IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

WSOU INVESTMENTS LLC D/B/A 

BRAZOS LICENSING AND 

DEVELOPMENT,

 Plaintiff,

v. 

ZTE CORPORATION, ZTE (USA) INC. 

AND ZTE (TX), INC.,

 Defendants.

§

§

§

§

§

§

§

§

§

§

C.A. NO. 6:20-cv-00496-ADA

UNOPPOSED MOTION FOR EXTENSIONS BY ZTE

Defendants ZTE Corporation, ZTE (USA) Inc. and ZTE (TX), Inc. (collectively “ZTE”)

submit this Unopposed Motion for Extensions to extend the time for the respective party 

deadlines, with respect to Plaintiff WSOU Investments, LLC d/b/a Brazos Licensing and 

Development’s (“WSOU”) Amended Complaint, as filed on November 6, 2020 (Dkt. 36).

1. On October 9, 2020, ZTE filed Motions to Dismiss, and in the alternate Motions to 

Transfer, respectively, at Dkt. Nos. 23, 24, 25 (Dkt. No. 26 correcting Dkt. No. 25). ZTE’s 

motions were styled as collective “motions to dismiss for improper jurisdiction and/or 

venue, and with an alternative relief styled as a motion to transfer venue for convenience.” 

WSOU’s responses were originally due by October 24, 2020.

2. On October 13, 2020, WSOU filed an unopposed motion for extension of time, Dkt. 27. 

With responses due by October 24, 2020, WSOU requested three-week extensions to 

November 6, 2020, at Dkt. No. 27, which were granted. (Order of October 15, 2020).

3. On November 6, 2020, WSOU filed Oppositions to ZTE’s Motions to Dismiss, and in 

alternative Motions to Transfer, Dkt Nos. 34 and 35 regarding Dkt. Nos. 23 and 24.

Case 6:20-cv-00496-ADA Document 39 Filed 11/11/20 Page 1 of 4
4. On November 6, 2020, WSOU also filed an Amended Complaint, Dkt. No. 36

(supplemented by Dkt. No. 37). The Amended Complaint pertains to all ZTE entities. 

5. With respect to any response by ZTE to the Amended Complaint, ZTE’s current deadline

is November 20, 2020. ZTE requests a two-week extension to December 4, 2020. In 

exchange, WSOU requests a reciprocal two-week extension (not including the week of 

December 25-January 1) of its responsive deadlines then, to January 8, 2021.

6. With respect to briefing on transfer, the parties have a dispute. It is ZTE’s position that 

WSOU’s Amended Complaint moots all briefings, including the sought relief stylized as 

the Motions to Dismiss, and the alternative Motions to Transfer for convenience. But it 

is Plaintiff’s position that WSOU’s Amended Complaint only moots the Motion to 

Dismiss briefings, not the Motion to Transfer briefings, and that the preexisting Motion 

to Transfer briefings are still active. Therefore, WSOU maintains that ZTE must reply 

on the pending motion to transfer for convenience by the current deadline of November 

13, 2020. To the extent that this dispute continues, ZTE request a one-week extension to 

respond to November 20, 2020.

7. The requested extensions should cause no delay in the schedule.

8. Defendants consulted with counsel for Plaintiff, and both parties do not oppose the 

respective extensions.

WHEREFORE, to the extent necessary, and not eventually deemed moot by the parties, 

ZTE respectfully requests that the deadlines to file replies on transfer for convenience are to be 

extended to November 20, 2020; and

WHEREFORE, ZTE respectfully requests that the deadlines to respond to the 

Amendment Complaint (with a new Motion to Dismiss or otherwise), in view of the Amended 

Complaint, Dkt No. 36 (supplemented by Dkt. No. 37), is to be extended to December 4, 2020.

Case 6:20-cv-00496-ADA Document 39 Filed 11/11/20 Page 2 of 4
WHEREFORE, ZTE respectfully requests that WSOU’s deadlines to file responses to the 

new Motions to Dismiss, be extended to January 8, 2021.

DATED: November 11, 2020 Respectfully submitted,

/s/Lionel M. Lavenue 

Lionel M. Lavenue

Virginia Bar No. 49,005

lionel.lavenue@finnegan.com 

FINNEGAN, HENDERSON, FARABOW,

GARRETT & DUNNER, LLP

1875 Explorer Street, Suite 800

Reston, VA 20190

Phone: (571) 203-2700

Fax: (202) 408-4400

Attorney for Defendants, 

ZTE Corporation

ZTE (USA), Inc.

ZTE (TX), Inc.

Case 6:20-cv-00496-ADA Document 39 Filed 11/11/20 Page 3 of 4
CERTIFICATE OF CONFERENCE

Defendants state that (1) counsel complied with the meet and confer requirements of 

Local Rule CV-7, and (2) that counsel for the Plaintiff stated that they do not oppose the 

extensions of time as outlined in this motion.

/s/Lionel M. Lavenue 

Lionel M. Lavenue

CERTIFICATE OF SERVICE

The undersigned hereby certifies that all counsel of record who are deemed to have 

consented to electronic service are being served with a copy of this document via the Court’s 

CM/ECF system on November 11, 2020. 

/s/Lionel M. Lavenue 

Lionel M. Lavenue

Case 6:20-cv-00496-ADA Document 39 Filed 11/11/20 Page 4 of 4