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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page1 of 17














STEVEN N. WILLIAMS (SBN 175489)
[email protected]
MATTHEW K. EDLING (SBN 250940)
[email protected]
COTCHETT, PITRE & McCARTHY, LLP
San Francisco Airport Office Center
840 Malcolm Road, Suite 200
Burlingame, CA 94010
Telephone: (650) 697-6000
Facsimile: (650) 697-0577




JONATHAN K. LEVINE (SBN 220289)
[email protected]
ELIZABETH C. PRITZKER (SBN 146267)
[email protected]
PRITZKER LEVINE LLP
180 Grand Avenue, Suite 1390
Oakland, CA 94612
Telephone: (415) 692-0772
Facsimile: (415) 366-6110

DANIEL C. GIRARD (SBN 114826)
[email protected]
ADAM E. POLK (SBN 273000)
[email protected]
GIRARD GIBBS LLP
601 California Street, Suite 1400
San Francisco, CA 94104
Telephone: (415) 981-4800
Facsimile: (415) 981-4846



Attorneys for Plaintiffs Sterling International Consulting Group, Rhonda Estrella, Sonia Ferezan,
John Whittle, Alan Woyt, and JGX, Inc. d/b/a Lefty O’Doul’s

[Additional Counsel Appear on Signature Pages]




UNITED STATES DISTRICT COURT



FOR THE DISTRICT OF NORTHERN CALIFORNIA



SAN JOSE DIVISION

Plaintiff,

STERLING INTERNATIONAL CONSULTING
GROUP,
on behalf of itself and all others similarly situated,


v.

LENOVO (UNITED STATES) INC.,
LENOVO GROUP LIMITED, and SUPERFISH,
INC.,



CAPTION CONTINUED ON THE NEXT PAGE

Defendants.





Case No. 5:15-cv-00807-RMW

PLAINTIFFS’ JOINT OPPOSITION TO
DEFENDANTS SUPERFISH, INC.’S
AND LENOVO (UNITED STATES),
INC.’S MOTION FOR STAY


Date: May 8, 2015
Time: 9:00 a.m.
Courtroom: 6, 4th Floor
Judge: Hon. Ronald M. Whyte








PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW





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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page2 of 17



Case No. 5:15- cv-00819-RSW

Case No. 5:15-cv-00964-RMW

Case No. 5:15-cv-01044-RMW



Plaintiff,

This document relates to:

DAVID HUNTER, individually, and on behalf of all
others similarly situated,


v.

LENOVO (UNITED STATES), INC., a Delaware
corporation, and SUPERFISH, INC., a Delaware
corporation,




Defendants.











Plaintiff,

Defendants.

This document relates to:

CHRISTOPHER HALL, MATTHEW KELSO,
MICHAEL MORICI, JAYNE COSTANZO, RYAN
BAUMGARTNER, LAURA BURNS, THOMAS
CARNEY, BEATRIZ DAVIS, DENNIS HASTY,
WENDY DURAN and GABE DURAN,
individually, and on behalf of all others similarly
situated,


v.

LENOVO (UNITED STATES), INC., LENOVO
GROUP LIMITED and SUPERFISH, INC.,



This document relates to:

RHONDA ESTRELLA, SONIA FEREZAN,
JOHN WHITTLE, and ALAN WOYT on behalf of
themselves and all others similarly situated,


v.

LENOVO (UNITED STATES), INC. and
SUPERFISH, INC.,



CAPTION CONTINUED ON THE NEXT PAGE




Defendants.

Plaintiffs,











PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW





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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page3 of 17



Case No. 5:15-cv-01069-RMW

Case No. 5:15-cv-01113-RMW




Case No. 5:15-cv-01122-RMW











Plaintiff,

Plaintiff,

Defendants.

This document relates to:

KEN MARTINI, individually and on behalf of all
others similarly situated,


v.

