Pro Marketing Sales, Inc. v. Cyber Solutions International, LLC et al
Plaintiff: Pro Marketing Sales, Inc.
Defendant: Cyber Solutions International, LLC, Secturion Systems, Inc. and Richard J. Takahashi
Case Number: 2:2017cv00038
Filed: February 28, 2017
Court: US District Court for the Northern District of Georgia
Office: Gainesville Office
County: Forsyth
Presiding Judge: Richard W Story
Nature of Suit: Contract: Other
Cause of Action: 28 U.S.C. § 1332 Diversity-Declaratory Judgement
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on June 7, 2019. A more recent docket listing may be available from PACER.

Date Filed Document Text
June 7, 2019 Filing 114 CLERK'S JUDGMENT that the action be, and the same hereby is dismissed without prejudice from Defendants' Secturion Systems, Inc and Richard J. Takahashi's Motion to Dismiss. (dgr)--Please refer to http://www.ca11.uscourts.gov to obtain an appeals jurisdiction checklist--
June 7, 2019 Clerk's Entry of Dismissal APPROVING #113 Stipulation of Dismissal pursuant to Fed.R.Civ.P.41(a)(1)(A)(ii) (dgr)
June 7, 2019 Civil Case Terminated. (dgr)
June 6, 2019 Filing 113 STIPULATION of Dismissal with Prejudice by Pro Marketing Sales, Inc.. (Powell, Michael)
June 6, 2019 Opinion or Order Filing 112 ORDER: Pursuant to 35 U.S.C. 256 and by consent of the parties, the Court ORDERS that the inventorship designation of U.S. Patent No. 9,258,119 be corrected to add ANAN NAGARAJAN as a named inventor. The Court further ORDERS the Director of the U.S. Patent and Trademark Office to issue a certificate adding ANAN NAGARAJAN as a named inventor on U.S. Patent No. 9,258,119 in accordance with this order. Plaintiff is ORDERED to transmit this order along with the other required documentation to the U.S. Patent and Trademark Office within thirty days. Signed by Judge Richard W. Story on 6/6/2019. (dgr)
April 26, 2019 Filing 111 Minute Entry for proceedings held before Judge Richard W. Story: Settlement Conference held on 4/26/2019. The Court met with parties and counsel to discuss the pending settlement and outstanding issues. (sk)
March 20, 2019 Opinion or Order Filing 110 ORDER granting #107 Motion for a Judicially Supervised Settlement Conference. The matter is set for Settlement Conference Hearing on Friday, April 26, 2019 at 9:30 a.m. in Courtroom 303, United States Courthouse, 121 Spring Street, SE, Gainesville, Georgia. IT IS ORDERED that all discovery in this case is STAYED pending the outcome of the settlement conference. Signed by Judge Richard W. Story on 03/20/19. (rsg)
March 20, 2019 Settlement Conference set for 4/26/2019 at 09:30 AM in GAIN Courtroom 303 before Judge Richard W. Story. (rsg)
March 15, 2019 Filing 109 RESPONSE re #107 MOTION for Order for Judicially Supervised Settlement Conference and Stay of Litigation filed by Pro Marketing Sales, Inc.. (Olson, Erik)
March 4, 2019 Filing 108 NOTICE Of Filing Exhibits to Motion by Cyber Solutions International, LLC re #107 MOTION for Order for Judicially Supervised Settlement Conference and Stay of Litigation (Attachments: #1 Exhibit A - February 7 Settlement Proposal, #2 Exhibit B - February 15 Settlement Proposal, #3 Exhibit C - February 20 Powell E-mail, #4 Exhibit D - February 20 Bejin E-mail, #5 Exhibit E - February 21 Boehm E-mail)(Mendel, Jarrod)
