Telinit Technologies, LLC v. Glu Mobile Inc.

MOTION to Dismiss with Prejudice as to Electronic Arts, Inc.

E.D. Tex.February 17, 2015

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION TELINIT TECHNOLOGIES, INC. § § § Plaintiff, § § v. § § § GLU MOBILE INC. § 2:14-CV-01052-JRG SNK PLAYMORE CORPORATION ET AL. § 2:14-CV-01053-JRG CONCRETE SOFTWARE, INC. § 2:14-CV-01081-JRG DOODLE MOBILE LTD § 2:14-CV-01082-JRG ELECTRONIC ARTS, INC. § 2:14-CV-01083-JRG SEGA OF AMERICA, INC. ET AL § 2:14-CV-01084-JRG MOTION TO DISMISS WITH PREJUDICE COMES NOW, Plaintiff Telinit Technologies, Inc. (hereafter “Telinit”), through its undersigned counsel, and hereby respectfully states and prays: 1. On December 1, 2014 Telinit filed its Complaint for Patent Infringement against Electronic Arts, Inc. (“EA” or “Defendant”) (Docket No. 1). 2. Today, Telinit is filing this Motion to Dismiss with Prejudice as to Defendant in this action due to the fact that the parties have reached an agreement. 3. Therefore, and pursuant to Fed.R.Civ.P. 41(a)(1)(A)(i), Telinit hereby requests that this Honorable Court grant its request to dismiss Telinit’s claims for relief against Defendant with prejudice and with all attorneys’ fees, costs of court and expenses borne by the party incurring same. Case 2:14-cv-01052-RWS Document 25 Filed 02/17/15 Page 1 of 3 PageID #: 70 WHEREFORE, it is respectfully requested that this Honorable Court grant Telinit’s request to dismiss Telinit’s claims for relief against Defendant with prejudice and with all attorneys’ fees, costs of court and expenses borne by the party incurring same. Dated: February 17, 2015 Respectfully Submitted, TELINIT TECHNOLOGIES, INC. By: /s/ Eugenio J. Torres-Oyola Eugenio J. Torres-Oyola USDC No. 215505 Ferraiuoli LLC 221 Plaza, 5th Floor 221 Ponce de León Avenue San Juan, PR 00917 Telephone: (787) 766-7000 Facsimile: (787) 766-7001 Email: etorres@ferraiuoli.com William E. Davis, III Texas State Bar No. 24047416 The Davis Firm, PC 111 West Tyler Street Longview, Texas 75601 Telephone: (903) 230-9090 Facsimile: (903) 230-9661 Email: bdavis@bdavisfirm.com ATTORNEY FOR PLAINTIFF TELINIT TECHNOLOGIES, INC. Case 2:14-cv-01052-RWS Document 25 Filed 02/17/15 Page 2 of 3 PageID #: 71 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 the 17th day of February, 2015. /s/ Eugenio J. Torres-Oyola Eugenio J. Torres-Oyola CERTIFICATE OF CONFERENCE The undersigned certifies that counsel has complied with the meet and confer requirement in Local Rule CV-7(h), and that this motion expresses the parties positions. /s/ Eugenio J. Torres-Oyola Eugenio J. Torres-Oyola Case 2:14-cv-01052-RWS Document 25 Filed 02/17/15 Page 3 of 3 PageID #: 72