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UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

NORDIC INTERACTIVE 

TECHNOLOGIES LLC, 

 Plaintiff, 

v. 

SAMSUNG ELECTRONICS CO., LTD. and 

SAMSUNG ELECTRONICS AMERICA, 

INC., 

 Defendants. 

Case No.: 6:20-CV-00064 (ADA) 

Judge Alan D. Albright 

JURY TRIAL DEMANDED

PLAINTIFF’S REPLY TO UNOPPOSED MOTION 

TO WITHDRAW AS COUNSEL FOR PLAINTIFF 

[0001] SpencePC files this reply to its February 8, 2012 Motion to Withdraw. In support of its 

Motion to Withdraw, SpencePC responds as follows: 

[0002] Plaintiff Nordic has placed SpencePC in a compromised professional and ethical 

position by, inter alia, refusing to honor the terms of a 2018 Engagement Letter between Nordic 

and SpencePC. Thus, good cause exists for why SpencePC should be permitted to withdraw 

from its representation of Nordic. 

[0003] Contrary to statements by Nordic in opposition to the Motion to Withdraw, the parties 

have unsuccessfully attempted to amicably resolve these professional and ethical concerns for 

almost a year now. To that end, sometime prior to March 11, 2020, Nordic retained another 

law firm, Powers Taylor, adverse to SpencePC to attempt to resolve the dispute. The issue of 

potential termination of the engagement was first raised in subsequent written correspondence 

between SpencePC and Powers Taylor at least as early April 28, 2020. Thus, Nordic cannot 

feign surprise at SpencePC’s motion to withdraw. 

[0004] At the recommendation of SpencePC, Nordic previously retained Parker, Bunt & 

Ainsworth, PC to serve as local counsel in this matter. Upon information and belief, the 

attorneys from Parker, Bunt & Ainsworth, PC withdrew from this case over similar 

professional concerns. 

[0005] Nordic subsequently retained new local counsel, Ni Wang & Massand. Notably, Nordic 

did so without input from, or discussion with, SpencePC. Upon information and belief, Ni 

Wang & Massand intends to remain as counsel in this matter. At Nordic’s request, SpencePC 

is no longer communicating with Ni Wang & Massand. 

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[0006] Prior to filing of the instant motion to withdraw, on February 8, 2021, SpencePC 

contacted Samsung counsel and informed counsel of its intent to file a motion to withdraw. 

After some additional exchange of correspondence, Samsung counsel responded again on 

February 8, 2021, as follows: 

For the district court, since Nordic has other counsel in the case, as long as this 

will not be worked to Samsung’s prejudice (e.g., discovery requests served by 

Samsung will be responded to as due, etc.), we would not oppose. 

[0007] SpencePC responded on February 8, 2021, as follows: 

Thanks for your response. Unless and until the Court grants our motion, I 

confirm that we will of course work with you and the client to address all 

pending deadlines. 

[0008] Prior to filing of the instant motion to withdraw, SpencePC also contacted Ni Wang & 

Massand to request assistance with its motion to withdraw. Nordic refused to permit Ni Wang 

& Massand to assist SpencePC, unnecessarily increasing the burden and expense for SpencePC 

to withdraw. 

[0009] Despite present challenges, as stated above, SpencePC notified Nordic that it will 

continue to assist Nordic will all pending deadlines until the Court grants SpencePC’s motion 

to withdraw. SpencePC did so despite Nordic refusing to respond in writing to SpencePC’s 

requests for certain professional assurances related to the representation. 

[0010] Despite Nordic’s refusal to respond in writing to SpencePC with the requested 

professional assurances, SpencePC is nonetheless willing to agree to Nordic’s request to remain 

as counsel for approximately two additional weeks from the filing of the motion to withdraw. 

Nordic has represented that it can retain new lead counsel during this time frame and that such 

change will not necessitate any changes to the pre-trial schedule or the trial date. 

[0011] For all of these reasons, SpencePC respectfully requests that the Court grant its Motion 

to Withdraw, effective February 19, 2021. 

 

Case 6:20-cv-00064-ADA Document 52 Filed 02/12/21 Page 2 of 3
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Dated: February 12, 2021 Respectfully submitted, 

 SPENCEPC.

 /s/ William Cory Spence 

William Cory Spence 

Jason Wejnert 

SpencePC 

515 N. State St., 14th Floor 

Chicago, Illinois 60654 

312-404-8882 

william.spence@spencepc.com

jason.wejnert@spencepc.com 

Attorneys for Plaintiff Nordic Interactive 

Technologies LLC 

CERTIFICATE OF SERVICE 

I hereby certify that, on February 12, 2021, a true and correct copy of the foregoing was 

served to all counsel of record via email. 

/s/ William Cory Spence

William Cory Spence 

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