CASE NO. 3:17-cv-00561-WHO (LB) 

MTN RE WITHDRAWAL OF MORRISON & FOERSTER AS COUNSEL FOR CHING-HAN TSAI

sf-3885245

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JENNIFER LEE TAYLOR (SBN 161368)

JTaylor@mofo.com 

STACEY M. SPRENKEL (SBN 241689) 

SSprenkel@mofo.com 

JOYCE LIOU (SBN 277720) 

JLiou@mofo.com 

AMANDA D. PHILLIPS (SBN 305614) 

APhillips@mofo.com 

MORRISON & FOERSTER LLP 

425 Market Street 

San Francisco, California 94105-2482 

Telephone: (415) 268-7000 

Facsimile: (415) 268-7522 

Attorneys for Defendants 

UBIQUITI NETWORKS, INC. and 

UBIQUITI NETWORKS 

INTERNATIONAL LIMITED 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SYNOPSYS, INC., 

Plaintiff, 

v. 

UBIQUITI NETWORKS, INC., UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

CHING-HAN TSAI, and DOES 1-20, 

inclusive 

Defendants. 

Case No. 3:17-cv-00561-WHO (LB) 

UBIQUITI DEFENDANTS’ 

NOTICE AND MOTION FOR 

MORRISON & FOERSTER LLP 

TO WITHDRAW AS COUNSEL OF 

RECORD FOR DEFENDANT 

CHING-HAN TSAI 

 Date: May 9, 2018 

 Time: 2:00 p.m. 

 Place: Courtroom 2, 17th Floor 

 Judge: Honorable William H. Orrick 

UBIQUITI NETWORKS, INC. and UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

 Counterclaimants, 

 v. 

SYNOPSYS, INC., 

 Counterdefendant. 
CASE NO. 3:17-cv-00561-WHO (LB) 

MTN RE WITHDRAWAL OF MORRISON & FOERSTER AS COUNSEL FOR CHING-HAN TSAI

sf-3885245

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NOTICE OF MOTION 

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 

PLEASE TAKE NOTICE that on Wednesday, May 9, 2018, at 2:00 p.m., or as soon as 

the matter may be heard by the Honorable William H. Orrick in Courtroom 2 of the United States 

District Court for the Northern District of California, 450 Golden Gate Avenue, San Francisco, 

CA 94102, Defendants and Counterclaimants Ubiquiti Networks, Inc. and Ubiquiti Networks 

International Limited (“Ubiquiti”) will and hereby do move this Court pursuant to Civil Local 

Rule 11-5 for an Order permitting Jennifer Lee Taylor, Stacey M. Sprenkel, Joyce Liou, 

Christopher Robinson, and Amanda D. Phillips of Morrison & Foerster LLP to withdraw as 

attorneys of record for Defendant Ching-Han Tsai. 

This motion is based on this Notice of Motion and Motion; the Declaration of Jennifer Lee 

Taylor in Support of the Motion; and such other written or oral argument as may be presented 

before this motion is taken under submission by the Court. 

STATEMENT OF RELIEF REQUESTED 

Pursuant to Civil Local Rule 11-5, Ubiquiti respectfully requests an order permitting 

Jennifer Lee Taylor, Stacey M. Sprenkel, Joyce Liou, Christopher Robinson, and Amanda D. 

Phillips of Morrison & Foerster LLP to withdraw as attorneys of record for Defendant Ching-Han 

Tsai. 

 
CASE NO. 3:17-cv-00561-WHO (LB) 

MTN RE WITHDRAWAL OF MORRISON & FOERSTER AS COUNSEL FOR CHING-HAN TSAI

sf-3885245

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MOTION 

On January 12, 2018, Morrison & Foerster LLP’s engagement to provide legal services to 

Defendant Ching-Han Tsai in connection with this pending matter was terminated. (Declaration 

of Jennifer Lee Taylor in Support of Morrison & Foerster’s Motion to Withdraw as Counsel for 

Ching-Han Tsai (“Taylor Decl.”) ¶ 2).) Morrison & Foerster LLP has continued to represent the 

two corporate defendants, Ubiquiti Networks, Inc. and Ubiquiti Networks International Limited, 

in connection with this matter since January 12, 2018. (Id. ¶ 3.) 

On or about January 22, 2018, Mr. Tsai retained The Business Litigation Group, P.C. 

(“BLG”) to represent him in connection with this matter. (Id. ¶ 4.) Two attorneys from BLG—

Will Fitton and Marc Bernstein—entered appearances in the matter on January 23, 2018 (Dkt. 

Nos. 115-116), and have since represented Mr. Tsai at depositions and the Court’s hearings, but 

the record does not reflect a substitution of counsel as contemplated by Civil Local Rule 11-5. 

Ubiquiti moves the Court to permit Jennifer Lee Taylor, Stacey M. Sprenkel, Joyce Liou, 

Christopher Robinson, and Amanda D. Phillips of Morrison & Foerster LLP to withdraw as 

counsel of record for Defendant Ching-Han Tsai. 

Dated: April 2, 2018 MORRISON & FOERSTER LLP 

By: /s/ Jennifer Lee Taylor Jennifer Lee Taylor 

Attorneys for Defendants 

UBIQUITI NETWORKS, INC. and 

UBIQUITI NETWORKS 

INTERNATIONAL LIMITED