Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 243

UNOPPOSED MOTION to Move the Hearing Date for #153 Motion to Dismiss and Motion to Strike , filed by Samsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Arnold Declaration, #2 Proposed Order)(Maroulis, Victoria) (Filed on 9/19/2011) Modified on 9/20/2011 linking entry to document #153 (dhm, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Charles K. Verhoeven (Cal. Bar No. 170151)
 [e-mail]
50 California Street, 22nd Floor
 San Francisco, California 94111
Telephone: [phone]
 Facsimile: [phone]
 Kevin P.B. Johnson (Cal. Bar No. 177129)
[e-mail]
 Victoria F. Maroulis (Cal. Bar No. 202603)
[e-mail]
 555 Twin Dolphin Drive 5th Floor
Redwood Shores, California 94065
 Telephone: [phone]
Facsimile: [phone]

Michael T. Zeller (Cal. Bar No. 196417)
 [e-mail]
865 S. Figueroa St., 10th Floor
 Los Angeles, California 90017
Telephone: [phone]
 Facsimile: [phone]
 Attorneys for SAMSUNG ELECTRONICS
CO., LTD., SAMSUNG ELECTRONICS
 AMERICA, INC. and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

 APPLE INC., a California corporation,

CASE NO. 11-cv-01846-LHK



SAMSUNG’S UNOPPOSED MOTION TO
MOVE THE HEARING DATE FOR ITS
MOTION TO DISMISS AND MOTION TO
STRIKE



Plaintiff,
vs.

 SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Defendants.






02198.51855/4352811.2

Case No. 11-cv-01846-LHK
SAMSUNG’S UNOPPOSED MOTION TO MOVE THE HEARING DATE FOR ITS MOTION TO DISMISS
AND STRIKE________

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Pursuant to Civil L.R. 6-3, Defendants Samsung Electronics Co. Ltd. (“SEC”), Samsung

2 Electronics America, Inc. (“SEA”) and Samsung Telecommunications America, LLC (“STA”)
3 (collectively, “Samsung”) hereby bring this unopposed motion to move the hearing date on
4 Samsung’s Motion to Dismiss and Motion to Strike Apple’s Counterclaims (“Samsung’s Motion
5 to Dismiss”) to Thursday, October 20, 2011 at 1:30 p.m., and would show the Court the following:
6

The hearing date for Samsung’s Motion to Dismiss is currently set for Thursday,

7 September 22, 2011 at 1:30 p.m.

(Dkt No. 153.)

Throughout this week, September 19–23, the

8 parties will be conducting and defending at least three depositions around the country in
9 connection with Apple’s Preliminary Injunction Motion.

(Arnold Decl. ¶ 3.) These depositions

10 are taking place on September 20, 21, and 23, and will be located in Dallas, Texas, and Columbia,
11 Missouri.

(Id.) The parties have been negotiating and scheduling these depositions over the

12 past several weeks and have only solidified all these dates in the past week.

(Id.)

In addition,

13 counsel for Samsung not participating in these depositions have scheduling conflicts, including
14 preparation for trial.
15

(Arnold Decl. ¶ 4.)

Samsung believes that moving the hearing date for Samsung’s Motion to Dismiss from its

16 current date to Thursday, October 20, 2011 will significantly reduce the burden on the parties and
17 their counsel to attend the hearing.

(Arnold Decl. ¶ 5.) Samsung further believes this will

18 prevent prejudice to all the parties as under the current schedule they will need to prepare for the
19 hearing on Samsung’s Motion to Dismiss at the same time that they are preparing to conduct
20 and/or defend multiple depositions around the country in connection with Apple’s Preliminary
21 Injunction Motion.
22

(Id.)

For the foregoing reasons, Samsung respectfully requests that the Court change the motion

23 hearing date for Samsung’s Motion to Dismiss to Thursday, October 20, 2011 at 1:30 p.m.
24 Apple does not oppose this motion. (Arnold Decl. ¶ 8.)
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02198.51855/4352811.2

Case No. 11-cv-01846-LHK
-1SAMSUNG’S UNOPPOSED MOTION TO MOVE THE HEARING DATE FOR ITS MOTION TO DISMISS
AND STRIKE

1
2 DATED: September 19, 2011
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By /s/ Victoria F. Maroulis
Charles K. Verhoeven
Kevin P.B. Johnson
Victoria F. Maroulis
Michael T. Zeller
Attorneys for SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS AMERICA,
INC., and SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC

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02198.51855/4352811.2

Case No. 11-cv-01846-LHK
-2SAMSUNG’S UNOPPOSED MOTION TO MOVE THE HEARING DATE FOR ITS MOTION TO DISMISS
AND STRIKE