March 4, 2019 Filing 107 MOTION for Order for Judicially Supervised Settlement Conference and Stay of Litigation with Brief In Support by Cyber Solutions International, LLC, Cyber Solutions International, LLC. (Mendel, Jarrod)
March 1, 2019 Filing 106 NOTICE by Pro Marketing Sales, Inc. Plaintiff's Proof of Service of Garrett Pritchyk (Attachments: #1 Exhibit Subpoena of Garrett Pritchyk)(Olson, Erik)
March 1, 2019 Filing 105 CERTIFICATE OF SERVICE Plaintiff's Amended Notice of Depo of Garrett Pritchyk by Pro Marketing Sales, Inc..(Olson, Erik)
February 21, 2019 Filing 104 CERTIFICATE OF SERVICE Plaintiff's 4th RPD to Defendant by Pro Marketing Sales, Inc..(Olson, Erik)
February 8, 2019 Filing 103 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena for Depo. of Michael J. Lee (Attachments: #1 Exhibit Subpoena of Michael J. Lee)(Olson, Erik)
February 8, 2019 Filing 102 CERTIFICATE OF SERVICE Notice of Deposition of Michael J. Lee by Pro Marketing Sales, Inc..(Olson, Erik)
February 4, 2019 Filing 101 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena for Depo. of William Klingensmith (Attachments: #1 Exhibit Subpoena of William Klingensmith)(Olson, Erik)
February 4, 2019 Filing 100 CERTIFICATE OF SERVICE Notice of Depo of William Klingensmith by Pro Marketing Sales, Inc..(Olson, Erik)
January 29, 2019 Filing 99 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena for Depo. of Garrett Pritchyk (Attachments: #1 Exhibit Subpoena of Garrett Pritchyk)(Olson, Erik)
January 29, 2019 Filing 98 CERTIFICATE OF SERVICE Plaintiff's Notice of Deposition of Garrett Pritchyk by Pro Marketing Sales, Inc..(Olson, Erik)
January 28, 2019 Filing 97 CERTIFICATE OF SERVICE Plaintiff's Resp. to Def's 2nd RPDs by Pro Marketing Sales, Inc..(Olson, Erik)
January 7, 2019 Filing 96 CERTIFICATE OF SERVICE Notice of 30b6 Depo of Defendant and Depo of Cheever by Pro Marketing Sales, Inc..(Olson, Erik)
January 3, 2019 Opinion or Order Filing 95 ORDER granting #93 Motion for Extension of Time to Complete Discovery. Discovery ends on 4/1/2019. Signed by Judge Richard W. Story on 01/03/2019. (rsg)
December 28, 2018 Filing 94 CERTIFICATE OF SERVICE of 2nd Request for Production and Cyber Solutions' Responses to Pro Marketing's 3rd Request for Production by Cyber Solutions International, LLC.(Haughton, Craig)
December 24, 2018 Filing 93 Consent MOTION for Extension of Time to Complete Discovery by Pro Marketing Sales, Inc.. (Attachments: #1 Text of Proposed Order)(Olson, Erik)
December 18, 2018 Filing 92 CERTIFICATE OF SERVICE of Discovery Materials - Notice of Deposition and Subpoena to Produce Documents by Cyber Solutions International, LLC.(Haughton, Craig)
November 30, 2018 Filing 91 CERTIFICATE OF SERVICE Plaintiff's 3rd RPDs to Def by Pro Marketing Sales, Inc..(Olson, Erik)
November 29, 2018 Filing 90 CERTIFICATE OF SERVICE of First Supplemental Respones to Second Request for Production by Cyber Solutions International, LLC.(Haughton, Craig)
November 29, 2018 Filing 89 CERTIFICATE OF SERVICE Notice of 30b6 Depo of Defendant by Pro Marketing Sales, Inc..(Olson, Erik)
November 29, 2018 Opinion or Order Filing 88 ORDER granting #86 Motion for Extension of Time to Complete Discovery. The Court grants a forty-nine day discovery extension, up through and including January 30, 2019. Discovery ends on 1/30/2019. Signed by Judge Richard W. Story on 11/29/2018. (dgr)