LENOVO (UNITED STATES), INC. and
SUPERFISH, INC.,



This document relates to:

JGX, INC. D/B/A LEFTY O’DOUL’S,
individually and on behalf of a class of those
similarly situated,



v.

LENOVO GROUP LIMITED,
LENOVO (UNITED STATES), INC., and
SUPERFISH, INC.



This document relates to:

STANLEY D. JOHNSON, individually and on
behalf of all others similarly situated,


v.

LENOVO (UNITED STATES), INC., LENOVO
GROUP LIMITED, and SUPERFISH, INC.,



CAPTION CONTINUED ON THE NEXT PAGE


Defendants.

Defendants.

Plaintiff,

















PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW





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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page4 of 17



Case No. 5:15-cv-01125-RMW

Case No. 5:15-cv-01166-RMW

Case No. 5:15-cv-01177-RMW









Plaintiff,

Plaintiffs,

Defendants.

This document relates to:

MICHAEL SIMONOFF, individually and on
behalf of all others similarly situated,


v.

LENOVO (UNITED STATES), INC., and
SUPERFISH, INC.,



This document relates to:

RUSSELL WOOD and THOMAS WILSON,
individually and on behalf of all others similarly
situated,


v.

LENOVO (UNITED STATES), INC., LENOVO
HOLDING COMPANY, INC., LENOVO GROUP
LIMITED, and SUPERFISH, INC.,



This document relates to:

MICHELLE BEHREN and MARY JANE
BARBOSA, individually and on behalf of all
others similarly situated,


v.

LENOVO (UNITED STATES) INC. and
SUPERFISH INC.,



CAPTION CONTINUED ON NEXT PAGE


Defendants.

Defendants.

Plaintiffs,



















PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW





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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page5 of 17



Case No. 5:15-cv-01206-RMW

Case No. 5:15-cv-01270-RMW

Case No. 5:15-cv-01432-RMW

Case No. 5:15-cv-01478-PSG









Plaintiff,

Plaintiff,

Defendants.

Defendants.

This document relates to:

ROBERT RAVENCAMP, on behalf of Himself
and all others similarly situated,


v.

LENOVO (UNITED STATES), INC. and
SUPERFISH, INC.,


This document relates to:

SUSAN WEBSTER SCHULTZ, on behalf of
herself and all others similarly situated,


v.

LENOVO GROUP LIMITED, LENOVO
(UNITED STATES) INC. and SUPERFISH
INC.,


This document relates to:

THOMAS KIM, individually, and on behalf of all
others similarly situated,


v.

LENOVO (UNITED STATES), INC., a
Delaware corporation, and SUPERFISH, INC., a
Delaware corporation,



This document relates to:

VINCENT WONG and AGASUBRAHMANYAM
KUMMARAGUNTA, individually, and on behalf
of all others similarly situated,


v.

LENOVO (UNITED STATES), INC., a
Delaware corporation, and SUPERFISH, INC., a
Delaware corporation,



CAPTION CONTINUED ON THE NEXT PAGE

Defendants.

Defendants.

Plaintiffs,

Plaintiff,

























PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW





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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page6 of 17



Case No.: 5:15-cv-01496-PSG

Case No. 5:15-cv-01665-HRL

This document relates to:

