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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

PATENT ARMORY INC.,

Plaintiff,

v.

SAMSUNG ELECTRONICS AMERICA, 

INC.,

Defendant.

 

Civil Action No. 2:23-CV-00199-JRG

 

JOINT MOTION TO EXTEND STAY OF ALL DEADLINES AND NOTICE OF 

SETTLEMENT

Plaintiff Patent Armory Inc. (“Plaintiff”) and Defendant Samsung Electronics 

America, Inc. (“Defendant”) (collectively, “the Parties”) notified the Court that the Parties had 

reached a settlement in principle that will resolve all pending claims between them. [DE 12.] On 

July 7, 2023, Joint Motion to Stay All Deadlines up to and including August 7, 2023, was granted. 

[DE 13.] 

The Parties require an additional thirty (30) days, up to and including September 6, 2023, 

to finalize their agreement, complete the necessary payment, and submit dismissal papers. The 

Parties have finalized all terms of agreement. However, Plaintiff requires additional time to gather 

bank account information and documentation. Once Plaintiff obtains the necessary bank account 

information, the agreement can be finalized and executed. Once the agreement has been executed, 

Defendant will need approximately thirty (30) days to process and transfer the settlement payment 

to Plaintiff’s designated bank account. 

Accordingly, the Parties file this joint motion for an additional thirty-day stay of all pending 

deadlines, up to and including September 6, 2023, so that the Parties may finalize their agreement, 

Case 2:23-cv-00199-JRG Document 14 Filed 08/03/23 Page 1 of 3 PageID #: 521
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complete the necessary payment, and submit dismissal papers. This stay is not sought for the 

purpose of delay, but so that justice may be served. 

WHEREFORE, the Parties respectfully request that the Court enter the proposed order 

submitted with this Motion and grant the Parties such other and further relief to which they 

are entitled. 

Dated: August 3, 2023 Respectfully submitted,

/s/ Isaac Rabicoff

Isaac Rabicoff

RABICOFF LAW LLC 

600 Mamaroneck Avenue, STE 400

Harrison, New York 10528

Telephone: (773) 669-4590

isaac@rabilaw.com

Attorney for Plaintiff

Patent Armory Inc. 

/s/ Melissa R. Smith

Melissa R. Smith 

Texas Bar No. 24001351

GILLAM & SMITH, LLP

303 South Washington Avenue

Marshall, Texas 75670

Telephone: (903) 934-8450

Facsimile: (903) 934-9257

melissa@gillamsmithlaw.com

Attorney for Defendant

Samsung Electronics America, Inc.

Case 2:23-cv-00199-JRG Document 14 Filed 08/03/23 Page 2 of 3 PageID #: 522
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CERTIFICATE OF CONFERENCE

The undersigned hereby certifies that counsel for Defendant met and conferred with 

counsel for Plaintiff to discuss the substantive issues addressed in this Motion. The Parties are 

jointly seeking the relief sought in this Motion. 

/s/ Melissa R. Smith

 Melissa R. Smith

CERTIFICATE OF SERVICE

The undersigned hereby certifies that counsel of record who are deemed to have consented 

to electronic services are being served with a copy of this document via the Court’s CM/ECF 

system on this the 3

rd day of August, 2023.

/s/ Melissa R. Smith

 Melissa R. Smith

Case 2:23-cv-00199-JRG Document 14 Filed 08/03/23 Page 3 of 3 PageID #: 523