November 27, 2018 Filing 87 CERTIFICATE OF SERVICE of Notice of Rule 30(b)(6) Deposition of Pro Marketing Sales Inc. by Cyber Solutions International, LLC.(Haughton, Craig)
November 27, 2018 Filing 86 Consent MOTION for Extension of Time to Complete Discovery by Pro Marketing Sales, Inc.. (Attachments: #1 Text of Proposed Order Proposed Order)(Olson, Erik)
November 26, 2018 Filing 85 CERTIFICATE OF SERVICE of Rule 30(b)(6) Notice of Deposition of Plaintiff by Cyber Solutions International, LLC.(Haughton, Craig)
November 23, 2018 Filing 84 CERTIFICATE OF SERVICE Notice of Depo of Douglas Benefield by Pro Marketing Sales, Inc..(Olson, Erik)
November 21, 2018 Filing 83 CERTIFICATE OF SERVICE Notice of Depo of Edward A. Cheever by Pro Marketing Sales, Inc..(Olson, Erik)
November 20, 2018 Filing 82 CERTIFICATE OF SERVICE Expert Report of Dr. Alan T. Sherman by Pro Marketing Sales, Inc..(Olson, Erik)
November 5, 2018 Opinion or Order Filing 81 ORDER granting #80 Motion for Extension of Time to Complete Discovery. Discovery ends on 12/12/2018. Signed by Judge Richard W. Story on 11/5/2018. (dgr)
November 3, 2018 Filing 80 Consent MOTION for Extension of Time to Complete Discovery by Pro Marketing Sales, Inc.. (Attachments: #1 Text of Proposed Order)(Olson, Erik)
November 2, 2018 Opinion or Order Filing 79 ORDER: Pursuant to paragraph 5 of the Standing Order Regarding Civil Litigation #4 , Plaintiff submitted a discovery dispute to the Court. Copies of thesubmissions are attached to this Order as Exhibit A. Having reviewed thosesubmissions, the Court enters the following Order. In its October 26, 2018 letter. Plaintiff raises two issues: (1) Defendant's boilerplate objections; and (2) Defendant's deficient responses. To the extent that Defendant has asserted the objection, as set out on page two of Plaintiff's letter, without indication as to whether added documents would be provided but for the objections, the Court SUSTAINS Plaintiff's request. Defendant must state if it has withheld documents due to its objection. As to the deficient responses, it appears Plaintiff's second document requests go to sensitive financial relationships, between privately held companies and their individual members and investors, that bear no legitimate relationship to the matters in dispute here. As such, this information is not discoverable at this stage and Plaintiff's request for these documents is DENIED. Signed by Judge Richard W. Story on 11/02/18. (Attachments: #1 Exhibit A)(sk)
October 12, 2018 Filing 78 CERTIFICATE OF SERVICE of Responses to Second Request for Production of Documents by Cyber Solutions International, LLC.(Haughton, Craig)
September 18, 2018 Opinion or Order Filing 77 ORDER granting #73 Application for Admission of Thomas E. Bejin Pro Hac Vice. Signed by Judge Richard W. Story on 09/18/2018. (rsg)
September 17, 2018 Filing 76 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena for Dep. on Secturion Systems (Olson, Erik)
September 17, 2018 Filing 75 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena for Dep. on Takahashi (Olson, Erik)
September 17, 2018 Filing 74 CERTIFICATE OF SERVICE Notice of Depos of Takahashi and Secturion Systems by Pro Marketing Sales, Inc..(Olson, Erik)
