UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

COMMSCOPE HOLDING COMPANY, INC., 

COMMSCOPE INC., ARRIS US HOLDINGS, 

INC., ARRIS SOLUTIONS, INC., ARRIS 

TECHNOLOGY, INC., ARRIS ENTERPRISES 

LLC, ARRIS INTERNATIONAL LIMITED, 

ARRIS GLOBAL LTD., 

Defendants.

Case No. 2:23-cv-00455-JRG-RSP

JURY TRIAL DEMANDED

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR 

COMMSCOPE HOLDING COMPANY, INC., COMMSCOPE INC., ARRIS US 

HOLDINGS, INC., ARRIS SOLUTIONS, INC., ARRIS TECHNOLOGY, INC., ARRIS 

ENTERPRISES LLC, ARRIS INTERNATIONAL LIMITED, ARRIS GLOBAL LTD TO 

RESPOND TO COMPLAINT

Plaintiff Cobblestone Wireless, LLC (“Cobblestone” or “Plaintiff”) respectfully moves for 

an extension of time for CommScope Holding Company, Inc., CommScope Inc., Arris US 

Holdings, Inc., Arris Solutions, Inc., Arris Technology, Inc., Arris Enterprises LLC, Arris 

International Limited, Arris Global Ltd. (collectively “CommScope”) to answer or otherwise 

respond to Cobblestone’s Complaint. In support of this Motion, Cobblestone states as follows:

1. Cobblestone served its Complaint on CommScope Holding Company, Inc.,

CommScope Inc., Arris US Holdings, Inc., Arris Solutions, Inc., Arris Technology,

Inc., and Arris Enterprises LLC, on October 4, 2023, 2023,such that their responses

are currently due on October 25, 2023. (Docket No. 8).

2. On October 23, 2023, counsel for Cobblestone and counsel for CommScope, Philip

Case 2:23-cv-00455-JRG-RSP Document 14 Filed 10/24/23 Page 1 of 5 PageID #: 81
- 2 -

P. Caspers, agreed that in exchange for CommScope waiving service of process on

Arris International Limited and Arris Global Ltd., Cobblestone shall agree to an

extension for each and every named CommScope entity to answer on January 23, 

2024. CommScope has agreed to such a waiver and Cobblestone has agreed to 

such an extension with the approval of the Court.

3. On behalf of CommScope, Mr. Caspers has requested that Cobblestone file the

present unopposed motion for extension on behalf both parties. Cobblestone so

agrees to file this present unopposed motion.

4. Cobblestone and CommScope are in agreement that the response date for all

CommScope defendants should be aligned, and counsel for CommScope has

advised that they do not oppose this Motion.

5. Cobblestone and CommScope believe there is good cause for and an extension.

Accordingly, Cobblestone respectfully requests that CommScope Holding Company, Inc., 

CommScope Inc., Arris US Holdings, Inc., Arris Solutions, Inc., Arris Technology, Inc., Arris 

Enterprises LLC, Arris International Limited, Arris Global Ltd. have until January 23, 2024 to 

answer or otherwise respond to Cobblestone’s Complaint.

Dated: October 24, 2023

By: /s/ Reza Mirzaie

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

Amy E. Hayden 

CA State Bar No. 287026

Jonathan Ma

Case 2:23-cv-00455-JRG-RSP Document 14 Filed 10/24/23 Page 2 of 5 PageID #: 82
- 3 -

CA State Bar No. 312773

Jacob R. Buczko

CA State Bar No. 269408

Peter Tong

TX State Bar No. 24119042

Matthew D. Aichele

VA State Bar No. 77821

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: ahayden@raklaw.com

Email: jma@raklaw.com

Email: jbuczko@raklaw.com

Email: ptong@raklaw.com

Email: maichele@raklaw.com

ATTORNEYS FOR PLAINTIFF,

COBBLESTONE WIRELESS, LLC

Case 2:23-cv-00455-JRG-RSP Document 14 Filed 10/24/23 Page 3 of 5 PageID #: 83
- 4 -

CERTIFICATE OF SERVICE

I hereby certify that on October 24, 2023, a copy of the foregoing was filed with the Court 

using CM/ECF. On this date, copies of the foregoing have been emailed to counsel for the 

CommScope Defendants: Philip P. Caspers at pcaspers@carlsoncaspers.com, who has agreed to 

accept service by email.

/s/ Reza Mirzaie

Case 2:23-cv-00455-JRG-RSP Document 14 Filed 10/24/23 Page 4 of 5 PageID #: 84
- 5 -

CERTIFICATE OF CONFERENCE

The undersigned certifies that counsel complied with the requirements of Eastern District 

of Texas Local Rule CV-7(h). The parties are in agreement on filing the Unopposed Motion for 

Extension of Time.

 /s/ Reza Mirzaie

Case 2:23-cv-00455-JRG-RSP Document 14 Filed 10/24/23 Page 5 of 5 PageID #: 85