IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

)

DISPLAY TECHNOLOGIES, LLC )

)

Plaintiff, )

)

v. ) C.A. No. 2:23-cv-00591

)

SIRIUS XM RADIO, INC., )

)

Defendant. )

)

JOINT MOTION TO EXTEND THE DEADLINE TO ANSWER OR OTHERWISE 

RESPOND TO PLAINTIFF’S ORIGINAL COMPLAINT 

Plaintiff Display Technologies, LLC (“Display” or “Plaintiff”) and Defendant Sirius XM 

Radio, Inc. (“SXM” or “Defendant”) (collectively, “the parties”), file this Joint Motion for 

Extension of Time to Answer or Otherwise Respond to Plaintiff’s Original Complaint and 

respectfully move for fifteen (15) days, up to and including March 4, 2024. 

SXM was served on December 27, 2023. SXM previously applied for, and was granted, 

an extension of time to answer up to February 16, 2024. Display and SXM are currently 

engaged in discussions which would resolve this matter in its entirety, and therefore respectfully 

request that the Court enter an order extending the time to answer or otherwise respond in this 

case until March 4, 2024. The parties have conferred and counsel for Display consents to and 

joins this motion for extension. 

The parties submit that this extension is needed to allow time for continued discussions 

relating to early resolution, made in good faith, for good cause, and not for dilatory purposes. 

Further, this motion to extend is intended to conserve judicial resources by pursuing an expedient 

Case 2:23-cv-00591-JRG-RSP Document 8 Filed 02/07/24 Page 1 of 4 PageID #: 191
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conclusion to this litigation, if possible. Accordingly, Display and SXM respectfully request that 

this Court extend the deadline for SXM to answer or otherwise respond to Plaintiff’s complaint 

up to and including March 4, 2024. 

A proposed Order reflecting the parties’ request for a stay is filed herewith. 

Dated: February 7, 2024 Respectfully submitted,

By: /s/ Mark A. Baghdassarian

Mark A. Baghdassarian 

State Bar No. 3025558 

mbaghdassarian@kramerlevin.com 

Kramer Levin Naftalis & Frankel LLP 

1177 Avenue of the Americas 

New York, NY 10036 

Tel: (212) 715-9100 

Fax: (212) 715-8000 

Counsel for Defendant Sirius 

XM Radio, Inc. 

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CERTIFICATE OF SERVICE

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

consented to electronic service are being served with a copy of the foregoing via the Court’s 

CM/ECF system per Local Rule CV-5(a)(3) on February 7, 2024. 

By: /s/ Mark A. Baghdassarian

Case 2:23-cv-00591-JRG-RSP Document 8 Filed 02/07/24 Page 3 of 4 PageID #: 193
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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

)

DISPLAY TECHNOLOGIES, LLC )

)

Plaintiff, )

)

v. ) C.A. No. 2:23-cv-00591

)

SIRIUS XM RADIO, INC., )

)

Defendant. )

)

ORDER GRANTING JOINT MOTION FOR AN EXTENSION OF TIME TO ANSWER 

OR OTHERWISE RESPOND TO PLAINTIFF’S ORIGINAL COMPLAINT 

WHEREFORE, this Court has considered Plaintiff Display Technologies, LLC and 

Defendant Sirius XM Radio, Inc.’s Joint Motion for Extension of Time to Answer or Otherwise 

Respond to Plaintiff’s Original Complaint; 

WHEREFORE, good cause appearing, it is therefore ORDERED that the deadline to 

answer or otherwise respond in this case is extended up to and including March 4, 2024; 

SO ORDERED. 

Case 2:23-cv-00591-JRG-RSP Document 8 Filed 02/07/24 Page 4 of 4 PageID #: 194