September 17, 2018 APPROVAL by Clerks Office re: #73 APPLICATION for Admission of Thomas E. Bejin Pro Hac Vice (Application fee $ 150, receipt number 113E-8144053). Attorney Thomas E. Bejin added appearing on behalf of Cyber Solutions International, LLC, Cyber Solutions International, LLC (pmb)
September 13, 2018 Filing 73 APPLICATION for Admission of Thomas E. Bejin Pro Hac Vice (Application fee $ 150, receipt number 113E-8144053)by Cyber Solutions International, LLC. (Mendel, Jarrod)
September 11, 2018 Filing 72 CERTIFICATE OF SERVICE Plaintiff's 2nd RPDs to Def by Pro Marketing Sales, Inc..(Olson, Erik)
September 10, 2018 Filing 71 CERTIFICATE OF SERVICE Pl. Resp. to Def. 1st Req. for Admissions by Pro Marketing Sales, Inc..(Olson, Erik)
September 7, 2018 Filing 70 CERTIFICATE OF SERVICE of Supplemental Production of Documents by Cyber Solutions International, LLC.(Haughton, Craig)
September 6, 2018 Opinion or Order Filing 69 ORDER granting #68 Consent Motion for Extension of Time to Complete Discovery. Discovery ends on 11/12/2018. Signed by Judge Richard W. Story on 09/06/18. (sk)
September 6, 2018 Filing 68 Consent MOTION for Extension of Time to Complete Discovery by Pro Marketing Sales, Inc.. (Attachments: #1 Text of Proposed Order Proposed Order)(Olson, Erik)
August 31, 2018 Filing 67 CERTIFICATE OF SERVICE of Supplemental Document Production by Cyber Solutions International, LLC.(Haughton, Craig)
August 29, 2018 Filing 66 CERTIFICATE OF SERVICE Plaintiff's Suppl. Resp. to Def.'s discovery by Pro Marketing Sales, Inc..(Olson, Erik)
August 29, 2018 Filing 65 CERTIFICATE OF SERVICE of Supplemental Discovery Responses by Cyber Solutions International, LLC.(Haughton, Craig)
August 17, 2018 Filing 64 Certification of Consent to Substitution of Counsel. Michael Joseph Powell replacing attorney Thomas Rosseland and Holly Hawkins Saporito. (Powell, Michael)
August 10, 2018 Filing 63 CERTIFICATE OF SERVICE of First Set of Requests for Admissions by Cyber Solutions International, LLC.(Haughton, Craig)
August 3, 2018 Filing 62 CERTIFICATE OF SERVICE Plaintiff's Resp. to Defendant's 1st INTs and RPDs by Pro Marketing Sales, Inc..(Olson, Erik)
August 2, 2018 Filing 61 CERTIFICATE OF SERVICE Plaintiff's 1st Amended Initial Disclosures by Pro Marketing Sales, Inc..(Olson, Erik)
June 27, 2018 Filing 60 CERTIFICATE OF SERVICE of First Interrogatories and Request for Production by Cyber Solutions International, LLC.(Haughton, Craig)
June 11, 2018 Filing 59 Minute Entry for proceedings held before Judge Richard W. Story: Scheduling Conference held on 6/11/2018. The Court met with counsel to discuss scheduling matters. Counsel agreed that the current discovery deadline of September 10, 2018 is attainable. The Court informed the parties that consent motions for extensions of time for discovery would be approved if necessary. The Court requested to be notified as soon as possible if patent issues are present. (sk)
June 11, 2018 Opinion or Order Filing 58 SCHEDULING ORDER approving the #41 Joint Preliminary Report and Discovery Plan. Signed by Judge Richard W. Story on 06/11/2018. (rsg)
June 8, 2018 Opinion or Order Filing 57 CONSENT PROTECTIVE ORDER. See Order for Specifics. Signed by Judge Richard W. Story on 06/08/2018. (Attachments: #1 Exhibit A)(dgr)
June 8, 2018 Filing 56 PROPOSED CONSENT ORDER Consent Protective Order. (Attachments: #1 Exhibit A- Confidentiality Agreement)(Olson, Erik)
