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

Filing 10

ORDER AS MODIFIED GRANTING STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT 9 . Case Management Statement due by 9/14/2016. Initial Case Management Conference set for 9/21/2016 01:30 PM in Courtroom 4, 3rd Floor, Oakland. Signed by Judge Donna M. Ryu on 6/13/2016. (lmh, COURT STAFF) (Filed on 6/13/2016)

1 Jack Russo (Cal. Bar No. 96068)
Christopher Sargent (Cal. Bar No. 246285)
2 COMPUTERLAW GROUP LLP
401 Florence Street
3 Palo Alto, CA 94301
[phone]
4 [phone] fax
[e-mail]
5 [e-mail]
6 Attorneys for Plaintiff
GEOVECTOR CORPORATION
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U NITED S TATES D ISTRICT C OURT

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N ORTHERN D ISTRICT OF C ALIFORNIA

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O AKLAND D IVISION

Computerlaw Group LLP
www.computerlaw.comsm

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GEOVECTOR CORPORATION, a California
corporation,

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Plaintiff;
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v.

Case No. 4:16-cv-02463-DMR
MODIFIED
STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO RESPOND TO
COMPLAINT

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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.

Complaint Filed: May 5, 2016
Before the Hon. Donna M. Ryu

Defendants.

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Stip. and [Prop.] Order Ext. Time to Answer

Case No. 4:16-cv-02463-DMR

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S TIPULATION TO E XTEND TIME

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

3 Corporation, hereinafter “GeoVector,” or “Plaintiff,”) and Defendants Samsung Electronics Co.,
4 Ltd. (“SEC”), and Samsung Electronics America, Inc. (“SEA”) (collectively, “Samsung,” or
5 “Defendants”) by their respective counsel. 1
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R ECITALS

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1.

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

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2.

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

9 August 3, 2016.
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3.

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

Computerlaw Group LLP
www.computerlaw.comsm

11 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

14 Complaint by 90 days in exchange for SEC’s agreement to accept or otherwise waive service of
15 the Summons and Complaint such that Defendants’ response to the First Amended Complaint is
16 due on the same date.
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6.

Civil Local Rule 6-1(a) for the United States District Court for the Northern

18 District of California allows the parties to stipulate, without a court order, to extend the time
19 within which to respond to a complaint, provided that the extension will not alter the dates of any
20 events or deadlines already set by the Court; and
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7.

Civil Local Rule 6-1(a) requires that any such stipulations be promptly filed with

22 the Court.
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The First Amended Complaint also lists Samsung Telecommunications America, LLC (“STA”),
26 Samsung Research America, Inc. (“SRA”), and Samsung International, Inc. (“SII”) as
defendants. However, Samsung makes the representation that certain of these parties are
27 improperly listed and should be removed from this case, including STA which merged into SEA
prior to the filing of the Original Complaint. Accordingly, Samsung reserves the right to move to
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dismiss improperly-named parties such as STA at a later date.
Stip. and [Prop.] Order Ext. Time to Answer

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Case No. 4:16-cv-02463-DMR

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S TIPULATION

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The parties agree that (i) the Case Management Conference should be continued from

3 August 3, 2016 to September 14, 2016, or any other date suitable for the Court that is after the
4 Defendants file their answer, and (ii) the Case Management Statement is due one week prior to
5 the rescheduled Case Management Conference.
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The parties also agree that the undersigned Mr. Dan Girdwood hereby accepts service on

7 behalf of all named defendants listed in the First Amended Complaint that has been filed by
8 Plaintiff. 2
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The parties also agree that all named defendants may have an extension of time through

10 September 2, 2016 to file a response to the First Amended Complaint.
COMPUTERLAW GROUP LLP

Computerlaw Group LLP
www.computerlaw.comsm

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12 Dated: June 10, 2016

By:

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Attorneys for Plaintiff
GEOVECTOR CORPORATION

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SAMSUNG ELECTRONICS AMERICA, INC.
Dated: June 10, 2016

By:

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A TTESTATION

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/s/ Dan Girdwood
Dan Girdwood
On Behalf of Defendants
SAMSUNG ELECTRONICS CO., LTD.,
SAMSUNG ELECTRONICS AMERICA, INC.,
SAMSUNG INTERNATIONAL, INC. and
SAMSUNG RESEARCH AMERICA, INC.

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/s/ Christopher Sargent
Jack Russo
Christopher Sargent

OF

E-FILED S IGNATURE

I, Christopher Sargent, am the ECF user whose ID and password are being used to file
this stipulation. In compliance with Civil L. R. 5-1(i)(3), I hereby attest that Dan Girdwood has
concurred in the filing’s content and has authorized this filing.

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/s/ Christopher Sargent

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Mr. Girdwood’s acceptance of service is not a representation that any party named in Plaintiff’s
Original Complaint or First Amended Complaint is a proper party to this dispute.

Stip. and [Prop.] Order Ext. Time to Answer

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Case No. 4:16-cv-02463-DMR

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MODIFIED

O RDER

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The case management conference set for August 3, 2016 is now set for September 14,

3 2016 at 10:00 a.m. in Courtroom 4, 3rd Floor, Oakland before Magistrate Judge Donna M. Ryu
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4 and the Case Management Statement is due on September 7, 2016.
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Dated: June ___, 2016

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Hon. Donna M. Ryu
United States Magistrate Judge

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Computerlaw Group LLP
www.computerlaw.comsm

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Stip. and [Prop.] Order Ext. Time to Answer

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Case No. 4:16-cv-02463-DMR