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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

DEVELOPMENT,

Plaintiff,

v.

ZTE CORPORATION, ZTE (USA) 

INC., AND ZTE (TX), INC. 

Defendants.

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CIVIL ACTION NO. 6:20-cv-487-ADA

CIVIL ACTION NO. 6:20-cv-488-ADA

CIVIL ACTION NO. 6:20-cv-489-ADA

CIVIL ACTION NO. 6:20-cv-490-ADA

CIVIL ACTION NO. 6:20-cv-491-ADA

CIVIL ACTION NO. 6:20-cv-492-ADA

CIVIL ACTION NO. 6:20-cv-493-ADA

CIVIL ACTION NO. 6:20-cv-494-ADA

CIVIL ACTION NO. 6:20-cv-495-ADA

CIVIL ACTION NO. 6:20-cv-496-ADA

CIVIL ACTION NO. 6:20-cv-497-ADA

JURY TRIAL DEMANDED

PLAINTIFF’S RESPONSE TO 

STATUS REPORT REGARDING PENDING VENUE MOTIONS

Plaintiff respectfully files this Response to Defendants’ Status Report Regarding Pending 

Venue Motions. 

1. Defendants’ “Status Report” re-urges their pending motion to stay pending venue 

discovery. Defendants’ motion to stay should be denied for at least three reasons. 

2. First, it is plainly unnecessary. This Court’s March 23, 2021 Standing Order 

Regarding Motions for Inter-District Transfer clearly states how this Court will address the types 

of concerns raised in Defendants’ Motion to Stay. Defendants’ proposed order is unnecessary and 

is inconsistent with this Court’s Standing Order. 

3. Second, although WSOU has until June 4 to complete its venue discovery, WSOU 

has been diligent in accelerating its discovery to the point where it should be complete by April 

30. The wild cards are two depositions of the ZTE, which have been pushed back at ZTE’s request.

The depositions are scheduled for and should be completed on April 13 and 14 if Defendants 

cooperate and are properly prepared for their depositions. 

Case 6:20-cv-00487-ADA Document 68 Filed 04/06/21 Page 1 of 3
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4. Third, the third-third party discovery identified in Defendants’ Status Report will 

not delay venue briefing. Indeed, all third-party venue discovery is complete, other than one third 

party, which should be completed before the depositions of Defendants. 

5. Finally, as a separate matter, in paragraph 1 of the Status Report, Defendants claim

Plaintiff forced Defendants to file a reply in support of Defendants’ original motions to dismiss by 

refusing to treat the motions to dismiss as moot. It is unclear why this claim is included in 

Defendants’ Status Report on venue discovery, but it is incorrect. Although Plaintiff considered 

its Amended Complaint to moot only the motion to dismiss filed by ZTE Corporation, Plaintiff 

agreed as a courtesy to extend Defendants ZTE TX’s and ZTE USA’s deadlines to file renewed 

motions to dismiss. Defendants were not forced to file a reply in support of their original motions 

to dismiss. Nor did they file replies in support of their motions to dismiss. The document 

Defendants cite in their Status Report (-487 Dkt. No. 42) is an untimely reply in support of their 

motions to transfer, not a reply in support of their motions to dismiss. Defendants later filed an 

untimely renewed motion to transfer, which this Court struck. 

Dated: April 6, 2021

Jim@EtheridgeLaw.com

Facsimile: (817) 887-5950

Telephone: (817) 470-7249

Southlake, Texas 76092

2600 E. Southlake Blvd., Suite 120 / 324

ETHERIDGE LAW GROUP, PLLC

Texas State Bar No. 24061296

Travis Lee Richins

Texas State Bar No. 24065671

Brett A. Mangrum

Texas State Bar No. 24036997

Ryan S. Loveless

Texas State Bar No. 24059147

James L. Etheridge

/s/ Travis Richins 

Respectfully submitted,

Case 6:20-cv-00487-ADA Document 68 Filed 04/06/21 Page 2 of 3
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Ryan@EtheridgeLaw.com

Brett@EtheridgeLaw.com

Travis@EtheridgeLaw.com

Mark D. Siegmund

State Bar No. 24117055

mark@waltfairpllc.com

Law Firm of Walt, Fair PLLC.

1508 North Valley Mills Drive

Waco, Texas 76710

Telephone: (254) 772-6400

Facsimile: (254) 772-6432

ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE

I certify that on April 6, 2021 a true and correct copy of the foregoing document was served 

upon all counsel of record via the Court’s electronic delivery system under this Court’s Local 

Rules.

/s/ Travis Richins

Travis Richins

Case 6:20-cv-00487-ADA Document 68 Filed 04/06/21 Page 3 of 3