June 6, 2018 Filing 55 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena on 3A, Inc. (Olson, Erik)
June 5, 2018 Filing 54 NOTICE by Pro Marketing Sales, Inc. Notice of Intent to Serve Subpoena on 3A, Inc. (Olson, Erik)
June 1, 2018 Filing 53 CERTIFICATE OF SERVICE Plaintiff's 1st INTs and 1st RPDs to Def. by Pro Marketing Sales, Inc..(Olson, Erik)
May 31, 2018 Filing 52 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena on GlobalFoundries (Olson, Erik)
May 23, 2018 Filing 51 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena on Richard Takahashi (Olson, Erik)
May 23, 2018 Filing 50 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena on Secturion Systems (Olson, Erik)
May 23, 2018 Filing 49 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena on Honeywell (Olson, Erik)
May 22, 2018 Filing 48 CERTIFICATE OF SERVICE Notice of Intent to Serve Subpoena on Honeywell by Pro Marketing Sales, Inc..(Olson, Erik)
May 21, 2018 Filing 47 CERTIFICATE OF SERVICE Notice of Intent to Serve Subpoena on Secturion and Takahashi by Pro Marketing Sales, Inc..(Olson, Erik)
May 21, 2018 Filing 46 NOTICE by Pro Marketing Sales, Inc. Proof of Service of Subpoena on Wes Hansford of MOSIS (Olson, Erik)
May 16, 2018 Filing 45 CERTIFICATE of Counsel Notice of Intent to Serve Subpoena on MOSIS by Erik Hodne Olson on behalf of Pro Marketing Sales, Inc. (Olson, Erik)
May 15, 2018 Filing 44 CERTIFICATE of Counsel Notice of Intent to Serve Subpoena on GlobalFoundries by Erik Hodne Olson on behalf of Pro Marketing Sales, Inc. (Olson, Erik)
May 14, 2018 Filing 43 CERTIFICATE OF SERVICE Regarding Rule 26(a)(1) Initial Disclosures by Cyber Solutions International, LLC.(Haughton, Craig)
May 14, 2018 Filing 42 CERTIFICATE of Counsel Service of Plaintiff's Initial Disclosures by Erik Hodne Olson on behalf of Pro Marketing Sales, Inc. (Olson, Erik)
May 14, 2018 Filing 41 JOINT PRELIMINARY REPORT AND DISCOVERY PLAN filed by Pro Marketing Sales, Inc.. (Olson, Erik)
May 9, 2018 Filing 40 NOTICE of Hearing: Scheduling Conference set for 6/11/2018 at 02:00 PM in GAINESVILLE Courtroom 303 before Judge Richard W. Story. (sk)
May 8, 2018 Filing 39 Certificate of Interested Persons and Corporate Disclosure Statement by Cyber Solutions International, LLC. (Haughton, Craig)
April 25, 2018 Filing 38 ANSWER to #36 Counterclaim by Pro Marketing Sales, Inc..(Olson, Erik) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
April 23, 2018 Opinion or Order Filing 37 ORDER granting #35 Application for Admission Ronald L. Fouse Pro Hac Vice. Signed by Judge Richard W. Story on 04/23/2018. (dgr)
April 23, 2018 Clerk's Certificate of Mailing as to Ronald L. Fouse the #37 Order on Application for Admission PHV. (dgr)
April 18, 2018 APPROVAL by Clerks Office re: #35 APPLICATION for Admission of Ronald L. Fouse Pro Hac Vice (Application fee $ 150, receipt number 113E-7811801). Attorney Ronald L. Fouse added appearing on behalf of Cyber Solutions International, LLC, Cyber Solutions International, LLC (pmb)
April 12, 2018 Filing 36 ANSWER to #11 Amended Complaint ( Discovery ends on 9/10/2018.), COUNTERCLAIM against Pro Marketing Sales, Inc. by Cyber Solutions International, LLC.(Haughton, Craig) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions.
