Wireless Recognition Technologies LLC v. A9.com, Inc. et al

Filing 119

Unopposed MOTION to Dismiss Ricoh Company, Ltd. and Ricoh Innovations, Inc. by Wireless Recognition Technologies LLC. (Attachments: # 1 Text of Proposed Order)(Tousi, Cameron)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
v.
A9.COM, INC et al.

Defendants.
WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
v.
NOKIA CORPORATION et al.

Defendants.
WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
v.
A9.COM, INC et al.

Defendants.
WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,

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C.A. No. 2:10-cv-00364-JRG

JURY TRIAL DEMANDED

C.A. No. 2:10-cv-00365-JRG

JURY TRIAL DEMANDED

C.A. No. 2:10-cv-00577-JRG

JURY TRIAL DEMANDED

v.
NOKIA CORPORATION et al.

Defendants.

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C.A. No. 2:10-cv-00578-JRG

JURY TRIAL DEMANDED

UNOPPOSED MOTION FOR DISMISSAL
Pursuant to Fed. R. Civ. P. 41(a)(2), Plaintiff Wireless Recognition Technologies LLC
(“WRT”) hereby moves for an order dismissing any and all claims and counterclaims in the
foregoing actions, namely C.A. No. 2:10-cv-00364-JRG, C.A. No. 2:10-cv-00365-JRG, C.A. No.
2:10-cv-00577-JRG and C.A. No. 2:10-cv-00578-JRG, by and between (i) WRT and (ii)
Defendants Ricoh Company, Ltd. and Ricoh Innovations, Inc. (collectively “Ricoh”) with
prejudice. Defendants Ricoh do not oppose this motion.
All attorneys’ fees, costs of court and expenses shall be borne by each party incurring the
same.
Dated: January 5, 2012

Respectfully submitted,
By:
/s/ Cameron H. Tousi
Cameron H. Tousi
ALBRECHT TOUSI & FARNUM, PLLC
1701 Pennsylvania Avenue, NW
Suite 300
Washington, DC 20006
[phone] (direct)
[phone] (fax)
[e-mail]
Admitted pro hac vice
Attorney for Plaintiff

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CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was filed electronically in
compliance with Local Rule CV-5(a). As such, this document was served on all counsel who are
deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R.
Civ. P. 5(d) and Local Rule CV-5(d) and (e), all other counsel of record not deemed to have
consented to electronic service were served with a true and correct copy of the foregoing by
email, on this fifth day of January, 2012.
/s/ Cameron H. Tousi
Cameron H. Tousi

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