Talon Research, LLC v. Hynix Semiconductor America Inc. et al

Filing 97

ORDER by Judge Claudia Wilken Granting 96 Stipulation for Dismissal with Prejudice (ndr, COURT STAFF) (Filed on 12/28/2012)

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David Martinez (SBN 193183)
[e-mail]
ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
2049 Century Park East, Suite 3400
Los Angeles, CA 90067-3208
Telephone: [phone]
Facsimile: 310.229.5800

Jeffrey M. Ratinoff (SBN 197241)
[e-mail]
K&L GATES LLP
630 Hansen Way
Palo Alto, CA 94304
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff and CounterDefendant TALON RESEARCH, LLC.

Attorneys for Defendants and Counterclaimants
HYNIX SEMICONDUCTOR AMERICA INC.
and SK HYNIX

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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TALON RESEARCH, LLC,
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Plaintiff/Counterclaim
Defendant,

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v.
HYNIX SEMICONDUCTOR AMERICA
INC.; SK HYNIX INC.,

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Case No. 4:11-CV-05058-CW

STIPULATED MOTION FOR DISMISSAL
WITH PREJUDICE AND [PROPOSED] ORDER
OF DISMISSAL WITH PREJUDICE

Defendants/Counterclaim
Plaintiffs.

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AND RELATED COUNTERCLAIMS
The Plaintiff Talon Research, LLC and Defendants Hynix Semiconductor America Inc.

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and SK Hynix Inc., pursuant to Fed. R. Civ. P. 41(a)(2) and (c), hereby move for an order

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dismissing all claims and counterclaims in this action WITH PREJUDICE, with each party to

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bear its own costs, expenses and attorneys’ fees.

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/s/ David Martinez
David Martinez
ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
Attorneys for Plaintiff and CounterDefendant TALON RESEARCH, LLC

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Case No. CV 11-05058 CW

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/s/ Jeffrey M. Ratinoff
_
Jeffrey M. Ratinoff
K & L GATES L.L.P.
Attorneys for Defendants and
Counterclaimants HYNIX
SEMICONDUCTOR AMERICA INC. and
SK HYNIX
STIPULATED MOTION FOR DISMISSAL WITH
PREJUDICE AND [PROPOSED] ORDER OF
DISMISSAL WITH PREJUDICE

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ATTESTATION
In accord with the Northern District of California’s General Order No. 45, Section X(B), I

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attest that concurrence in the filing of this document has been obtained from each of the other

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signatories who are listed on the signature pages. I will maintain an executed copy of this

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stipulation in our files that can be made available for inspection upon request.

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[PROPOSED] ORDER OF DISMISSAL WITH PREJUDICE
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CAME ON THIS DAY for consideration of the Stipulated Motion for Dismissal With
Prejudice of all claims and counterclaims asserted between Plaintiff and Counter-Defendant

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Talon Research, LLC and Defendants and Counterclaimants Hynix Semiconductor America Inc.

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and SK Hynix Inc., in this case, and the Court being of the opinion that said motion should be

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GRANTED, it is hereby ORDERED, ADJUDGED AND DECREED that all claims asserted in

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this suit between Plaintiff Talon Research, LLC and Defendants Hynix Semiconductor America

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Inc. and SK Hynix Inc., are hereby dismissed WITH PREJUDICE. It is further ORDERED that

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all attorneys’ fees and costs are to be borne by the party that incurred them.

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12/28/2012

Dated: _______________________

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________________________________
Hon. CLAUDIA WILKEN
UNITED STATES DISTRICT COURT JUDGE

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Case No. CV 11-05058 CW

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STIPULATED MOTION FOR DISMISSAL WITH
PREJUDICE AND [PROPOSED] ORDER OF
DISMISSAL WITH PREJUDICE