BILL CULLIFER, LIZ EDWARDS, DOUGLAS
IRWIN, JOSEPH GUERRA, AUSTIN ARDMAN,
HANK BAUMER, THOMAS BEHRENDT,
ALLAN BOGH, RICHARD BROOKS, JILL
CAZAUBON, JENNIFER COLE, LAUREN
DANNHEIM, JENNIFER DAVIS, EDWARD
DRESSEL, CHRISTOPHER DUNN, DONALD
GEARHART, KENG GEE, BRIAN
GUTTERMAN, HEATHER HARE, JOSE
HIDALGO, NEERAJ KALRA, RYAN KEMPER,
JIM KOPPS, RAJKUMAR KOTHAPA,
MICHELE LARGÉ , ARUL LOUIS, THOMAS
LUCAS, TOM MILLER, ERIC MORETTI,
TREVOR MURDOCK, TRAVIS PALMER,
ELIZABETH PRATT, ROBERT QAKISH, TINA
RICHMAN, CANDACE ROSE, DANIELLE
ROUGIER, RAY SCHMALZER, ZESHAN
SHEIKH, CHRIS SHOUTS, ALICE SPALITTA,
ZACHARY STEIN, CONNIE SUPERNAULT,
RUSS TAKLE, NATE TALLEY, NIKOLAS
THERIOT, ARIELLA VASQUEZ, KATE
WOODS, KYLE YOUNGS, AND LIANGFANG
ZHAO, INDIVIDUALLY AND ON BEHALF OF
ALL OTHERS SIMILARLY SITUATED,


v.

SUPERFISH, INC., and LENOVO (UNITED
STATES), INC.



This document relates to:

DIMITRIY KHAZAK, individually, and on behalf
of all others similarly situated,


v.

SUPERFISH, INC., LENOVO (UNITED
STATES), INC., and LENOVO GROUP
LIMITED,




Defendants.

Defendants.

Plaintiffs,

Plaintiff,

















PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW





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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page7 of 17



Plaintiffs in the Sterling, Estrella, JGX, Inc., Hall, Martini, Johnson, Simonoff, Wood,

Ravencamp, Schultz, Cullifer and Khazak actions respectfully submit this joint opposition to the

motion for stay requested by defendants Lenovo (United States), Inc. and Superfish, Inc. (collectively,

the “Defendants”).

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I.

INTRODUCTION

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The stay requested by Defendants is unnecessary. The parties have already agreed to extend

Defendants’ response obligations until after the Judicial Panel on Multidistrict Litigation (“JPML”)

decides the motion to transfer in the In re Lenovo Adware Litigation, MDL Case No. 2624.

Defendants’ only obligation at present is to participate in the June 19, 2015 initial case management

conference, scheduled to take place after the JPML hearing on the transfer motion, and to cooperate

with plaintiffs to prepare for that conference. Proceeding with these initial case management

activities now will make for a more productive initial case management conference on June 19. There

is no reason to put these activities off until after the JPML decides the motion to transfer.

No party opposes consolidation by the JPML, and most parties, including Defendants, support

transfer to this Court. Defendants will not be prejudiced if they are required to cooperate with

plaintiffs’ counsel in preparing for the initial case management conference. On the contrary, they

will benefit from early identification of any issues that require the Court’s attention at the initial

conference.

Defendants will not have to engage in sixteen different meet and confers with plaintiffs’

counsel. Plaintiffs in 12 of the 16 actions pending in the Northern District of California have

authorized counsel for plaintiffs in Sterling, Estrella and JGX, Inc. to speak with Defendants on their

behalf. And while plaintiffs in three of the other actions (Hunter, Kim and Wong) have agreed to

stay their cases, they will be encouraged to share their views with plaintiffs’ counsel in the Sterling,

Estrella and JGX, Inc. actions in connection with any initial case management activities. There is

accordingly no reason why these related cases cannot begin to move forward in an efficient and

orderly manner.

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PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page8 of 17



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II.

BACKGROUND

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Sterling was filed February 23, 2015 and assigned to this Court on February 24, 2015. Dkt

Nos. 1, 6. Between February 23 and April 10, 2015, 15 additional similar actions were filed in the

Northern District of California against Defendants. Twelve of the 16 pending actions have since been

related to Sterling and assigned to this Court. Dkt. Nos. 23, 25, 27. Unopposed administrative

motions to relate the other three actions to Sterling are pending.1 Dkt. Nos. 28, 30. Defendants have

not responded to any of the complaints filed in any of the 16 related actions. An initial case

management conference in the related actions has been scheduled for June 19, 2015 and a joint case

management statement is due on June 12, 2015. Dkt. No. 23.