April 12, 2018 Filing 35 APPLICATION for Admission of Ronald L. Fouse Pro Hac Vice (Application fee $ 150, receipt number 113E-7811801)by Cyber Solutions International, LLC. (Mendel, Jarrod)
March 29, 2018 Opinion or Order Filing 34 ORDER: Cyber Solutions International LLC's Motion to Dismiss Plaintiffs First Amended Complaint #19 is GRANTED in part and DENIED in part. More specifically, it is GRANTED as to Count VII and Count IX and DENIED as to all other counts. Secturion Systems, Inc.'s and Richard J. Takahashi's Motion to Dismiss Under FRCP 12(b)(l)-(2), (6) #31 is GRANTED. Signed by Judge Richard W. Story on 03/29/2018. (dgr)
June 23, 2017 Submission of #31 MOTION to Dismiss to District Judge Richard W. Story. (dgr)
June 15, 2017 Filing 33 REPLY BRIEF re #31 MOTION to Dismiss Renewed filed by Secturion Systems, Inc., Richard J. Takahashi. (Attachments: #1 Affidavit Second Declaration of Richard J. Takahashi)(Boehm, Joel)
June 8, 2017 Filing 32 RESPONSE in Opposition re #31 MOTION to Dismiss Renewed filed by Pro Marketing Sales, Inc.. (Attachments: #1 Brief in Support, #2 Exhibit A- Security Agreement, #3 Exhibit B- Summary of Business and Sales, #4 Exhibit C- Benefield deposition, #5 Exhibit D- Altera Press Release, #6 Exhibit E- Takahashi deposition, #7 Exhibit F- SEC Form D, #8 Exhibit G- Takahashi email corr., #9 Exhibit H- Mask release and email corr.)(Olson, Erik)
May 25, 2017 Filing 31 MOTION to Dismiss Renewed with Brief In Support by Secturion Systems, Inc., Richard J. Takahashi. (Attachments: #1 Brief in Support, #2 Affidavit Declaration of Richard Takahashi, #3 Exhibit A (to Takahashi Dec), #4 Exhibit B (to Takahashi Dec), #5 Exhibit C (to Takahashi Dec), #6 Exhibit D (to Takahashi Dec), #7 Exhibit E (to Takahashi Dec), #8 Exhibit F (to Takahashi Dec))(Boehm, Joel)
May 18, 2017 Opinion or Order Filing 30 ORDER Defendants #21 Motion for Reconsideration is DENIED, but the Motion for Extension of Time is GRANTED. Defendant Secturion is ORDERED to file a Motion to Dismiss or Answer to the Amended Complaint within seven days. Signed by Judge Richard W. Story on 05/18/2017. (rsg)
May 17, 2017 Filing 29 Reply in Support re #19 MOTION to Dismiss Plaintiffs First Amended Complaint filed by Cyber Solutions International, LLC. (Haughton, Craig) Modified to reply on 5/17/2017 (rsg).
May 17, 2017 Submission of #19 MOTION to Dismiss Plaintiffs First Amended Complaint, to District Judge Richard W. Story. (rsg)
May 8, 2017 Opinion or Order Filing 28 ORDER granting #14 Application for Admission of Joel Boehm Pro Hac Vice. Signed by Judge Richard W. Story on 05/08/2017. (rsg)
May 8, 2017 Clerks Certificate of Mailing as to Joel Boehm for Secturion Systems, Inc. re #28 Order on Application for Admission PHV. (sk)
May 4, 2017 Clerks Certificate of Mailing as to Attorney Joel Boehm for Secturion Systems, Inc. re #26 Order on Motion for Leave to File Excess Pages. Notice of street name change for the Atlanta courthouse included. (sap)
May 3, 2017 Filing 27 RESPONSE in Opposition re #19 MOTION to Dismiss Plaintiffs First Amended Complaint filed by Pro Marketing Sales, Inc.. (Attachments: #1 Brief, #2 Exhibit Richard Hall Affidavit, #3 Exhibit Security Agreement, #4 Exhibit Takahashi Email Correspondence, #5 Exhibit Mask release and emails, #6 Exhibit Summary of Business and Sales, #7 Exhibit Reseller Agreement, #8 Exhibit Escrow Agreement, #9 Exhibit Nagarajan Employment Agreement)(Olson, Erik)
May 3, 2017 Opinion or Order Filing 26 ORDER granting #25 Motion for Leave to File Excess Pages. Signed by Judge Leigh Martin May for Richard W. Story on 05/03/2017. (sap)
May 2, 2017 Filing 25 MOTION for Leave to File Excess Pages with Brief In Support by Pro Marketing Sales, Inc.. (Attachments: #1 Text of Proposed Order)(Olson, Erik)
May 2, 2017 APPROVAL by Clerks Office re: #14 APPLICATION for Admission of Joel Boehm Pro Hac Vice (Application fee $ 150, receipt number 113E-7086740). Attorney Joel Boehm added appearing on behalf of Secturion Systems, Inc., Richard J. Takahashi (pmb)
April 24, 2017 Filing 24 REPLY BRIEF re #21 MOTION for Reconsideration re #20 Order on Motion to Dismiss,, Order on Motion to Stay,,, Or In The Alternative, Motion For Brief Extension Of Time To File Renewed Motion To Dismiss filed by Secturion Systems, Inc., Richard J. Takahashi. (Hopkins, J.)
