IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

TRUESIGHT COMMUNICATIONS LLC,

Plaintiff,

v.

SAMSUNG ELECTRONICS CO., LTD and 

SAMSUNG ELECTRONICS AMERICA, 

INC.,

Defendants.

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Case No. 2:23-cv-00643-JRG

JURY TRIAL DEMANDED

JOINT MOTION TO AMEND SCHEDULING ORDER

Plaintiff Truesight Communications LLC (“Truesight”) and Defendants Samsung 

Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Defendants” or 

“Samsung”), (collectively, the “Parties”) respectfully file this Joint Motion to Amend the 

Scheduling Order (Dkt. No. 12) and would show the Court as follows: 

The original deadline for the Parties to file the Proposed Discovery Order was June 12, 

2024, and the current deadline for the Parties to file the Proposed Protective Order is June 20, 

2024. (Dkt. 12). On June 12, 2024, the Parties jointly moved to extend the deadline for the Parties 

to file the Proposed Discovery Order until June 20, 2024. (Dkt. 24). The next day, the Court 

graciously granted the Parties’ request for an extension of time to file the Proposed Discovery 

Order until June 20, 2024. (Dkt. 25). At this time, the Parties request another brief extension of 

the deadline to file the Proposed Discovery Order up to and including June 27, 2024, as well as a 

brief extension of the deadline to file the Proposed Protective Order up to and including June 27, 

2024. No other deadlines will be affected by this amendment to the Scheduling Order.

Case 2:23-cv-00643-JRG Document 28 Filed 06/19/24 Page 1 of 4 PageID #: 286
The Parties represent that this Motion is not filed for the purpose of delay but rather so that 

justice may be served. Good cause exists for the Parties to use the time to further narrow or 

eliminate disputes and submit a more streamlined proposal for any remaining issues requiring the 

Court’s attention with respect to the Proposed Discovery Order, as well as the Proposed Protective 

Order. The Parties have met and conferred and are jointly seeking the relief sought in this Motion. 

Accordingly, the Parties respectfully request that the Court grant this Joint Motion to 

Amend the Scheduling Order (Dkt. No. 12) as follows: 

Original Date Amended Date Event

June 20, 2024 (3 Weeks After 

Scheduling Conference)

June 27, 2024 *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.

June 12, 2024 (2 Weeks After 

Scheduling Conference)

June 27, 2024 *File 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. 

Dated: June 19, 2024

/s/ Jin-Suk Park (with permission)

Jin-Suk Park

jin.park@arnoldporter.com

Arnold & Porter Kaye Scholer LLP

601 Massachusetts Ave., NW

Washington, DC 20001-3743

Telephone: (202) 942-5000

Facsimile: (202) 942-5555

Melissa R. Smith 

State Bar No. 24001351 

GILLAM & SMITH, LLP 

303 South Washington Avenue 

Respectfully submitted,

/s/ Vincent J. Rubino, III

Alfred R. Fabricant

NY Bar No. 2219392

Email: ffabricant@fabricantllp.com

Peter Lambrianakos

NY Bar No. 2894392

Email: plambrianakos@fabricantllp.com

Vincent J. Rubino, III

NY Bar No. 4557435

Email: vrubino@fabricantllp.com

FABRICANT LLP

411 Theodore Fremd Avenue

Suite 206 South

Case 2:23-cv-00643-JRG Document 28 Filed 06/19/24 Page 2 of 4 PageID #: 287
Marshall, Texas 75670 

Telephone: (903) 934-8450 

Facsimile: (903) 934-9257 

Email: melissa@gillamsmithlaw.com 

ATTORNEY FOR DEFENDANTS

SAMSUNG ELECTRONICS 

COMPANY, LTD., AND 

SAMSUNG ELECTRONICS 

AMERICA, INC.

Rye, New York 10580

Telephone: (212) 257-5797

Facsimile: (212) 257-5796 

John Andrew Rubino

NY Bar No. 5020797

Email: jarubino@rubinoip.com

Michael Mondelli III

NY Bar No. 5805114

Email: mmondelli@rubinoip.com

RUBINO IP

51 J.F.K. Parkway

Short Hills, NJ 07078

Telephone: (973) 535-0920

Facsimile: (973) 535-0921

Samuel F. Baxter 

State Bar No. 01938000 

Email: sbaxter@mckoolsmith.com 

Jennifer L. Truelove 

State Bar No. 24012906 

Email: jtruelove@mckoolsmith.com 

MCKOOL SMITH, P.C. 

104 E. Houston Street, Suite 300 

Marshall, Texas 75670 

Telephone: (903) 923-9000 

Facsimile: (903) 923-9099

ATTORNEYS FOR PLAINTIFF,

TRUESIGHT COMMUNICATIONS LLC

Case 2:23-cv-00643-JRG Document 28 Filed 06/19/24 Page 3 of 4 PageID #: 288
CERTIFICATE OF SERVICE

The undersigned hereby certifies that, on June 19, 2024, all counsel of record who are 

deemed to have consented to electronic service are being served with a copy of this document via 

the Court’s CM/ECF system per Local Rule CV-5(a)(3).

/s/ Vincent J. Rubino, III 

 Vincent J. Rubino, III

CERTIFICATE OF CONFERENCE

The undersigned hereby certifies that counsel for Plaintiff has met and conferred with 

counsel for Defendants, and the parties agree to the entry of the proposed order submitted herewith. 

/s/ Vincent J. Rubino, III 

 Vincent J. Rubino, III

Case 2:23-cv-00643-JRG Document 28 Filed 06/19/24 Page 4 of 4 PageID #: 289