Amazon.com Inc et al v. Goyal et al

Filing 33

ORDER granting Parties' 32 Stipulated Motion to Extend Time for Defendants to Respond to Plaintiffs' Complaint. Defendants' deadline to respond to Plaintiffs' Complaint is extended to 4/21/2025. Signed by Judge Ricardo S. Martinez. (KRA)

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UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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AMAZON.COM, INC., a Delaware
corporation; AMAZON.COM SERVICES
LLC, a Delaware limited liability company;
LIFESCAN, INC., a California corporation;
and LIFESCAN IP HOLDINGS, LLC, a
Delaware limited liability company,

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Plaintiff,

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Case No.: 2:24-cv-00880-RSM
STIPULATION AND ORDER TO
EXTEND THE TIME FOR
DEFENDANTS TO RESPOND TO
PLAINTIFFS’ COMPLAINT
NOTE ON MOTION CALENDAR:
Friday, March 21, 2025

v.
VIKAS GOYAL, an individual; SNEHA
SAXENA, an individual; RAJENDRA
KUMAR AGARWAL, an individual;
ANSHITA GOSWAMI, an individual;
ANINDIYA RAI, an individual; RAJANI
DEVI, an individual; KAMAL KUMAR
ANAND, an individual; VIVEK GUPTA, an
individual; STRIP POINT LLC, a Colorado
limited liability company; VIKASH
ENTERPRISES, a foreign company; A S
HOMES, a foreign company; VOVOA PVT
LTD., a foreign company; SPARK
ENTERPRISES, a foreign company; LUCID
QUEST LIMITED, a foreign company;
DHANLAXMI TRANSPORT COMPANY, a
foreign company; and DOES 1-10,
Defendants.

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO
RESPOND TO PLAINTIFFS’ COMPLAINT - 1
CASE NO. 2:24-CV-00880-RSM
BN 87804226v2

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Plaintiffs Amazon.com, Inc, Amazon.com Services LLC, Lifescan, Inc., and Lifescan

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IP Holdings, LLC, (“Plaintiffs”) and Defendants Vikas Goyal, Sneha Saxena, Rajendra Kumar

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Agarwal, Anshita Goswami, Rajani Devi, Strip Point LLC, Vikash Enterprises, A S Homes,

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Vovoa Pvt Ltd., Spark Enterprises, and Dhanlaxmi Transport Company (collectively,

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“Defendants”; Plaintiffs and Defendants, collectively, the “Parties”), by and through their

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counsel of record, respectfully submit this Stipulation—and respectfully request that the Court

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enter the subjoined proposed order—to extend the time for Defendants to respond to Plaintiffs’

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Complaint.

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1.

WHEREAS, on June 20, 2024, Plaintiffs filed the Complaint against Defendants

in the above-captioned action [Dkt. No. 1].
2.

WHEREAS, on September 25, 2024, a Certificate of Service was filed showing

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service of Summons, Complaint and Exhibits, and Civil Cover Sheet to Defendant Strip Point

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[Dkt. No. 9].

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3.

WHEREAS, on November 19, 2024 a Certificate of Service was filed showing

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service of Summons, Complaint and Exhibits, and Civil Cover Sheet to Defendant Vovoa Pvt

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Ltd. [Dkt. No. 19].

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4.

WHEREAS, on November 19, 2024 a Certificate of Service was filed showing

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service of Summons, Complaint and Exhibits, and Civil Cover Sheet to Defendant Dhanlaxmi

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Transport Company [Dkt. No. 20].

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5.

WHEREAS, on February 28, 2025, Defendant Vikash Enterprises signed a

Waiver of the Service of Summons [Dkt. No. 23].
6.

WHEREAS, on February 28, 2025, Defendant Vikash Goyal signed a Waiver

of the Service of Summons [Dkt. No. 24].
7.

WHEREAS, on February 28, 2025, Defendant Spark Enterprises signed a

Waiver of the Service of Summons [Dkt. No. 25].

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO
RESPOND TO PLAINTIFFS’ COMPLAINT - 2
CASE NO. 2:24-CV-00880-RSM
BN 87804226v2

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8.

WHEREAS, on February 28, 2025, Defendant Sneha Saxena signed a Waiver

of the Service of Summons [Dkt. No. 26].
9.

WHEREAS, on February 28, 2025, Defendant Rajendra Kumar Agarwal signed

a Waiver of the Service of Summons [Dkt. No. 27].
10.

WHEREAS, on February 28, 2025, Defendant Rajani Devi signed a Waiver of

the Service of Summons [Dkt. No. 28].
11.

WHEREAS, on February 28, 2025, Defendant Anshita Goswami signed a

Waiver of the Service of Summons [Dkt. No. 29].
12.

WHEREAS, on February 28, 2025, Defendant A S Homes signed a Waiver of

the Service of Summons [Dkt. No. 30].
13.

WHEREAS, Defendants’ response to Plaintiffs’ Complaint was due on January

21, 2025 and extended per email agreement between the Parties to March 20, 2025.
14.

WHEREAS, the Parties have been working cooperatively regarding the early

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stages of the litigation and are engaged in substantial discussions of the matters at issue in this

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dispute; and the Parties believe a 30-day extension of Defendants’ deadline to respond to the

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Complaint will further accommodate those discussions.

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15.

WHEREAS, this is the first request for an extension of time for Defendants to

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respond to the Complaint in this matter, and the requested extension is made in good faith and

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not for the purpose of delay or other procedural advantage.

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16.

ACCORDINGLY, the Parties stipulate and respectfully request to extend

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Defendants’ deadline to respond to Plaintiffs’ Complaint to April 21, 2025. A proposed order

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is subjoined herewith.

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO
RESPOND TO PLAINTIFFS’ COMPLAINT - 3
CASE NO. 2:24-CV-00880-RSM
BN 87804226v2

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD, on this 21st day of
March, 2025.

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BUCHALTER
A Professional Corporation

DAVIS WRIGHT TREMAINE LLP

By:s/Michelle Q. Pham
Michelle Q. Pham, WSBA #44286

By:s/Lauren Rainwater
Lauren Rainwater, WSBA #43625

1420 Fifth Avenue, Suite 3100
Seattle, WA 98101-1337
Email: [e-mail]
Telephone: [phone]

920 Fifth Avenue, Suite 3300
Seattle, WA 98104
Email: [e-mail]
Tel: [phone]

Attorneys for Defendants Vikas Goyal,
Sneha Saxena, Rajendra Kumar Agarwal,
Anshita Goswami, Rajani Devi, Strip Point
LLC, Vikash Enterprises, A S Homes, Vovoa
Pvt Ltd., Spark Enterprises, and Dhanlaxmi
Transport Company

Attorneys for Plaintiffs

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO
RESPOND TO PLAINTIFFS’ COMPLAINT - 4
CASE NO. 2:24-CV-00880-RSM
BN 87804226v2

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ORDER
PURSUANT TO THE STIPULATION, IT IS SO ORDERED that Defendants’
deadline to respond to Plaintiffs’ Complaint is extended to April 21, 2025.
DATED this 24th day of March, 2025.

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A

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RICARDO S. MARTINEZ
UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO
RESPOND TO PLAINTIFFS’ COMPLAINT - 5
CASE NO. 2:24-CV-00880-RSM
BN 87804226v2