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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC d/b/a )

BRAZOS LICENSING AND )

DEVELEOPMENT, ) Case No. 6:20-cv-493-ADA

)

Plaintiff, )

v. )

)

ZTE CORPORATION, ZTE (USA), INC., )

AND ZTE (TX), INC., )

)

Defendants )

DEFENDANT ZTE (USA) INC.’S UNOPPOSED MOTION TO EXTEND TIME TO 

ANSWER OR OTHERWISE PLEAD

PURSUANT TO Local Rule CV-7, Defendant ZTE (USA), Inc. herein moves the Court 

for an additional ten days, until October 9, 2020, for Defendant ZTE (USA) to answer or otherwise 

plead. In furtherance of this Motion, the Court is informed as follows:

1. The instant matter was filed on June 3, 2020. [ECF 1].

2. The instant matter is one of 11 cases filed by Plaintiff, on the same day, alleging 

patent infringement on the part of the three Defendants named in the caption in all 11 actions.

3. On July 17, 2020, a waiver of service of process, as executed by Defendant ZTE 

(USA) on July 1, 2020, by and through counsel, was filed. [ECF 13].

4. Due to the waiver, Defendant’s date to answer or otherwise plead is currently 

September 29, 2020.

5. This matter involves a Defendant that is a domicile of the People’s Republic of 

China, which necessitates interaction with persons outside of the United States on the part of 

Defendant’s counsel.

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6. Specifically, because Defendant intends to file a responsive motion (in this and the 

other ten cases), counsel for Defendant requires certain information for an accompanying affidavit, 

including, but not limited to, identifying the proper person(s) to execute the affidavit on behalf of 

Defendant, particularly in consideration of the probability of pre-decision discovery pertaining to 

matters that will be raised in the affidavit and motion.

7. The effects of the worldwide COVID pandemic have created unusual and 

extraordinary obstacles for counsel for Defendant, including impediments to travel to meet with 

agents for Defendant, which until the onset of the pandemic had been the normal course of action 

for counsel for Defendant.

8. Counsel for Defendant has been working on drafting the appropriate responsive 

motion and coordinating with Defendant regarding the information and affidavits that are needed.

9. Counsel for Defendant believes that everything necessary can be accomplished in 

the additional ten days requested.

10. This extension is not being sought for any purposes of undue delay or strategic 

advantage for any party, but is being requested for the reasons set forth in this Motion.

11. Counsel for Defendant has conferred with counsel for Plaintiff; Plaintiff offers no 

objection to this Motion.

PRAYER FOR RELIEF

WHEREFORE, Defendant ZTE (USA), Inc. pray(s) the Court will grant the relief 

requested, i.e., order that Defendant’s deadline for filing an answer or responsive motion be 

extended ten (10) days, from the current deadline of September 29, 2020 to October 9, 2020.

Respectfully submitted,

DUNLAP BENNETT & LUDWIG

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/s/ Timothy S. Kittle

Erick S. Robinson

Texas Bar No. 24039142

Dunlap Bennett & Ludwig PLLC

7215 Bosque Blvd.

Waco, Texas 76710

(254) 870-7302 – Telephone 

(713) 583-9737 – Facsimile 

erobinson@dbllawyers.com

David R. Keesling, OBA No. 17881

Timothy S. Kittle, OBA No. 21979

6660 South Sheridan Road, Suite 250

Tulsa, Oklahoma 74133

(918) 998-9350 – Telephone

(918) 998-9360 – Facsimile

dkeesling@dbllawyers.com

tkittle@dbllawyers.com 

Attorneys for Defendants:

ZTE Corporation

ZTE (USA), Inc.

ZTE (TX), Inc.

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CERTIFICATE OF SERVICE

I hereby certify that on the 25th day of September, 2020, I electronically transmitted the 

attached document to the Clerk of Court using the ECF system for filing and transmittal of Notice 

of Electronic Filing to the following ECF registrants:

James L. Etheridge 

Texas State Bar No. 24059147

Ryan S. Loveless

Texas State Bar No. 24036997

Travis L. Richins

Texas State Bar No. 24061296

ETHERIDGE LAW GROUP, PLLC

2600 East Southlake Boulevard, Suite 120 /324

Southlake, Texas 76092

(817) 470-7259 – Telephone 

(817) 887-5950 – Facsimile

Jim@EtheridgeLaw.com

Ryan@EtheridgeLaw.com

Travis@EtheridgeLaw.com

Attorneys for Plaintiff:

WSOU Investments, LLC 

d/b/a Brazos Licensing and Development

/s/ Timothy S. Kittle

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