In addition to the 16 related actions pending in the Northern District of California, there are

ten similar actions against Defendants pending in eight other federal judicial districts. See

Declaration of Jonathan K. Levine (“Levine Decl.”), ¶ 6. On February 25, 2015, a motion to transfer

all of the pending actions to a single judicial district for consolidated pretrial proceedings was filed

with the JPML. See In re Lenovo Adware Litigation, MDL Case No. 2624, Dkt. No. 1.

Plaintiffs in 24 of the 26 actions (representing eight of the nine judicial districts in which

actions have been filed) support transfer of the litigation to the Northern District of California. Levine

Decl., ¶ 8. Defendants also support transfer of the litigation to the Northern District of California.

Id. Of the other two actions, plaintiffs in one support transfer to the Eastern District of North Carolina

and plaintiffs in the other support transfer to the Southern District of Florida. Id. The MDL transfer

motion is scheduled to be heard by the JPML on May 28, 2015. Id.

Counsel for plaintiffs have coordinated their efforts where possible. Plaintiffs in 19 of the 21

actions then pending in eight judicial districts filed a joint response with the JPML advocating for

transfer of all of the actions to this Court. Levine Decl., ¶ 9. Plaintiffs in all but four cases (Hunter,

Kim, Behren and Wong), pending in this District have agreed to designate plaintiffs’ counsel in

1 The Khazak action was filed on April 10, 2015, after Defendants filed their motion to stay. An
unopposed motion to relate Khazak to Sterling was filed on April 14, 2015. Accordingly, plaintiffs
have included Khazak in this response.


PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page9 of 17



Sterling, Estrella and JGX, Inc. to negotiate with Defendants on their behalf pending entry of a formal

organizational order.2 Id., ¶ 10. While plaintiffs in Hunter, Kim and Wong have agreed with

Defendants to stay their respective actions, plaintiffs’ counsel in Sterling, Estrella and JGX, Inc.

nevertheless intends to consult with counsel in those three actions and take their views into

consideration in connection with any initial case management activities. Id. Plaintiffs in the Northern

District of California actions are therefore able to speak with one voice at this time for the purposes

of dealing with Defendants and moving the litigation forward without awaiting a formal transfer

order.

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III. ARGUMENT

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A.

Legal Standard

In determining whether a stay is warranted pending the JPML’s determination of a transfer

petition, courts consider: (1) the judicial resources that would be saved by avoiding duplicative

litigation if the cases are in fact consolidated; (2) potential prejudice to the non-moving party; and (3)

hardship and inequity to the moving party if the action is not stayed. See, e.g., Rivers v. Walt Disney

Co., 980 F. Supp. 1358, 1360 (C.D. Cal. 1997). These factors counsel against the complete stay

sought by Defendants.

B.

A Stay Will Not Promote Judicial Efficiency

Contrary to the positions taken by Defendants, allowing the parties to engage in routine, initial

case management related activities while a motion to transfer and consolidate is pending before the

JPML is the better approach. Most recently, Judge Tigar considered a very similar request to delay

the Lumber Liquidators proceedings while the JPML considers a motion to transfer and consolidate

that litigation. See Order Granting in Part and Denying in Part Motion to Extend Time; Setting Case

Management Conference, Balero v. Lumber Liquidators, Inc., Case No. 15-cv-01005-JST, Dkt. No.

32 (N.D. Cal. April 4, 2015). In denying that stay motion, Judge Tigar found that “a complete stay

of all pretrial proceedings would not promote judicial economy” because “[t]he Court’s continued

2

Pending entry of a formal organizational order, counsel for plaintiffs in Sterling, Estrella and
JGX, Inc. are also authorized to confer with Defendants, if necessary, on behalf of a majority of
the ten actions pending in the other eight judicial districts. Id., ¶ 11.

PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page10 of 17



management of the[] related cases during the pendency of the JPML’s consideration of the transfer

motion would benefit a potential transferee court in the event that the consolidation and transfer

motion is granted.” Id.

Judge Tigar’s reasoning is consistent with that of other California district courts. For example,

in Rivers, 980 F. Supp. at 1360, the court noted that “a district judge should not automatically stay

discovery, postpone rulings on pending motions, or generally suspend further rulings upon a parties’

motion to the MDL Panel for transfer and consolidation.” This is consistent with the JPML’s Rules

of Procedure. JPML Rule 2.1(d) specifically provides that the pendency of a transfer motion before

the JPML “does not affect or suspend orders and pretrial proceedings in any pending federal district

court action and does not limit the pretrial jurisdiction of that court.”

Even with the transfer motion pending before the JPML, much can be accomplished if the

litigation is allowed to proceed. The parties here can and should discuss the following (all of which

will benefit the ultimate transferee court): (1) jurisdiction and service; (2) anticipated legal issues and

motions; (3) initial disclosures and identification of topics on which discovery might be needed; (4)

the Northern District’s Guideline’s for the Discovery of ESI; (5) any suggested changes to discovery

permitted by the Federal Rules; and (6) case scheduling.

These types of initial discussions advance the litigation and will need to occur, independent

of the JPML’s decision on consolidation and transfer.


C. Complying with This Court’s Case Management Order Will Cause No Prejudice

to Defendants

Defendants claim they will face a risk of duplicative case management discussions in

separate actions prior to the appointment of lead counsel by the MDL transferee court. Here,

Defendants need only comply with the Civil Local Rules and Rules 16 and 26(f) of the Federal Rules

of Civil Procedure as they would in any other matter. There is little risk of inconsistent positions

taken by plaintiffs because plaintiffs’ counsel in three of the actions (Sterling, Estrella and JGX, Inc.)

are authorized to speak for and on behalf of most of the plaintiffs in the pending actions. Notably,

plaintiffs’ counsel speak for all but four of the actions pending in this District. And in three of those

other actions, plaintiffs voluntarily have agreed to stay their cases. Plaintiffs’ counsel in Sterling,

PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page11 of 17



Estrella and JGX, Inc. intend to take the views of these plaintiffs into account in their discussions

with Defendants, notwithstanding their agreement to stay their cases.

Defendants quote Rifenbery v. Organon USA, Inc., No. 13-cv-05463-JST, 2014 WL 296955

(N.D. Cal. Jan. 26, 2014), for the proposition that a stay should be granted because they “face the risk

of unnecessary proceedings and inconsistent rulings on recurring questions of law and fact if the case

is not stayed.” But here, Defendants cannot demonstrate prejudice because there is no risk here of

unnecessary proceedings or inconsistent rulings on recurring questions of fact and law prior to any

ruling by the JPML on the transfer motion. Other than Defendants’ stay motion, there are no

proceedings scheduled in any of the actions pending in this District prior to the June 19 initial case

management conference, and therefore, there will be no rulings on any questions of fact and law,

recurring or otherwise, prior to a ruling by the JPML.

The authorities relied on by Defendants in support of their stay motion are distinguishable.

Rifenbery; Tucker v. Organon USA, Inc., No. 13-cv-00728-SBA, 2013 WL 2255884 (N.D. Cal. May

22, 2013); Couture v. Hoffman-La Roche, Inc., No. 12-cv-02657-PJH, 2012 WL 3042994 (N.D. Cal.

