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Technology Licensing Pan Corp. v. Thomson

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION


January 19, 2010

TECHNOLOGY LICENSING PAN CORPORATION, PLAINTIFF,
v.
THOMSON, INC., DEFENDANT.

STIPULATED REQUEST AND [PROPOSED] ORDER PERMITTING TECHNOLOGY LICENSING CORPORATION TO FILE ITS SECOND AMENDED COMPLAINT

The parties hereto, through their respective counsel of record, hereby submit this stipulated request that TLC be permitted to file its Second Amended Complaint. As TLC explained in the Parties Joint Status Report (Dkt. No. 226 at p. 2), the originally asserted patents in this litigation, U.S. Patent Nos. 5,754,250 and 5,486,869, and were reissued by the United States Patent and Trademark Office as United States Patent Nos. RE 40,411 and RE 40,412, Stipulated Request and [Proposed] Order Permitting - 1 - Technology Licensing Corporation to File Its Second Amended Complaint respectively. TLC thereby seeks to file its Second Amended Complaint in order to substitute the reissue patents for the originally asserted patents, to remove AV Technologies as a party, and to assert infringement by Thomson of one or more of the additional claims from each of the '411 and '412 reissue patents.

Good cause exists for TLC to file its Second Amended Complaint, as Thomson has consented (without waiving any objections or defenses) to TLC's filing its Second Amended Complaint pursuant to Fed.R.Civ.Proc. 15(a)(2). This filing will not impact any deadlines in the scheduling order (Dkt. No. 229). Pursuant to L.R. 5-137(c), TLC's Second Amended Complaint is attached as Exhibit 1.

Dated: January 15, 2010

ORDER

IT IS HEREBY ordered that Technology Licensing Corporation may file its Second Amended Complaint.

20100119

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