April 24, 2017 Submission of #21 MOTION for Reconsideration re #20 Order on Motion to Dismiss, Order on Motion to Stay, Or In The Alternative, Motion For Brief Extension Of Time To File Renewed Motion To Dismiss, to District Judge Richard W. Story. (rsg)
April 21, 2017 Filing 23 RESPONSE in Opposition re #21 MOTION for Reconsideration re #20 Order on Motion to Dismiss,, Order on Motion to Stay,,, Or In The Alternative, Motion For Brief Extension Of Time To File Renewed Motion To Dismiss filed by Pro Marketing Sales, Inc.. (Olson, Erik)
April 20, 2017 Opinion or Order Filing 22 ORDER granting #18 Motion for Leave to File Excess Pages. Signed by Judge Richard W. Story on 4/20/17. (rsg)
April 19, 2017 Filing 21 MOTION for Reconsideration re #20 Order on Motion to Dismiss,, Order on Motion to Stay,,, Or In The Alternative, Motion For Brief Extension Of Time To File Renewed Motion To Dismiss by Secturion Systems, Inc., Richard J. Takahashi. (Hopkins, J.)
April 19, 2017 Opinion or Order Filing 20 ORDER denying as moot #7 Motion to Dismiss and #8 Motion to Dismiss in light of the Amended Complaint. Defendants' #15 Motion to Stay is GRANTED. All discovery obligations are stayed. The Court will request a proposed scheduling order from the parties, if necessary, in its order addressing the dispositive motions which will be filed in response to the Amended Complaint. Signed by Judge Richard W. Story on 4/19/17. (rsg)
April 19, 2017 Filing 19 MOTION to Dismiss Plaintiffs First Amended Complaint with Brief In Support by Cyber Solutions International, LLC. (Attachments: #1 Brief, #2 Exhibit A)(Haughton, Craig)
April 19, 2017 Filing 18 MOTION for Leave to File Excess Pages with Brief In Support by Cyber Solutions International, LLC. (Attachments: #1 Text of Proposed Order)(Haughton, Craig)
April 19, 2017 Filing 17 REPLY BRIEF re #8 MOTION to Dismiss filed by Secturion Systems, Inc., Richard J. Takahashi. (Hopkins, J.)
April 14, 2017 Filing 16 NOTICE of Appearance by Craig Robert Haughton on behalf of Cyber Solutions International, LLC (Haughton, Craig)
April 14, 2017 Filing 15 MOTION to Stay Pretrial Deadlines and Discovery Conference with Brief In Support by Cyber Solutions International, LLC. (Attachments: #1 Supplement Memorandum in Support, #2 Text of Proposed Order)(Haughton, Craig)
April 13, 2017 Filing 14 APPLICATION for Admission of Joel Boehm Pro Hac Vice (Application fee $ 150, receipt number 113E-7086740)by Secturion Systems, Inc., Richard J. Takahashi. (Attachments: #1 Exhibit)(Hopkins, J.)
April 7, 2017 Filing 13 RESPONSE in Opposition re #7 MOTION to Dismiss Plaintiff's Complaint filed by Pro Marketing Sales, Inc.. (Attachments: #1 Brief, #2 Exhibit Security Agreement, #3 Exhibit Takahashi Email Corr., #4 Exhibit Mask Release, #5 Exhibit Summary of Business and Sales, #6 Exhibit RBOA)(Olson, Erik)
April 7, 2017 Filing 12 RESPONSE in Opposition re #8 MOTION to Dismiss filed by Pro Marketing Sales, Inc.. (Attachments: #1 Brief, #2 Exhibit Security Agreement, #3 Exhibit Takahashi email corr., #4 Exhibit Mask Release, #5 Exhibit Summary of Business and Sales, #6 Exhibit Secturion Conversion, #7 Exhibit Benefield Testimony, #8 Exhibit SEC Form D, #9 Exhibit Altera Press Release)(Olson, Erik)
April 5, 2017 Filing 11 First AMENDED COMPLAINT against All Defendants with Jury Demand, filed by Pro Marketing Sales, Inc..(Olson, Erik) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions which includes the Consent To Proceed Before U.S. Magistrate form.
