1

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

NOKIA CORP., et al.,

Plaintiffs,

v.

STOUT RISIUS ROSS LLC.,

Defendant.

Civil Action No. 3:22-MC-00068-N

AGREED MOTION TO TRANSFER MOTION TO COMPEL

TO THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

Plaintiffs Nokia Corp., Nokia Solutions and Networks Oy, and Nokia of America Corp. 

(collectively, “Nokia”) and Defendant Stout Risius Ross, LCC (“Stout”) respectively request that 

the Court, pursuant to Federal Rule of Civil Procedure 45(f) transfer Nokia’s Motion to Compel 

Stout to Comply With Subpoena (Dkt. Nos. 1-4) to the United States District Court for the Eastern 

District of Texas. In support, Nokia and Stout (collectively, “the Parties”) state:

1. On August 19, 2022, Nokia filed its Motion to Compel Stout to Comply With 

Subpoenas (“Motion”). (Dkt. Nos. 1-3; see also Dkt. No. 4 (Nokia’s Amended Motion to Compel 

Stout to Comply with Subpoena)).

2. This Motion arises out of a lawsuit filed on August 12, 2021 by TQ Delta, LLC 

against Nokia in the United States District Court for the Eastern District of Texas. See TQ Delta, 

LLC v. Nokia Corp., No. 2:21-cv-00309-JRG (E.D. Tex.).

3. The United States District Court for the Eastern District of Texas is the district court 

that issued the subpoenas underlying Nokia’s Motion.

Case 3:22-mc-00068-N-BT Document 6 Filed 08/30/22 Page 1 of 3 PageID 282
2

4. Federal Rule of Civil Procedure 45(f) states: “When the court where compliance is 

required did not issue the subpoena, it may transfer a motion under this rule to the issuing court if 

the person subject to the subpoena consents or if the court finds exceptional circumstances.” FED.

R. CIV. P. 45(f).

5. Stout, the party subject to the subpoena, consents to the transfer of Nokia’s Motion 

to the issuing court, the United States District Court for the Eastern District of Texas.

6. Accordingly, the Parties respectfully request that the Court transfer Nokia’s Motion 

(Dkt. Nos. 1-4) to the United States District Court for the Eastern District of Texas for 

consideration.

Respectfully submitted,

By: /s/ M. Scott Stevens

M. Scott Stevens (NC Bar No. 37828)

ALSTON & BIRD LLP

101 S. Tryon Street; Suite 4000

Charlotte, North Carolina 28280

Phone: (704) 444-1000

Fax: (704) 444-1935

scott.stevens@alston.com

Counsel for Nokia Corp., Nokia Solutions 

and Networks Oy, and Nokia of America 

Corp.

By: /s/ William E. Davis, III

William E. Davis, III

Texas State Bar No. 24047416

bdavis@davisfirm.com

 THE DAVIS FIRM, PC

 213 N. Fredonia Street, Suite 230

 Longview, Texas 75601

 Telephone: (903) 230-9090

 Facsimile: (903) 230-9661

Counsel for Stout Risius Ross, LLC

Case 3:22-mc-00068-N-BT Document 6 Filed 08/30/22 Page 2 of 3 PageID 283
3

CERTIFICATE OF CONFERENCE

Pursuant to N.D. Tex. L.R. 7.1(b), undersigned counsel for Stout certifies that this Motion 

is agreed to by the Parties.

/s/ William E. Davis, III_______________

William E. Davis, III

CERTIFICATE OF SERVICE

The undersigned certifies that on this 30th day of August, 2022 a true and correct copy of 

the foregoing was electronically filed with the Clerk of Court using CM/ECF, which will send 

notification to the registered attorney(s) of record that the document has been filed and is available 

for viewing and downloading.

/s/ William E. Davis, III__ ________

William E. Davis, III

Case 3:22-mc-00068-N-BT Document 6 Filed 08/30/22 Page 3 of 3 PageID 284