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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.,

Defendant.

Case No. 6:20-cv-00487-ADA

Case No. 6:20-cv-00488-ADA

Case No. 6:20-cv-00489-ADA

Case No. 6:20-cv-00490-ADA

Case No. 6:20-cv-00491-ADA

Case No. 6:20-cv-00492-ADA

Case No. 6:20-cv-00492-ADA

Case No. 6:20-cv-00493-ADA

Case No. 6:20-cv-00494-ADA

Case No. 6:20-cv-00496-ADA

Case No. 6:20-cv-00497-ADA

JURY TRIAL DEMANDED

JOINT CASE READINESS STATUS REPORT

TO THE HONORABLE COURT:

Plaintiff WSOU Investments, LLC and Defendants ZTE Corporation, ZTE (USA) Inc, and 

ZTE (TX) Inc. hereby provide the following status report in advance of the initial Case 

Management Conference (CMC).

FILING AND EXTENSIONS

Plaintiff WSOU filed 11 complaints in the above-numbered cases on June 3, 2020. 

Through extension, Defendants filed Motions to Dismiss or Transfer on October 9, 2020. Through 

extensions, Plaintiff’s deadline to respond the Motions to Dismiss is November 9, 2020. 

RESPONSES TO THE COMPLAINTS

Defendants filed Motions to Dismiss or Alternatively Transfer all of the cases on October 

9, 2020. 

Case 6:20-cv-00496-ADA Document 28 Filed 10/20/20 Page 1 of 4
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PENDING MOTIONS

Each Defendant filed Motions to Dismiss or Alternatively Transfer in each of the 11 cases

challenging the venue as improper. There are no other pending motions. With the granted 

extensions, Plaintiff has until November 9 to respond.

RELATED CASES IN THIS JUDICIAL DISTRICT

The above-numbered cases were all filed by Plaintiff against Defendants in this District. 

There are no known related cases. 

IPR, CBM, AND OTHER PGR FILINGS

There are no known IPR, CBM, or other PGR filings with respect to the patents asserted 

in the above-numbered cases.

NUMBER OF ASSERTED PATENTS AND CLAIMS

Plaintiff has asserted one patent in each of the above 11 suits; Plaintiff has not yet disclosed 

its asserted claims. Plaintiff will timely serve its infringement contentions including the asserted 

claims pursuant to any order set forth in the Order Governing Proceedings. 

APPOINTMENT OF TECHNICAL ADVISOR

The parties believe appointment of a technical adviser would be beneficial due to the highly 

technical aspects of these cases.

MEET AND CONFER STATUS

The parties raise the following pre-Markman issues:

Conduct of Markman Hearing – the parties understand that the Court has scheduled these 

cases for Markman on May 20-21, 2021. The parties are meeting and conferring and will make a 

proposal to the Court for orderly presentation of the claim construction issues presented in the 

above-numbered cases over the two days allocated for hearing.

Case 6:20-cv-00496-ADA Document 28 Filed 10/20/20 Page 2 of 4
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Protective Order – the parties anticipate submitting a proposed form of

protective/confidentiality order, or their limited disputes regarding such an order, in the coming 

days.

Date: October 20, 2020 Respectfully submitted,

By: /s/ James L. Etheridge

James L. Etheridge 

Texas Bar No. 24059147 

Ryan S. Loveless 

Texas Bar No. 24036997 

Brett A. Mangrum 

Texas Bar No. 24065671 

Travis L. Richins 

Texas Bar No. 24061296 

Jeff Huang 

Etheridge Law Group, PLLC 

2600 E. Southlake Blvd., Suite 120 / 324 

Southlake, TX 76092 

Tel.: (817) 470-7249 

Fax: (817) 887-5950 

Jim@EtheridgeLaw.com 

Ryan@EtheridgeLaw.com 

Brett@EtheridgeLaw.com 

Travis@EtheridgeLaw.com 

Jeff@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

Counsel for Plaintiff WSOU Investments, LLC

/s/ Erick Robinson

Dunlap, Bennett & Ludwig PLLC 

Case 6:20-cv-00496-ADA Document 28 Filed 10/20/20 Page 3 of 4
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Erick Robinson

State Bar No. 24039142 

7215 Bosque Blvd., 

Waco, TX 76710

Telephone: (254) 870-7302

Facsimile: (713)583-9737

Email:erobinson@dbllawyers.com

David R. Keesling, 

OK Bar No. 17881

Timothy S. Kittle, 

OK Bar No. 219796660 

South Sheridan Road, Suite 250

Tulsa, Oklahoma 74133

(918) 998-9350 Telephone

(918) 998-9360 –Facsimile

dkeesling@dbllawyers.com

kittle@dbllawyers.com

Attorneys for Defendants

Case 6:20-cv-00496-ADA Document 28 Filed 10/20/20 Page 4 of 4