IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

REDSTONE LOGICS LLC,

Plaintiff,

v.

SAMSUNG ELECTRONICS CO., LTD.

SAMSUNG ELECTRONICS AMERICA, 

INC.,

Defendants.

Civil Action No. 2:23-cv-00485

PLAINTIFF REDSTONE LOGICS LLC’S CORRECTED UNOPPOSED MOTION

TO AMEND THE SCHEDULING ORDER

Plaintiff Redstone Logics LLC (“Redstone”) moves to amend the Scheduling Order (Dkt. 

18) entered by the Court on February 14, 2024. Due to a docketing error, Redstone was unable to

comply with P.R. 3-1 & 3-2 and serve its infringement contentions by the March 11, 2024 deadline 

set forth in the Court’s Scheduling Order. Redstone respectfully requests an additional two weeks 

to comply with this deadline and further agrees to move certain deadlines following this deadline

as set forth below.

Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung Electronics America, 

Inc. (“SEA”) (collectively, “Samsung”) do not oppose granting Redstone the relief requested, with 

certain deadlines following the deadline for which Redstone has requested an extension likewise 

being moved.

Redstone thus requests, and Samsung does not oppose, the entry of the following 

amendment to the Court’s Scheduling Order, Dkt. 18:

Case 2:23-cv-00485-JRG Document 22 Filed 03/18/24 Page 1 of 4 PageID #: 124
2

Activity Current Deadline Proposed Deadline

Comply with P.R. 3-1 & 3-2 (Infringement 

Contentions)

3/11/24 3/25/24

Join Additional Parties 4/1/24 No Change

*File Proposed Docket Control Order and 

Proposed Discovery Order

The Proposed Docket Control Order and Proposed 

Discovery Order shall be filed as separate motions 

with the caption indicating whether or not the 

proposed order is opposed in any part.

4/8/24 No Change

*File Proposed Protective Order

The Proposed Protective Order shall be filed as a 

separate motion with the caption indicating 

whether or not the proposed order is opposed in 

any part.

4/15/24 No Change

*Comply with Paragraphs 1 & 3 of the Discovery 

Order (Initial and Additional Disclosures)

4/15/24 4/29/24

Comply with P.R. 3-3 & 3-4 (Invalidity 

Contentions)

5/6/24 6/3/24

Comply with Standing Order Regarding SubjectMatter Eligibility Contentions

5/6/24 6/3/24

The above proposed amendments would seek to move deadlines potentially impacted by 

the amended deadline for Redstone to comply with P.R. 3-1 & 3-2 and include moving one 

deadline for which good cause must be shown—the deadline for the parties to comply with 

Paragraphs 1 & 3 of the Discovery Order (Initial and Additional Disclosures). Redstone 

respectfully submits that good cause exists for moving the deadlines identified above in order to 

correct the aforementioned docketing error. These dates will not impact the date of the Scheduling 

Conference (March 25, 2024). 

Case 2:23-cv-00485-JRG Document 22 Filed 03/18/24 Page 2 of 4 PageID #: 125
3

Dated: March 18, 2024 /s/ Reza Mirzaie

RUSS AUGUST & KABAT

Reza Mirzaie, SBN 246953

Email: rmirzaie@raklaw.com

Marc A. Fenster, SBN 181067

Email: mfenster@raklaw.com

Neil A. Rubin, SBN 250761

Email: nrubin@raklaw.com

Christian W. Conkle, SBN 306374

Email: cconkle@raklaw.com

Jonathan Ma, SBN 312773

Email: jma@raklaw.com

12424 Wilshire Boulevard, 12th Floor

Los Angeles, California 90025

Telephone: (310) 826-7474

Facsimile: (310) 826-6991

Attorneys for Plaintiff Redstone Logics LL

Case 2:23-cv-00485-JRG Document 22 Filed 03/18/24 Page 3 of 4 PageID #: 126
CERTIFICATE OF CONFERENCE

Pursuant to Eastern District of Texas Local Rule CV-7(h), I certify that counsel met and 

conferred telephonically on March 15, 2024, and counsel for Defendants indicated that Defendants 

are unopposed to the relief sought by this motion. 

/s/ Reza Mirzaie

Reza Mirzaie

CERTIFICATE OF SERVICE

I certify that counsel of record who are deemed to have consented to electronic service are 

being served today, March 18, 2024, with a copy of this document via the Court’s CM/ECF system 

per Local Rule CV-5(a)(3).

/s/ Reza Mirzaie

Case 2:23-cv-00485-JRG Document 22 Filed 03/18/24 Page 4 of 4 PageID #: 127