July 225, 2012); J.W. Pfizer, Inc., No. 13-cv-00318-YGR, 2013 WL 1402962 (N.D. Cal. Apr. 5,

2013); and Little v. Pfizer, Inc., No. 14-cv-01177-EMC, 2014 WL 1569425 (N.D. Cal. Apr. 18, 2014),

are all factually similar. Each case involves a single non-class case originally filed in state court that

the defendant removed to federal court and sought to transfer to an MDL proceeding already pending

in another district before an existing transferee judge. At the time the stay was granted in each case,

there also was a motion to remand pending. In each case, then, the court granting the stay would

either lose jurisdiction by way of MDL transfer or be required to make a substantive ruling on remand

if a stay was not granted. None of those facts are present here and, as noted above, there is nothing

pending in any of the related actions before this Court that would require a ruling if the stay is denied.

Moreover, all of the parties to the related cases before this Court – including Defendants - support

transfer of the MDL to this Court.

For these reasons, Defendants suffer no prejudice by complying with this Court’s case

management order at this time.

PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page12 of 17



IV. CONCLUSION

For the foregoing reasons, plaintiffs respectfully request that Defendants’ motion for stay be

denied.

Dated: April 17, 2015

















































































PRITZKER LEVINE LLP
Jonathan K. Levine (SBN 220289)
Elizabeth C. Pritzker (SBN 146267)

______/s/ Jonathan K. Levine_________

180 Grand Avenue, Suite 1390
Oakland, California 94612
Telephone: (415) 692-0772
Facsimile: (415) 366-6110
[email protected]
[email protected]

Attorneys for Plaintiff in Sterling v. Lenovo
(United States) Inc., et al.

GIRARD GIBBS LLP
Daniel C. Girard (SBN 114826)
Adam E. Polk (SBN 273000)

/s/ Daniel C. Girard
601 California Street, Suite 1400
San Francisco, CA 94104
Telephone: (415) 981-4800
Facsimile: (415) 981-4846
[email protected]
[email protected]

Attorneys for Plaintiffs in Estrella, et al. v.
Lenovo (United States) Inc., et al.

COTCHETT, PITRE & McCARTHY,
LLP
Steven N. Williams (SBN 175489)
Matthew K. Edling (SBN 250940)

/s/ Matthew K. Edling _______

San Francisco Airport Office Center
840 Malcolm Road, Suite 200
Burlingame, CA 94010
Telephone: (650) 697-6000

PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page13 of 17



Facsimile: (650) 697-0577
[email protected]

Attorneys for Plaintiff in JGX, Inc. v. Lenovo
Group Limited, et al.

KAPLAN FOX & KILSHEIMER LLP
Laurence D. King (SBN 206423)
Linda Fong (SBN 124232)

/s/ Laurence D. King
350 Sansome Street, Suite 400
San Francisco, CA 94104
Telephone: (415) 772-4700
Facsimile: (415) 772-4707
[email protected]
[email protected]

Attorneys for Plaintiffs in Hall, et al. v.
Lenovo (United States) Inc., et al.

COHELAN KHOURY & SINGER
Timothy D. Cohelan (SBN 060827)
J. Jason Hill (SBN 179630)



/s/ Timothy D. Cohelan

605 C Street, Suite 200
San Diego, California 92101
Telephone: (619) 595-3001
Facsimile: (619) 595-3000
[email protected]
[email protected]

Attorneys for Plaintiffs in Martini v. Lenovo
(United States) Inc., et al.

GREEN & NOBLIN, P.C.
Robert S. Green (SBN 136183)

/s/ Robert S. Green

700 Larkspur Landing Circle, Suite 275
Larkspur, CA 94939
Telephone: (415) 477-6700
Facsimile: (415) 477-6710
[email protected]

FEDERMAN & SHERWOOD

PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

CASE NO. 5:15-CV-00807-RMW

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William Federman
10205 N. Pennsylvania Avenue
Oklahoma City, OK 73120
Telephone: (405) 235-1560
Facsimile: (405(239-2112
[email protected]

Attorneys for Plaintiffs in Johnson v. Lenovo
(United States) Inc., et al.

