UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

COBBLESTONE WIRELESS, LLC,

Plaintiff,

V.

SAMSUNG ELECTRONICS CO., LTD., 

SAMSUNG ELECTRONICS AMERICA, 

INC.; 

Defendants.

Case No. 2:23-cv-00285-JRG-RSP 

PLAINTIFF’S UNOPPOSED MOTION TO WITHDRAW 

ITS MOTION TO COMPEL (DKT. 52)

Plaintiff Cobblestone respectfully moves to withdraw its Motion to Compel Production of 

All Discovery Withheld Pending MOTIE Review, Dkt. 52. After the motion was filed, 

Defendants’ counsel have provided the following assurances without agreeing that the motion was 

properly brought:

1. On May 5, 2024, Defendants’ counsel wrote, “MOTIE approved Samsung’s application this 

week.”

2. On May 9, 2024, Defendants’ counsel wrote, “Samsung is producing source code in this case 

by making it available for inspection starting on May 14, 2024 . . . .”

3. On May 10, 2024, Defendants’ counsel wrote, “confirmed – all responsive technical 

documents have been produced, and all source code that was subject to MOTIE approval is 

being loaded onto a source code computer.”

Case 2:23-cv-00285-JRG-RSP Document 53 Filed 05/15/24 Page 1 of 4 PageID #: 877
4. On May 10, 2024, Defendants’ counsel responded “No,” in response to the question, “Are 

there any other documents, code, or other discovery materials still pending MOTIE review?”

5. On May 15, 2024, Defendants’ counsel wrote, “we can commit to supplementing Samsung’s 

response to Interrogatory No. 6 by June 7.”

Thus, all relief sought in Plaintiff’s Motion to Compel is now moot. Plaintiff moves with withdraw 

its motion to compel, reserving the right to re-raise the issue and seek expedited briefing if MOTIErelated production is found later to be incomplete.

Dated: May 15, 2024 Respectfully submitted,

/s/ Reza Mirzaie

CA State Bar No. 246953

Marc A. Fenster

CA State Bar No. 181067

Neil A. Rubin

CA State Bar No. 250761

Christian W. Conkle

CA State Bar No. 306374

Jonathan Ma

CA State Bar No. 312773

RUSS AUGUST & KABAT

12424 Wilshire Boulevard, 12th Floor

Los Angeles, CA 90025

Telephone: 310-826-7474

Email: rmirzaie@raklaw.com

Email: mfenster@raklaw.com

Email: nrubin@raklaw.com

Email: cconkle@raklaw.com

Email: jma@raklaw.com

Qi (Peter) Tong

TX State Bar No. 24119042

RUSS AUGUST & KABAT

4925 Greenville Ave., Suite 200

Dallas, TX 75206

Email: ptong@raklaw.com

Andrea Fair 

Case 2:23-cv-00285-JRG-RSP Document 53 Filed 05/15/24 Page 2 of 4 PageID #: 878
Ward Smith & Hill, PLLC

1507 Bill Owens Parkway

Longview, Texas 75604

(903) 757-6400

andrea@wsfirm.com

ATTORNEYS FOR PLAINTIFF,

COBBLESTONE WIRELESS, LLC

Case 2:23-cv-00285-JRG-RSP Document 53 Filed 05/15/24 Page 3 of 4 PageID #: 879
CERTIFICATE OF SERVICE

I hereby certify that on May 15, 2024, I electronically filed the foregoing document with 

the Clerk of the Court for the Eastern District of Texas using the ECF System, and served 

defendants with a copy via electronic mail.

/s/ Reza Mirzaie

Reza Mirzaie 

CERTIFICATE OF CONFERENCE

I hereby certify that counsel for Plaintiff has confirmed with counsel for Defendants that 

the relief sought herein is unopposed.

/s/ Reza Mirzaie

Reza Mirzaie

Case 2:23-cv-00285-JRG-RSP Document 53 Filed 05/15/24 Page 4 of 4 PageID #: 880