILE OPPOSITION AND REPLY REGARDING
DEFENDANTS’ MOTION TO DISMISS
Date: October 19, 2016
Time: 2:00 PM
Presiding: Hon. William H. Orrick
Complaint Filed: May 5, 2015
JURY TRIAL DEMANDED

Defendants.

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Stip. and Order Ext. Time re Mot. to Dismiss

CASE NO. 3:16-CV-02463-WHO

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STIPULATION TO EXTEND TIME

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This Stipulation is entered into by Plaintiff GeoVector Corporation (originally CritiCom

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Corporation, hereinafter “GeoVector,” or “Plaintiff,”) and Defendants Samsung Electronics Co.,

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Ltd. (“SEC”), Samsung International, Inc. (“SII”), Samsung Research America, Inc. (“SRA”),

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and Samsung Electronics America, Inc. (“SEA”) (collectively, “Samsung,” or “Defendants”) by

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their respective counsel.1
RECITALS

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1.

On May 5, 2016, Plaintiff filed its Original Complaint in the instant action.

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2.

On May 6, 2016, the Court scheduled the initial case management conference for

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August 3, 2016.

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Computerlaw Group LLP
www.computerlaw.comsm

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3.

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On May 13, 2016, Plaintiff served SEA with the Summons and Original

Complaint.

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4.

On June 7, 2016, Plaintiff filed its First Amended Complaint.

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5.

Plaintiff agreed to an extension of time for the Defendants to respond to the

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Complaint by 90 days in exchange for SEC’s agreement to accept or otherwise waive service of

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the Summons and Complaint such that the Defendants’ response to the First Amended Complaint

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is due on the same date.
6.

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On June 13, 2016, the Honorable Donna M. Ryu signed a Stipulation and Order

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that contained the 90-day extension and continued the Case Management Conference from

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August 3, 2016 to September 21, 2016.
7.

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Complaint in Part (the “Motion”).
8.

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On September 2, 2016, Defendants filed a Motion to Dismiss First Amended

For the past two weeks, lead counsel for Plaintiff, Mr. Jack Russo, has been ill and

is overseas.

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The First Amended Complaint also lists Samsung Telecommunications America, LLC (“STA”)
as a Defendant. Samsung has moved to dismiss STA as an improperly named Defendant, as STA
merged into SEA prior to the filing of the Original Complaint. [Dkt. No. 14]. Samsung reserves
the right to move to remove any other improperly-named parties at a later date.
Stip. and Order Ext. Time re Mot. to Dismiss

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CASE NO. 3:16-CV-02463-WHO

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STIPULATION
In light of Mr. Russo’s illness, the parties agree that time schedule for the Opposition and
Reply on the Motion be modified as follows:
A.

The Deadline to File the Opposition to the Motion be changed from September 16,

2016 to September 23, 2016:
B.

The Deadline to file the Reply in Support of the Motion be changed from

September 23, 2016 to October 7, 2016.

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Respectfully submitted,

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Computerlaw Group LLP
www.computerlaw.comsm

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COMPUTERLAW GROUP LLP
By:
/s/ Christopher Sargent
Jack Russo
Christopher Sargent

Dated: September 14, 2016

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Attorneys for Plaintiff
GEOVECTOR CORPORATION

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PAUL HASTINGS LLP
Dated: September 14, 2016

By:

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/s/ Elizabeth L. Brann
Elizabeth L. Brann

On Behalf of Defendants
SAMSUNG ELECTRONICS CO., LTD.,
SAMSUNG ELECTRONICS AMERICA, INC.,
SAMSUNG INTERNATIONAL, INC. and
SAMSUNG RESEARCH AMERICA, INC.

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Stip. and Order Ext. Time re Mot. to Dismiss

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CASE NO. 3:16-CV-02463-WHO

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ORDER
Plaintiff’s Opposition to Defendants’ Motion to Dismiss First Amended Complaint in Part
shall be filed no later than September 23, 2016.
Defendants’ Reply in Support of Defendants’ Motion to Dismiss First Amended
Complaint in Part shall be filed no later than October 7, 2016.

Dated: September 16, 2016

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______________________________________
Hon. William H. Orrick
United States District Judge

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Computerlaw Group LLP
www.computerlaw.comsm

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Stip. and Order Ext. Time re Mot. to Dismiss

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CASE NO. 3:16-CV-02463-WHO