SCHNEIDER WALLACE COTTRELL
KONECKY WOTKYNS LLP
Todd M. Schneider (SBN 158253)
Mark T. Johnson (SBN 076904)

/s/ Todd M. Schneider

180 Montgomery Street, Suite 2000
San Francisco, California 94104
Telephone: (415) 421-7100
Facsimile: (415) 421-7105
[email protected]
[email protected]

BERGER & MONTAGUE, P.C.
Shanon J. Carson
1622 Locust Street
Philadelphia, PA 19103
Telephone: (215) 875-4656
Facsimile: (215) 875-4604
[email protected]

Attorneys for Plaintiff in Simonoff v. Lenovo
(United States) Inc., et al.

WEITZ & LUXENBERG, P.C.
Christopher B. Dalbey (SBN 285562)
Robin L. Greenwald
James J. Bilsborrow

/s/ Christopher B. Dalbey

700 Broadway
New York, NY 10003
Telephone: (212) 558-5500
Facsimile: (212) 344-5461

1880 Century Park East, Suite 700

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page15 of 17



Los Angeles, CA 90067
Telephone: (310) 247-0921
Facsimile: (310) 786-9927
[email protected]
[email protected]
[email protected]

Attorneys for Plaintiffs in Wood, et al. v.
Lenovo (United States) Inc., et al.

STUEVE SIEGEL HANSON LLP
Jason S. Hartley (SBN 192514)

____/s/ Jason S. Hartley___________

550 West C Street, Suite 1750
San Diego, CA 92101
Telephone: (619) 400-5822
Facsimile: (619) 400-5832
[email protected]

STUEVE SIEGEL HANSON LLP
Norman E. Siegel
Barrett J. Vahle
460 Nichols Road, Suite 200
Kansas City, MO 64112
Telephone: (816) 714-7100
Facsimile: (816) 714-7101
[email protected]
[email protected]

Attorneys for Plaintiffs in Ravencamp v.
Lenovo (United States) Inc., et al.

SAVERI & SAVERI, INC.
Cadio Zirpoli (SBN 179108)
Carl N. Hammarskjold (SBN 280961)

____/s/ Cadio Zirpoli______________

706 Sansome Street
San Francisco, CA 94111
Telephone: (415) 217-6810
Facsimile: (415) 217-6813
[email protected]
[email protected]


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CASE NO. 5:15-CV-00807-RMW

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page16 of 17



Attorneys for Plaintiffs in Schultz v. Lenovo
Group Limited, et al.

THE ROSEN LAW FIRM, P.A.
Laurence M. Rosen (SBN 219683)

____/s/ Laurence M. Rosen_________

355 South Grand Avenue, Suite 2450
Los Angeles, CA 90071
Telephone: (213) 785-2610
Facsimile: (213) 226-4684
[email protected]

THE ROSEN LAW FIRM, P.A.
Phillip Kim
275 Madison Avenue, 34th Floor
New York, NY 10016
Telephone: (212) 686-1060
[email protected]

Attorneys for Plaintiffs in Cullifer et al. v.
Superfish, Inc., et al.

CONSUMER LAW PRACTICE OF
DANIEL T. LEBEL
Daniel T. LeBel (SBN 246169)

____/s/ Daniel T. LeBel_________

3 Embarcadero Center, Suite 1650
San Francisco, CA 94111
Telephone: (415) 513-1414
Facsimile: (415) 563-7848
[email protected]

Attorneys for Plaintiff in Khazak v.
Superfish, Inc., et al.







PLAINTIFFS’ JOINT OPPOSITION TO DEFENDANTS’ MOTION TO STAY;

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Case5:15-cv-00807-RMW Document31 Filed04/17/15 Page17 of 17



ATTESTATION



I, Jonathan K. Levine, am the ECF user whose ID and password are being used to file this

document. In compliance with Local Rule 5-1(i)(3), I hereby attest that all other signatories listed

have concurred in this filing.























/s/ Jonathan K. Levine_______
Jonathan K. Levine

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