March 30, 2017 Filing 10 NOTICE Of Filing by Cyber Solutions International, LLC re #8 MOTION to Dismiss (Attachments: #1 Exhibit A)(Mendel, Jarrod)
March 24, 2017 Filing 9 Certificate of Interested Persons by Secturion Systems, Inc., Richard J. Takahashi. (Hopkins, J.)
March 24, 2017 Filing 8 MOTION to Dismiss with Brief In Support by Secturion Systems, Inc., Richard J. Takahashi. (Attachments: #1 Brief In Support, #2 Affidavit Declaration of Richard Takahashi, #3 Exhibit A (to Takahashi Dec), #4 Exhibit B (to Takahashi Dec), #5 Exhibit C (to Takahashi Dec), #6 Exhibit D (to Takahashi Dec), #7 Exhibit E (to Takahashi Dec), #8 Exhibit F (to Takahashi Dec))(Hopkins, J.)
March 24, 2017 Filing 7 MOTION to Dismiss Plaintiff's Complaint with Brief In Support by Cyber Solutions International, LLC. (Attachments: #1 Brief, #2 Affidavit of Douglas Benefield, #3 Text of Proposed Order)(Mendel, Jarrod)
March 10, 2017 Filing 6 First Certificate of Interested Persons by Pro Marketing Sales, Inc.. (Olson, Erik)
March 7, 2017 Filing 5 Return of Service Executed by Pro Marketing Sales, Inc.. All Defendants. (Attachments: #1 Exhibit Cyber Solutions, #2 Exhibit Secturion, #3 Exhibit Takahashi)(Olson, Erik)
March 2, 2017 Opinion or Order Filing 4 Court Notice of Filing: Standing Order Regarding Civil Litigation By Judge Richard W. Story. (sk)
March 2, 2017 Opinion or Order Filing 3 ORDER REASSIGNING CASE. Case reassigned to Judge Richard W. Story for all further proceedings. Judge William C. O'Kelley no longer assigned to case. NOTICE TO ALL COUNSEL OF RECORD: The Judge designation in the civil action number assigned to this case has been changed to 2:17-cv-00038-RWS. Please make note of this change in order to facilitate the docketing of pleadings in this case. Signed by Judge William C. O'Kelley on 3/2/2017. (rsg)
March 1, 2017 Filing 2 Electronic Summons Issued as to Cyber Solutions International, LLC, Secturion Systems, Inc., Richard J. Takahashi. (Attachments: #1 Summons Secturion, #2 Summons Takahashi)(rsg)
February 28, 2017 Filing 1 COMPLAINT with Jury Demand filed by Pro Marketing Sales, Inc.. ( Filing fee $ 400.00 receipt number 113E-7000455.) (Attachments: #1 Civil Cover Sheet)(rsg) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions which includes the Consent To Proceed Before U.S. Magistrate form.

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Plaintiff: Pro Marketing Sales, Inc.
Represented By: Erik Hodne Olson
Represented By: Holly Hawkins Saporito
Represented By: Michael Joseph Powell
Represented By: Thomas Rosseland
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Defendant: Cyber Solutions International, LLC
Represented By: Ronald L. Fouse
Represented By: Thomas E. Bejin
Represented By: Craig Robert Haughton
Represented By: Jarrod Sean Mendel
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Defendant: Secturion Systems, Inc.
Represented By: Joel Boehm
Represented By: J. David Hopkins, III
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Defendant: Richard J. Takahashi
Represented By: Joel Boehm
Represented By: J. David Hopkins, III
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