TZU Technologies, LLC v. Lelo, Inc.

Filing 16

ORDER granting ECF No. 15 Stipulation to Extend Time to Response to ECF No. 1 Complaint. Lelo, Inc.'s answer/response due 12/13/2017. Signed by Magistrate Judge George Foley, Jr on 11/13/2017. (Copies have been distributed pursuant to the NEF - KW)

1 Obi I. Iloputaife (CA Bar No. 1992271)
[e-mail]
2 admitted pro hac vice
Jayson S. Sohi (CA Bar No. 293176)
[e-mail]
3 admitted pro hac vice
COTMAN IP LAW GROUP, PLC
4 35 Hugus Alley, Suite 210
Pasadena, CA 91103
5 [phone]/FAX: [phone]
6 Attorneys for Plaintiff TZU Technologies,
LLC
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Steven A. Caloiaro
Nevada Bar No. 12344
Email: [e-mail]
8363 West Sunset Road, Suite 200
DICKINSON WRIGHT PLLC
Las Vegas, Nevada 89113-2210
Tel: [phone]
Fax: [phone]
Hector J. Ribera (CA Bar No. 221511
(pending admission pro hac vice)
[e-mail]
MARTON RIBERA SCHUMANN & CHANG LLP
548 Market St. Suite 36117
San Francisco, CA 94104
[phone]

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Attorneys for Defendant, LELO Inc.
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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TZU Technologies, LLC

Case No. 2:17-cv-01952-MMD-GWF

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Plaintiff,
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v.

17 LELO Inc.
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STIPULATION AND
PROPOSED ORDER TO
EXTEND TIME TO RESPOND
TO COMPLAINT
(Second Stipulation)
[LR IA 6-1(a)]

Defendant.

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[Civil Local Rule 6-1(a)]
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Pursuant to Local Civil Rule 6-1(a), Plaintiff TZU Technologies, LLC (“Plaintiff”) and
[Cif

21 Defendant Lelo Inc. (“Defendant”) (jointly “the Parties”), by and through their respective
22 counsel, hereby stipulate as follows:
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WHEREAS, Plaintiff filed its Complaint against Defendant on July 18, 2017 (ECF No.

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2 1);

WHEREAS Defendant was served with the summons and complaint on September 22,

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4 2017;

WHEREAS Defendant was required to serve its respective answer and/or response to the

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6 Complaint by October 13, 2017;
WHEREAS Plaintiff and Defendant jointly stipulated to a first extension of time to

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8 answer and/or respond to the Complaint and the Court granted the stipulated request extending
9 the time for Defendant’s answer and/or response to the Complaint to November 13, 2017 (first
10 extension)(ECF No. 13);
WHEREAS Plaintiff and Defendant have been engaged in informal settlement

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12 discussions in an attempt to resolve their dispute and wish to continue such discussions;
WHEREAS Plaintiff and Defendant have again agreed to extend the date for Defendant

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14 to answer and/or respond to the Complaint by an additional thirty (30) days, up to and including
15 December 13, 2017; and
WHEREAS this is Defendant’ second request for extension of time to respond to the

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17 Complaint in this action;
WHEREAS the stipulation is made in good faith to allow the parties to continue to

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19 discuss a settlement agreement; and
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WHEREAS the stipulation is not an attempt to delay proceedings.

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties,

22 through their respective counsel, that Defendant Lelo Inc. shall have an extension, up to and
23 including December 13, 2017, to answer and/or respond to Plaintiff’s Complaint in this action.
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25 SECOND STIPULATION TO EXTEND
TIME

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2

2:17-cv-01952-MMD-GWF

Respectfully submitted,

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3 Dated: November 9, 2017

Dated: November 9, 2017

4 COTMAN IP LAW GROUP, PLC
By: /s/ Jayson S. Sohi____________
5 Jayson S. Sohi
Attorneys for Plaintiff
6 TZU Technologies, LLC

DICKINSON WRIGHT PLLC
/s/ Steven A. Caloiaro
Steven A. Caloiaro
Nevada Bar No. 12344
8363 West Sunset Road, Suite 200
Las Vegas, Nevada 89113-2210
Tel: [phone]
Fax: [phone]

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Hector J. Ribera
[e-mail]
MARTON RIBERA SCHUMANN & CHANG
LLP
548 Market Street, Suite 36117
San Francisco, CA 94104
Tel: [phone]

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Attorneys for Defendant LELO Inc.

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ORDER
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IT IS SO ORDERED.
November 13
Dated: ______________, 2017
_____________________________
Hon. Miranda M. Du
GEORGE FOLEY, JR.
United States District Judge
UNITED STATES MAGISTRATE JUDGE

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25 SECOND STIPULATION TO EXTEND
TIME

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2:17-cv-01952-MMD-GWF

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CERTIFICATE OF SERVICE
Pursuant to FRCP 5(b), I certify that I am an employee of Dickinson Wright, PLLC, and

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3 that on this date a true and correct copy of the foregoing STIPULATION AND PROPOSED
4 ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT will be served upon
5 counsel of record via the Court’s ECF System electronic mail.
6 DATED: November 9, 2017

/s/ Cindy Grinstead
An Employee of Dickinson Wright, PLLC

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25 SECOND STIPULATION TO EXTEND
TIME

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2:17-cv-01952-MMD-GWF