Egozi & Bennett, P.A.  2999 NE 191st Street, Suite 407  Aventura, Florida 33180  Tel 305.931.3000  Fax 305.931.9343

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

Case No. 1:20-cv-22050-FAM 

SISVEL INTERNATIONAL, S.A. 

and SISVEL S.p.A., 

Plaintiff, 

v. 

BLU PRODUCTS, INC., 

Defendant. 

 / 

BLU PRODUCTS, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO 

RESPOND TO COMPLAINT 

Defendant BLU PRODUCTS, INC. (“BLU”), by and through its undersigned counsel, 

hereby moves the Court for the entry of an order extending the time in which BLU may file a 

response to the Complaint for Patent Infringement ("Complaint") filed by the Plaintiffs, SISVEL 

INTERNATIONAL, S.A. and SISVEL S.p.A ("Plaintiffs"). In support of its motion, BLU states 

as follows: 

1. On May 15, 2020, Plaintiffs filed the Complaint (ECF No. 1). 

2. The period prescribed for BLU to file a response to the Complaint expires today, 

August 4, 2020. 

3. Due to the press of other matters and in order to allow the parties additional time 

for ongoing settlement discussions, BLU requests additional time to file its response to the 

Complaint. 

4. Specifically, BLU seeks a thirty-day (30) extension of time through September 3, 

2020 within which to file its response. Plaintiffs do not oppose the relief sought in this Motion. 

Case 1:20-cv-22050-FAM Document 7 Entered on FLSD Docket 08/04/2020 Page 1 of 5
Egozi & Bennett, P.A.  2999 NE 191st Street, Suite 407  Aventura, Florida 33180  Tel 305.931.3000  Fax 305.931.9343

This is BLU's first request for an extension of time to respond to the Complaint. 

5. BLU makes this motion in good faith and not for the purpose of undue delay. 

6. Pursuant to Rule 7.1(a)(2), Local Rules of the United States District Court for the 

Southern District of Florida, a proposed order is attached for the Court’s convenience as Exhibit 

A, and a copy will be transmitted to judge’s chambers pursuant to Rule 3(I)(6) of the CM/ECF 

Administrative Procedures of the Southern District of Florida. 

CERTIFICATE OF GOOD FAITH CONFERENCE

The undersigned certifies that as required by S.D. Fla. L.R. 7.1(a)(3), the office of the 

undersigned has contacted counsel for the Plaintiffs and the relief requested in this motion is 

unopposed. 

Respectfully submitted, 

s/ Yanina Zilberman 

Bernard L. Egozi (Florida Bar No. 152544) 

begozi@egozilaw.com 

Yanina Zilberman (Florida Bar No. 105665) 

yanina@egozilaw.com 

EGOZI & BENNETT, P.A. 

2999 NE 191 Street, Suite 407 

Aventura, Florida 33180 

Telephone: (305) 931-3000 

Counsel for Defendant 

 

Case 1:20-cv-22050-FAM Document 7 Entered on FLSD Docket 08/04/2020 Page 2 of 5
Egozi & Bennett, P.A.  2999 NE 191st Street, Suite 407  Aventura, Florida 33180  Tel 305.931.3000  Fax 305.931.9343

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail 

through the CM/ECF system on this 4th day of August, 2020, on all counsel of record on the 

service list below. 

 s/ Yanina Zilberman 

 

Service List 

GRAY ROBINSON, P.A. 

Jorge Espinosa, Esq. 

Francesca Russo, Esq. 

Robert R. Jimenez, Esq. 

333 SE 2nd Avenue, Suite 300 

Miami, FL 33131 

Tel.: 305-416-6880 

Fax: 305-416-6887 

jespinosa@etlaw.com 

frusso@etlaw.com 

rjimenez@etlaw.com 

Counsel for Plaintiff 

 

Case 1:20-cv-22050-FAM Document 7 Entered on FLSD Docket 08/04/2020 Page 3 of 5
Egozi & Bennett, P.A.  2999 NE 191st Street, Suite 407  Aventura, Florida 33180  Tel 305.931.3000  Fax 305.931.9343

EXHIBIT "A" 

Case 1:20-cv-22050-FAM Document 7 Entered on FLSD Docket 08/04/2020 Page 4 of 5
Egozi & Bennett, P.A.  2999 NE 191st Street, Suite 407  Aventura, Florida 33180  Tel 305.931.3000  Fax 305.931.9343

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

Case No. 1:20-cv-22050-FAM 

SISVEL INTERNATIONAL, S.A. 

and SISVEL S.p.A., 

Plaintiff, 

v. 

BLU PRODUCTS, INC., 

Defendant. 

 / 

ORDER 

THIS CAUSE is before the Court on the Unopposed Motion for Extension of Time to 

Respond to Complaint ("Motion"), filed by Defendant BLU PRODUCTS, INC. ("BLU") [ECF 

No. 7]. It is:

ORDERED AND ADJUDGED that the Motion is granted. BLU shall file its response to 

the Complaint on or before September 3, 2020. 

 

Hon. Federico A. Moreno 

 United States District Court Judge 

Copies to: 

Counsel of Record 

Case 1:20-cv-22050-FAM Document 7 Entered on FLSD Docket 08/04/2020 Page 5 of 5